This Privacy Policy sets out how we, https://slowtonglobal.com/  (our website) collect, store and use information about you when you use or interact with our website, https://slowtonglobal.com/ (our website) and where we otherwise obtain or collect information about you. This Privacy Policy is effective from May 1, 2019.

 

Contents

• Summary
• Our details
• Information we collect when you visit our website
• Information we collect when you contact us
• Information we collect when you interact with our website
• Information we collect when you place an order on our website
• Our use of automated decision-making and profiling
• How we collect or obtain information about you from third parties
• Disclosure and additional uses of your information
• How long we retain your information
• How we secure your information
• Your rights in relation to your information
• Your right to object to the processing of your information for certain purposes
• Sensitive Personal Information
• Changes to our Privacy Policy
• Children’s Privacy
• Copyright, credit and logo

 

Summary

This section summarises how we obtain, store and use information about you. It is intended to provide a very general overview only. It is not complete in and of itself and it must be read in conjunction with the corresponding full sections of this Privacy Policy.

• Data controller: https://slowtonglobal.com/

 

• How we collect or obtain information about you:
  • when you provide it to us (e.g. by contacting us , placing an order on our website, sign up for our email newsletter, take a quiz, or create an account).
  • from your use of our website, using cookies and similar technologies, and
  • occasionally, from third parties.

 

• Information we collect: name, contact details, payment information e.g. your credit or debit card details, IP address, information from cookies, information about your computer or device (e.g. device and browser type), information about how you use our website (e.g. which pages you have viewed, the time when you view them and what you clicked on, the geographical location from which you accessed our website (based on your IP address), your answers to quizzes or surveys, and information about your internet connection.

 

• How we use your information: for administrative and business purposes (particularly to contact you and process orders you place on our website), to improve our business and website, to fulfil our contractual obligations, to advertise our goods and services, to analyse your use of our website, and in connection with our legal rights and obligations.

 

• Do we sell your information to third parties (other than in the course of a business sale or purchase or similar event): No.

 

• Use of cookies and similar technologies: we use cookies and similar information-gathering technologies such as web beacons on our website including essential, functional analytical and advertising cookies. 

 

• Your rights in relation to your information
• • to access your information and to receive information about its use
  • to have your information corrected and/or completed
  • to have your information deleted
  • to restrict the use of your information
  • to receive your information in a portable format
  • to object to the use of your information
  • to withdraw your consent to the use of your information

 

Our details

The data controller in respect of our website is  https://slowtonglobal.com/.

If you have any questions about this Privacy Policy, please contact the data controller.

 

Information we collect when you visit our website

We collect and use information from website visitors in accordance with this section and the section entitled Disclosure and additional uses of your information.

 

Web server log information

We use a third party server to host our website called Shopify Inc., the privacy policy of which is available here https://www.shopify.com/legal/privacy. Our website server automatically logs the IP address you use to access our website as well as other information about your visit such as the pages accessed, information requested, the date and time of the request, the source of your access to our website (e.g. the website or URL (link) which referred you to our website), and your browser version and operating system.

 

Use of website server log information for IT security purposes

 Our  third party hosting provider collect(s) and store(s) server logs to ensure network and IT security and so that the server and website remain uncompromised. This includes analysing log files to help identify and prevent unauthorised access to our network, the distribution of malicious code, denial of services attacks and other cyber attacks, by detecting unusual or suspicious activity.

Unless we are investigating suspicious or potential criminal activity, We/we do not make, nor do we allow our hosting provider to make, any attempt to identify you from the information collected via server logs.

 

Information we collect when you contact us

We collect and use information from individuals who contact us in accordance with this section and the section entitled Disclosure and additional uses of your information.

Email and Contact Form

When you send an email to the email address displayed on our website we collect your email address and any other information you provide in that email (such as your name, telephone number and the information contained in any signature block in your email).

 

Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).

 

Transfer and storage of your information

We use a third party email provider/customer service management tool to store emails and messages you send us. Our third party email provider is Shopify,Inc. Their privacy policy is available here https://www.shopify.com/legal/privacy.

 

Mail

If you contact us by mail, we will collect any information you provide to us in any postal communications you send us.

 

Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).

 

Information we collect when you interact with our website

We collect and use information from individuals who interact with particular features of our website in accordance with this section and the section entitled Disclosure and additional uses of your information.

 

E-Newsletter

When you sign up for our e-newsletter on our website or opt to receive news, offers, updates on out-of-stock items from us by entering your name and email address and clicking subscribe or ticking a box at checkout indicating that they would like to receive your e-newsletter, we collect your email address, information about your browser, information about the page you signed up on,  and any other additional information you may provide to us.

 

Consent: you give your consent to us sending you our e-newsletter by signing up to receive it using the steps described above.

 

Transfer and storage of your information

We use a third party service to send out our e-newsletter and administer our mailing list, Shopify,Inc. Their privacy policy is available here:  https://www.shopify.com/legal/privacy .

