Privacy Policy

1. Who we are and how to contact us

We are a limited company trading as Baileo Ltd, registered number NI658137. Baileo Ltd is registered, and operates, in the United Kingdom. Baileo Ltd is the controller and responsible for your personal data (collectively referred to as, “we”, “us” or “our” in this Privacy Policy).

Our Registered Address is: Baileo Ltd, 12 Annaghmore Rd, Coalisland, Dungannon, County Tyrone, Northern Ireland, BT71 4QZ.

If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact us via customercare@baileo.com and state that your query is relating to Data Privacy.

We may need to update this Policy at any time and without notice and where we do this we will notify you by including pop up boxes on the website and/or emailing our customers.

It is important that the personal data we hold about you is accurate and up to date. Please keep us informed if your personal data changes during your relationship with us and periodically review your account settings on our website.

2. The data we collect about you

Personal data only includes information relating to natural persons who:

• can be identified or who are identifiable, directly from the information in question; or
• who can be indirectly identified from that information in combination with other information.
• Personal data may also include special categories of personal data or criminal conviction and offences data. These are considered to be more sensitive and you may only process them in more limited circumstances.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

• Identity Data includes first name and last name. It also includes your gender, if you choose to provide it to us.
• Contact Data means the data we use to contact you including your billing address, delivery address, email address and telephone number.
• Financial Data means the payment method and card association used to process your payments for your orders. We do not store or process your card details ourselves, they are processed and stored via one of our contracted Payment Processors. In certain limited cases, we may receive bank account details in the context of administering refunds.
• Transaction Data means details about transactions you have made on our website including the payments to and from you along with other details of products and services you have purchased from us.
• Technical Data means details about the device(s) you use to access our website including your internet protocol (IP) address, browser type and version, location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
• Profile Data includes your username (email address), your login data, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our website, products and services. This includes your browsing patterns and information such as how long you might spend on one of our webpages and what you look at and for on our website, the page that referred you to our site and the click stream during your visit to our website, page response times and page interaction information (clicks you make on a page).
• Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
  

We also collect, use and share aggregated and/or anonymised data (“Aggregated Data”) such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this type of data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

We do not collect any “Special Categories of Personal Data” about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, where you do not provide suitable delivery instructions to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

3. How your personal data is collected

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity Data, Contact Data, Transaction Data, Profile Data, Financial Data and Marketing and Communications Data by using our website, filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you

• purchase a product or service (including gift cards) through our website;
• create an account on our website;
• request marketing to be sent to you;
• enter a competition; or
• give us some feedback

Automated technologies or interactions. As you interact with our website, we may automatically collect Usage Data and Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our Cookies Policy for further details.

THIRD PARTY SOURCES OF DATA/DATA SHARING:

We also collect from and share data with the following providers:

• Essential Service Providers. Sometimes, other businesses give us data about you which we may need for our legitimate interests of conducting business with you and on occasion they are necessary to perform our contract with you. It usually comprises Financial Data or Transaction Data. This happens when we link through to third party payment providers. They tell us that you have paid for your products and, where relevant and/or necessary they will provide us with your Contact Data and Transaction Data. We also might engage third party contractors to provide us with technical or delivery services that are related to your account with us.
• Professional Advisers and Investors. WWe may also share your data with professional advisers such as our lawyers and insurers to manage risks and legal claims, and/or as part of our relationship and obligations to investor organizations. This is in our legitimate interests and does not affect your statutory rights.
• Group. It is possible we could sell our business to a third party or re-organise our business or become insolvent. In that scenario, our database of customers is one of the biggest parts of that business and so we would need to share it with the third-party buyer and their advisers. This is in the legitimate interests of selling our business. We may also expand our group of companies and in this scenario we may share your data within our group in order to improve our products and services and because of some of our internal support services may be shared across the group. This is in our legitimate interests of cost efficiency and growing our business. Where this occurs, we will post a link to all group companies and their locations in this Privacy Policy and they will use it in the ways set out in this Policy.
• Law Enforcement/Legal Compliance. We will cooperate with all third parties to enforce their intellectual property or other rights. We will also cooperate with law enforcement requests from within or outside your country of residence. This may include disclosing your personal information to government or law enforcement agencies, or private parties, when we have a good faith belief that disclosure is required by law or when we, in our discretion, believe that disclosure is necessary to protect our legal rights, or those of third parties and/or to comply with a judicial proceeding, court order, fraud reduction or legal process served on us. In such cases, we may raise or waive any legal objection or right available to us. These uses of your data are in our legitimate interests of protecting our business security. We may also use your data and share it with the recipients listed in this Privacy Policy for the purpose of complying with our legal obligations.

