Privacy Policy

Confidentiality,
Privacy and Data
Retention Policy

Any information given to us, either verbally or in writing, regarding your child or your Family will be treated as confidential. We are registered with the Information Commissioner’s Office (ICO) and are aware of our responsibilities under General Data Protection Regulation (GDPR) Data Protection Regulations (GDPR) and the Data Protection Act, 2018.

1. INTRODUCTION

This privacy notice explains how we collect and process your personal data when you use our site www.sunnykidsshine.com. By providing us with your data, you warrant to us that you are over 18 years of age.

By providing us with your child’s data (if under the age of 13), you warrant to us that you are giving consent on their behalf, that you are their legal guardian and that you have full parental responsibility.

Sunny Kids Shine® Ltd are the data controller, and we are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).

Our registered office is: 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ.

Contact Number: 0208 036 4946

It is very important that the information we hold about you is accurate and up to date. Please let us know if your personal information changes at any time by emailing us at info@sunnykidsshine.com.

2. WHAT DATA DO WE COLLECT ABOUT YOU, FOR WHAT PURPOSE AND ON WHAT GROUND WE PROCESS IT

Personal data means any information capable of identifying an individual. It does not include anonymised data. We may process the following categories of personal data about you:

• Communication Data includes any communication you send to us, whether through the contact form on our website, email, text, social media messaging, social media posting, or any other communication. We process this data for the purposes of communicating with you, for record-keeping, and for the establishment, pursuit, or defence of legal claims. Our lawful ground for this processing is our legitimate interests, which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.
• Customer Data that includes data relating to any purchases of goods and/or services, such as your name, title, billing address, delivery address, email address, phone number, contact details, purchase details and your card details. We process this data to supply the goods and/or services you have purchased and to keep records of such transactions. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract.
• User Data that includes data about how you use our website and any online services, together with any data that you post for publication on our website or through other online services. We process this data to operate our website and ensure relevant content is provided to you, to ensure the security of our website, to maintain backups of our website and/or databases, and to enable the publication and administration of our website, other online services, and our business. Our lawful ground for this processing is our legitimate interests, namely, to properly administer our website and our business.
• Technical Data that includes data about your use of our website and online services, such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is from our analytics tracking system. We process this data to analyse your use of our website and other online services, to administer and protect our business and website, to deliver relevant website content and advertisements to you and to understand the effectiveness of our advertising. Our lawful ground for this processing is our legitimate interests, which in this case are to properly administer our website and business, grow our business, and determine our marketing strategy.
• Marketing Data includes your preferences for receiving marketing from third parties and from us, as well as your communication preferences. We process this data to enable you to participate in our promotions, such as competitions, prize draws, and free giveaways, to deliver relevant website content and advertisements to you, and to measure or understand the effectiveness of this advertising. Our lawful ground for this processing is our legitimate interests, which in this case are to study how customers use our products/services, to develop them, to grow our business and to decide our marketing strategy.
• We may use Customer Data, User Data, Technical Data and Marketing Data to deliver relevant website content and advertisements to you (including Facebook adverts or other display advertisements) and to measure or understand the effectiveness of the advertising we serve you. Our lawful ground for this processing is legitimate interests, which is to grow our business. We may also use this data to send you other marketing communications. Our lawful ground for this processing is either consent or legitimate interests (namely, to grow our business).
• We need to collect the following sensitive data about you to deliver our services: your race or ethnicity, religious or philosophical beliefs, and health information. We do not collect any information about criminal convictions and offences. We require your explicit consent to process sensitive data. When you submit your details, we will send you further communication to confirm your consent to this processing.

Where we are required to collect personal data by law or under the terms of the contract between us, and you do not provide it when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have ordered. If we do, we will notify you at that time.

We will only use your personal data for the purpose it was collected for or a reasonably compatible purpose if necessary. For more information, please email us at info@sunnykidsshine.com. If we need to use your details for an unrelated purpose, we will let you know and explain the legal grounds for processing.

We may process your personal data without your knowledge or consent where this is required or permitted by law.

