Welcome to Neom Ltd’s privacy notice.
Neom is committed to your privacy and protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of what country you visit it from) and tell you about your privacy rights and how the law protects you.
We know that there’s a lot of information here, but we want you to be fully informed about your rights and how Neom uses your data. Accordingly, this privacy notice is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary for more information on the meaning of some of the terms used in this privacy notice.
1.1 PURPOSE OF THIS PRIVACY NOTICE
This privacy notice aims to give you information on how Neom collects and processes your personal data you provide to us, including any data you may provide through this website when you sign up to our newsletter, purchase a product or take part in a competition.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
1.2 DATA CONTROLLER
Neom Ltd is the controller and responsible for your personal data (collectively referred to as ”company”, “we”, “us” or “our” in this privacy notice). We are registered with the Information Commissioner. Our registration number is Z8810781.
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.
1.3 OUR CONTACT DETAILS
Our full details are:
Neom Ltd (Company Number 05127949)
For the attention of the Data Privacy Manager
Email address: email@example.com
Postal address: Neom Organics, Gardner House, Hornbeam Park Avenue, Harrogate, HG2 8NA.
Telephone number: 01423 878810
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
1.4 CHANGES TO THE PRIVACY NOTICE
The data protection law in the UK will change on 25 May 2018. Although this privacy notice sets out most of your rights under the new laws, we may not yet be able to respond to some of your requests (for example, a request for the transfer of your personal data) until May 2018 as we are still working towards getting our systems ready for some of these changes.
1.5 YOUR DUTY TO INFORM US OF CHANGES
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
1.6 THIRD-PARTY LINKS
Our website may include links to third-party websites, plug-ins and applications. We currently link to Feefo, Facebook, twitter, Google, Instagram and YouTube on the blog section of our website (and we will update this as and when we change this list). 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.
2.1 THE DATA WE PROCESS
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
We also collect, use and share 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 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 notice.
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.
Please note that we do not store your password in plain text. It is encrypted and so we are unable to see what your password is. We can process a request to re-set your password if you have forgotten it.
2.2 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, to provide you with products). In this case, we may have to cancel a product you have with us but we will notify you if this is the case at the time.
We use different methods to collect data from and about you including through:
3.1 DIRECT INTERACTIONS
You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
3.2 AUTOMATED TECHNOLOGIES OR INTERACTIONS.
3.3 THIRD PARTIES OR PUBLICLY AVAILABLE SOURCES.
We may receive personal data about you from various third parties with whom we may partner with.
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 you give your consent to any of our processing, you have the right to withdraw consent at any time by contacting us at firstname.lastname@example.org.
4.1 PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us at email@example.com if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as a new customer||(a) Identity
|Performance of a contract with you|
|To process and deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(e) Marketing and Communications
|(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
|To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey
(d) Marketing and Communications
|(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products)
|To take part in a consumer perception study||(a) Identity
(c ) Profile
|(a) With your consent
(b) Necessary for our legitimate interests (to develop products that our customers wish to purchase in the future)
|To enable you to take part in a prize draw, competition or complete a survey||(a) Identity
(e) Marketing and Communications
|(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products, to develop them and grow our business)
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity
|(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||(a) Identity
(e) Marketing and Communications
|Necessary for our legitimate interests (to study how customers use our products, to develop them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve our website, products, customer services marketing, customer relationships and experiences||(a) Technical
|Necessary for our legitimate interests (to define types of customers for our products, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
|To make suggestions and recommendations to you about goods or services that may be of interest to you||(a) Identity
|(a) With your consent
(b) Necessary for our legitimate interests (to develop our products and grow our business)
4.2 COMMUNICATIONS PREFERENCES
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established a preference centre where you can view and make certain decisions about your personal data use. You can decide how you would like us to communicate with you, how often and what information you would like to hear from us about.
4.3 PROMOTIONAL OFFERS FROM US
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.
You will receive marketing communications from us if you have requested information from us or purchased goods from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
4.4 THIRD-PARTY MARKETING
We do not sell, rent or otherwise disclose your personal information to third parties for their marketing purposes. We will get your express opt-in consent before we share your personal data with any company outside the Neom group of companies for marketing purposes.
4.5 OPTING OUT
If you do not wish to receive marketing communications from us, you can unsubscribe at any time via the link in an e-mail you received, or by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by contacting us at firstname.lastname@example.org at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product purchase, warranty registration, product experience or other transactions.
4.7 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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
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.
