Privacy Policy

WEBSITE PRIVACY POLICY (INCLUDES COOKIE POLICY)

Introduction

Welcome to the Silver Health Limited privacy policy.

Silver Health Limited (trading as Active Silver) respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our websites (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

If you have accessed this Privacy Policy via our websites https://active-silver.co.uk  or https://activesilveruk.com (our website), you can write to us at info@active-silver.co.uk to obtain a hard or PDF copy. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.

1.    Important information and who we are

Purpose of this privacy policy

This privacy policy aims to give you information on how Silver Heath Limited trading as Active Silver collects and processes your personal data through your use of this website, including any data you may provide through this website when you purchase a product.

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 policy together with any other privacy policy or fair processing policy 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 policy supplements other notices and privacy policies and is not intended to override them.

Controller

Silver Health Limited is the controller and responsible for your personal data, "we", "us" or "our" in this privacy policy.
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, please contact the data privacy manager using the details set out below.

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact our data privacy manager in the following ways:

Full name of legal entity:  Silver Health Limited
Email address:  info@active-silver.co.uk
Postal address:  Carrington Cottage, Wokingham Road, Hurst, Berkshire, RG10 ORU
Telephone number:  07914 694549

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, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated March 2019

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.

Third-party links

This website may include links to third-party websites, plug-ins and applications. 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 policy of every website you visit.

2.    The data we collect about you
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:

„Äą¬†¬† ¬†Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.

„Äą¬†¬† ¬†Contact Data includes billing address, delivery address, email address and telephone numbers.

„Äą¬†¬† ¬†Financial Data includes bank account and payment card details.

„Äą¬†¬† ¬†Transaction Data includes details about payments to and from you and other details of products you have purchased from us.

„Äą¬†¬† ¬†Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.

„Äą¬†¬† ¬†Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.

„Äą¬†¬† ¬†Usage Data includes [information about how you use our website or products
 
„Äą¬†¬† ¬†Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We may collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will 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 policy.

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.

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 goods). 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.

3.    How is your personal data collected?

When you visit the site, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the site, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site. We refer to this automatically-collected information as ‚ÄúDevice Information‚ÄĚ.

We collect Device Information using the following technologies:
- ‚ÄúCookies‚ÄĚ are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org. See our Cookie Policy further down this document.
- ‚ÄúLog files‚ÄĚ track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
- ‚ÄúWeb beacons‚ÄĚ, ‚Äútags‚ÄĚ, and ‚Äúpixels‚ÄĚ are electronic files used to record information about how you browse the Site.

We use different methods to collect data from and about you including through:

„Äą¬†¬† ¬†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:

‚Äʬ†¬† ¬†apply to purchase our products;
‚Äʬ†¬† ¬†create an account on our website;
‚Äʬ†¬† ¬†request marketing to be sent to you;
‚Äʬ†¬† ¬†enter a competition, promotion or survey; or
‚Äʬ†¬† ¬†give us feedback or contact us.

„Äą¬†¬† ¬†Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.

„Äą¬†¬† ¬†Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:

‚Äʬ†¬† ¬†Technical Data from the following parties:
 (a) analytics providers such as Google, based outside the EU;
 (b) advertising networks such as Google and Facebook, based outside the EU;
 (c) search information providers such as Google based outside the EU.
 (d) Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Interparcel, DPD or Hermes based inside the EU.
(e) Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.
(g) Identity and Contact Data from social media networks such as Facebook, Instagram and LinkedIn based outside the EU.

4.    How we use your personal data

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:

„Äą¬†¬† ¬†Where we need to perform the contract we are about to enter into or have entered into with you.
„Äą¬†¬† ¬†Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, 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 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 below.

Purpose/Activity: To register you as a new customer
Type of data: (a) Identity (b) Contact
Lawful basis for processing including basis of legitimate interest: Performance of a contract with you

Purpose/Activity: To process and deliver your order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us
Type of data: (a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications
Lawful basis for processing including basis of legitimate interest: (a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us)

Purpose/Activity: To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey
Type of data: (a) Identity (b) Contact (c) Profile (d) Marketing and Communications
Lawful basis for processing including basis of legitimate interest: (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)

Purpose/Activity: To enable you to partake in a prize draw, competition or complete a survey
Type of data: (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications
Lawful basis for processing including basis of legitimate interest: (a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

Purpose/Activity: To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
Type of data: (a) Identity (b) Contact (c) Technical
Lawful basis for processing including basis of legitimate interest: (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    

Purpose/Activity: To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
Type of data: (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical
Lawful basis for processing including basis of legitimate interest: 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)

Purpose/Activity: To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
Type of data: (a) Technical (b) Usage
Lawful basis for processing including basis of legitimate interest: 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)

Purpose/Activity: To make suggestions and recommendations to you about goods or services that may be of interest to you
Type of data: (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications
Lawful basis for processing including basis of legitimate interest: Necessary for our legitimate interests (to develop our products and grow our business)

Purpose/Activity: To administer an respond to enquiries from customers using online enquiry form
Type of data: (a) Identity (b) Contact
Lawful basis for processing including basis of legitimate interest: Necessary for our legitimate interests (for running our business and taking care of customer’s needs)


Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
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 (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods from us and you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by contacting us 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 or other transactions.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. See our Cookie Policy further down in this document.