We do not engage in automated decision-making or any form of automated profiling.

3. HOW WE COLLECT YOUR PERSONAL DATA

We may collect data about you by you providing the data directly to us (for example, by filling in forms on our site or by sending us emails). We may automatically collect certain data from you as you use our website by using cookies and similar technologies. Please see our cookie policy for more details about this.

We may receive data from third parties such as analytics providers, such as Google, based outside the UK, advertising networks, such as Facebook, based outside the UK, search information providers, such as Google, based outside the UK, providers of technical, payment and delivery services, such as data brokers or aggregators.

We may also receive data from publicly available sources such as Companies House and the Electoral Register, based in the UK.

4. MARKETING COMMUNICATIONS

Our lawful grounds for processing your personal data to send you marketing communications are either your consent or our legitimate interests (namely, to grow our business).

[Under the Privacy and Electronic Communications Regulations, we may send you marketing communications from us if (i) you made a purchase or asked for information from us about our goods or services, or (ii) you agreed to receive marketing communications, and in each case you have not opted out of receiving such communications since. Under these regulations, if you are a limited company, we may send you marketing emails without your consent. However, you can still opt out of receiving marketing emails from us at any time.]

Before we share your personal data with any third party for their own marketing purposes, we will get your express consent.

You can ask third parties or us to stop sending you marketing messages at any time by emailing us at info@sunnykidsshine.com. If you opt out of receiving marketing communications, this opt-out does not apply to personal data provided as a result of other transactions, such as purchases, warranty registrations, etc.

5. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below:

• Service providers who provide IT and system administration services.
• Professional advisers, including lawyers, bankers, auditors and insurers.
• Government bodies that require us to report processing activities.
• Third parties to whom we sell, transfer, or merge parts of our business or our assets.

We require all third parties to whom we transfer your personal data to respect its security and treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

6. INTERNATIONAL TRANSFERS

We are subject to the General Data Protection Regulation, which protects your personal data. Where we transfer your data to third parties outside the UK, we will ensure that appropriate safeguards are in place to maintain a similar degree of security for your personal data. As such:

• We may transfer your personal data to countries that the United Kingdom regulatory authorities have approved as providing an adequate level of protection for personal data, by; or
• If we use US-based providers that are part of a UK regulator-approved privacy framework, we may transfer data to them, as they have equivalent safeguards in place; or
• Where we use certain service providers established outside the UK, we may use specific contracts, codes of conduct, or certification mechanisms approved by the European Commission that give personal data the same protection it has in Europe.

If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.

7. DATA SECURITY

We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorisation. We also allow access to your personal data only to employees and partners who have a business need to know it. They will only process your personal data on our instructions, and they must keep it confidential.

We have procedures in place to address any suspected personal data breach and will notify you and any applicable regulator if we are legally required to do so.

8. DATA RETENTION

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

When deciding what the correct time is to keep the data for, we look at its volume, nature and sensitivity, the potential risk of harm from unauthorised use or disclosure, the processing purposes, whether these can be achieved by other means, and legal requirements.

For tax purposes, the law requires us to retain basic information about our customers (including Contact, Identity, Financial, and Transaction Data) for 6 years after they stop being customers.

In some circumstances, we may anonymise your personal data for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9. YOUR LEGAL RIGHTS

Under data protection laws, you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent.

You can see more about these rights at: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

If you wish to exercise any of the rights set out above, please email us at info@sunnykidsshine.com.

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, or refuse to comply with it in these circumstances.

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 anyone who does not have the right to receive it. We may also contact you to request further information regarding your request to expedite our response.

We try to respond to all legitimate requests within one month. Occasionally, it may take us longer than a month if your request is particularly complex or if you have made multiple requests. In this case, we will notify you.

If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk).

We would be grateful if you would contact us first if you have a complaint, so we can try to resolve it for you.

10. THIRD-PARTY LINKS

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

11. 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 www.sunnykidsshine.com/cookie-policy

We update these policies and terms and conditions from time to time, so please check them regularly to stay up to date with the latest revision.