Privacy policy

 

Introduction

Welcome to the Horbaach.co.uk privacy notice.

Horbaach respects your privacy and is committed to protecting your personal information. This privacy notice will inform you as to how we look after your personal information when you:

  • visit our website (regardless of where you visit it from)

 and tell you about your privacy rights and how the law protects you.

 There is a Glossary to help you understand the meaning of some of the terms used in this privacy notice.

 PURPOSE OF THIS PRIVACY NOTICE 

 This privacy notice aims to give you information on how Horbaach collects and processes your personal information through your use of this website, or purchase a product or service or take part in a competition.

 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 notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal information about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

CONTROLLER 

Horbaach is the controller and responsible for your personal information (collectively referred to as ”Horbaach”, “we”, “us” or “our” in this privacy notice).

If you have any questions about this privacy notice, please contact the customer service team using the details set out below.  Our team will be happy to help with any questions that you may have.

CONTACT DETAILS 

Our full details are:

Legal entity: PIPING ROCK Limited

Contact Email address: customerservice@Horbaach.co.uk

Postal address: PIPING ROCK UK Ltd, Unit 8, Leicester Distribution Park, 2 Ashridge Close, LE3 1BY

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.

 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 notice of every website you visit.

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).

 THE DATA WE COLLECT ABOUT YOU:

 We may collect, use, store and transfer different kinds of personal information about you, which we have grouped together as follows: 

  • Identity Data includes first name, maiden name, last name, username or similar identifier, gender, marital status, title, date of birth, email address.
  • Contact Data includes billing address, delivery address, email address and telephone number.
  • Financial Data includes bank account and payment card details.
  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
  • 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, cookie ID’s, web log information, device identifiers and other technology on the devices you use to access this website.
  • Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
  • Usage Data includes information about how you use our website, products and services, your browsing activity including intended purchases and aborted baskets, completion of surveys, wish-lists, connection information and statistics on your visits to site and page views, the links you click and other actions you take on our services, within our advertising or e-mail content and participation in promotional activity.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal information but is not considered personal information in law as this data does 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 information so that it can directly or indirectly identify you, we treat the combined data as personal information which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal information 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 INFORMATION 

Where we need to collect personal information 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 or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

HOW IS YOUR PERSONAL DATA COLLECTED:

We capture, process and retain personal information from you and any devices you may use when you navigate to Horbaach.co.uk web or mobile view, by transacting, by registering an account and otherwise interacting with us. We may also collect personal information from you when you purchase our products through Horbaach.co.uk

 Some more examples of the different methods by which we collect information from and about you include through: 

  • 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 information you provide when you
    • register or purchase our products or services through the site or mobile app;
    • create an account on our website;
    • subscribe to our services or publications;
    • request marketing to be sent to you;
    • contact our customer service team;
    • enter a competition, promotion, survey or complete a questionnaire; or
    • give us some feedback.
  • Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal information by using cookies, server logs and other similar technologies. These machine learning algorithms generate content which they apply to personalising your experience and select more specifically the items you have an interest in as well as supporting general service optimisation including bid/ markdown automation. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.

 We may allow you to share information with social media sites, or use social media sites to create your account or to connect your account with the respective social media site. Those social media sites may give us automatic access to certain personal information retained by them about you (e.g., content viewed by you, content liked by you and information about the advertisements you have been shown or may have clicked on). Where this information is received by us, we will use this information to further personalise your experience with Horbaach.co.uk.

 Third parties or publicly available sources. We may receive personal information about you from various third parties as set out below:

Technical Data from the following parties:    

 (a)  analytics providers such as Google Analytics, Amazon and Google DoubleClick based outside the EU;

 (b)  advertising networks such as Amnet based inside the EU and Google Display Network based outside the EU; or

 (c)  Social Network providers such as Facebook based outside the EU;

Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as PayPal based outside the EU;

Identity and Contact Data from data brokers or aggregators such as Experian based inside the EU; and

Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.

