This privacy notice applies to the processing of personal data by CBD Labs LLC Limited referred to as Naked Leaf we, us, or our in this notice.
Naked Leaf 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 contact us or visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
1. Important information and who we are
Purpose of this privacy notice
This privacy notice aims to give you information on how Naked Leaf collects and processes your personal data through your use of this website, including any data you may provide when you purchase a product, sign up to our newsletter, take part in a competition, or any other communications you have with us for example when you call or email us or contact us via social media.
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.
Naked Leaf is the controller and responsible for your personal data.
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.
Full name of legal entity: CBD Labs LLC Limited trading as Naked Leaf.
Email address: [email protected]
Postal address: 8-9 Ship Street Brighton BN1 1AD
Telephone number: +44 (0)7432265592
Lodging a complaint
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
We will keep this notice updated and keep you informed of any material changes to the way we process your personal data. Future changes will be posted here and, where appropriate, notified to you by email. We encourage you to read about the changes so that you keep up to date.
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.
We do not include or offer third-party products or services on our website.
Our website does however; 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. This includes information such as your name, email address, telephone number and address. It does not include data where the identity has been removed (anonymous data).
We collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
- Identity Data includes first name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Contact Data includes billing address, delivery 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 you have purchased from us.
- Technical Data includes internet protocol (IP) address, your login 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 our third parties and us 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. 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 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.
If you include any special categories of personal data when you use our website or contact us, it is your responsibility to make sure you are happy for us to use that personal data in accordance with this notice. You should be aware that this personal data is more sensitive and is more heavily protected by data protection legislation, so you should avoid including this kind of data if possible.
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). 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:
- Direct interactions – You may give us your Identity, Contact, Financial, Profile and Marketing and Communications Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- create an account on our website;
- purchase our products;
- subscribe to our publications or updates;
- request marketing to be sent to you;
- enter a competition or promotion;
- complete a survey; or
- make contact with us through email, telephone, post or through social media regarding a query, feedback or complaint.
- Third parties – We may receive personal data about you from third parties as set out below:
- Technical Data from analytics providers such as Google; and
- Identity, Contact and Profile Data from social media platforms such as Facebook, Twitter, Instagram and LinkedIn.
4. How we use your personal data
Under data protection legislation, we are only permitted to use your personal data if we have a legal basis for doing so as set out by data protection legislation. 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;
- 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; or
- with your consent (for example, where you have provided your consent in order for us to send you marketing materials), which you have the right to withdraw at any time by contacting us using the contact details above.
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 using the contact details above 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.
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.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We will provide you with a clear choice to opt into receiving marketing materials and communications when you first register an account with us.
We use your Identity, Contact, Technical, Usage, Profile and Marketing and Communications Data to provide you with details of products and offers that may be relevant to you.
You will receive marketing communications from us if you have requested information from us or if you provided us with your details when purchasing products or when contacting us and in each case, you have not opted out of receiving that marketing.
You can ask us to stop sending you marketing messages at any time by logging into the website and unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you 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 purchase, warranty registration, product experience or other transactions.
We do not sell, trade, or otherwise transfer your personal data to outside parties.
5. Disclosures of your personal data
We will treat all of your personal data as private and confidential and in accordance with the data protection laws. We may however, need to share your personal data with third parties who provide services to us to enable them to provide their services to us such as IT providers, payment facilitators, delivery services and system administration services.
Where we use third parties to process your personal data on our behalf, we will always carry out checks to ensure that there are appropriate protections for the safeguarding your personal data. We will also monitor the performance of these third parties (and their approved subcontractors) to ensure that your personal data remains secure.
Any third party service provider that we instruct will only process your personal data:
- for the same purposes for which we may use your personal data (as set out in this notice);
- as is strictly necessary to perform its obligations to us; and
- in the ways instructed by us.
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.
We will not usually disclose your personal data other than as set out above. However, there may be circumstances where we need to share personal data other than as anticipated above. These include:
- Where we are legally required to disclose the information, for example because a court orders us to do so;
- Where the disclosure of the personal information is required for the purposes of the prevention and detection of crime. This includes sharing the personal information with tax authorities and law enforcement agencies;
- Where we need to disclose the personal information for the purpose of or in connection with any legal proceedings, or for the purpose of obtaining legal advice, or the disclosure is otherwise necessary for the purposes of establishing, exercising or defending legal rights;
- Where disclosure is necessary to protect your vital interests (for example if you are unwell at one of our events, we may need to seek medical assistance); and
- To any actual or prospective purchaser of our business assets or organisation.
6. International transfers
We share your personal data with consultants and contractors who work with us in order to provide our service to you. Some 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 that our consultants and contractors enter into data transfer agreements which place obligations on them to adequately protect your personal data when it is transferred to non-EU countries.
Other than the above, we do not work with any other third-parties based outside the EEA and we do not store, host or transfer any of your personal data outside of the EEA.
In the event that this changes and we transfer personal data outside of the EEA to other third parties, we will update this notice accordingly and provide further information on the specific mechanisms used by us when transferring your personal data.
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.
Our website is scanned on a regular basis for security holes and known vulnerabilities in order to make your visit to our site as safe as possible. We use regular Malware Scanning and your personal data is contained behind secured networks.
Your personal data is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential. In addition, all sensitive/credit information you supply is encrypted via Secure Socket Layer (SSL) technology.
We implement a variety of security measures when a user places an order enters, submits, or accesses their information to maintain the safety of your personal data. All transactions are processed through a gateway provider and are not stored or processed on our servers.
We have also 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.
We will keep your personal data for as long as you have an account with us and generally for a period of [3 years] following closure of your account or following our response to your query. However, where we have a statutory obligation to keep the personal data for a longer period or where we may need to keep your personal data for a longer period in case of a legal claim or dealing with on-going queries or complaints, then the retention period may be longer.
9. Your legal rights
You have a number of rights in relation to your personal data. You have the right within certain parameters, 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.
If you would like to exercise any of the rights set out above, please contact us using the contact details above.
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.
You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser (like Internet Explorer) settings. Each browser is a little different, so look at your browser’s Help menu to learn the correct way to modify your cookies.
Our cookies help to:
- make our website work as you would expect;
- remember your settings during and between visits;
- improve your and other users’ experiences of our website;
- allow you to sign up to marketing and updates if you have requested to do so; and
- improve the speed/security of our website.