EFFECTIVE DATE: 18th June 2021
wearejude.com (our website) is provided by The Wise Collective Ltd (‘Wise’, ‘we’, ‘our’ or ‘us’), a care products manufacturer and distributor. We are the controller of personal data obtained via our website, email and certain marketing activities, meaning we are the organisation that is legally responsible for deciding how and for what purposes it is used.
When we collect and process your personal data we are subject to the UK General Data Protection Regulation (UK GDPR). We are also subject to the EU General Data Protection Regulation (EU GDPR) in relation to any services we provide to individuals in the European Economic Area (EEA).
Personal data means any information relating to an identified or identifiable individual (known as the data subject). Personal data includes information irrespective of how it is stored. Different pieces of information, which collected together can lead to the identification of a particular person, also constitute personal data. Common examples of personal data include an individual’s name, address, contact information, photograph, IP address and information about the individual such as their age or employment status.
Special category personal data means personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership, genetic and biometric data (when processed to uniquely identify an individual), or data concerning health, sex life or sexual orientation.
your name and contact information, including email address and telephone number and company details;
demographic information such as gender, age, date of birth or nationality;
information you choose to give us relating to:
your personal or professional interests, education and employment
your experience using our care products
your online and social media presence;
visual images, such as photos you provide to us
information about how you use our website (which may include location data associated with your use of the website);
your responses to forms, surveys, competitions and promotions including, without limitation, information provided via Typeform;
information from accounts you link to us, eg Facebook; and
information which you share via social media.
The above list is not exhaustive, and Wise may also collect and process other personal data to the extent that this is considered necessary for providing our services or compliance with legal requirements.
If you do not provide personal data we ask for where it is requested (for example, at point of sale), it may delay or prevent us from providing services to you.
We collect most of this personal data directly from you – in person, by email, through customer surveys, through testing programs, or via our website. However, we may also collect information:
from publicly accessible sources such as online directories, social networks and internet searches;
from Wise's online customer advisory panels;
directly from Wise's third party partners; and
Under data protection law, we can only use your personal data if we have a proper reason, eg:
where you have given consent;
to comply with our legal and regulatory obligations (referred to as ‘legal and regulatory obligations’ below);
for the performance of a contract with you or to take steps at your request before entering into a contract (referred to as ‘contractual obligations’ below); or
for our legitimate interests or those of a third party (referred to as ‘legitimate interests’ below).
A legitimate interest is when we have a reason to use your information in connection with Wise's activities, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own.
The table below explains what we use your personal data for and why.
|What we use your personal data for||Our reasons|
|Product development and improvement||Legitimate interests, ie to offer you a better product|
|Delivering our services and offerings to you||Legitimate interests, ie to offer you the benefit of our services and offerings|
|Preventing and detecting fraud against you or us||Legitimate interests, ie to minimise fraud that could be damaging for you or us|
|Ensuring our policies are adhered to, eg policies covering security and internet use||Legitimate interests, ie to make sure we are complying with our own internal procedures so we can deliver the best services to you|
|Operational reasons, such as statistical analysis of our user/member base, monitoring performance metrics, training and quality control||Legitimate interests, ie to be as effective as we can and continually improve our offerings and reach|
|Ensuring confidentiality of information where appropriate||Legitimate interests, ie to protect confidential information, or to comply with legal and regulatory obligations|
|Preventing unauthorised access and modifications to systems||Legitimate interests, ie to prevent and detect criminal activity that could be damaging for you or us, or to comply with our legal and regulatory obligations|
|Updating user records||Legitimate interests, ie ensuring that we can keep in touch with our user base, or to comply with contractual, legal or regulatory obligations.|
|Statutory returns||Legal and regulatory obligations|
|Ensuring safe working practices, staff administration and assessments||Legal and regulatory obligations or legitimate interests (ie to make sure we are following our internal procedures and working efficiently)|
|Sending you marketing communications||Legitimate interests, ie to promote our activities and offerings (see under ‘Marketing’ below for more information)|
|External audits and quality checks||Legitimate interests, eg to maintain accreditations so we can demonstrate we operate at the highest standards; or to comply with our legal and regulatory obligations|
We do not generally anticipate collecting or processing any special category personal data. If we do, we will ensure we are permitted to do so under data protection laws, for example: by obtaining your explicit consent; by confirming that the processing is necessary to protect your (or someone else’s) vital interests where you are physically or legally incapable of giving consent; or where the processing is necessary to establish, exercise or defend legal claims.
What are cookies?
We may collect information using 'cookies'. Cookies are small data files stored on the hard drive of your computer or mobile device by a website. We may use both 'session cookies' (which expire once you close your web browser) and 'persistent cookies' (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience on our website.
Cookies we use
We may use both ‘first party cookies’, which are created and accessed only by us, and ‘third party cookies’, which may be created and accessed by our partners or service providers. The types of cookies used by our website and what they are used for is outlined below:
How to disable cookies and consequences of doing so
You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser. Many browsers are set to accept cookies until you change your settings. If you do not accept our website’s cookies, you may experience some inconvenience in your use of the website. For example, we may not be able to recognise your computer or mobile device and you may need to log in every time you visit our website. Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.com.uk.
