SCOPE OF THIS NOTICE
Please read this privacy notice (“Notice”) carefully to understand our policies and practices regarding your Personal Data and how we will treat it. This Notice applies to individuals who interact with Sweetdreams Ltd (“you”). This Notice explains how your Personal Data are collected, used, and disclosed by Sweetdreams Ltd (“We”, Us”). It also tells you how you can access and update your Personal Data and make certain choices about how your Personal Data are used.
This Notice covers both our online and offline data collection activities, including Personal Data that We collect through our various channels such as websites, apps, third party social networks and events.
If you do not provide necessary Personal Data to Us (We will indicate to you when this is the case, for example, by making this information clear in our registration forms), We may not be able to provide you with our products and/or services. This Notice can change from time to time (see Section 11).
1. SOURCES OF PERSONAL DATA
This Notice applies to Personal Data that We collect from or about you, through the methods described below (see Section 2), from the following sources:
Sweetdreams Ltd websites.
Consumer-directed websites operated by or for Sweetdreams Ltd including sites that We operate under our own domains/URLs and mini-sites that We run on third party social networks such as Facebook (“Websites”).
E-mail, text and other electronic messages.
Interactions with electronic communications between you and Sweetdreams Ltd.
Offline registration forms.
Printed or digital registration and similar forms that We collect via, for example, postal mail and events.
Data We create.
In the course of our interactions with you, we may create Personal Data about you (e.g. email interactions).
Data from other sources.
Third party social networks (e.g. such as Facebook, Google), market research (if feedback not provided on an anonymous basis), Sweetdreams Ltd.
2. PERSONAL DATA THAT WE COLLECT ABOUT YOU AND HOW WE COLLECT IT
Depending on how you interact with Sweetdreams Ltd (online, offline, over the phone, etc.), We collect various types of information from you, as described below.
Personal contact information.
This includes any information you provide to Us that would allow Us to contact you, such as your name, postal address, e-mail address, social network details, or phone number.
Information from computer/mobile device.
Any information about the computer system or other technological device that you use to access one of our Websites or apps, such as the Internet protocol (IP) address used to connect your computer or device to the Internet, operating system type, and web browser type and version. If you access a Sweetdreams Ltd website via a mobile device such as a smartphone, the collected information will also include, where permitted, your phone’s unique device ID, geo-location, and other similar mobile device data.
Websites/communication usage information.
As you navigate through and interact with our Websites or newsletters, We use automatic data collection technologies to collect certain information about your actions. This includes information such as which links you click on, which pages or content you view and for how long, and other similar information and statistics about your interactions, such as content response times, download errors and length of visits to certain pages. This information is captured using automated technologies such as cookies and web beacons, and is also collected through the use of third party tracking for analytics and advertising purposes. You have the right to object to the use of such technologies, for further details please see Section 4.
Market research & consumer feedback.
Any information that you voluntarily share with Us about your experience of consuming our products and services.
Any content that you create and then share with Us on third party social networks or by uploading it to one of our Websites or apps, including the use of third party social network apps such as Facebook. Examples include photos, videos, personal stories, or other similar media or content. Where permitted, We collect and publish consumer-generated content in connection with a variety of activities, including contests, website features, consumer engagement, and third party social networking.
Sensitive Personal Data.
We do not seek to collect or otherwise process sensitive personal data in the ordinary course of our business. Where it becomes necessary to process your sensitive personal data for any reason, we rely on your prior express consent for any processing which is voluntary (e.g. for marketing purposes). If we process your sensitive personal data for other purposes, we rely on the following legal bases: (i) detection and prevention of crime (including the prevention of fraud); and (ii) compliance with applicable law (e.g. to comply with our diversity reporting).
3. PERSONAL DATA OF CHILDREN
We do not knowingly solicit or collect personal data from children below the age of 13. If we discover that we have unintentionally collected personal data from a child below 13, we will remove that child’s personal data from our records promptly. However, Sweetdreams Ltd may collect personal data about children below the age of 13 years of age from the parent or guardian directly, and with that person’s explicit consent.
4. COOKIES/SIMILAR TECHNOLOGIES, LOG FILES AND WEB BEACONS
Please see our Cookie Notice to learn how you can manage your cookie settings and for detailed information on the cookies We use and the purposes for which We use them.
We collect information in the form of log files that record website activity and gather statistics about your browsing habits. These entries are generated automatically, and help Us to troubleshoot errors, improve performance and maintain the security of our Websites.
Web beacons (also known as “web bugs”) are small strings of code that deliver a graphic image on a web page or in an email for the purpose of transferring data back to Us. The information collected via web beacons will include information such as IP address, as well as information about how you respond to an email campaign (e.g. at what time the email was opened, which links you click on in the email, etc.). We will use web beacons on our Websites or include them in e-mails that We send to you. We use web beacon information for a variety of purposes, including but not limited to, site traffic reporting, unique visitor counts, email auditing and reporting, and personalisation.
