We collect, use and are responsible for certain personal information about you. When we do so we are subject to the General Data Protection Regulation, which applies across the European Union (including in the United Kingdom) and we are responsible as ‘controller’ of that personal information for the purposes of those laws.
Key terms
It would be helpful to start by explaining some key terms used in this policy:
| We, us, our | Calm & Bright Limited, C&B |
| [Our representative] | Any member of the Calm & Bright team |
| [Our data protection officer] | Jenny Watts, contactable on support@calmandbright.co.uk |
| Personal information | Any information relating to an identified or identifiable individual |
| Special category personal information | Personal information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership Genetic and biometric data Data concerning health, sex life or sexual orientation |
Personal information we collect about you
We may collect and use the following personal information about you:
- your name and contact information, including email address and telephone number
- Information to enable us to check and verify your identity, eg your date of birth
- Your gender information, if you choose to give this to us
- Location data, ifyou choose to give this to us
- Your billing information, transaction and payment card information
- Your professional online presence, eg LinkedIn profile
- Your contact history, purchase history and saved items
- Information from accounts you link to us (e.g. instagram)
- Information about how you use our website, IT, communication and other systems
- Your responses to surveys, competitions and promotions
This personal information is required to provide our service to you. If you do not provide personal information we ask for, it may delay or prevent us from providing our service to you.
How your personal information is collected
We collect this personal information directly from you, by telephone, text or emailand/ or via our website, social media channels or apps.
How and why we use your personal information
Under data protection law, we can only use your personal information if we have a proper reason for doing so, eg:
- to comply with our legal and regulatory obligations;
- for the performance of our contract with you or to take steps at your request before entering into a contract;
- for our legitimate interests or those of a third party; or
- where you have given consent
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
The table below explains what we use (process) your personal information for and our reasons for doing so:
| What we use your personal information for | Our reasons |
| To provide our service to you | To enable us to deliver the support and advice that you have contracted us to provide |
| Conducting checks to identify our customers and verify their identity Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business, eg under health and safety regulation or rules issued by our professional regulator |
To comply with our legal and regulatory obligations |
| Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies | To comply with our legal and regulatory obligations |
| Ensuring business policies are adhered to, eg policies covering security and internet use | For our legitimate interests or those of a third party, ie to make sure we are following our own internal procedures so we can deliver the best service to you |
| Operational reasons, such as improving efficiency, training and quality control | For our legitimate interests or those of a third party, ie to be as efficient as we can so we can deliver the best service for you at the best price |
| Ensuring the confidentiality of commercially sensitive information | For our legitimate interests or those of a third party, ie to protect trade secrets and other commercially valuable information To comply with our legal and regulatory obligations |
| Statistical analysis to help us manage our business, eg in relation to our financial performance, customer base, product range or other efficiency measures | For our legitimate interests or those of a third party, ie to be as efficient as we can so we can deliver the best service for you at the best price |
| Preventing unauthorised access and modifications to systems | For our legitimate interests or those of a third party, ie to prevent and detect criminal activity that could be damaging for us and for you To comply with our legal and regulatory obligations |
| Updating and enhancing customer records | For the performance of our contract with you or to take steps at your request before entering into a contract. To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, eg making sure that we can keep in touch with our customers about existing orders and new products |
| Refunds or discounts | To comply with our legal and regulatory obligations |
| Ensuring safe working practices, staff administration and assessments | To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, eg to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you |
| Marketing our services to: —existing and former customers; —third parties who have previously expressed an interest in our services; —third parties with whom we have had no previous dealings |
For our legitimate interests or those of a third party, ie to promote our business to existing and former customers |
| External audits and quality checks, eg for ISO or Investors in People accreditation and the audit of our accounts | For our legitimate interests or a those of a third party, ie to maintain our accreditations so we can demonstrate we operate at the highest standards To comply with our legal and regulatory obligations |
The above table does not apply to special category personal information, which we will only process with your explicit consent.
Promotional communications
We may use your personal information to send you updates (by email, text message, telephone or post) about our products and/or services, including exclusive offers, promotions or new products or services.
We have a legitimate interest in processing your personal information for promotional purposes (see above ‘How and why we use your personal information’). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.
We will always treat your personal information with the utmost respect and never sell OR shareit with other organisations for marketing purposes.
You have the right to opt out of receiving promotional communications at any time by:
- contacting us at support@calmandbright.co.uk
- using the ‘unsubscribe’ link in emails
We may ask you to confirm or update your marketing preferences if you instruct us to provide further products/ servicesin the future, or if there are changes in the law, regulation, or the structure of our business.
Who we share your personal information with
We routinely share personal information with:
- our payment service provider
- other third parties we use to help us run our business e.g. website hosts
- third parties approved by you, eg social media sites you choose to link your account to
- Our insurers and financial aids
- our bank
We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external parties in relation to child protection and safe-guarding if necessary. We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.