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 paragraph.

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.

5.    Disclosures of your personal data

We share your Personal Information with third parties to help us use your Personal Information, as described above. For example, we use Shopify to power our online store you can read more about how Shopify uses your Personal Information here: https://www.shopify.com/legal/privacy.

We also use Google Analytics to help us understand how our customers use the Site - you can read more about how Google uses your Personal Information here: https://www.google.com/intl/en/policies/privacy/. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.

Finally, we may also share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.

We may share your personal data with the parties set out below for the purposes set out in paragraph 4 above.

„Äą¬†¬† ¬†External Third Parties as set out in the Glossary below.

„Äą¬†¬† ¬†Purposes for which we will use your personal data paragraph 4 above

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.

6.    International transfers

We may share your personal data outside the European Economic Area (EEA).
If we use an external third parties based outside the EEA, their processing of your personal data will involve a transfer of data outside the EEA.
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:

„Äą¬†¬† ¬†We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.

„Äą¬†¬† ¬†Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.

„Äą¬†¬† ¬†Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7.    Data security

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.

8.    Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

In some circumstances you can ask us to delete your data: see below for further information.

In some circumstances we will 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.

9.    Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see the Glossary below to find out more about these rights:

If you wish to exercise any of the rights set out above, please contact us.

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 could refuse to comply with your request in these circumstances.

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.
Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could 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.    Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best 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). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

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 obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

THIRD PARTIES

External Third Parties

„Äą¬†¬† ¬†Service providers acting as processors based in the United Kingdom who provide IT and system administration services.

„Äą¬†¬† ¬†Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in¬† the United Kingdom who provide consultancy, banking, legal, insurance and accounting services

„Äą¬†¬† ¬†HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

„Äą¬†¬† ¬†Third Parties include: PayPal, Shopify, Google, Facebook, Instagram, Lee Harris Trading as Harris Solutions, BuyAPower, Amazon, PAW Consulting, DPD, Interparcel, Companies House.

YOUR LEGAL RIGHTS

You have the right to:

10.1    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.

10.2    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.

10.3    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.

10.4    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.

10.5    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:

‚Äʬ†¬† ¬†If you want us to establish the data's accuracy.
‚Äʬ†¬† ¬†Where our use of the data is unlawful but you do not want us to erase it.
‚Äʬ†¬† ¬†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.
‚Äʬ†¬† ¬†You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

10.6    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.

10.7    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.

COOKIES POLICY

Active Silver ("us", "we", or "our") uses cookies on https://active-silver.co.uk and https://activesilveruk.com  (the "Service"). By using the Service, you consent to the use of cookies.

Our Cookies Policy explains what cookies are, how we use cookies, how third-parties we may partner with may use cookies on the Service, your choices regarding cookies and further information about cookies.

What are cookies
Cookies are small pieces of text sent by your web browser by a website you visit. A cookie file is stored in your web browser and allows the Service or a third-party to recognize you and make your next visit easier and the Service more useful to you.

Cookies can be "persistent" or "session" cookies.

How Active Silver uses cookies
When you use and access the Service, we may place a number of cookies files in your web browser.

We use cookies for the following purposes: to enable certain functions of the Service, to provide analytics, to store your preferences, to enable advertisements delivery, including behavioural advertising.

We use both session and persistent cookies on the Service and we use different types of cookies to run the Service:

- Essential cookies. We may use essential cookies to authenticate users and prevent fraudulent use of user accounts.

Third-party cookies
In addition to our own cookies, we may also use various third-parties cookies to report usage statistics of the Service, deliver advertisements on and through the Service, and so on.

What are your choices regarding cookies
If you'd like to delete cookies or instruct your web browser to delete or refuse cookies, please visit the help pages of your web browser.

Please note, however, that if you delete cookies or refuse to accept them, you might not be able to use all of the features we offer, you may not be able to store your preferences, and some of our pages might not display properly.

Where can your find more information about cookies
You can learn more about cookies and the following third-party websites:

‚󏬆¬† ¬†AllAboutCookies: http://www.allaboutcookies.org/
‚󏬆¬† ¬†Network Advertising Initiative: http://www.networkadvertising.org/


Document last updated: March 2019
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