Cookies are small files of letters and numbers. These files are stored on the hard drive of the device you are using, be it a PC, mobile phone, or tablet. These letters and numbers are used to allow a website to remember certain bits of information, so that the user experience can be improved next time you visit.
By using our website you agree that we may store and access cookies on your device.
When you visit our website it is likely we will create cookies which are stored on your device. For the duration of your ‘session’ on our website these cookies help us to deliver the correct information and ensure you only have to enter required information once, thereby improving your browsing experience.
We also use web analytics to understand how many people have visited our website, what they have looked at and how they found us etc. This gives us a better understanding of how our website is working. All data accrued cannot be used to identify personal information and merely gives us a general idea of how our website performs.
This overview of the type of cookies we use is based on categories outlined by the international Chamber of Commerce, in the ICC UK Cookie Guide. Some cookies may appear in multiple categories.
Category 1: strictly necessary cookies
These cookies are necessary for the website to function. By disabling these cookies, some aspects of a website will either not work, or not work properly, such as secure logins, location services, and e-commerce functionality.
Category 2: performance cookies
These cookies gather information to help improve the day to day performance of a website. By analysing data collected we can enhance popular pages, fix bugs and error messages etc. All data is based on totals and averages and is strictly anonymous.
For example we use Google Analytics, which creates several first-party cookies. The data that Google collects is kept strictly private and confidential and won’t be shared with anyone else. We don’t feel that Google Analytics is a breach of privacy as we are merely aggregating the data survey. The information that is collected is used to understand website trends and performance.
Category 3: functionality cookies
These are cookies which provide a ‘memory’ for the website, this enables the website to remember any personal choices you make (for example, your username, language or geographic location). A website may provide local weather reports, traffic updates and other similar localised information. These cookies are also used to remember changes you may make to text sizes, fonts and other customisable elements of the website. The information these cookies collect may be made anonymous and can’t track activity on other websites.
Category 4: targeting cookies or advertising cookies
We nurture the use of social media websites and believe sharing is a key part of how people access new information. Social media networks are a popular way of doing this. To enable people to share information via popular social media, our website may have functionality allowing this type of activity.
The owners of social media websites may place cookies on users’ devices and they will have their own cookie policies. We have no control over these companies’ cookies policies.
Browsers allow you to change your cookie settings. These links may be helpful in helping you update your browser cookie settings if you wish to update them:
The Adobe website provides comprehensive information on how to delete or disable Flash cookies – see http://www.adobe.com/products/flashplayer/security for details.
Find out how to disable cookies by clicking on the “Manage Cookies” section of the Interactive Advertising Bureau website on the following link allaboutcookies.org
WhiffAway Ltd (“We”) are committed to protecting and respecting your privacy.
Our nominated data privacy manager for the purpose of overseeing questions in relation to this privacy notice is Miss Georgina McLean. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.
Name or title of data privacy manager: Miss Georgina McLean
Email address: email@example.com
Postal address: Conservation House, Unit 7, Premacto Business Estate, Queensmead Road, High Wycombe, Bucks, HP10 9XA, United Kingdom
Telephone number:+44 (0) 1494 512 959
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.
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.
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.
Information we collect from 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 will collect and process the following kinds of Personal Data about you:
Uses made of 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:
Generally we do not rely on consent as a legal basis for processing your personal data 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 us.
We have set out below, in a table format, 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 in the table below.
|Purpose/Activity||Lawful basis for processing including basis of legitimate interest|
|To register you as a new customer||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) 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:
(b) Asking you to leave a review or take a survey
|(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) 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) 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||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||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||Necessary for our legitimate interests (to develop our products/services and grow our business)|
We may use your personal 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 or services from us and, in each case, you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any company outside the WhiffAway group of companies for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by contacting our Data Protection Officer: Miss Georgina McLean via email: firstname.lastname@example.org
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/service purchase, warranty registration, product/service experience or other transactions.
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 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.
Disclosure of your information
We may have to share your personal data with the parties set out below for the purposes set out in the table above
We will disclose your personal information to third parties:
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.
International Transfers and where we store your personal data
We share your personal data within the WhiffAway Ltd Group. This will involve transferring your data outside the European Economic Area (EEA).
Many of our external third parties are based outside the European Economic Area (EEA) so 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:
All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. 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.
How long will we keep your personal data for
We will only retain your personal data 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.
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 requirements.
In some circumstances we may 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.
You have certain rights in respect of the processing of your personal information, which may vary dependent on the legal basis for collection of your personal information and the uses made of this personal information.
For all uses made of your personal information you have the right to be informed about how we use your personal information, and this notice discharges that obligation. However, further rights may apply in different circumstances, as set out below:
Access to information
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 may refuse to comply with your request in these circumstances.
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.
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.