Privacy and Cookie Policy
What does this Privacy Policy Cover?
We respect your privacy and are committed to protecting your personally identifiable information that can be used to contact or identify you (“Personal Data”). We want to be transparent with you about how we collect and use your Personal Data in making available our community platform (“Platform”) and tell you about your privacy rights and how the law protects you.
With that in mind, this Privacy Policy is designed to describe:
- Who we are and how to contact us
- Your rights relating to your Personal Data
- What Personal Data we collect
- How we use your Personal Data and why
- What happens when you do not provide necessary Personal Data?
- How we use cookies and other tracking or profiling technologies
- Who we share your Personal Data with
- How we keep your Personal Data secure
- How long we store your Personal Data
- Our policy on children
- Third party links
This Privacy Policy aims to give you information on how we collect and process your Personal Data through your use of this Platform, including any data you may provide through this Platform.
The Privacy Policy is intended to meet our duties of transparency under the “General Data Protection Regulation” or “GDPR”.
We will post any modifications or changes to this Privacy Policy on this page.
Who we are and how to contact us
Who we are
Torera George is the Controller (for the purposes of the GDPR) of your Personal Data (referred to as either “we”, “us” or “our” in this Privacy Policy).
Our Platform is a platform where members can access content on DIY, self-care, haircare and living.
How to contact us
You can contact us by emailing: hello@torerageorge.com.
What Personal Data we collect
All the Personal Data we collect, both from you and from third parties about you, is outlined in the table below.
| Category of Personal Data collected | What this means |
| Identity Data | First name, surname, maiden name, last name, username or similar identifier. |
| Contact Data | Your email address. |
| Behavioural Data | Inferred or assumed information relating to your behaviour and interests, based on your online activity. This is most often collated and grouped into “segments”. |
| Marketing Data | Data such as your preferences for receiving our marketing communications and details about your engagement with them. |
| Communication Data | Communications that we exchange with you, including when you contact us with questions or feedback, social media, or otherwise. |
| Financial Data | Your bank account and payment card details. |
Aggregated Data
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 once in aggregated form it will not constitute considered Personal Data for the purposes of the GDPR as this data does not directly or indirectly reveal your identity. 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 Policy.
How we use your Personal Data and why
We will only use your Personal Data for the purposes for which we collected it as listed below, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
If we need to use your Personal Data for an unrelated purpose, we will update this Privacy Policy and we will explain the legal basis which allows us to do so.
What is our “legal basis” for processing your Personal Data?
In respect of each of the purposes for which we use your Personal Data, the GDPR requires us to ensure that we have a “legal basis” for that use. Most commonly, we will rely on one of the following legal bases:
- Where we need to perform a contract we are about to enter into or have entered into with you (“Contractual Necessity”).
- Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests (“Legitimate Interests”). More detail about the specific legitimate interests pursued in respect of each Purpose we use your Personal Data for is set out in the table below.
- Where we need to comply with a legal or regulatory obligation (“Compliance with Law”).
- Where we have your specific consent to carry out the processing for the Purpose in question (“Consent”).
Generally, we do not rely on your Consent as a legal basis for using your Personal Data other than in the context of direct marketing communications.
Marketing
We aim to provide you with choices regarding certain Personal Data uses, particularly around marketing and advertising. As part of our ongoing marketing activity, we may use your Personal Data in the following ways:
- Promotions. We may process your Identity Data and Contact Data to understand what we think you may want, need or may be of interest to you.
You will receive marketing communications from us if you have requested information from us, with us or if you have provided us with your Personal Data to receive marketing promotions and have not opted-out of receiving marketing communications from us.
- Third Party Marketing. We will request your express opt-in consent before we share your Personal Data with a third-party for marketing purposes.
- Opting Out. You may request that we or third parties stop sending you marketing messages at any time by contacting us or by following the opt-out links on any marketing messages sent to you. If 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 or experience or any other transactions.
What happens when you do not provide necessary Personal Data?
Where we need to process your Personal Data either to comply with law, or to perform 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 the functionalities of the Platform).
In this case, we may have to stop you using our Platform but we will notify you if this is the case at the time.
How we use cookies & other tracking or profiling technologies
Cookies
What are cookies?
We may collect information using “cookies”. Cookies are small data files stored on the hard drive of your computer or mobile device by a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience on our Platform.
We use two broad categories of cookies:
- first party cookies, served directly by us to your computer or mobile device; and
- third party cookies, which are served by our partners or service providers on our Platform.