We may have to share your personal data with the:
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Sometimes we need to share your personal data with third parties outside the European Economic Area (EEA). The EEA consists of all EU Member States as well as Norway, Iceland and Liechtenstein.
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 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.
If you have any questions about security of our website, please contact us at email@example.com.
8.1 HOW LONG WILL NEOM 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. At the end of that retention period, your data will be either deleted or completely anonymised (as discussed further below).
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.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see section 9, “Request erasure” 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.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see the Glossary (“Your Legal Rights”) and our data subject access request policy for more about these rights:
If you wish to exercise any of the rights set out above, please contact us at firstname.lastname@example.org.
9.1 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 may refuse to comply with your request in these circumstances.
9.2 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.
9.3 TIME LIMIT TO RESPOND
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 you have made a number of requests. In this case, we will notify you and keep you updated.
10.1 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).
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.
Consent means that the data subject’s clear and unambiguous consent; this must be requested in an intelligible and easily accessible form, using clear and plain language and where it is required in writing, it is clearly distinguishable from any other matters which may also be referred to. Consent can be withdrawn by the data subject at any time.
10.2 THIRD PARTIES
EXTERNAL THIRD PARTIES
Service providers acting as processors who:
Please contact us at email@example.com. if you would like an up to date list of all our data processors.
10.3 YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). 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 data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
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 successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third 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.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Some of our site pages utilize "cookies" and other tracking technologies. A "cookie" is a small text file that may be used, for example, to collect information about site activity. Some cookies and other technologies may serve to recall Personal Information previously indicated by a site user. You may block cookies, or delete existing cookies, by adjusting the appropriate setting on your browser. Please consult the HELP menu of your browser to learn how to do this. If you block or delete "cookies" you may find the usefulness of our site to be impaired.
Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us. You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.
For an exhaustive list of cookies that we collect please see the list of cookies we use section below.
We may collect the following information:
- Contact information including email address
- Demographic information such as postcode, preferences and interests
- Other information relevant to customer surveys and/or offers
For the exhaustive list of cookies we collect see the list of cookies we use section below.
We require this information to understand your needs and provide you with a better service, and in particular for the following reasons:
- Internal record keeping.
- We may use the information to improve our products and services.
- We may periodically send promotional emails about new products, special offers or other information which we think you may find interesting using the email address which you have provided.
- We may use the information to customise the website according to your interests.
Below is a list of cookies that our site may use when you're visiting. They will only be placed on your device when needed and may not be present depending on the cookie settings you have chosen.
|COOKIE Name||COOKIE Description|
|EXTERNAL_NO_CACHE||A flag, which indicates whether caching is disabled or not.|
|persistent_shopping_cart||Used for shopping basket functionality|
|user_allowed_save_cookie||Used to identify if consent has been given to store cookies|
|FRONTEND||Your session ID on the server. Used to save basket contents & if you're logged in.|
|NO_CACHE||Indicates whether it is allowed to use cache.|
|__ga||Used by Google Analytics to collect website statistics.|
|__utma||Used by Google Analytics to determine unique visitors.|
|__utmb||Used by Google Analytics to see which pages you visit.|
|__utmc||Used by Google Analytics to see which pages you visit.|
|__utmt||Used by Google Analytics used to throttle request rate.|
|__utmz||Used by Google Analytics to see where you were referred from.|
|__utmv||Sometimes used by Google Analytics to track sessions.|
|__utmx||Used by Google Website Optimiser to help us look at user behaviour.|
|__gat_NeomTracker||Used by Google Universal Analytics to collect website statistics.|
|gaCookie||Used by Google Universal Analytics to distinguish users.|
|Goal||Used by Mailchimp to track sessions and user behaviour.|
|newsletterState||Used check the newsletter subscription status of a user.|
|magemonkey_campaign_id||Used by Neom to track email campaign statistics.|
|magemonkey_email_id||Used by Neom to link customer website activity data with their mailing list subscription.|
|new_user_popup||Used by Neom to present a one off offer to new users.|
|NEOM-pgCount||Used to keep track of the amount of times new user pop up is shown.|
|NEOM-popupTrigger||Used to trigger new user pop up.|
|NEOMcookieSettings||Used to set cookie preferences for the user.|
|_hjIncludedInSample||This session cookie is set to let Hotjar know whether that visitor is included in the sample which is used to generate funnels.|
|_hjUserId||This cookie is set as soon as a user loads a page which contains the Hotjar code. The cookie contains a universally unique identifier (UUID) which allows Hotjar to track the same visitor across multiple pages and sessions.|