Privacy Policy

Privacy and cookies policy

  1. Introduction

1.1    We are committed to safeguarding the privacy of our website visitors.

1.2    This policy applies where we are acting as a data controller with respect to the personal data of our website visitors; in other words, where we determine the purposes and means of the processing of that personal data.

1.3    In this policy, “we”, “us” and “our” refer to MWY Ltd. For more information about us, see Section 14.

  1. How we use your personal data

2.1    In this Section 2 we have set out:

(a)    the general categories of personal data that we may process;

(b)    in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;

(c)    the purposes for which we may process personal data; and

(d)    the legal bases of the processing.

2.2    We may process data about your use of our website and services (“analytics data“). The analytics data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the analytics data is our analytics tracking system. This analytics data may be processed for the purposes of analysing the use of the website. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.

2.3    We may process information contained in any enquiry you submit to us regarding goods and/or services or information contained in or relating to any communication between us (“enquiry data“). The enquiry data may be processed for the purposes of offering, marketing and selling relevant services and/or goods to you and for the purposes of communicating with you and record-keeping. The enquiry data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.

2.4    We may process information that you provide to us for the purpose of subscribing to our newsletters (“marketing data“). The marketing data may be processed for the purposes of sending you the relevant newsletters. The legal basis for this processing is consent.

2.5    We may process information that you provide to us for the purpose of purchasing of goods on our website or over the telephone (“transaction data”). This data may include your name, address, email address or telephone number. This transaction data may be processed for the purposes of payment for, shipping and delivering of the relevant goods and communicating with you in connection with the payment for, shipping and delivering of the goods. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.

2.6    We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

2.7    We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

2.8    In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

2.9    Please do not supply any other person’s personal data to us, unless we prompt you to do so.

  1. Providing your personal data to others

3.1    We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

3.2    We may disclose your enquiry data to one or more of those selected third party suppliers of services for the purpose of enabling them to contact you so that they can offer, market and sell to you the relevant services. For example, we may disclose your enquiry data to a hospital, health centre, medical doctor or therapist. Please contact us for a list of relevant third-party suppliers. Each such third party will act as a data controller in relation to the enquiry data that we supply to it; and upon contacting you, each such third party will supply to you a copy of its own privacy policy, which will govern that third party’s use of your personal data.

3.3    ‌We may disclose your transaction data to one of our drop-shipping partners for the purpose of enabling them to ship and deliver the products you have purchased to you and so they are able to contact you in connection with the relevant shipping and delivery. We may also disclose the transaction data to our payment services providers. Each such third party will act as a data controller in relation to the transaction data that we supply to it; and upon contacting you, each such third party should supply or make available to you a copy of its own privacy policy, which will govern that third party’s use of your personal data.

3.4    Information generated by the use of cookies on our website will be provided directly to relevant third-party services. In particular, analytics data will be provided to Google, Inc and Defiant Inc (who provide the Wordfence plugin used on our website). You can review the Wordfence privacy and data protection policies at https://www.wordfence.com/help/general-data-protection-regulation/#data-processing-agreement. See Section 11.2 for information about Google, Inc’s privacy and data protection policies. These service providers have facilities outside the United Kingdom and European Economic Area, including in the United States of America, and those facilities may be used to process the personal data that is supplied. We will ensure that any transfers of personal data that we make outside the United Kingdom and European Economic Area are protected by appropriate safeguards (namely, the use of standard contractual clauses or the Privacy Shield scheme) or are to a jurisdiction provided adequate protection to personal data.

3.5    In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

  1. Retaining and deleting personal data

4.1    This Section 4 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

4.2    Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

4.3    We will retain your personal data as follows:

(a)    analytics data will be retained for a maximum period of 36 months following the date of collection of that data;

(b)    enquiry data will be retained for a maximum period of 36 months following the date of the enquiry;

(c)    marketing data will be retained for a maximum period of 6 months following the date that we are instructed to cease sending the notifications (providing that we will retain marketing data insofar as necessary to fulfil any request you make to actively suppress notifications); and

(d)    transaction data will be retained for a minimum period of 10 years following date of the relevant transaction, and for a maximum period of 11 years following that date.