We may use your personal data to send you updates by email about our activities and offerings. We have a ‘legitimate interest’ in using your personal data for marketing purposes (see section above headed ‘How and why we use your personal data’). This means we do not usually need your consent to send you marketing information. However, where consent is needed, we will ask for this separately and clearly.
You have the right to opt out of receiving marketing communications at any time by:
contacting us at firstname.lastname@example.org
using the ‘unsubscribe’ link in emails; or
updating your marketing preferences via our website (if this function is applicable to you).
We will always treat your personal data with the utmost respect and will never share it with other organisations for marketing purposes without your explicit consent.
We routinely share personal data with:
third parties we use to help deliver our services and run our organisation, eg marketing and communications service providers, website hosts, IT and data analytics service providers, our bank or other financial services providers, and professional services providers such as our lawyers and accountants; and
third parties specifically approved by you, eg social media channels or other third party services you choose to link your account.
We only allow our service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers to ensure they can only use your personal data to provide services to us and to you.
We may also need to:
share personal data with external auditors, eg in relation to industry accreditations or the auditing of our accounts or operations; or
disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).
Personal data may be held at our offices and those of our third party agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal data with’).
Some of these third parties may be based outside the UK/EEA. For more information, including on how we safeguard your personal data when this happens, see below: ‘Transferring your personal data out of the UK and EEA’.
We will keep your personal data for as long as required to continue providing services you have requested, and thereafter only for as long as is necessary (eg to respond to any questions, complaints or claims made by you or on your behalf) and in compliance with data protection laws. We will not keep your personal data for longer than necessary. When it is no longer necessary to keep your personal data, we will delete or anonymise it.
To deliver our services to you, it may sometimes be necessary for us to share your personal data outside the UK/EEA, eg with service providers located outside the UK/EEA; if you are based outside the UK/EEA; or where there is a European and/or international dimension to the services we are providing to you. Under data protection law, we can only transfer your personal data to a country or international organisation outside the UK/EEA where:
the UK government (or, where the EU GDPR applies, the European Commission) has decided the particular country or international organisation ensures an adequate level of protection of personal data (known as an ‘adequacy decision’);
there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for data subjects; or
a specific exception applies under data protection law.
These are explained below.
We may transfer your personal data to certain countries, on the basis of an adequacy decision. These include all EEA countries, Gibraltar, Andorra, Argentina, Canada, Faroe Islands, Guernsey, Israel, Isle of Man, Japan, Jersey, New Zealand, Switzerland and Uruguay. The list of countries that benefit from adequacy decisions will change from time to time. We will always seek to rely on an adequacy decision, where one exists. Other countries we are likely to transfer personal data to do not have the benefit of an adequacy decision. This does not necessarily mean they provide poor protection for personal data, but we must look at alternative grounds for transferring the personal data, such as ensuring appropriate safeguards are in place or relying on an exception, as explained below.
Transfers with appropriate safeguards
Where there is no adequacy decision, we may transfer your personal data to another country if we are satisfied the transfer complies with data protection law, appropriate safeguards are in place, and enforceable rights and effective legal remedies are available for data subjects. The safeguards will usually include using legally-approved standard data protection contract clauses. To obtain a copy of the standard data protection contract clauses and further information about relevant safeguards, please contact us.
Transfers under an exception
In the absence of an adequacy decision or appropriate safeguards, we may transfer personal data to a third country or international organisation where an exception applies under relevant data protection law, eg you have explicitly consented to the proposed transfer after having been informed of the possible risks; the transfer is necessary for the performance of a contract between us or to take pre-contract measures at your request; the transfer is necessary for a contract in your interests, between us and another person; or the transfer is necessary to establish, exercise or defend legal claims. We may also transfer information for the purpose of our compelling legitimate interests, so long as those interests are not overridden by your interests, rights and freedoms. Specific conditions apply to such transfers and we will provide relevant information if and when we seek to transfer your personal data on this ground.
If you would like further information about data transferred outside the UK/EEA, please contact us.
You have the following rights, which you can exercise free of charge:
Access: The right to be provided with a copy of your personal data.
Rectification: The right to require us to correct any mistakes in your personal data.
Erasure (also known as the right to be forgotten): The right to require us to delete your personal data in certain situations.
Restriction of processing: The right to require us to restrict processing of your personal data in certain circumstances, eg if you contest the accuracy of the data.
Data portability: The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations.
To object: The right to object at any time to your personal data being processed for direct marketing (including profiling); or in certain other situations to our continued processing of your personal data, eg processing carried out for the purpose of our legitimate interests.
Automated decision making: The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you. Wise does not currently engage in such automated decision making but should it do so you have the right to object.
For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights.
If you would like to exercise any of those rights, please:
email, call or write to us—see ‘How to contact us’ below; and
provide enough information to identify yourself and any additional identity information we may reasonably request from you;
let us know what right you want to exercise and the information to which your request relates.
We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine operational need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
Please contact us if you have any query or concern about our use of your information (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have. You also have the right to lodge a complaint with the Information Commissioner or any relevant European data protection supervisory authority. The Information Commissioner may be contacted at https://ico.org.uk/make-a-complaintor telephone: 0303 123 1113.
The Wise Collective Ltd
Flat 33 Ensign House, Rope Street, London, United Kingdom, SE16 7EX
Individuals within the EEA can contact us direct (see above).
If you would like this policy in another format (for example audio, large print, braille) please contact us.