The lawful basis for sharing and processing this data is set out in the Glossary at the end of this Policy. Please refer to the External Third Parties listed in the Glossary for further information.

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into, or have entered into, with you.
• 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.
• Where we need to comply with a legal or regulatory obligation.

See the Glossary at the end of this Privacy Policy to find out more about the types of lawful basis that we will rely on to process your personal data.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by visiting our Preferences Page.

Marketing Communications

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you. We only use the data you provide to us directly for this purpose along with the Aggregated Data provided to us by our analytics partners and we do not track what other websites you may visit after visiting our site, though in common with most websites, we may register the site which referred you to our site (e.g. a search engine).

You can ask us to stop sending you marketing messages at any time by:

• Logging into your account and adjusting your marketing preferences
• Following the “Unsubscribe” links on any marketing message sent to you
• Contacting us at any time via customercare@baileo.com

Where you opt-out of receiving marketing messages, opt-outs will not apply to service-related communications (and any processing of your Personal Data involved in sending such communications). Examples of these service-related communications may include emails or notifications:

• about orders you make using the Baileo platform;
• relating to the management of your account on the Site;
• about your use of the Site; or
• concerning updates to this Privacy Policy or our Terms & Conditions etc.

Opting out of receiving marketing messages will also not apply to personal data provided to us as a result of a product/service purchase, or related correspondence, and we will continue to process such data in accordance with this Privacy Policy and only ever as permitted by law.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookies Policy.

Change of Purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Disclosures of your personal data

We require all third parties to respect the security of your personal data and to treat it in accordance with the law and they may only use your data for the purposes we specify in our contract with them and for no other purpose. We will always work with them to protect your privacy.

International transfers

Some of our External Third Parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
• We may transfer data to partners in the USA if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.

Please contact us via customercare@baileo.com if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

5. Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

You acknowledge that the Internet is not a completely secure medium for communication and, accordingly, we cannot guarantee the security of any information you send to us (or we send to you) via the Internet. We are not responsible for any damages which you, or others, may suffer as a result of the loss of confidentiality of such information.

6. Data Retention

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?.

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. For example, details of your orders will be kept for as long as we need to retain that data to comply with our legal and regulatory requirements. This is generally 7 years unless the law prescribes a longer period.

In some circumstances you can ask us to delete your data: see ‘Your Legal Rights’ below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

7. Our policy on children

While this Site may carry content and products for children e.g. children’s stories or children’s gifts, the site itself is not intended for children below 16. We do not knowingly collect data relating to any such children.

8. Your legal rights

Under certain circumstances, you have rights under UK data protection laws in relation to your personal data.

You have the right to:

Request access to your Personal Data. This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.

Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.

Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have exercised your right to object to processing (see below).

Object to processing of your Personal Data. This right exists where we are relying on a Legitimate Interest as the legal basis for our processing 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 Data for direct marketing purposes.

Request the restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of Personal Data about you, for example if you want us to establish its accuracy or the reason for processing it.

Request the transfer of your Personal Data. 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 these rights, please contact us via customercare@baileo.com, using Data Protection Query in the subject line.

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 may refuse to comply with your request in these circumstances.

We may need to ask you for specific information 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 our response.

We try to respond to all legitimate requests within one month. Occasionally, it may take 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.

9. How we use cookies & other tracking or profiling technologies

Cookies
What are cookies?

We may collect information using “cookies”. Cookies are small data files stored on the hard drive of your computer or mobile device by a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience on our Site.

We use two broad categories of cookies:

• first party cookies, served directly by us to your computer or mobile device; and
• third party cookies, which are served by our partners or service providers on our Site.

Cookies we use

Essential Cookies. These cookies are essential to provide you with services available through our Site and to enable you to use some of its features. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.