 

Registering on our website

When you register and create an account on our website, we collect the following information: Email address, IP address, and any other information you provide to us when you complete the registration form.

If you do not provide the mandatory information required by the registration form, you will not be able to register or create an account on our website. 

 

Information we collect when you place an order on our website

We collect and use information from individuals who place an order on our website in accordance with this section and the section entitled Disclosure and additional uses of your information.

 

Information collected when you place an order

Mandatory information

When you place an order for goods or services on our website, we collect your name, email address,  shipping address and information about your browser.

If you do not provide this information, you will not be able to purchase goods or services from us on our website or enter into a contract with us.

 

  

Processing your payment

After you place an order on our website you will need to make payment for the goods or services you have ordered. In order to process your payment we use a third party payment processor (Shopify Payments). Your payment will be processed by Shopify Payments.

Shopify Payments collects, uses and processes your information, including payment information, in accordance with their privacy policies. You can access  their privacy policy via the following link(s): Shopify Payments: https://pay.shopify.com/tos-privacy-policy

 

 

Our goods and services

You can opt in to receiving marketing communications from us in relation to our goods and services by email ticking a box indicating that you would like to receive such communications during checkout or at any time while browsing the site by entering your email address into our newsletter sign-up form.

We will send you marketing communications in relation to our goods and services only if you opt-in to receive them.

Consent: you give your consent to us sending you information about our goods and services by signing up to receive such information in accordance with the steps described above.

 

Information collected or obtained from third parties

This section sets out how we obtain or collect information about you from third parties.

Information received from third parties

Generally, we do not receive information about you from third parties. The third parties from which we receive information about you will generally include partner companies who we are doing a joint promotion with..

It is also possible that third parties with whom we have had no prior contact may provide us with information about you.

Information we obtain from third parties will generally be your name and contact details, but will include any additional information about you which they provide to us.

Reason why necessary to perform a contract: where a third party has passed on information about you to us (such as your name and email address) in order for us to provide services to you, we will process your information in order to take steps at your request to enter into a contract with you and perform a contract with you (as the case may be).

Consent: where you have asked that a third party to share information about you with us and the purpose of sharing that information is not related to the performance of a contract or services by us to you, we will process your information on the basis of your consent, which you give by asking the third party in question to pass on your information to us.

 

 

Use of profiling for web analytics

Our web analytics services, Google Analytics and Qubit, Inc. use collects information such as your location (based on your IP address) and your behaviour (based on cookies) when you access our website (such as the pages you visit and what you click on) and how much you are spending on our site. We will only process information from cookies if you have consented to us setting cookies on your computer in accordance with our cookies policy. Information collected about you, once collected is anonymised and stored on an aggregate basis. IP addresses are anonymized at the point of collection on our site.

 

  

Disclosure and additional uses of your information

This section sets out the circumstances in which will disclose information about you to third parties and any additional purposes for which we use your information.

 

 

Disclosure of your information to other third parties

We disclose your information to other third parties in specific circumstances, as set out below.

Providing information to third parties such as Google Inc.  Google collects information through our use of Google Analytics on our website. Google uses this information, including IP addresses and information from cookies, for a number of purposes, such as improving its Google Analytics service. Information is shared with Google on an aggregated and anonymised basis. To find out more about what information Google collects, how it uses this information and how to control the information sent to Google, please see the following page: https://www.google.com/policies/privacy/partners/]

 

Reason why necessary to perform a contract: we need to share your information with other companies in order to be able to meet our contractual obligations to you or to take steps at your request prior to entering a contract., for example because of the services or information you have requested.

 

Sharing your information with a prospective or actual purchaser or seller in the context of a business or asset sale or acquisition by us, a merger or similar business combination event, whether actual or potential.

 

 

Disclosure and use of your information for legal reasons

Indicating possible criminal acts or threats to public security to a competent authority

If we suspect that criminal or potential criminal conduct has been occurred, we will in certain circumstances need to contact an appropriate authority, such as the police. This could be the case, for instance, if we suspect that we fraud or a cyber crime has been committed or if we receive threats or malicious communications towards us or third parties.

We will generally only need to process your information for this purpose if you were involved or affected by such an incident in some way.

 

In connection with the enforcement or potential enforcement our legal rights

We will use your information in connection with the enforcement or potential enforcement of our legal rights, including, for example, sharing information with debt collection agencies if you do not pay amounts owed to us when you are contractually obliged to do so. Our legal rights may be contractual (where we have entered into a contract with you) or non-contractual (such as legal rights that we have under copyright law or tort law).

 

 

 

In connection with a legal or potential legal dispute or proceedings

We may need to use your information if we are involved in a dispute with you or a third party for example, either to resolve the dispute or as part of any mediation, arbitration or court resolution or similar process.

