Privacy & Cookie Policy
Effective date: June 15, 2024
Privacy Policy
Introduction
Welcome to our privacy policy.
We respect your privacy and are committed to protecting your personal data. This privacy policy will inform you about how we look after your personal data when you visit our website www.sarasmitsvanoyen.com and includes any content and services offered through “Smitsvanoyen.com” and also informs you about your privacy rights and how the law protects you, whether as a guest or registered user.
It contains important information on who we are and how and why we collect, store, use and share your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint.
We collect, use and are responsible for certain personal information about you. When we do so we are subject to data protection laws and we are responsible as ‘controller’ of that personal information for the purposes of those laws.
Our website is not intended for children under 13 years of age. By providing us with your data, you warrant to us that you are over 13 years of age. We do not knowingly collect personal information from children under 13 years of age and if we learn that we have received personal information from a child under 13 without verification of parental consent, that data will be deleted.
Please read this Privacy Policy prior to using our website. By using the website, you are confirming you agree to the terms of this policy.
Purpose of this privacy policy
This privacy policy aims to give you information on how we collect and process your personal data through your use of this website, including any data you may provide through this website when you fill in our contact form, sign up to receive information from us, purchase a product or service, during the performance of a service, or to take part in a giveaway/competition.
It is important that you read this privacy policy together with any other privacy policy or 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 policy supplements the other policies and notices and is not intended to override them.
Controller
Sara Smits van Oyen is the controller and responsible for your personal data (collectively referred to as ["we", "us" or "our"] or [“I”, “me” or “my”] in this privacy policy).
If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us using the details set out below.
Contact details
If you have any questions about this privacy policy or our privacy practices, please contact us. Our full details are:
Sarai Wellness
Name or title of person to contact: Sara Smits van Oyen
Email address: Huizwerweg 47
Postal address: 1261AT Blaricum, The Netherlands
You may have the right to make a complaint to the data protection authority in the country where you are based. However, we care deeply about your data protection rights and we would appreciate the chance to deal with and resolve your concerns so please contact us using the details above in the first instance.
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 policy or notice of every website you visit.
When you access our website, we learn certain information 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, last name, username or similar identifier, title, date of birth and gender.
- Contact Data includes billing address, delivery or postal 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 products and services you have purchased from us.
- Technical Data includes internet protocol (IP) address, your log-in 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 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.
Sensitive Data
Sensitive data refers to data that 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, and criminal convictions and offences.
We do not collect any sensitive data about you.
We use different methods to collect data from and about you including through:
- 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 (where applicable):
- apply for our products or services;
- necessary images, copy, branding assets used in performing services
- create an account on our website;
- subscribe to our service or publications;
- request marketing to be sent to you;
- enter a competition, promotion or survey; or
- give us some feedback or contact us.
- Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy at the end of this document for more information.
- Analytics We may receive technical personal data about you from analytics providers such as Google.
- We may receive Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as PayPal.
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:
- To present our website and its content to you, to provide you with information and offers for our products and services, to carry out our business activities and provide customer service.
- Where we need to perform the contract we are about to enter into or have entered into with you.
- 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.
- To keep you updated about our products and services where you have consented to this. We shall send this information to you by email or online. You have the right to withdraw consent to marketing at any time by contacting us [email protected] and by clicking on the ‘unsubscribe’ button in our emails.
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.
|
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 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 |
Necessary for our legitimate interests (to develop our products/services and grow our business) |
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. Our lawful ground for processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business).
Under applicable regulations, we may send you marketing communications from us if (i) you made a purchase or asked for information from us about our goods or services or (ii) you agreed to receive marketing communications and in each case you have not opted out of receiving such communications since. If permitted under regulations, if you are a limited company, we may send you marketing emails without your consent. However, you can still opt out of receiving marketing emails from us at any time.