 HOW WE USE YOUR PERSONAL DATA:

 We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • 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.
  • Where we need to comply with a legal or regulatory obligation.

Please see below, (Purposes for which we will use your personal information) to find out more about the types of lawful basis that we will rely on to process your personal information.

Generally, we do not rely on consent as a legal basis for processing your personal information other than in relation to 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 our customer services team on customerservice@Horbaach.co.uk

We may from time to time ask that you verify your e-mail address. In performing such checks, your information may be disclosed to credit reference agencies such as Experian who keep a record of that information, but these are not credit checks and your credit rating will not be affected. We may contact you by e-mail, phone, text, or SMS in relation to managing your account or the performance of our contract with you including: 

  • delivery fulfilment, where we need further information from you; and
  • to give you updates in relation to your account, order or delivery

PURPOSES FOR WHICH WE USE YOUR PERSONAL INFORMATION:

In general terms, we use the personal information we collect to help Horbaach better understand you and to enable us to personalise your experience with Horbaach, including offers, promotions and services to meet your needs. We use your information to:

  • personalise our services, offers and promotions to you and provide you with a personalised experience on our sites;
  • process your online orders;
  • offer you site content that includes items that you might like and to keep track of your basket;
  • contact you about your account and tell you about important changes to Horbaach;
  • provide, develop and improve our products and services;
  • provide you customer service;
  • manage promotions, competitions, customer surveys and questionnaires;
  • check and verify your identity, and prevent, mitigate or detect and investigate crime, fraudulent or illegal activities; and
  • process purchases, payments, customer support and order fulfilment.

Note that we may process your personal information for more than one lawful ground depending on the specific purpose for which we are using your data. If you need details about the specific legal ground we are relying on to process your personal information where more than one ground has been set out in above, you can request this information by e-mailing your request for this information to customerservice@Horbaach.co.uk

MARKETING 

We strive to provide you with choices regarding certain personal information uses, particularly around marketing and advertising. You can make certain decisions about your personal information use at any time by e-mailing our Customer Services team customerservice@Horbaach.co.uk

In summary:

  • contact our customer services team on customerservice@Horbaach.co.uk;
  • click on the "unsubscribe" link on the bottom of any of our e-mails to opt of email communications; or
  • write to us at Horbaach, PIPING ROCK UK Ltd, Unit 8, Leicester Distribution Park, 2 Ashridge Close, LE3 1BY

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). 

MARKETING COMMUNICATIONS FROM US

In general, you will receive marketing communications from us by email, postal mail, SMS, phone or social media if you have requested information from us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, 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 information with any company outside the Horbaach group of companies for marketing purposes.

THIRD-PARTY COOKIES USED FOR RETARGETING 

We may from time to time have relationships with carefully selected third parties who may also set cookies during your visit to be used for remarketing purposes – in other words to show you different products and services based on what you appear to be interested in. This type of advertising is designed to provide you with a selection of products based on what you’re viewing on Horbaach.co.uk which are presented to you by our business partners when you visit other selected websites. The adverts may highlight products you’ve viewed, alternative items and formulas, as well as products from other categories deemed relevant to your browsing history. The technology behind these adverts is based on cookies.

Disabling these advertisements

We would like to continue to display content that's relevant to you, however, you can choose to opt out of this type of advertising permanently by deleting our cookies.  Please note that if you delete your cookies, we will no longer know that you have opted out, and the banners from Amnet or our other providers from time to time will reappear when you visit other selected websites.  You can request more details of our third party service providers from customerservice@Horbaach.co.uk

You can use your web browser to:

  • delete all cookies;
  • block all cookies;
  • allow all cookies;
  • block third-party cookies;
  • clear all cookies when you close the browser;
  • open a 'private browsing' / 'incognito' session, which allows you to browse the internet without storing local data; and
  • install add-ons and plug-ins to extend browser functionality.

 To find information about controlling cookies see our Cookies Policy.

