Privacy policy

This policy sets out:

(1) the information we collect about you when you visit our website, use our products or

services, or otherwise interact with us;

(2) how we use, share, store, and secure the information; and

(3) how you may access and control the information.

In this policy, “Gifted, by Nature Ltd” or “we” refers to Gifted, by Nature of Somerset House, Strand, WC2R 1LA.

(Company Number 12351240) and “Platform” means our website

at www.giftedbynature.me.

In this policy, “personal information” refers to any data, information, or combination of data

and information that is provided by you to us, or through your use of our products or services,

that relates to an identifiable individual.

1 What information we collect about you

1.1 We collect the following types of information about you:

(a) account and profile information that you provide when you register for an account or

sign up for our products or services, for example Name, Physical address (billing or

delivery or both), Email address (collectively, “Account Data”);

(b) information you provide through support channels, for example when you report a

problem to us or interact with our support team, including any contact information,

documentation, or screenshots (collectively, “Support Data”);

(c) content you provide through use of our products or services, for example blog

comments, reviews (collectively, “User Content”);

(d) communication, marketing, and other preferences that you set when you set up your

account or profile (collectively, “Preference Data”);

(e) details of any transactions, purchases, or orders that you've made with us

(collectively, “Transaction Data”);

(f) payment information, for example Payment card information (collectively, “Financial

Data”);

(g) information about your device or connection, for example your internet protocol (IP)

address, browser type and version, time-zone setting, browser plug-in types and

versions, operating system and platform, and other technology on the devices you

use to access our products or services and information we collect through cookies

and other data collection technologies (please read our Cookies Policy for details)

(collectively, “Technical Data”); and

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(h) Information about your use of or visit to our Platform, for example your clickstream to,

through, and from our Platform, products you viewed, used, or searched for, page

response times, download errors, length of visits to certain pages, page interaction

information (such as clicks) (collectively, “Usage Data”).

1.2 We collect the above information when you provide it to us or when you use or visit our

Platform. We may also receive information about you from other sources, including:

(a) our personnel, agents, advisors, consultants, and contractors based in United

Kingdom in connection with our operations or services, for example our staff engaged

in the fulfilment of your order, processing of your payment, and provision of support

services;

1.3 We do not collect sensitive data or special category data about you. This includes details

about your race, ethnic origin, politics, religion, trade union membership, genetics,

biometrics, health, or sexual orientation.

2 How we use information we collect

2.1 We only use your personal information where the law allows us to. We use your personal

information only where:

(a) we need to perform the contract we have entered into (or are about to enter into) with

you, including to operate our products or services, to provide customer support and

personalised features, and to protect the safety and security of our Platform;

(b) it satisfies a legitimate interest which is not overridden by your fundamental rights or

data protection interests, for example for research and development, and in order to

protect our legal rights and interests

(c) you've given us consent to do so for a specific purpose, for example we may send

you direct marketing materials or publish your information as part of our testimonials

or customer stories to promote our products or services with your permission; or

(d) we need to comply with a legal or regulatory obligation.

2.2 If you have given us consent to use your personal information for a specific purpose, you

have the right to withdraw your consent any time by contacting us (please refer to

paragraph 9 for contact information), but please note this will not affect any use of your

information that has already taken place.

2.3 We do not share your personal information with any company outside our group for

marketing purpose, unless with your express specific consent to do so.

2.4 We have set out our legal bases for processing your information in the Legal Bases Table

at the end of this policy.

3 How we share information we collect

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3.1 We may share personal information on aggregated or de-identified basis with third parties

for research and analysis, profiling, and similar purposes to help us improve our products

and services.

3.2 If you use any third-party software in connection with our products or services, for

example any third-party software that our Platform integrates with, you might give the

third-party software provider access to your account and information. Policies and

procedures of third-party software providers are not controlled by us, and this policy does

not cover how your information is collected or used by third-party software providers. We

encourage you to review the privacy policies of third-party software providers before you

use the third-party software.

3.3 Our Platform may contain links to third-party websites over which we have no control. If

you follow a link to any of these websites or submit information to them, your information

will be governed by their policies. We encourage you to review the privacy policies of

third-party websites before you submit information to them.

3.4 We may share your information with government and law enforcement officials to comply

with applicable laws or regulations, for example when we respond to claims, legal

processes, law enforcement, or national security requests.

3.5 If we are acquired by a third party as a result of a merger, acquisition, or business

transfer, your personal information may be disclosed and/or transferred to a third party in

connection with such transaction. We will notify you if such transaction takes place and

inform you of any choices you may have regarding your information.

4 How we store and secure information we collect

4.1 We use data hosting service providers based in United Kingdom to host the information

we collect.

4.2 We have adopted the following measures to protect the security and integrity of your

personal information:

(a) your account is password-protected;

(b) access to your personal information is restricted to personnel or service providers on

a strictly need-to-know basis, who will only process your information on our

instructions and who are subject to a duty of confidentiality; and

(c) our information collection, storage, and processing practices are reviewed regularly.

