PRIVACY POLICY

1. Who we are and what this Policy covers Privacy Notice Relating To Your Personal Data

Root7 ("us", "we", or "our") operates https://www.root7.com (the “site” or “website”). This privacy notice describes what personal data we collect about you when you use our site and if relevant, purchase products. Personal data is any information that could be used to identify you as a living individual. This website is not intended for children and we do not knowingly collect data relating to children. We do not and will not sell your personal data to any other third parties. This privacy notice also describes how we process (i.e. handle) your personal data, the basis upon which we process it, with whom it is shared, how it is stored and certain other important information relating to the protection of your personal data. The following policy explains all of this in some detail but we have also summarised the key points below. Please read this privacy policy carefully as it contains important information.

In summary:

1. What personal data we collect about you? We will collect personal data such as your name, address, email address, phone number and bank details in order to process and deliver your order(s) to you. In addition, you may consent to us sending you marketing material.

2. How we collected it and from whom? We collect data from you when you sign up to our website and when you place an order, return an order or inquire about products or services. This is collected from our website and from any phone calls or email correspondence you make to us.

3. What do we use your personal data for? We use your personal data in order to send your order, make returns or enquire about products or services. If consent is given on our website, we will also use your personal data (such as email address) to send you marketing communications about us.

4. What is our lawful basis for using your personal data? As a party to a transaction, we have certain duties, powers and obligations conferred on us by law. In most cases we need to process your personal data in order to comply with these legal obligations and duties.

5. Do we need your consent to the use of your personal data? In certain circumstances this may be necessary. In those circumstances, you will be fully informed about why your data is being used and your consent requested. Your right to withdraw your consent will be explained.

6. Do we share your personal data? A list of all the parties with whom we may share your personal data are set out in the detailed information below. We do not allow third parties to use your personal data for their own purposes, we only permit them to process your personal data for our specified purposes.

7. For how long do we retain your personal data? We will need to keep most of your personal data for as long as you are a customer. We will only keep your personal data for as long as we need to in order to carry out our duties, in order to comply with the law or until you request we delete it (see 4 above).

8. What rights do you have in relation to your personal data? Your rights are explained below in more detail but, among other things, you have the right to request that we provide you with a copy of all of the personal data that we hold about you and you also have the right to be forgotten.

9. How do we make sure your personal data is secure? Once we have any of your personal data we will use strict procedures and security features to prevent unauthorised access. However, we cannot guarantee the security of data transmitted to us over the internet.

2. Personal data we collect about you. The personal data we collect about you includes:

• Your name (first name and last name)
• Your postal address for both billing and delivery
• Your telephone number and email address
• If relevant, your bank/card/PayPal details which are used for payment/refund purposes only

Inability to provide personal data

If you do not provide us with personal data that we require by law or under the terms of a contract with us, then we may not be able to perform the contract we have or are attempting to enter into with you (for example, providing you with products you would like to order). In this case, we may have to cancel an order you have placed with us but we will notify you of this at the time if this is the case.

Aggregated Data

 

We also collect, use and share aggregated data with third parties which include statistical and demographic data for any purpose. Aggregated Data is derived from your personal data. This data is, however, not considered personal data by law as it does not directly, or indirectly, reveal your identity. We share this data with our third party agency to identify specific areas on our website that a customer interacts with to help us formulate our marketing strategy. For example, we may aggregate your Usage Data to calculate a percentage of users accessing a certain area or product on the website. If we combine or connect Aggregated Data with your personal data, it will be used in accordance with this Privacy Policy.

3. How is personal data collected?

We collect personal data from you in a number of different ways:

• you may share information with us in order to purchase products from us and to make returns or inquiries associated with those products;
• you may create an account with us in order to store personal information such as delivery addresses and products you would like to add to your wish-list for later use;
• with your consent, you may share other information with us so that you are informed of events, promotions and offers that we may hold from time to time via email marketing.
• you may provide us with feedback on products and services you have purchased from us which will be posted on a third-party review website which you agree to at the time of writing this information. This review is then posted on our website for customers to view;
• with your consent upon visiting our website, we will collect technical and usage data such as IP address, browser type, time zone settings, current location, operating system and information regarding the device(s) you have used to access our website and how you have used our website.

Cookies

We use cookies which are placed when you visit our website for the first time. You have the option to accept these cookies or to update your preferences that relate to cookies you would like to accept. Please note that if you decide to disable cookies through your browser settings, certain areas of our website may become inaccessible or no longer function properly. For further information about cookies, please read our Cookie Policy. To update your cookie setting, please visit Cookie Preferences which can be found in the footer of our website.

4. How we use your personal data

We use your personal data only when the law allows us to. We most commonly use your personal data in the following circumstances:

• when we need to perform the contract we have, or are about to enter into with you;
• where it is considered necessary for our legitimate interests, or those of a third party, and your interests, along with your fundamental rights, do not override these;
• where we are in a position to comply with a legal or regulatory obligation

Below you will see all of the ways in which we plan to use your personal data:

• registration as a new customer;
• process and deliver your order(s);
• managing our relationship with you (for example, asking you to review your purchase)
• participation in a competition or survey;
• deliver relevant website content and advertisements;
• send email communications if explicit consent has been provided in order for us to do so;
• use of data analytics to improve the website, products, marketing, and user experience;

When you have given your consent, we may use your personal data to send you information on products, offers, promotions and events which we think you may be interested in. If you have decided to opt-out then you will no longer receive this information from us. You will, however, continue to receive transactional emails from us in relation to an order you have placed with us such as order confirmation, dispatch confirmation, product review, confirmation of returns/refunds and when an item has returned to stock if you requested a notification.

We use your technical and usage data to further improve our website in order to provide you with a better shopping experience. This is necessary for our legitimate interests and allows us to study how customers interact with the website, products, and services which in turn contribute to the development and growth of our business as well as our marketing strategy.