- If you are based outside the European Union and receive our free resources, register for our webinar or live event or take part in our free training workshops or programmes, we will automatically enrol you to receive our free newsletter by email. You may unsubscribe at any time by clicking on the “unsubscribe” link at the bottom of our emails or by emailing your request to unsubscribe to [email protected]
- If you are based inside the European Union and receive our free resources, register for our webinar or live event or take part in our free training workshops or programmes, we will only enrol you to receive our free email newsletter if you expressly consent to it. You may unsubscribe at any time by clicking on the “unsubscribe” link at the bottom of our emails or by emailing your request to unsubscribe to [email protected]
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. 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.
Third-party marketing
We do not share your personal data with any third parties.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us [email protected] 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, warranty registration, product/service experience or other transactions.
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, please see our cookie policy at the end of this document.
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.
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 such as our subsidiaries, affiliates, service providers, professional advisers, tax or other government authorities and regulators; and
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy. We do not otherwise rent, lease or sell any information collected as a general rule.
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.
- Emails
If you communicate with us by email, we may retain the content of those emails, our responses and details of your email address and provide the same protection that we employ for maintenance of online information received.
We will maintain the information you send via email in accordance with applicable law.
To deliver services to you, it is [sometimes] necessary for us to share your personal information outside the European Economic Area (EEA) e.g.:
- when we work outside of the EEA
- with our service providers located outside the EEA;
- These transfers are subject to special rules under European and UK data protection law.
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
- 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.
If you would like further information please contact us using the contact details in clause 1 above .
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. 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 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. 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 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 you can ask us to delete your data: see ‘Request erasure’ below for further information.
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.
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
If you are within the European Union, you are entitled to certain information and rights under GDPR, which include the following:
- 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.
- Right to lodge a complaint with a supervisory authority which has jurisdiction relating to GDPR.
If you wish to exercise any of the rights set out above, please contact us at [email protected].
We will retain any personal data you provide to us until either (a) you ask us to delete the information, (b) we no longer use our existing data providers, or (c) we decide that the value in retaining the data is outweighed by the costs of retaining it.
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.
Changes to this privacy policy
We may change this privacy policy from time to time – when we do, we shall inform you via our website.
Cookie Policy
Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.
A cookie is a small text file which is placed onto your computer (or other electronic device) when you access our website.
We use cookies on this website to:
recognise you whenever you visit this website (this speeds up your access to the website as you do not have to log in each time);
obtain information about your preferences, online movements and use of the internet;
carry out research and statistical analysis to help improve our content, products and services and to help us better understand our visitor requirements and interests;
target our marketing and advertising campaigns more effectively by providing interest-based advertisements that are personalised to your interests; and
make your online experience more efficient and enjoyable.
The information we obtain from our use of cookies will not usually contain your personal data. Although we may obtain information about your computer or other electronic device such as your IP address, your browser and/or other internet log information, this will not usually identify you personally. In certain circumstances we may collect personal information about you—but only where you voluntarily provide it (eg by completing an online form).
We use the following types of cookies:
- Strictly necessary cookies. These are cookies that are required for the operation of our website.
- Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
- Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
- Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests.
Apart from in the case of strictly necessary cookies, we will need your consent in order to use cookies on this website.
First and third party cookies
First party cookies are cookies set by our website. Third party cookies are cookies on our website that are set by another website, such as where we have adverts on our website or use Facebook pixels so that we can show you relevant content from us when you are on Facebook.
We use both first party cookies as well as relevant third party cookies on our website and details of these are included in the table below.
- More detail about our cookies can be found on our website cookie banner.
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How to turn off cookies or alter settings
You can alter your cookie preferences at any time by‘going to the cookie consent mechanism and changing the relevant setting to ‘off’.
If you do not want to accept cookies, you can also change your browser settings so that cookies are not accepted. If you do this, please be aware that you may lose some of the functionality of this website.
To opt out of being tracked by Google Analytics across all websites, visit http://tools.google.com/dlpage/gaoptout.