Cookies we use
Our Platform uses the following types of cookies for the purposes set out below:
| Type of cookie | Purpose |
| Essential Cookies | These cookies are essential to provide you with services available through our Platform and to enable you to use some of its features. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services. |
| Functionality Cookies | These cookies allow our Platform to remember choices you make when you use our Platform. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you visit our Platform. |
| Analytics and Performance Cookies | These cookies are used to collect information about traffic to our Platform and how users use our Platform. The information gathered via these cookies does not “directly” identify any individual visitor. However, it may render such visitors “indirectly identifiable”. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access our Platform. The information collected is aggregated and anonymous. It includes the number of visitors to our Platform, the websites that referred them to our Platform, the pages they visited on our Platform, what time of day they visited our Platform, whether they have visited our Platform before, and other similar information. We use this information to help operate our Platform more efficiently, to gather broad demographic information and to monitor the level of activity on our Platform.
We use Google Analytics for this purpose. Google Analytics uses its own cookies. It is only used to improve how our Platform works. You can find out more information about Google Analytics cookies here: https://developers.google.com/analytics/resources/concepts/gaConceptsCookies You can find out more about how Google protects your data here: www.google.com/analytics/learn/privacy.html. |
Disabling cookies
You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings”, “help” “tools” or “edit” facility). Many browsers are set to accept cookies until you change your settings.
If you do not accept our cookies, you may experience some inconvenience in your use of our Platform. For example, we may not be able to recognise your computer or mobile device and you may need to log in every time you visit our Platform.
Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.com.uk.
You can also prevent the use of Google Analytics relating to your use of our Platform by downloading and installing the browser plugin available via this link: http://tools.google.com/dlpage/gaoptout?hl=en-GB
Who we share your Personal Data with
We may share your Personal Data with the following parties and as otherwise described in this Privacy Policy or at the time of collection.
- Service providers. Third parties that provide services on our behalf or help us operate our business (such as data hosting, information technology, customer support, email delivery, marketing, and website analytics).
- Payment processors. Any payment card information you use to make a purchase on the website is collected and processed directly by our payment processors, such as PayPal or Stripe. PayPal and Stripe may use your payment data in accordance with their privacy policy, https://www.paypal.com/uk/webapps/mpp/ua/privacy-full and https://stripe.com/privacy respectively.
- Business and marketing partners. Third parties with whom we collaborate on joint activities (such as co-sponsors of contests and promotions), with whom we have entered into joint marketing relationships or other joint ventures.
We do not transfer your Personal Data to any parties located outside the European Economic Area.
How we keep your Personal Data secure
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 limit access to your Personal Data to those employees and other staff who have a business need to have such access. All such people are subject to a contractual duty of confidentiality.
We have put in place procedures to deal with any actual or suspected Personal Data breach. In the event of any such breach, we have systems in place to work with applicable regulators. In addition, in certain circumstances (e.g., where we are legally required to do so) we may notify you of breaches affecting your Personal Data.
How long we store your Personal Data
We will only retain your Personal Data for so long as we reasonably need to use it for the purposes set out above under “How we use your Personal Data and why”, unless a longer retention period is required by law (for example for regulatory purposes).
The table below shows our standard retention practices:
| Category of Personal Data | Retention period |
| Behavioural Data | One year from the date on which we collected or received it. |
| Contact Data | For so long as retention is necessary to fulfil the Purposes/Use for which it is used (see “How we use your Personal Data and why.”). |
| Financial Data | For so long as retention is necessary to fulfil the Purposes/Use for which it is used (see “How we use your Personal Data and why.”). |
Our policy on children
This Platform is not intended for children below 16 and we do not knowingly collect data relating to such children.
Third party links
This Platform 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 your Personal Data. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Platform, we encourage you to read the privacy policy of every site you visit.
Your rights relating to your Personal Data
By law you have the right to:
-
- Request access to your Personal Data. 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 information we hold about you corrected.
- 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 exercised your right to object to processing (see below).
- Object to processing of your Personal Data. This right exists where we are relying on a Legitimate Interest as the legal basis for our processing and there is something about your particular situation, which makes you want to object to processing on this ground. You also have the right to object where we are processing your Personal Data for direct marketing purposes.
- Request the restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of Personal Data about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your Personal Data. 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. This right only exists where we are relying on consent to process your Personal Data (“Consent Withdrawal”). If you withdraw your consent, we may not be able to provide you with access to the certain specific functionalities of our Platform. We will advise you if this is the case at the time you withdraw your consent.
How to exercise your rights
If you want to exercise any of the rights described above, please contact us using the contact details shown at “Who We Are and How to Contact Us”.
Typically, you will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, except in relation to Consent Withdrawal, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive, or, we may refuse to comply with your request in these circumstances.
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.
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.
Sending your information outside of the United Kingdom or European Economic Area
Whenever we transfer your personal information outside of the United Kingdom or European Economic Area, we will seek to ensure that a similar degree of protection is afforded.
Complaints
If you would like to make a complaint regarding this Privacy Policy or our practices in relation to your Personal Data, please contact us at: hello@torerageorge.com.
We will reply to your complaint as soon as we can.
If you feel that your complaint has not been adequately resolved, please note that the GDPR gives you the right to contact your local data protection supervisory authority, which for the UK, is the Information Commissioner’s Office.
