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Privacy policy
Introduction
Your privacy is important to us, so to:
We have prepared this Privacy Policy. Please use the guide to specific sections below to easily find what you are looking for.
1. IMPORTANT INFORMATION AND WHO WE ARE
2. THE DATA WE COLLECT ABOUT YOU
3. HOW IS YOUR PERSONAL DATA COLLECTED
4. HOW AND WHY 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
Purpose of this privacy notice
Our privacy notice aims to give you information on how tails.com collects and processes your personal data through your use of our website and related services, including any personal data you may provide through this website when you create an account with us or purchase our products.
For the avoidance of doubt, this privacy policy and any references to personal data herein do not include information relating to your dog. For further information about how we use information relating to your dog, including use of your dog’s photo, please see the tails.com Terms and Conditions.
Given the nature of our services, we do not knowingly collect data relating to children. It is important that you read this privacy notice together with any other notices we may provide you so that you are fully aware of how and why we are using your data. This privacy notice does not override our other notices and may be updated from time to time.
Data Controller
Tailsco control and are responsible for the personal data that we hold about you. Our company correspondence details, registered company number and ICO registration number are included in the introduction paragraph to these terms and conditions.
If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us using the details set out below.
We would appreciate the chance to deal with any data protection concerns you may have before you approach the Information Commissioner's Office (ICO) so please contact us at mydata@tails.com in the first instance.
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 (ico.org.uk).
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 follows:
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does 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 notice.
We do not usually 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. In some circumstances, we may inadvertently record Special Categories of Personal Data if voluntarily disclosed to us in email or over the phone. Under such circumstances, any Special Categories of Personal Data will be treated in accordance with your rights.
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 goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
(a) analytics providers;
(b) advertising networks; and
(c) search information providers.
4. How and why we use your personal data
We will only use your personal data when the law allows us to. Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email or text message from us. 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 direct marketing communications to you via email or text message from us. You have the right to withdraw consent to marketing at any time by visiting our communication preference centre or by contacting us.
The points below set out how we use your data and the lawful basis for doing so.
Activity:
To register you as a new customer
Data required:
(a) Identity,
(b) Contact,
(c) Financial
Data required for:
Performance of a contract with you
Activity:
To contact you regarding completion of the registration process
Data required:
(a) Identity,
(b) Contact,
(c) Usage
Data required for:
Performance of a contract with you
Activity:
To process and deliver your order including:
(a) Manage payments, fees and charges,
(b) Collect and recover money owed to us
Data required:
(a) Identity,
(b) Contact,
(c) Financial,
(d) Transaction,
(e) Marketing and Communications
Data required for:
(a) Performance of a contract with you, (b) Necessary for our legitimate interests (to recover debts due to us)
Activity:
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
Data required:
(a) Identity,
(b) Contact,
(c) Profile,
(d) Marketing and Communications
Data required for:
(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)
Activity: To enable you to complete a survey
Data required:
(a) Identity,
(b) Contact,
(c) Profile,
(d) Usage,
(e) Marketing and Communications
Data required for:
(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)
Activity:
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
Data required:
(a) Identity,
(b) Contact,
(c) Technical
Data required for:
(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
Activity:
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
Data required:
(a) Identity,
(b) Contact,
(c) Profile,
(d) Usage,
(e) Marketing and Communications,
(f) Technical
Data required for:
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)
Activity:
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
Data required:
(a) Contact,
(b) Technical,
(c) Usage
Data required for:
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)
Activity:
To make suggestions and recommendations to you about goods or services that may be of interest to you on the basis of previous sales to you via electronic means (telephone, email, SMS or App push notifications)
Data required:
(a) Identity,
(b) Contact,
(c) Technical,
(d) Usage,
(e) Profile,
Data required for:
Necessary for our legitimate interests (to develop our products/services and grow our business)
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 list above. For the most part, we’ll be using your data to fulfil our contract with you. In providing any peripheral services, we will only use your data where it is in our legitimate interests, such as improving our goods/services, which we hope will benefit you and your dog.
Marketing
We provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established a communication preferences centre within your account area where you can view and make certain decisions about how we communicate with you.
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you (and your dog). This is how we decide which products, services and offers may be relevant for you.
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you started our signup process and, in each case, you have not opted out of receiving that marketing.
Third-party marketing
We will get your express opt-in consent before we share your personal data with any company outside the tails.com group of companies for marketing purposes.
We work with Epsilon Abacus (registered as Epsilon International UK Ltd), a company that manages the Abacus Alliance on behalf of UK retailers. The participating retailers are active in the clothing, collectables, food & wine, gardening, gadgets & entertainment, health & beauty, household goods, and home interiors categories. Retailers share information about their customers and what they buy. Epsilon Abacus processes this information as a processor on behalf of the retailers to help them understand consumers’ wider buying patterns. From this information, retailers can tailor their communications, sending individuals suitable offers that should be of interest to them, based on what they like to buy. You can learn more about how Epsilon Abacus processes your personal information in their Privacy Policy, which is available here: https://abacus.epsilon.com/privacy-policy/
Opting out
We have established a communication preferences centre within your account area where you can view and make certain decisions about how we communicate with you (https://tails.com/settings/communication-preferences). You can ask us to stop sending you marketing messages at any time by logging into the website and selecting yes or no to adjust your marketing preferences or by following the unsubscribe links on any marketing message sent to you via email or by contacting us at any time.
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. We will continue to communicate with you for reasons essential to the fulfilment of any orders (this includes information relating to your account and deliveries), you cannot opt out of any such messages.
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.
For more information about the cookies we use, including third-party cookies, please see our cookie policy.
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
Alternatively, we may seek to acquire other businesses or merge with them.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We only permit third parties to process your personal data for specified purposes and in accordance with our instructions. Third-parties may contact you directly in connection to the provision of our goods/services e.g. relating to the delivery of your orders – such communications may include satisfaction surveys relating to your delivery. These communications will be covered by the third party’s privacy policy.
6. International transfers
Some of our servers and processors are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.
Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
Please contact us at mydata@tails.com if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
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.
In some circumstances you can ask us to delete your data: see 'Request erasure' below for further information.
For Personal Data that is not required to be kept for legal purposes or where our legitimate interest is not overridden by your interests or fundamental rights and freedoms, we will retain your data for 24 months from the point at which you cancel your subscriptions with us and stop all interaction with tails.com. If you don’t complete our signup process for your first delivery, we will retain any Personal Data that you provide during the signup process for 12 months. If you have opted into receiving marketing messages from us, we will notify you via email prior to deleting your Personal Data so you have a chance to prevent the deletion and enable you to retain access to your account, your dog’s order profile and any correspondence with us.
If you have opted out of marketing, please be aware that we will delete your Personal Data in accordance with the timeframes above without further notification to you.
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.
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data, these include:
If you wish to exercise any of the rights set out above, please contact us at mydata@tails.com. 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.
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 30 days. Occasionally it may take us longer than 30 days 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/product 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.