4.4    Notwithstanding the other provisions of this Section 4, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

  1. Your rights

5.1    In this Section 5, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

5.2    Your principal rights under data protection law are:

(a)    the right to access – you can ask for copies of your personal data;

(b)    the right to rectification – you can ask us to rectify inaccurate personal data and to complete incomplete personal data;

(c)    the right to erasure – you can ask us to erase your personal data;

(d)    the right to restrict processing – you can ask use to restrict the processing of your personal data;

(e)    the right to object to processing – you can object to the processing of your personal data;

(f)     the right to data portability – you can ask that we transfer your personal data to another organisation or to you;

(g)    the right to complain to a supervisory authority – you can complain about our processing of your personal data; and

(h)    the right to withdraw consent – to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.

5.3    You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.

5.4    You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

5.5    In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.

5.6    In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

5.7    You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

5.8    You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.

5.9    You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

5.10  To the extent that the legal basis for our processing of your personal data is:

(a)    consent; or

(b)    that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,

and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

5.11  If you consider that our processing of your personal data infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.

5.12  To the extent that the legal basis for our processing of your personal data is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

5.13  You may exercise any of your rights in relation to your personal data by written notice to us.

  1. Third party websites

6.1    Our website includes hyperlinks to, and details of, third party websites.

6.2    We have no control over, and are not responsible for, the privacy policies and practices of third parties.

  1. Personal data of children

7.1    Please do not submit to our website personal data of children.

7.2    If we have reason to believe that we hold personal data of a person under the age of 18 in our databases, we will delete that personal data.

  1. Updating information

8.1    Please let us know if the personal information that we hold about you needs to be corrected or updated.

  1. About cookies

9.1    A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

9.2    Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

9.3    Cookies do not typically contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.

  1. Cookies that we use

10.1  We may use cookies for the following purposes:

(a)    authentication and status – we use cookies to identify you when you visit our website and as you navigate our website, and to determine if you are logged into the website;

(b)    personalisation – we use cookies to store information about your preferences and to personalise the website for you, including blocking and showing content based on your geographical location;

(c)    security – we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally;

(d)    cookie consent – we use cookies to store your preferences in relation to the use of cookies more generally.

  1. Cookies used by our service providers

11.1  We may use Google Analytics to analyse the use of our website. Google Analytics gathers information about the use of our website by means of cookies. The information gathered is used to create reports about the use of our website. You can find out more about Google’s use of information by visiting https://www.google.com/policies/privacy/partners/ and you can review Google’s privacy policy at https://policies.google.com/privacy.

11.2  We may publish Google AdSense interest-based advertisements on our website. These are tailored by Google to reflect your interests. To determine your interests, Google will track your behaviour on our website and on other websites across the web using cookies. You can view, delete or add interest categories associated with your browser by visiting: https://adssettings.google.com. You can also opt out of the AdSense partner network cookie using those settings or using the Network Advertising Initiative’s multi-cookie opt-out mechanism at: http://optout.networkadvertising.org. However, these opt-out mechanisms themselves use cookies, and if you clear the cookies from your browser your opt-out will not be maintained. To ensure that an opt-out is maintained in respect of a particular browser, you may wish to consider using the Google browser plug-ins available at: https://support.google.com/ads/answer/7395996.

11.3 We use Zendesk Chat to allow visitors to communicate with us through the website. Zendesk Chat uses cookies to identify visitors, website visits and country location information. You can view the privacy policy of Zendesk, Inc at https://www.zendesk.com/company/customers-partners/privacy-policy/.

  1. Managing cookies

12.1  Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

(a)    https://support.google.com/chrome/answer/95647 (Chrome);

(b)    https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);

(c)    https://help.opera.com/en/latest/security-and-privacy/ (Opera);

(d)    https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);

(e)    https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac (Safari); and

(f)     https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).

12.2  Blocking all cookies will have a negative impact upon the usability of many websites.

12.3  If you block cookies, you will not be able to use all the features on our website.

  1. Amendments

13.1  We may update this policy from time to time by publishing a new version on our website.

13.2  You should check this page occasionally to ensure you are happy with any changes to this policy.

  1. Our details

14.1  This website is owned and operated by MWY Limited.

14.2  We are registered in England and Wales under registration number 10174181, and our registered office is at Top Flat, 29 The Mall, Faversham, Kent, England, ME13 8JL.

14.3  You can contact us:

(a)    by post, to the postal address given above;

(b)    using our website contact form;

(c)    by telephone, on the contact number published on our website; or

(d)    by email, using the email address published on our website.

14.4  Our data protection registration number is ZA394321.