Privacy
INTRODUCTION
Before you read our Privacy Policy, which has been designed to protect you (our customer), our employees and our suppliers, we wanted to assure you that we keep the personal information you give us, secure. We do not share it with illegitimate third parties and honour the security standards that applicable privacy laws require.
This policy tells you how we will collect and use your personal information, and what you should expect in respect of the personal information about you that we have collected.
This website is not intended for children and we do not knowingly collect data relating to children.
We are Argentum Apothecary Limited (registered in England & Wales with Company No: 07521601). Our Registered Office is at 119 Portland Road, Notting Hill, London, W11 4LN.
We have a dedicated Data Protection Manager who is responsible for our data protection compliance, and you can contact them via email at privacy@argentumapothecary.com.
We are the data controller of the personal information that we keep and use, and we are therefore responsible for making sure that our systems, processes and people comply with the relevant data protection laws in respect of that personal information.
We will act in respect of personal information to comply with the six principles of the General Data Protection Regulation (GDPR), which are:
Lawfulness, fairness and transparency;
Purpose limitation;
Data minimisation;
Accuracy;
Storage limitation;
Integrity and confidentiality.
You have rights in respect of how your personal information can be processed; these include the right to request:
a copy of your personal information;
that inaccurate information is corrected;
and that your personal information, is, in certain circumstances, erased or restricted.
You have the right to complain to the Information Commissioner, which you can do by contacting the Information Commissioner’s Office (ICO) directly. Full contact details, including a helpline number, can be found on the ICO website. This website also has useful information on your rights and our obligations. However, please raise any concerns or issues with us first so that we may deal with this as quickly as possible for you.
COLLECTION, USE & DISCLOSURE OF PERSONAL INFORMATION
We collect and process information for the following reasons:
personal information collected and created in relation to our providing our products or information about them; and
personal information relating to people who have asked to attend events run by us, receive our newsletters and other information services or marketing materials; and
personal information relating to our people (which means those people working for our company, or providing services to us, or potentially working or providing services to us, including employees, consultants, temporary or casual workers and contractors).
As you interact with our website, we will automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy [LINK] for further details.
All of our people are required to abide by our Privacy Policy when handling personal information. We provide them with appropriate data protection training. Any breach of data protection will be taken seriously and may result in disciplinary action. Our Data Protection Manager provides the advice and guidance to our people on data protection issues, as is required.
PROVIDING PRODUCTS & SERVICES
Collection
We will collect personal information which may include names, phone number, email address and any message. This will be done for the management of the commercial relationship with our customers.
We may collect this personal information from you directly, and also from third parties, including publicly available third party sources. Additional personal information will be collected as it is created by or supplied to us.
We will also collect personal information, including name and contact information, for individuals with whom we have a business relationship related to our supply of products or services.
Use
We will use the personal information to provide information relating to and the actual supply of our products, including for the necessary administration of the relationship with our customers, and to comply with requirements that we are required or recommended to undertake, whether by statute or otherwise, such as credit checks.
We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
in the performance of a contract (the supply of products); and/or
compliance with a legal obligation; and/or
vital interests of the data subject; and/or
where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
We may also use your personal information in the following situations, which are likely to be less common:
where we need to protect your interests (or someone else’s interests);
where it is needed in the public interest or for official purposes.
Disclosure
We may share personal information with third parties as is necessary for the supply of our products, including to third-party providers who deliver services to support the operation of our business (such as the Logistics and Fulfilment companies we work with). We may also need to share your personal information to comply with the law.
In respect of all disclosures of personal information, we will only share the personal information which is necessary for the particular purpose for which it is provided, or where we have another legitimate interest in doing so, and we will ensure that the personal information is appropriately protected.
Retention Period
We will keep personal information only for as long as is necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting or reporting requirements. Normally, our retention period for personal information collected for this purpose is a minimum of 7 years after the supply of our products or services.
