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privacy policy

Our Privacy Policy

Overview

This Privacy Policy has been updated in accordance with the Data Protection Act 1998 , Privacy and Electronic Communications (EC Directive) Regulations 2003 and EU General Data Protection Regulation (GDPR) 2018. It outlines how Pretty Amazing Group Ltd. collect, store, use and share data. ‘Data' is defined as any kind of information that can be used to personally identify an individual.

The purpose of the Privacy Policy is to inform all users about key points of information regarding the data collected on the turtl website (weareturtl.com), through use of the turtl IOS app, and orally (by telephone). turtl is committed to ensuring that your privacy is protected and we follow strict procedures to ensure the legal policies are adhered to in respect of all data.

By visiting the turtl website, you are accepting and consenting to the practices described in this policy.

Everything we do relating to your information is covered by the following data principles:

  • Your information belongs to you – you should be able to control it through your online account or by contacting us, and you should know about, and be comfortable with, everything that we do with your information.

  • We will only collect, store, use and share your information either in a way that is outlined in this privacy policy. If we change the way we use your data, we will inform you of this and regain consent for this change of use, unless we are using your data in the way you would expect and see reasonable.

  • As long as we have your information, we will protect it using appropriate security safeguards, having kept on top of and appropriately taken into account the latest industry standards and best practice.

Information that we collect

We have attempted to list all data turtl may collect on you. Any information we may collect which isn't listed, will be used and stored in line with the information on this Privacy Policy.

Information you give us

  • Name

  • Email address

  • Billing Address

  • Billing Country

  • Delivery Address

  • Delivery Country

  • Telephone Number

  • Passwords (to enable you to log in to your turtl account)

  • Delivery comments/requests

Information we get from your use of our site

  • Site searches

  • Wishlist use

  • Competition entries

  • Completed surveys

  • Shopping preferences information

  • Internet protocol (IP) address

  • Full Uniform Resource Locators ("URL") clickstream to, through and from our site (including date and time)

  • Browser type and version

  • Time zone setting

  • Browser plug-in types and versions

  • Operating system

  • Device

Customers will also need to input log in details or credit/debit card details to make payment on our website. For this, we will serve customers a secure iframe hosted by our payment providers, Stripe, PayPal and/or Amazon Pay. turtl do not store any details you input at the payment stage of our checkout. We have contracts with our payment providers to ensure your data is secure at all times.

How do we collect it?

We have made every effort to detail the information that we collect from the users of our website/app, as well as to ensure that the platforms we use to collect data, are secure in storing and retaining the data as you would expect. We have documented the main ways in which we collect this data below.

Cookies

A Cookie is a small text file that is downloaded onto ‘terminal equipment' (eg a computer or smartphone) when the user accesses a website. It allows the website to recognise that user's device and store some information about the user's preferences or past actions.

turtl will only use the data collected with Cookies to improve the service we provide to you.

Shopify

We use the third party e-commerce provider Shopify as our website host, central CRM system and email marketing platform. We have ensured that they are fully GDPR compliant as they collect and share your data with turtl.

Google Analytics

Google Analytics is a product which helps us to analyse the traffic to our websites. Google is based in the United States meaning it is possible that the data that Google Analytics collects could leave the EU. Google will use this information for the purpose of evaluating your use of our website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google. Further information about Google's privacy policy may be viewed here and information about their Data Compliance can be found here.

Mailchimp

When you subscribe to our newsletter via our online sign-up form or by ticking the agree to subscribe during account creation, you agree to be contacted via email from us. You also agree to receive online advertising and retargeting.

Personal data of our subscribers are transferred and processed to our processes, including MailChimp, and MailChimp's sub-processors (who perform some critical services, such as helping to prevent abuse and providing support). Processing activities are performed by MailChimp which are: the collection and storage of personal data in order to create and use distribution lists, send marketing email campaigns and place online advertisements.

We also use cookies and related pixels to track the activity of our subscribers which may be used to place Google Web Retargeting Ads and Facebook Ads.

Wholesale Customers

We may collect any or all of the data types stated above for use as you would expect it. We will contact you to gain your approval if we would like to use your data in any way that you wouldn't expect. You are free to opt out at any time. Please contact us here so we can make any amendments/remove your data from our database.

You have the right to be forgotten and to opt out of any communication by unsubscribing to our list at any time. You can request to remove all personal data from our records by requesting here.