5. USES MADE OF YOUR PERSONAL DATA
The following paragraphs describe the various purposes for which We collect and use your Personal Data, and the different types of Personal Data that are collected for each purpose. Please note that not all of the uses below will be relevant to every individual.
What We use your Personal Data for:
We use your Personal Data for consumer service purposes, including responding to your enquiries. This typically requires the use of certain personal contact information and information regarding the reason for your inquiry (e.g. order status, product question/complaint, general question, etc.).
– Fulfilling contractual obligations
– Legal obligations
– Our legitimate interests
– Improving and developing new products and services
– Being more efficient
Contests, marketing and other promotions.
With your consent (where required), We use your Personal Data to provide you with information about goods or services (e.g. marketing communications or campaigns or promotions). This can be done via means such as email, ads, phone calls and postal mailings to the extent permitted by applicable laws. Some of our campaigns and promotions are run on third party websites and/or social networks. This use of your Personal Data is voluntary, which means that you can oppose (or withdraw your consent in certain countries) to the processing of your Personal Data for this purposes. For detailed information on how to modify your preferences about marketing communication, please see Sections 9 and 10 below. For more information about our contests and other promotions, please see the official rules or details posted with each contest/promotion.
– With your consent (where required)
Third party social networks:
We use your Personal Data when you interact with third party social networking features, such as “Like” functions, to serve you with advertisements and engage with you on third party social networks. You can learn more about how these features work, the profile data that We obtain about you, and find out how to opt out by reviewing the privacy notices of the relevant third party social networks.
Personalisation (offline and online).
With your consent (where required), We use your Personal Data (i) to analyse your preferences and habits, (ii) to improve and personalise your experience on our Websites; (iii) to ensure that content from our Websites is optimised for you and for your computer or device; (iv) to provide you with targeted advertising and content, and (v) to allow you to participate in interactive features, when you choose to do so. Based on this type of information, and with your consent (where required), We also show you specific Sweetdreams Ltd content or promotions that are tailored to your interests. The use of your Personal Data is voluntary, which means that you can oppose the processing of your Personal Data for this purpose.
We use your Personal Data to process and ship your orders, inform you about the status of your orders, correct addresses and conduct identity verification and other fraud detection activities.
Other general purposes
(e.g. internal or market research, analytic, security). In accordance with applicable laws, We use your Personal Data for other general business purposes, such as maintaining your account, conducting internal or market research and measuring the effectiveness of advertising.
Legal reasons or merger/acquisition.
In the event that Sweetdreams Ltdor its assets are acquired by, or merged with, another company including through bankruptcy, we will share your Personal Data with any of our legal successors. We will also disclose your Personal Data to third parties (i) when required by applicable law; (ii) in response to legal proceedings; (iii) in response to a request from a competent law enforcement agency; (iv) to protect our rights, privacy, safety or property, or the public; or (v) to enforce the terms of any agreement or the terms of our Website.
6. DISCLOSURE OF YOUR PERSONAL DATA
In addition to the Sweetdreams Ltd entities mentioned in the data controllers and contact section (see Section 12), We share your Personal Data with the following types of third party organisations:
These are external companies that We use to help Us run our business (e.g. order fulfilment, payment processing, fraud detection and identity verification, website operation, support services, promotions, website development, data analysis, etc.).
Service providers, and their selected staff, are only allowed to access and use your Personal Data on Our behalf for the specific tasks that they have been requested to carry out, based on our instructions, and are required to keep your Personal Data confidential and secure. Where required by applicable law, you can obtain a list of the providers processing your Personal Data (see Section 12 to contact Us).
Credit reporting agencies/debt collectors.
To the extent permitted by applicable law, credit reporting agencies and debt collectors are external companies that We use to help Us to verify your creditworthiness (in particular for orders with invoice) or to collect outstanding invoices.
Third party companies using Personal Data for their own marketing purposes.
We do not license or sell your Personal Data to third party companies for their own marketing purposes.
Third party recipients using Personal Data for legal reasons or due to merger/acquisition.
We will disclose your Personal Data to third parties for legal reasons or in the context of an acquisition or a merger (see Section 5 for details).
7. RETENTION OF YOUR PERSONAL DATA
Sweetdreams Ltd takes every reasonable step to ensure that your personal data are only processed for the minimum period necessary for the purposes set out in this Privacy Notice. The criteria for determining the retention period for your Personal Data are:
Sweetdreams Ltd will retain copies of your Personal Data in a form that allows for identification only for as long as:
We maintain an ongoing relationship with you (e.g. where you are included in our mailing list and have not unsubscribed);
Your Personal Data are necessary in connection with the purposes set out in this Privacy Notice and we have a valid legal basis,
The duration of:
any applicable limitation period (i.e. any period during which a person could bring a legal claim against us), and
an additional 2 months following the end of the applicable limitation period (so we are able to identify any personal data of a person who may bring a claim at the end of the applicable period),
In addition, if any relevant legal claims are brought, we may continue to process your Personal Data for such additional time necessary in connection with that claim.
