Privacy Policy
Because your privacy is important to you and us
Background
Pure Ingenious Ltd t/a Ingenious Probiotics understands that your privacy is important to you and that you care
about how your personal data is used.
We respect and value the privacy of everyone who visits this website,
www.ingenious-probiotics-vet.com (“Our Site”) and will only
collect and use personal data in ways that are described here, and in a way that is consistent with our
obligations and your rights under the law. Please read this Privacy Policy carefully and ensure that you
understand it. By using this website, you agree to the terms of this Privacy Policy.
1.
Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
| Term | Definition |
|---|---|
| Account | An account required to access and/or use certain areas and features of Our Site; |
| Cookie | A small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in Part 14, below; |
| Cookie Law | The relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003; |
| We/Us/Our | Pure Ingenious Ltd t/a Ingenious Probiotics, a limited company registered in England under company number 11726508, whose registered address is Drogheda House, 36 Shevon Way, Brentwood Essex CM14 4PJ. |
2.
Information About Us
Our Site is www.ingenious-probiotics-vet.com owned and operated
by Pure Ingenious Ltd t/a Ingenious Probiotics, a limited company registered in England under company
number 11726508. Our registered address is Drogheda House, 36 Shevon Way, Brentwood Essex CM14 4PJ. VAT number:
312237641. Email address: enquiries@pure-ingenious.com.
Telephone number: 01268 544530.
3.
What Does This Policy Cover?
This Privacy Policy applies only to your use of Our Site. Our Site may contain links to other websites. Please
note that we have no control over how your data is collected, stored, or used by other websites and we advise
you to check the privacy policies of any such websites before providing any data to them.
4.
What Is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the
Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an
identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data
covers obvious information such as your name and contact details, but it also covers less obvious information
such as identification numbers, electronic location data, and other online identifiers.
5.
What Are My Rights?
Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:
a. The right to be informed about our collection and use of your personal data. This Privacy Policy should
tell you everything you need to know, but you can always contact us to find out more or to ask any questions
using the details in Part 15.
b. The right to access the personal data we hold about you. Part 13 will tell you how to do this.
c. The right to have your personal data rectified if any of your personal data held by us is inaccurate or
incomplete. Please contact us using the details in Part 15 to find out more.
d. The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your
personal data that we hold. Please contact us using the details in Part 15 to find out more.
e. The right to restrict (i.e. prevent) the processing of your personal data.
f. The right to object to us using your personal data for a particular purpose or purposes.
g. The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for
using your personal data, you are free to withdraw that consent at any time.
h. The right to data portability. This means that, if you have provided personal data to us directly, we are
using it with your consent or for the performance of a contract, and that data is processed using automated
means, you can ask us for a copy of that personal data to re-use with another service or business in many
cases.
i. Rights relating to automated decision-making and profiling.
For more information about our use of your personal data or exercising your rights as outlined above, please
contact us using the details provided in Part 15. It is important that your personal data is kept accurate
and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we
have that data.
Further information about your rights can also be obtained from the Information Commissioner’s Office or
your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a
complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your
concerns ourselves, however, so please contact us first, using the details in Part 15.
6.
What Data Do You Collect and How?
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:
Identity Data includes first name, maiden name, last name, username or similar identifier, marital
status, title, date of birth and gender.
Contact Data includes billing address, delivery address, email address and telephone numbers.
Financial Data includes bank account and payment (debit or credit) 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, 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.
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 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.
7.
How Do You Use My Personal Data?
Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following
table describes how we may use your personal data, and our lawful bases for doing so:
| Purpose/Activity | Type of Data | Lawful Basis for Processing including Basis of Legitimate Interest |
|---|---|---|
| To register you as a new customer | (a) Identity (b) Contact | Performance of a contract with you |
| To process and deliver your order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us | (a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications | (a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us) |
| 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 | (a) Identity (b) Contact (c) Profile (d) Marketing and Communications | (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/services) |
| To enable you to partake in a prize draw, competition or complete a survey | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications | (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) |
| To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | (a) Identity (b) Contact (c) Technical | (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 |
| To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical | Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) |
| To use data analytics to improve our website, products/services, marketing, customer relationships and experiences | (a) Technical (b) Usage | Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
| To make suggestions and recommendations to you about goods or services that may be of interest to you | (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications | Necessary for our legitimate interests (to develop our products/services and grow our business) |
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes,
which may include contacting you by email and/or telephone, text message and/or post with information, news, and
offers on our products.
You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply
with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC
Directive) Regulations 2003, and you will always have the opportunity to opt-out. We will always obtain your
express opt-in consent before sharing your personal data with third parties for marketing purposes and you will
be able to opt-out at any time.