4.3 We have put in place procedures to deal with any suspected privacy breach and will notify

you and any applicable regulator of a breach where we are legally required to do so.

4.4 While we implement safeguards designed to protect your information, please note that no

transmission of information on the Internet is completely secure. We cannot guarantee

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that your information, during transmission through the Internet or while stored on our

systems or processed by us, is absolutely safe and secure.

4.5 We only retain personal information for so long as it is reasonably necessary to fulfil the

purposes we collected it for, including for the purposes of satisfying any legal, accounting,

or reporting requirements. After such time, we will delete or anonymise your information.

We periodically review the basis and appropriateness of our data retention policy.

5 How we transfer information internationally

5.1 We collect information globally and primarily store that information in United Kingdom. We

transfer, process, and store your information outside your country of residence where we

or our service providers operate for the purpose of providing our products and services to

you.

5.2 Some of the countries in which our companies or service providers are located may not

have the privacy and data protection laws that are equivalent to those in your country of

residence. When we share information with these companies or service providers, we

make use of contractual clauses, corporate rules, and other appropriate mechanisms to

safeguard the transfer of information.

6 Your rights

6.1 You have the right to:

(a) be informed of what we do with your personal information;

(b) request a copy of personal information we hold about you;

(c) require us to correct any inaccuracy or error in any personal information we hold

about you;

(d) request erasure of your personal information (note, however, that we may not always

be able to comply with your request of erasure for record keeping purposes, to

complete transactions, or to comply with our legal obligations);

(e) object to or restrict the processing by us of your personal information (including for

marketing purposes);

(f) request to receive some of your personal information in a structured, commonly used,

and machine readable format, and request that we transfer such information to

another party; and

(g) withdraw your consent at any time where we are relying on consent to process your

personal information (although this will not affect the lawfulness of any processing

carried out before you withdraw your consent).

6.2 You may opt out of receiving marketing materials from us by using the unsubscribe link in

our communications, and/or by getting in direct contact with us. Please note, however,

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that even if you opt out from receiving marketing materials from us, you will continue to

receive notifications or information from us that are necessary for the use of our products

or services.

6.3 As a security measure, we may need specific information from you to help us confirm your

identity when processing your privacy requests or when you exercise your rights.

6.4 Any request under paragraph 6.1 will normally be addressed free of charge. However, we

may charge a reasonable administration fee if your request is clearly unfounded,

repetitive, or excessive.

6.5 We will respond to all legitimate requests within one (1) month. Occasionally, it may take

us longer than a month if your request is particularly complex or if you have made a

number of requests.

7 Changes to this policy

We may amend this policy from time to time by posting the updated policy on our

Platform. By continuing to use our Platform after the changes come into effect, you agree

to be bound by the revised policy.

8 Policy towards children

Our products and services are not directed to individuals under 16. We do not knowingly

collect personal information from individuals under 16. If we become aware that an

individual under 16 has provided us with personal information, we will take steps to delete

such information. Contact us if you believe that we have mistakenly or unintentionally

collected information from an individual under 16.

9 Contact us

9.1 Please contact us at contact@giftedbynature.me or submit any written request to:

Gifted, by Nature

Flat 22 Bray, Fellows Road. NW3 3JX.

Attn: Director

9.2 Please contact us in the first instance if you have any questions or concerns. If you have

unresolved concerns, you have the right to file a complaint with a data protection authority

in the country where you live or work or where you feel your rights have been infringed. If

you reside in the United Kingdom, you may file a complaint to the Information

Commissioner's Office (ICO), the UK supervisory authority for data protection issues

(www.ico.org.uk).

Last updated: 30 January 2020

COOKIES POLICY

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Cookies are small text files that are placed on your device by a web server when you access

our Platform. We use cookies to identify your access and monitor usage and web traffic on our

Platform to customise and improve our products and services.

We use both persistent cookies and session cookies. A persistent cookie stays in your browser

and will be read by us when you return to our Site or a partner site that uses our services.

Session cookies only last for as long as the session lasts (usually the current visit to a website

or a browser session).

We use the following types of cookies:

(a) Strictly necessary cookies – these are cookies that are required for the operation of

our site. They include, for example, cookies that enable you to log into secure areas

of our website.

(b) Analytical/performance cookies – these allow us to recognise and count the number

of visitors and to see how visitors move around our Site when they are using it. This

helps us to improve the way our site works, for example, by ensuring that users are

easily finding what they are looking for.

(c) Functionality cookies – these are used to recognise you when you return to our site.

(d) Targeting cookies – these cookies record your visit to our site, the pages you have

visited, and the links you have followed.

You can block cookies by activating the setting on your browser that allows you to

refuse the use of all or some cookies. However, if you do so, you may not be able to

access all or parts of our site.