OPTING OUT 

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

THE RIGHT TO OBJECT TO PROFILING

 Where we process personal information relating to your interaction (transactions, site visits) we do this to personalise your experience with Horbaach.co.uk. This processing activity constitutes profiling under the General Data Protection Regulation (please see GDPR below), and we process your personal information in this way as it is in our legitimate interest to offer you a personalised experience on our sites and to provide you with personalised advertising and marketing.

You have the right to object to how your personal information is processed, including your right to object to profiling as outlined in this privacy policy.  More information on this right to object and how to exercise your rights can be found in Your Legal Rights section below.

We do see profiling as a beneficial service allowing you to have easier and quicker access to products, services and offers tailored more specifically to your interests, but we respect that not everyone feels the same way and we will be sad to see you go. 

GDPR

 The General Data Protection Regulation (EU) 2016/679 (GDPR) is a regulation in EU law on data protection and privacy for all individual citizens of the European Union (EU) and the European Economic Area (EEA). It also addresses the transfer of personal data outside the EU and EEA areas. The GDPR aims primarily to give control to individuals over their personal data and to simplify the regulatory environment for international business by unifying the regulation within the EU. Superseding the Data Protection Directive 95/46/EC, the regulation contains provisions and requirements related to the processing of personal data of individuals (formally called data subjects in the GDPR) inside the EEA, and applies to any enterprise established in the EEA or—regardless of its location and the data subjects' citizenship—that is processing the personal information of data subjects inside the EEA.

EU RESIDENTS RIGHTS TO ACCESS, TRANSFER OR DELETE PERSONAL INFORMATION, OR WITHDRAW CONSENT TO COLLECTION OR PROCESSING

If you are an EU Data Subject and wish to access, transfer or delete any Personal Data that We hold about you, or withdraw your consent to collection or processing your data to request that We delete any information about you that We have obtained, you can do so by emailing us at customerservice@horbaach.co.uk and stating your request.  With respect to requests to delete your personal data, We will delete or block any ability to access any reference to you in our database, except for information required to be retained as provided for in our Privacy Policy, and consistent with our legal requirements and internal data retention policies, as described above.  This deletion is permanent and your account cannot be reinstated. 

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. For more information about the cookies we use, please see our Cookie Policy.

 CHANGE OF PURPOSE  

 We will only use your personal information 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.

 If we need to use your personal information 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 information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

DISCLOSURES OF YOUR PERSONAL DATA

 We may have to share your personal information with the parties set out below for the purposes set out above.

  • Internal Third Parties as set out in the Glossary below.
  • External Third Parties as set out in the Glossary below.
  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal information in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.

 Please contact customerservice@Horbaach.co.uk if you want further information on the third parties we use.

INTERNATIONAL TRANSFER:

 Many of our external third parties are based outside the EEA so their processing of your personal information will involve a transfer of data outside the EEA.

Whenever we transfer your personal information 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:

  • We will only transfer your personal information to countries that have been deemed to provide an adequate level of protection for personal information by the European Commission. For further details, see European Commission: Adequacy of the protection of personal information in non-EU countries.
  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal information the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal information to third countries.
  • 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 information shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact customerservice@Horbaach.co.uk if you want further information on the specific mechanism used by us when transferring your personal information out of the EEA.

If you would like further information on the European Commission please click on the link below;

https://ec.europa.eu/search/?QueryText=data+transfer&op=Search&swlang=en&form_build_id=form-axD7vs-YQpjp0NXnv4ibB0kLij7lrr6EDTruczYVQ64&form_id=nexteuropa_europa_search_search_form

 DATA SECURITY

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

DATA RETENTION

HOW LONG WILL YOU USE MY PERSONAL INFORMATION FOR? 

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.  In addition, this includes that we may retain personal information from closed accounts to comply with legal requirements, prevent fraud and resolve disputes. After it is no longer necessary for us to retain your personal information, we dispose of it securely according to our data retention and deletion policies.