Functionality Cookies These cookies allow our Site to remember choices you make when you use our Site. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-select your preferences every time you visit our Site.

Analytics and Performance Cookies These cookies are used to collect information about traffic to our Site and how users use our Site. The information gathered may include the number of visitors to our Site, the websites that referred them to our Site, the pages they visited on our Site, what time of day they visited our Site, whether they have visited our Site before, and other similar information. We use this information to help operate our Site more efficiently, to gather broad demographic information, monitor the level of activity on our Site, and improve the Site.

We use Google Analytics for this purpose. Google Analytics uses its own cookies. You can find out more information about Google Analytics cookies at https://support.google.com/analytics/answer/6004245 and about how Google protects your data at https://policies.google.com/privacy

Targeted and advertising cookies These cookies track your browsing habits to enable us to show advertising which is more likely to be of interest to you. These cookies use information about your browsing history to group you with other users who have similar interests. Based on that information, third party advertisers can place cookies to enable them to show advertisements which we think will be relevant to your interests while you are on third party websites.

Social Media Cookies These cookies are used when you share information using a social media sharing button or “like” button on our Site or you link your account or engage with our content on or through a social networking website such as Facebook or Twitter. The social network will record that you have done this.

Duration of Cookies
Session (or Transient) Cookies: Session cookies are stored in your computer's memory for the length of your browsing session. They become inaccessible after the session has been inactive for a time and are automatically deleted from your computer when the browser is closed. They allow you to move from page to page without having to log-in repeatedly.

Persistent (or Permanent) Cookies: Persistent cookies are stored in your computer memory and are not deleted when the browser is closed. They are used to keep your preferences for the website, so they will be remembered for next time you visit the website. They are also used to collect information about the numbers of visitors, the average time spent on a particular page and analyse shopping behaviour on the website. This information is used to find out how well the website works and where it can be improved.

Flash Cookies (or Locally Shared Objects): You probably have Adobe Flash installed on your computer. Websites that contain Flash can also store small files on your computer that are used in the same way as cookies.

Flash cookies can also back up the data that is stored in other cookies. When you delete cookies, your Flash cookies are not affected. Therefore, a website may still recognise you if it backed up the deleted cookie information on a Flash cookie.

Sharing with social networks: If you use the buttons that allow you to share products and content with your friends via social networks like Twitter and Facebook, these companies may set a cookie on your computer memory. Find out more about these here:

• https://www.facebook.com/about/privacy/
  
• http://twitter.com/privacy
  
• http://www.google.com/intl/en-GB/policies/privacy/
  

Managing Cookies

If cookies aren't enabled on your computer, it will mean that your shopping experience on our website will be limited to browsing and researching; you won't be able to add products to your basket or buy them. To enable and manage cookies, you can use your browser to do this. Each browser is different, so check the 'Help' menu of a particular browser (or your mobile phone's handset manual) to learn how to change your cookie preferences.

• Google Chrome
• Internet Explorer
• Mozilla Firefox
• Safari
• Opera
• Google Analytics Opt Out

10. Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

EXTERNAL THIRD PARTIES

Partners - when you place an order, we share your information with the relevant Partner so that they can process and deliver your order.

Cloud storage providers - we use cloud computing platforms that securely store all of our data, including customer details.

Email service providers - in order to send you marketing content and transactional emails, we share your details with our email service providers. **

Social Media Platforms - We may make your name and email address available to companies in order to advertise and market our services to you through other platforms on the internet (e.g. Facebook). See the ‘Marketing’ section of this Privacy Policy above.

Analytics tools - we use analytics tools to track the way that users interact with our website.

Profiling tools - we use profiling tools to understand how you engage with our website and show you content we think will be most relevant to you, based on our understanding of your interests and

Payment providers - in order to facilitate any payments made on our site, we facilitate the sharing of your Financial Data with payment providers.

Delivery providers - in order to package and mail your orders to you, it is necessary to share your information with delivery providers.

Marketing and insights providers - marketing and insights tools allow us to understand our customers better so that we may provide you with the best possible website, products and customer service experience. We may share certain information about our customers to facilitate this process.

Customer service platforms - when you interact with our customer service team, your details are shared with our customer service platform providers.

Feedback forms - when you make a purchase, we engage a third party to send out feedback forms on our behalf.