Our Site may use third-party Cookies, as detailed below in Part 14. Please refer to Part 14 for more information
on controlling cookies. Please note that we do not control the activities of such third parties, nor the data
that they collect and use themselves, and we advise you to check the privacy policies of any such third parties.
We use the following automated systems for carrying out certain kinds of decision-making and or profiling. If at
any point you wish to query any action that we take on the basis of this or wish to request ‘human intervention’
(i.e. have someone review the action themselves, rather than relying only on the automated method), the Data
Protection Legislation gives you the right to do so. Please contact us to find out more using the details in
Part 15.
We will only use your personal data for the purpose(s) for which it was originally collected unless we
reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use
your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how
the new purpose is compatible with the original, please contact us using the details in Part 15.
If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s)
for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.
In some circumstances, where permitted or required by law, we may process your personal data without your
knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal
rights.
8.
How Long Will You Keep My Personal Data?
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.
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 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.
How and Where Do You Store or Transfer My Personal Data?
We only store your personal data within the UK. This means that it will be fully protected under the Data
Protection Legislation. The security of your personal data is essential to us, and to protect your data, we take
a number of important measures, including the following:
a. limiting access to your personal data to those employees, agents, contractors, and other third parties with
a legitimate need to know and ensuring that they are subject to duties of confidentiality;
b. procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration,
unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information
Commissioner’s Office where we are legally required to do so;
10.
Do You Share My Personal Data?
We will not share any of your personal data with any third parties for any purposes, subject to the following
exceptions:
a. If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a
third party. Any new owner of our business may continue to use your personal data in the same way(s) that we
have used it, as specified in this Privacy Policy.
b. In some limited circumstances, we may be legally required to share certain personal data, which might
include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or
the instructions of a government authority.
c. We may share your data with a carefully chosen third party for the purposes of fulfilling your order and
for accountancy and customer service. We will take steps to ensure that your personal data is handled safely,
securely, and in accordance with your rights, our obligations, and the third party’s obligations under the
law, as described above in Part 9.
| Recipient | Activity carried out | Sector | Location |
|---|---|---|---|
| Arthur Francis Accountancy Ltd | Bookkeeping and accountancy | Accounts | Park Entrance, Howe Street CM3 1BA |
| Social Land Ltd | Marketing and emails | Marketing | Unit 8, Ongar Road Trading Estate, Great Dunmow, CM6 1EU |
| Task Fulfilment Ltd | Fulfilment of orders (including ecommerce, wholesale, drop shipping orders) – processing, packing, dispatch. | Logistics fulfilment | Unit 23 Morses Lane Industrial Estate, Brightlingsea, Colchester CO7 0SQ |
Third-party marketing
We will get your express opt-in consent before we share your personal data with any third party for marketing
purposes. If any of your personal data is shared with a third party, as described above, we will take steps to
ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations,
and the third party’s obligations under the law, as described above in Part 9.
If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third
party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used
it, as specified in this Privacy Policy.
In some limited circumstances, we may be legally required to share certain personal data, which might include
yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the
instructions of a government authority.
11.
How Can I Control My Personal Data?
a. In addition to your rights under the Data Protection Legislation, set out in Part 5, when you submit personal
data via Our Site, you may be given options to restrict our use of your personal data. In particular, we aim to
give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out
of receiving emails from us which you may do by unsubscribing using the links provided in our emails and at the
point of providing your details and by managing your Account).
b. You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone
Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing
Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note,
however, that these services will not prevent you from receiving marketing communications that you have
consented to receiving.
12.
Can I Withhold Information?
You may access certain areas of Our Site without providing any personal data at all. However, to use all
features and functions available on Our Site you may be required to submit or allow for the collection of
certain data.
You may restrict our use of Cookies. For more information, see Part 14 and our
Cookie Policy
13.
How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and
for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part
15. To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do
not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your
request as quickly as possible.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or
excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs
in responding.
We will respond to your subject access request within one month of receiving it. Normally, we aim to provide a
complete response, including a copy of your personal data within that time. In some cases, however, particularly
if your request is more complex, more time may be required up to a maximum of three months from the date we
receive your request. You will be kept fully informed of our progress.
14.
How Do You Use Cookies?
Our Site may place and access certain first-party Cookies on your computer or device. By using Our Site, you may
also receive certain third-party Cookies on your computer or device. All Cookies used by and on Our Site are
used in accordance with current Cookie Law. For more information please read our
Cookie Policy. If you do not agree to Our Cookie Policy, please stop using
Our Site immediately.
15.
How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject
access request, please email us at:
enquiries@pure-ingenious.com
16.
Changes to this Privacy Policy
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or
if we change our business in a way that affects personal data protection. Any changes will be immediately posted
on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our
Site following the alterations. We recommend that you check this page regularly to keep up-to-date.
This policy was reviewed on 12.11.24.