Third Parties

We may share your personal data with the following categories of third parties:

• Providers of payment systems that process your payments for products. Delivery companies that we use to deliver your orders to you or collect them from you.
• With your consent, agencies, and suppliers whom we have retained to assist us to conduct promotional and marketing activity as well as provide technical assistance and support.

We will also disclose your personal data to third parties:

• if we are under a legal duty to disclose or share your personal data in order to comply with any legal obligation or any lawful request from any legal or regulatory authority; or
• to respond to any claims, and to establish, exercise or defend our legal rights.

Most third parties with whom we share your personal data are limited (by law and by contract) in their ability to use your personal data for the specific purposes identified by us. These third parties are themselves subject to the General Data Protection Regulations (GDPR). They will be responsible for their own processing of personal data to the extent that processing is subject to, or relates to, those regulations.

We will always ensure that any third parties with whom we share your personal data are subject to privacy and security obligations consistent with this privacy notice and applicable laws.

We will ensure that we get your opt-in consent before we share your personal data with any external third parties that we use for email marketing purposes. We do not control these third party websites and are also not responsible for their own privacy or cookie policies. When you decide to leave our website, we encourage you to read, in full, Privacy and Cookie Policies of every website that you decide to visit.

Opting Out

You have the right to ask us or third parties to stop sending you marketing communications at any time. You can do this by opening an email you have received from us and click ‘unsubscribe’ which can be found at the bottom of the email. Alternatively, you can email us and request that we remove your email address from our database which can take up to 2 working days to complete.

If you decide to opt-out of receiving marketing communications from us, you will still continue to receive emails about your orders when placing one with us. This will include emails such as order confirmation, order dispatch confirmation, product/service experience (i.e. product review), abandon cart emails and information relating to returns such as exchange or refund confirmations. This is a legitimate interest to our business and to our customers.

If we wish to use your personal data for any other purpose, we will update this privacy notice and inform you.

5. Legitimate Interest

Under GDPR legislation, we have the ability to contact you if we believe you have shown a legitimate interest in our business and products. For example, if a customer has purchased a product from us, has shown interest in the products and brands or has a professional interest in the products and brands that we sell, we, therefore, can contact them knowing they have shown a legitimate interest in our company/service.

When visiting our website for the first time, you will have the opportunity to select your cookie preferences. You have the choice to accept all cookies which includes performance and marketing cookies or you can accept just the strictly necessary cookies in order for the website to perform properly. We utilize performance and marketing data to ensure we advertise relevant information to you and to provide a better shopping experience. It is our legitimate interest to use and analyze this data for our growth and future development. You have the right to update your cookie preferences at any time.

Where appropriate we may run an automated abandon cart email programme that will contact you via email if you decide to exit your shopping basket without making a purchase. We deem this email as valid and acceptable due to the legitimate interest a customer has shown in us. This email is sent shortly after they have abandoned their cart and contains information only related to the product(s) left in the cart. The customer’s email address is not stored in our subscriber list and they cannot be contacted for any other marketing purposes unless they have supplied us with explicit consent to do so. The customer has the right to unsubscribe from an abandon cart email at any time and will not be contacted in the future unless they have provided us with explicit consent to do so or have placed an order with us and receive transactional emails as previously highlighted.

6. Your legal rights

Under the General Data Protection Regulations (GDPR), which are designed to protect your personal data, we need to have what is called a lawful basis or ground each time we use, share or otherwise process your personal data. When you use our site to purchase products from us, the processing of your personal data is necessary to fulfill your orders and is a lawful basis for collecting and using the data you give us.

Certain uses of your personal data, or other processing activities, may not be strictly necessary to perform our legal duties, or to exercise our powers; however, they may be necessary for the purposes of our legitimate interests or the legitimate interests of a third party. They may also be in your interests.

When we say "legitimate interests", we mean ours (or a third party's) interests in operating the service as efficiently and securely as possible. For example, we may choose to use a third party to store your personal data; we may do this because our use of that service means that your personal data is more secure.

In order for you to receive the full benefit of our site, such as to take advantage of offers, promotions or receive marketing communications, we will need your consent to collect and use your personal data. Under these circumstances, we will inform you of how the data you provide will be collected, stored and used before seeking your consent. In addition, you will be informed how to withdraw or modify your consent at any time.

You may withdraw your consent, or object to our processing of your personal data in a certain way (where you have the right to do so), by contacting us website@root7.com

What are your rights in relation to your personal data?

You have certain rights in relation to your personal data; those rights will not necessarily apply in all cases or to all personal data which is processed by us.

For example, certain rights will not apply where we need to process personal data to comply with our legal duties.

You have the right to request that we:

• provide you with a copy of any personal data which we hold about you; • update any of your personal data which is out of date or incorrect;
• delete any personal data which we hold about you (although in these circumstances it may be difficult to provide you with orders that you may require);
• restrict the way that we process your personal data;
• consider any valid objections which you have to our use of your personal data; or
• provide your personal data to a third party provider of services 

We will consider all such requests (including whether they apply in a particular case) and provide our response within the time period stated by applicable law which is 30 days (1 month of receipt)

When you make a request, we will acknowledge your request and we may ask you to provide us with some further information to allow us to confirm your identity.

Changes to our Privacy Policy

We may amend this privacy policy from time to time. Any changes we make to our privacy notice in the future will be notified to you in the next communication from us to you such as a new order or a newsletter that you have consented to receive. The date of our most recent changes can be found at the bottom of this policy and will be updated as and when an amend is made. The most recent and up to date policy will be available on our website at all times unless the site is undergoing scheduled maintenance.

This privacy policy was last reviewed and updated on 22 May 2018