During the periods noted in paragraphs b (i) and b (ii) above, we will restrict our processing of your Personal Data to storage or, and maintaining the security of, those data, except to the extent the data need to be reviewed in connection with any claim, or any obligation under applicable law.
Once the periods in paragraphs (a), (b) and (c) above, each to the extent applicable, have concluded, we will either
permanently delete or destroy the relevant Personal Data or
anonymise the relevant Personal Data.
8. DISCLOSURE, STORAGE AND/OR TRANSFER OF YOUR PERSONAL DATA
We use appropriate measures (described below) to keep your Personal Data confidential and secure. Please note, however, that these protections do not apply to information you choose to share in public areas such as third party social networks.
People who can access your Personal Data.
Your Personal Data will be processed by our authorised staff or agents, on a need to know basis, depending on the specific purposes for which your Personal Data have been collected (e.g. our staff in charge of consumer care matters will have access to your consumer record).
Measures taken in operating environments.
We store your Personal Data in operating environments that use reasonable security measures to prevent unauthorised access. We follow reasonable standards to protect Personal Data.
9. YOUR RIGHTS
Access to Personal Data.
You have the right to access, review and request a physical or electronic copy of information held about you. You also have the right to request information on the source of your Personal Data.
These rights can be exercised by sending Us an e-mail firstname.lastname@example.org or writing to us at Data Protection Sweetdreams Ltd, Unit 2a Admiral Business Park, Nelson Way, Cramlington, NE23 1WG attaching a copy of your ID or equivalent details (where requested by Us and permitted by law). If the request is submitted by a person other than you, without providing evidence that the request is legitimately made on your behalf, the request will be rejected. Please note that any identification information provided to Us will only be processed in accordance with, and to the extent permitted by applicable laws.
Additional rights (e.g. modification, deletion of Personal Data). Where provided by law, you can (i) request deletion, the portability, correction or revision of your Personal Data; (ii) limit the use and disclosure of your Personal Data; and (iii) revoke consent to any of our data processing activities.
Subject to applicable law, you may also have the following additional rights regarding the use of your Relevant Personal Data:
the right to object, on grounds relating to your particular situation, to the use of your Relevant Personal Data by us, or on our behalf; and
the right to object to the Processing of your Relevant Personal Data by us, or on our behalf, for direct marketing purposes.
We hope that We can satisfy queries you may have about the way we process your Personal Data. However, if you have unresolved concerns you also have the right to complain to competent data protection authorities.
10. YOUR CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR PERSONAL DATA
We strive to provide you with choices regarding the Personal Data that you provide to Us. The following mechanisms give you the following control over your Personal Data:
You manage your consent via (i) our consent management solution or (ii) your browser so as to refuse all or some cookies/similar technologies, or to alert you when they are being used. Please see Section 4 above.
Advertising, marketing and promotions.
You can consent for your Personal Data to be used by Sweetdreams Ltd to promote its products or services through tick-box(es) located on the registration forms. If you decide that you no longer wish to receive such communications, you can subsequently unsubscribe from receiving marketing-related communications at any time, by following the instructions provided in each such communication. To unsubscribe from marketing communications sent by any medium, including third party social networks, you can opt-out at any time by unsubscribing through links available in our communications, logging into the Websites or third party social networks and adjusting your user preferences in your account profile by unchecking the relevant boxes.
Personalization (offline and online):
Where required by law, if you wish to have your Personal Data used by Sweetdreams Ltd to provide you with a personalized experience/targeted advertising & content, you can indicate so through the relevant tick-box(es) located on the registration form. If you decide that you no longer wish to benefit from this personalization, you can opt-out at any time by logging into the Websites and adjusting your user preferences in your account profile by unchecking the relevant boxes.
11. CHANGES TO THIS NOTICE
If We change the way We handle your Personal Data, We will update this Notice. We reserve the right to make changes to our practices and this Notice at any time, please check back frequently to see any updates or changes to our Notice.
12. DATA CONTROLLERS & CONTACT
To ask questions or make comments on this Notice and our privacy practices or to make a complaint about our compliance with applicable privacy laws, please contact Us at: Contact Us or Write in to us at: Sweetdreams Ltd< unit 2A Admiral Business Park, Nelson Way. Cramlington, NE23 1WG or call 01670 738435. We have nominated Cathy Stephenson as our Data Protection Officer.
We will acknowledge and investigate any complaint about the way We manage Personal Data (including a complaint that We have breached your rights under applicable privacy laws).