Welcome to the NATURHIN Limited privacy notice.
NATURHIN Limited respects your privacy and is committed to protecting your personal data. This
privacy notice will inform you as to how we look after your personal data 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.
Please also use the Glossary to understand the meaning of some of the terms used in this privacy
notice.
1. IMPORTANT INFORMATION AND WHO WE ARE
2. THE DATA WE COLLECT ABOUT YOU
3. HOW IS YOUR PERSONAL DATA COLLECTED
4. HOW WE USE YOUR PERSONAL DATA
5. DISCLOSURES OF YOUR PERSONAL DATA
6. INTERNATIONAL TRANSFERS
7. DATA SECURITY
8. DATA RETENTION
9. YOUR LEGAL RIGHTS
10. GLOSSARY
1. IMPORTANT INFORMATION AND WHO WE ARE AND PURPOSE OF THIS PRIVACY
NOTICE
This privacy notice aims to give you information on how NATURHIN collects and processes your
personal data through your use of this website, including any data you may provide through this
website when you contact us.
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 data 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
NATURHIN Limited is the controller and is responsible for your personal data (collectively referred
to as “NATURHIN”, “we”, “us” or “our” in this privacy notice).
We have appointed a Data Protection Officer, Ms Grace Arhin who is responsible for overseeing
questions in relation to this privacy notice. If you have any questions about this privacy notice,
including any requests to exercise your legal rights, please contact the Data Protection Officer using
the details set out below.
CONTACT DETAILS
Our full details are:
Full name of legal entity: NATURHIN Limited, director Ms Grace Arhin t/a NATURHIN
Email address: support@naturhin.com
Postal address: 15 Hatfield Road, Hatfield Road, Dagenham, United Kingdom, RM9 6JP
Telephone number: 07398 160809
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.
CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF
CHANGES
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.
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.
2. THE DATA WE COLLECT ABOUT 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 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 address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of services you
have purchased from us.
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, or any
information about criminal convictions and offences) unless required to enable us to provide our
services to you, in which case it will be used in accordance with this privacy notice.
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data 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 services). In this case, we may
have to cancel a service you have with us, but we will notify you if this is the case at the time.
COOKIES
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your
computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.
We use the following cookies:
• Analytical/performance cookies. They allow us to recognise and count the number of visitors. They
do not collect your personal data. We do not use any other type of cookie.
You block cookies by activating the setting on your browser that allows you to refuse the setting of all
or some cookies.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you are including through:
a) 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 data you
provide when you:
apply for and use our services;
request marketing to be sent to you;
give us some feedback.
b) Third parties or publicly available sources. We may receive personal data about you from
various third parties and public sources, including those set out below:
Experts instructed by us upon your behalf in the course of our dealings with you;
Technical Data from the following parties:
search information providers based inside the UK or the EU.
Identity and Contact Data from publicly availably sources such as Companies House and the
Electoral Register based inside the EU.
4. HOW WE USE 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:
Where we need to perform the contract, we are about to enter into or have entered into with
you to provide our services and assistance.
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.
See the Glossary below to find out more about the types of lawful basis that we will rely on to process
your personal data.
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.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
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 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
services including:
(a) Manage payments, fees and
charges
(b) Collect and recover money
owed to us
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(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 complete a
satisfaction questionnaire
(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 services)
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)
(b) Necessary to comply with a legal
obligation
MARKETING
We will not contact you for marketing purposes unless you have expressly opted in to receive
marketing communication about our offers and services from us. You can change your mind at any
time by contacting us.
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 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 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.
5. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the purposes set out in the
table in paragraph 4 above.
External Third Parties as set out in the Glossary.
Specific third parties such as technicians, solicitors, barristers, Independent Financial
advisers, Process Servers, Medical Experts, other experts etc. to enable us to perform the
contract we have entered into with you.
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.
6. INTERNATIONAL TRANSFERS
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:
We will only transfer your personal data to countries that have been deemed to provide an
adequate level of protection for personal data by the European Commission. For further
details, see European Commission: Adequacy of the protection of personal data in non-EU
countries.
Where we use certain service providers, we may use specific contracts approved by the
European Commission which give personal data the same protection it has in Europe. For
further details, see European Commission: Model contracts for the transfer of personal data
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 data shared
between the Europe and the US. For further details, see European Commission: EU-US
Privacy Shield.
Please contact us if you want further information on the specific mechanism used by us when
transferring your personal data out of the EEA.
7. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being
accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
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.
8. DATA RETENTION
HOW LONG WILL YOU USE MY 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.
Details of retention periods for different aspects of your personal data are available in our retention
policy which you can request from us.
9. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal
data. Please see the Glossary below to find out more about these rights:
Request access to your personal data.
Request correction of your personal data.
Request erasure of your personal data.
Object to processing of your personal data.
Request restriction of processing your personal data.
Request transfer of your personal data.
Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact our Data Protection Officer.
NO FEE USUALLY REQUIRED
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.
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 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.
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.
10. 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 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 data for our legitimate interests. We do not use your personal data 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.
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 data where it is
necessary for compliance with a legal or regulatory obligation that we are subject to.
THIRD PARTIES
EXTERNAL THIRD PARTIES
Service providers based in the United Kingdom who provide IT and system administration
services.
Professional advisers including lawyers, bankers, auditors and insurers based in the United
Kingdom who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue & Customs, regulators and other authorities based in the United Kingdom who
require reporting of processing activities in certain circumstances.
YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This
enables you to receive a copy of the personal data we hold about you and to check that we are
lawfully processing it.
Request correction of the personal data 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.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data
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 data 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 data 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.
Object to processing of your personal data 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 data 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.
Request restriction of processing of your personal data. This enables you to ask us to suspend the
processing of your personal data 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.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a
third party you have chosen, your personal data 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.
Withdraw consent at any time where we are relying on consent to process your personal data.
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.