 

For ongoing compliance with laws, regulations and other legal requirements

We will use and process your information in order to comply with legal obligations to which we are subject. For example, we may need to disclose your information pursuant to a court order or subpoena if we receive one.

 

 

How long we retain your information

This section sets out how long we retain your information. We have set out specific retention periods where possible. Where that has not been possible, we have set out the criteria we use to determine the retention period.

 

Retention periods

 Order information: when you place an order for goods and services, we retain that information indefinitely or until you request that we delete unless this conflicts with our compliance of a legal responsibility.

 

E-Newsletter: we retain the information you used to sign up for our e-newsletter for as long as you remain subscribed (i.e. you do not unsubscribe) or if we decide to cancel our e-newsletter service, whichever comes earlier.

 

Criteria for determining retention periods

In any other circumstances, we will retain your information for no longer than necessary, taking into account the following:

• whether we have any legal obligation to continue to process your information (such as any record-keeping obligations imposed by relevant law or regulation);
• whether we have any legal basis to continue to process your information (such as your consent);
• the levels of risk, cost and liability involved with us continuing to hold the information

 

How we secure your information

We take appropriate technical and organisational measures to secure your information and to protect it against unauthorised or unlawful use and accidental loss or destruction, including:

• only sharing and providing access to your information to the minimum extent necessary, subject to confidentiality restrictions where appropriate, and on an anonymised basis wherever possible;
• using secure servers to store your information;
• verifying the identity of any individual who requests access to information prior to granting them access to information;
• only transferring your information via closed system or encrypted data transfers 

 

E-Newsletter

Information you submit to us when you sign up for our e-newsletter is transferred outside the EEA and stored on our third party mailing list provider’s servers. Our third party mailing list provider is: Shopify. You can access their privacy policy here: www.shopify.com/privacy

Country of storage: The United States. This country is not subject to an adequacy decision by the European Commission.

Safeguard(s) used: our third party mailing list provider has self-certified its compliance with the EU-U.S. Privacy Shield.

 

 

 

Payment Processor

Information you submit to us by our third party payment processor, Shopify Payments, is transferred outside the EEA and stored on their servers. You can access their privacy policy here: https://pay.shopify.com/tos-privacy-policy

Country of storage: The United States and Canada. These countries are not subject to an adequacy decision by the European Commission.

Safeguard(s) used: our payment processor has self-certified its compliance with the EU-U.S. Privacy Shield.

 

Your rights in relation to your information

Subject to certain limitations on certain rights, you have the following rights in relation to your information, which you can exercise by sending an email to manager@slowtonglobal.com

• to request access to your information and information related to our use and processing of your information;
• to request the correction or deletion of your information;
• to request that we restrict our use of your information;
• to receive information which you have provided to us in a structured, commonly used and machine-readable format (e.g. a CSV file) and the right to have that information transferred to another data controller (including a third party data controller);
• to object to the processing of your information for certain purposes (for further information, see the section below entitled Your right to object to the processing of your information for certain purposes); and
• to withdraw your consent to our use of your information at any time where we rely on your consent to use or process that information. Please note that if you withdraw your consent, this will not affect the lawfulness of our use and processing of your information on the basis of your consent before the point in time when you withdraw your consent.

In accordance with Article 77 of the General Data Protection Regulation, EU Residents also have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or of an alleged infringement of the General Data Protection Regulation.

 

 

Verifying your identity where you request access to your information

Where you request access to your information, we are required by law to use all reasonable measures to verify your identity before doing so.

These measures are designed to protect your information and to reduce the risk of identity fraud, identity theft or general unauthorised access to your information.

  

Sensitive Personal Information

‘Sensitive personal information’ is information about an individual that reveals their racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic information, biometric information for the purpose of uniquely identifying an individual, information concerning health or information concerning a natural person’s sex life or sexual orientation.

We do not knowingly or intentionally collect sensitive personal information from individuals, and you must not submit sensitive personal information to us.

If, however, you inadvertently or intentionally transmit sensitive personal information to us, you will be considered to have explicitly consented to us processing that sensitive personal information under Article 9(2)(a) of the General Data Protection Regulation. We will use and process your sensitive personal information for the purposes of deleting it.

 

Changes to our Privacy Policy

We update and amend our Privacy Policy from time to time.

Minor changes to our Privacy Policy

Where we make minor changes to our Privacy Policy, we will update our Privacy Policy with a new effective date stated at the beginning of it. Our processing of your information will be governed by the practices set out in that new version of the Privacy Policy from its effective date onwards.

 

Major changes to our Privacy Policy or the purposes for which we process your information

Where we make major changes to our Privacy Policy or intend to use your information for a new purpose or a different purpose than the purposes for which we originally collected it, we will notify you by email (where possible) or by posting a notice on our website.

We will provide you with the information about the change in question and the purpose and any other relevant information before we use your information for that new purpose.

Wherever required, we will obtain your prior consent before using your information for a purpose that is different from the purposes for which we originally collected it.