When we determine the maximum retention duration of any personal data we hold we do so with regard to our legitimate interests to retain data, our obligation under GDPR to minimise data we hold, the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see Request erasure in section Your Legal Rights below for further information.

In some circumstances we may anonymise your personal information (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.

YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal information. Please see below to find out more about these rights and access the request forms should you want to make any of these requests:

You have the right to: 

Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it. If you want to receive a copy of any information we process about you, please contact us at customerservice@Horbaach.co.uk

Request correction of the personal information 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. You can update your information at any time by contacting us at customerservice@Horbaach.co.uk

Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information 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 information 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. You can request erasure of your information at any time by contacting us at customerservice@Horbaach.co.uk

Object to processing of your personal information 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 information 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. You can update your marketing preferences at any time by contacting us at customerservice@Horbaach.co.uk

Request restriction of processing of your personal information. This enables you to ask us to suspend the processing of your personal information in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. You can request restriction of processing by contacting us at customerservice@Horbaach.co.uk

Request the transfer of your personal information to you or to a third party. We will provide to you, or a third party you have chosen, your personal information 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. You can request the transfer of your personal information by contacting us customerservice@Horbaach.co.uk

Withdraw consent at any time where we are relying on consent to process your personal information. 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. You can withdraw your consent at any time by contacting us at customerservice@Horbaach.co.uk

If you wish to exercise any of the rights set out above, please contact us at customerservice@Horbaach.co.uk

 NO FEE USUALLY REQUIRED 

You will not have to pay a fee to access your personal information (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 may 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 information (or to exercise any of your other rights). This is a security measure to ensure that personal information 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 may 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.

 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 service/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 information for our legitimate interests. We do not use your personal information 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 at customerservice@Horbaach.co.uk

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

THIRD PARTIES 

 INTERNAL THIRD PARTIES 

Other companies within Horbaach who act as joint controllers or processors within the EEA and who provide IT and system administration services and undertake leadership reporting.

EXTERNAL THIRD PARTIES 

  • Service providers acting as processors based in the EEA who provide IT, system administration services, payment providers to facilitate purchases, fulfilment providers to facilitate order management, packaging and delivery and marketing and communications services providers in order to personalise your experience and communicate with you.
  • Professional advisers including lawyers, bankers, auditors and insurers based in the EEA who provide consultancy, banking, legal, insurance and accounting services.
  • HM Revenue & Customs, regulators, law enforcement bodies and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances and otherwise in defence of legal claims.
  • Market researchers, fraud prevention agencies and analytics providers.

Cookie Policy

First Party Cookies

First party cookies are used to retain your basket selection and help us to remember your browsing history, product and information preferences. We use cookies to enable you to add products to your shopping basket. We also use first party cookies to help us balance our servers. This allows us to deliver quick page load times for our customers.

Horbaach’s first party cookies contain no personally identifiable information. All personally identifiable Information on browsing, preference and purchase history, is stored in our secure website data base. This information is collected for our internal purposes only and shall not be disclosed to any other organisation except as required by law.

Third Party Cookies

Third party cookies are cookies that pass on information on browsing and purchase activity to third party service providers.

Horbaach primarily uses third party cookies to help us conduct website tracking and monitoring to ensure we provide our customers with the best possible shopping and web experience. We use the web analytics platform provided by Google called Google Analytics.

We will also intermittently use third party cookies to gather behavioural, browsing and demographic data. This information is used by third party partners to deliver marketing and advertising activities.

Blocking Cookies

We understand that people have different privacy concerns. You can choose not to receive a cookie file by enabling your web browser to refuse cookies or to prompt you before you accept a cookie.

Unless you have adjusted your browser setting so that it will refuse cookies, our website will issue cookies onto your device. Please note that if you refuse to accept certain cookies, some of the functions on the Horbaach Sites such as adding a product to a basket may not work.

By agreeing to these terms and conditions you are accepting the use of first and third party cookies on and by the Horbaach websites.

Further information about cookies can be found by clicking on the following links;

https://ico.org.uk/

http://www.allaboutcookies.org