Klarna

In order to be able to offer you Klarna’s payment options, we will pass to Klarna certain aspects of your personal information, such as contact and order details, in order for Klarna to assess whether you qualify for their payment options and to tailor the payment options for you.

General information on Klarna you can find here. Your personal data is handled in accordance with applicable data protection law and in accordance with the information in Klarna’s privacy policy.

How is the information used?

turtl will not collect any data that is not necessary to carry out and/or improve the service we provide to our customers. More details about the way in which we use your data can be found below:

  • Process any order made on our website/app. (please note that your details may need to be passed to a third party in order for them to supply or deliver the product or service that you ordered and we may retain your details for a reasonable period of time after you have completed the transaction in order to fulfil any contractual obligations such as refunds, guarantees etc).

  • Process payments and prevent fraudulent transactions (we may retain your details for these purposes for a reasonable period of time and we may pass your details to a third party to carry out these functions, for example, Stripe, PayPal, Amazon Pay).

  • With your consent, retain your personal information and preferences to keep you informed by email and/or through other digital means including social media platforms and advertising retargeting, about products and services (including special offers, discounts, promotions, events, competitions and so on) offered by turtl, as well as recommending those which we feel will be of particular interest to you.

  • Improve the content and appearance of the Website or App, to ensure that content is presented in the most effective manner for you.

  • Carry out assessment and analysis (for example market, customer and product analysis) to enable us to review, develop and improve the products or services which we offer.

In circumstances where you contact us by telephone, calls may be recorded for quality, training and security purposes. Calls may also be monitored without your consent for the following circumstances:

  • To provide evidence of a business transaction

  • To prevent or detect a crime

  • To ensure that a business complies with regulatory procedures

  • To see that quality standards or targets are being met

  • In the interests of national security

As detailed in the section ‘Who do we share your information with?', we will only share your data with third parties where we deem it necessary to provide you with the service you expect. You have the right to access, amend, remove your data that we share or store at any time.

Who do we share your information with?

turtl may share your data with third-party providers for reasons that you, the data subject, have accepted and would expect. We have applied a Lawful Basis for all data we hold. For more information on which Lawful Basis is used for your data, please get in touch here. We have made every effort to ensure all third parties we share your data with, collect and store this in accordance with our Privacy Policy. The contracts we hold with some third parties state information may be transferred outside of the EEA but will be stored in the most secure way if this is to happen.

The third parties we may share your data with are detailed below:

  • Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you.

  • Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others.

  • Analytics and search engine providers that assist us in the improvement and optimisation of our site.

  • Payment gateway providers to enable us to take payment for your order.

We will share selective data with Reviews.co.uk who invite customers, on our behalf, review on our services and the products we're selling. Reviews Privacy Policy is valid between Pretty Amazing Group Ltd, the data controller and Reviews.co.uk, as data processors and is compliant with our expectations in relation to your data. It can be found here.

turtl will never sell your data without your prior Consent. If Pretty Amazing Group Ltd. are acquired by another party, we will contact you if your rights are affected or if our legal basis for processing any data is altered.

We will not share any data we may hold that is sensitive without your prior Consent. Information about what data is defined as sensitive can be found here.

turtl may have a duty to share your personal data if we have a Legal Obligation or Vital Interest.

How long will turtl keep your data?

turtl will keep the information we hold for a time we deem necessary for the purpose for which we're collecting the data. You have the right to request we amend, remove and view the data we store and can do this, by getting in touch with our customer service team here.

More information on your rights to access to your data can be found here. Any access request may be subject to a fee of £10/$10 to meet our costs in providing you with the details of the information we hold about you. A full list of your rights in relation to data, can be found here.

Changes to Our Privacy Policy

We may make changes to our Privacy Policy from time to time. We will not reduce your rights under this Privacy Policy without your explicit Consent. We will post any Privacy Policy changes on this page and, if the changes are significant, we will provide a more prominent notice (including, for certain services, email notification of Privacy Policy changes). We will also keep prior versions of this Privacy Policy in an archive for your review.

Ways to contact us

If you wish to contact turtl regarding any of the information we collect or store, including making changes to your information, please contact the turtl Customer Services team via email or phone. All information provided by the customer and collected by turtl is controlled by us and within applicable laws and the Data Protection Act 1998.

Email: lou@weareturtl.com.

Telephone: (+44)161 945 8001

Post: turtl Registered Office, Danielle House, Ledson Road, Wythenshawe, Manchester M23 9GP

This Privacy Policy was last updated June 2020