OUR MARKETING COMMUNICATIONS & INFORMATION SERVICES
Collection
We will collect information such as a name, email address, IP address (or similar unique identifiers) job title and the business that you work for together with the additional information that you provide to us, for example when you let us know those products that you are interested in receiving information about. In respect of events that we offer, this information may include details of any access or dietary requirements that you have, which may reveal information about the health or religious beliefs of a data subject.
We may collect this information from you (whether directly or via automated means such as our website) or from third parties.
We will collect personal information in our CRM system when you tell us that you wish to receive all or part of our information, or otherwise give us your personal details. You may at any time tell us that you want to stop receiving our Information.
Use
Personal information will be used to provide you with our information that you ask for, or that we think are relevant to the preferences that you may have given to us. We may analyse what areas of information are of interest to you so that we can better target the Information that we provide.
We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
with your consent; and/or
in performance of a contract (the agreement to provide products); and/or
where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Disclosure
We may share personal information with third parties in respect of the provision of our Information, including to third parties who provide goods to us, including IT, website hosting, email delivery and other services. In respect of all disclosures of personal information, we will only share the personal information which is necessary for the particular purpose for which it is provided, or where we have another legitimate interest in doing so, and we will ensure that the personal information is appropriately protected. A list of the current third parties we use is set out at the end of this Privacy Policy.
We may also share personal information with third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
Retention Period
We will keep personal information only for as long as is necessary to fulfil the purposes for which we collected it. Any personal information that we have from you solely for the purposes of your receiving our Information will not be used once you have asked us to stop providing these to you (except to the extent that it is necessary to stop you receiving the Information).
OUR PEOPLE
Collection
We will collect names, addresses, contact details, education and employment history, identity and other background checks (which may include appropriate criminal and financial checks and confirmation of the right to work in the UK), marital status and information on next of kin and dependents, financial information (such as bank details and NI numbers), date of birth, gender, a copy of your passport and driving licence, performance information and compensation history, recruitment information (including references), salary, benefits, pension and annual leave information, disciplinary and grievance information, photographs, information about your use of our information and communications systems or other information obtained through electronic means.
We may collect and use special categories of personal information as required in the carrying out of obligations and exercising specific rights of us or the data subject in the field of employment. This may include information relating to matters such as health, racial origin, religious belief and offences or alleged offences.
Personal information may be collected from you during the selection process (for example via your application form and CV) and during your employment (including holiday forms, expense claims, performance reviews, any disciplinary or grievance processes), or from third parties, including referees, health service providers and background check providers.
Use
Personal information of our people will be used for HR administration and management, both in respect of the selection of people to work for us (including suitability, eligibility and/or fitness to work), and those who do work for us, to include learning and development, disciplinary and security (of people, offices and data) requirements, providing and liaising with benefits providers, business management and planning (including accounting and auditing), paying you and dealing with tax and NI deductions, assessing and deciding on salary reviews and compensation, conducting performance reviews and managing performance, dealing with legal disputes involving you or others, preventing fraud, monitoring your use of our information and communications systems, ensuring compliance with our policies, and equal opportunities monitoring.
We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
In performance of a contract with you; and/or
compliance with a legal obligation; and/or
vital interests of the data subject; and/or
where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
We may also use your personal information in the following situations, which are likely to be less common:
where we need to protect your interests (or someone else’s interests);
where it is needed in the public interest or for official purposes.
In respect of all disclosures of personal information, we will only share the personal information which is necessary for the particular purpose for which it is provided, or where we have another legitimate interest in doing so, and we will ensure that the personal information is appropriately protected.
In respect of special categories of personal information, we may process this in the following circumstances:
in limited circumstances with your explicit written consent; and/or
where we need to carry out our legal obligations and in line with our policies; and/or
where it is needed in the public interest (such as for equal opportunities monitoring or in relation to our occupational pension scheme), and in line with our policies; and/or
where it is needed to assess your working capacity on health grounds, subject to appropriate confidentiality safeguards.
Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your (or someone else’s) interests and you are not capable of giving your consent, or where you have already made the information public. We may also process such information about our people (or former people) in the course of our legitimate business activities with the appropriate safeguards.
The special categories of personal information may be used in the following ways:
in relation to leaves of absence, to comply with employment and other laws;
in relation to your physical or mental health, or disability status, to ensure your health and safety in the workplace and to assess your fitness to work, to monitor, manage and administer benefits and absences;
in relation to your race, national or ethnic origin, religious, philosophical or moral beliefs, or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting.
Disclosure
Personal information may be transferred to service providers who support the operation of our business (such as payroll service providers), to other third parties reasonably necessary in the conduct of our business (including insurers, professional advisors, regulators). These third parties may be acting as processor, or controller of personal information in their own right. Personal information may also be shared with our clients in offering or in the provision of legal services.
In respect of all disclosures of personal information, we will only share the personal information which is necessary for the particular purpose for which it is provided, or where we have another legitimate interest in doing so, and we will ensure that the personal information is appropriately protected.
Retention Period
We will keep personal information only for as long as is necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting or reporting requirements. We will normally keep personal information of applicants who we do not employ for six months after we receive it.
We will keep personal information of employees throughout your employment and normally for a minimum of six years after your employment ends.
CHANGES TO YOUR PERSONAL INFORMATION
It is very important that the personal information that we hold about you is accurate and current. Please tell us if your personal information changes during your relationship with us.
DATA SECURITY
We have put in place measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those of our people and other third parties who have a business need to know. They will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure. We have put in place procedures to deal with any suspected data security breach and will notify you and the ICO of a suspected breach where we are legally required to do so.
WHERE WE STORE YOUR PERSONAL INFORMATION
We principally store data, both electronically and on file, at our offices, with archive storage for files locally.
INTERNATIONAL TRANSFERS
Personal information may be transferred outside of the UK or EEA by processors acting on our behalf. For transfers to countries not considered adequate by the European Community (EC) or the UK, we will ensure that personal information is adequately protected, as required by the GDPR. This may include by use of the Standard Contractual Clauses adopted by the EC to protect personal information, together with the ICO’s international data transfer addendum.
YOUR RIGHTS
Under certain circumstances, you have the right by law to request:
Access to your personal information (often referred to as a “subject access request”). This enables you to ask to receive a copy of the personal information that we hold about you and to check that we are lawfully processing it.
Correction of the personal information that we hold about you (which may be subject to our verification of the new data provided).
Erasure of your personal information. We may not always be able comply with your request for erasure for specific legal reasons which will be notified to you at the time.
Object to the processing of your personal information where we are relying on our legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
Restriction of processing of your personal information, which will involve suspending processing of your personal data if you want us to establish its accuracy, where our use is unlawful but you do not want the data erased, if you need the data for a legal claim or you have objected to our processing and we need to establish if we have overriding legitimate grounds.
Transfer of your personal information to another party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
If you wish to exercise any of your rights please contact us at: privacy@argentumapothecary.com.
No fee usually required.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond.
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
LINKS FROM OUR WEBSITE
Our website may, from time to time, contain links to and from the websites of third parties that we permit to make such links. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. We recommend that you check these policies before you submit any personal information to these websites.
CHANGES TO THIS PRIVACY POLICY
Any changes we may make to our privacy policy in the future will be posted on our website, so please ensure that you are viewing the correct version.
Please contact our Data Protection Manager, by emailing privacy@argentumapothecary.com if you have any questions, comments or requests regarding this Privacy Policy.
THIRD-PARTIES WE WORK WITH
As part of our day to day business activities and service to our customers we may share your details with third parties and service providers in relation to: processing credit card payments, fulfilling orders, website processing and hosting, business analytics, advertising and marketing services through email, social media platforms and affiliate marketing networks.
