- IMPORTANT INFORMATION AND WHO WE ARE
- THE DATA WE COLLECT ABOUT YOU
- HOW IS YOUR PERSONAL DATA COLLECTED?
- HOW WE USE YOUR PERSONAL DATA
- DISCLOSURES OF YOUR PERSONAL DATA
- INTERNATIONAL TRANSFERS
- DATA SECURITY
- DATA RETENTION
- YOUR LEGAL RIGHTS
- Identity Data includes first name, maiden name, last name, username or similar identifier, title (although Little Ones does not request this personal data), date of birth (Little Ones may request age of your babies to be able to provide appropriate products) and gender.
- Contact Data includes billing address, email address, telephone numbers and social media handles.
- Comments Data includes any opinions or comments that may be expressed about you on Little Ones’ systems (mainly likely to be relevant in respect of individuals at our business to business contacts in the EEA, if at all).
- Financial Data includes bank account and payment card details (although Little Ones does not process this personal data, External Third Parties process such data). Where we ask for Financial Data of our relevant business to business contacts in the EEA, that data is corporate data and not personal data.
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us and your order number(s).
- Technical Data includes as may be applicable 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 (including reviews about us on third party sites) and survey responses and any image data which you post on our online applications and channels, including of your children.
- 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.
- apply for, purchase or use our products or services;
- create an account on our website;
- subscribe to our publications and newsletters;
- request marketing to be sent to you;
- enter a competition, promotion or survey;
- engage with us on our social media channels; or
- give us feedback (whether on our own applications and channels or on third party review sites) or contact us.
- analytics providers [such as Google based outside the EU];
- advertising networks [such as Facebook, Instagram based outside the EU]; and
- 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 obligation.
|Type of data
|Lawful basis for processing including basis of legitimate interest
|To register you as a new customer
|a) Identityb) Contactc) Profile
|Performance of a contract with you
|To process and deliver your order including:1. Mange transactions and which may involve you providing data about your children2. Send out your purchased product3. Collect and recover money owed to us
|a) Identityb) Contactc) Profiled)Transactione) Marketing & Communications
|a) Performance of a contract with youb) Necessary for our legitimate interests (to recover debts due to us)c) Your consent on behalf of your child where you provide their personal data
|a) Identityb) Contactc) Profiled) Marketing & Communicationse) Comments data
|a) Performance of a contract with you (or your business if you are an individual at our EEA service providers)b) Necessary to comply with a legal obligationc) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services and to enable proper use by us and you of our social media and online applications, to develop them and grow our business and to respond to reviews (negative or positive) in the interests of our business and customers and to enable discussion within the business about the performance of our service providers)d) Your consent on behalf of your child where you provide their personal data
|To enable you to partake in a prize draw, competition or complete a survey
|a) Identityb) Contactc) Profiled) Usagee) Marketing & Communications
|a) Performance of a contract with youb) 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) Identityb) Contactc) Technical
|a) Performance of a contract with you (as an e-commerce business, a working website is necessary to perform our services and provide our products)b) 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)c) Necessary to comply with a legal obligation (to protect user data)
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
|a) Technicalb) 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) Identityb) Contactc) Technicald) Usagee) Profilef) Marketing & Communications
|a) Consent (if you have agreed previously or recently to receive our direct marketing material)b) Necessary for our legitimate interests (to develop our products/services and grow our business)
- Internal Third Parties as set out in the Glossary.
- External Third Parties as set out in the Glossary.
- Any specific third parties listed in the table above from time to time.
- We will transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission, such as New Zealand. 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, such as Google or Apple, 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 Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
- 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 your 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. You can do this 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 your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data's accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- 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.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request transfer of your personal data. 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.
- Right to withdraw consent. 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.
- Service providers acting as processors based in various jurisdictions from time to time (including USA, New Zealand and Australia) who provide client relationship management (CRM) and marketing and IT and system administration services. [Our CRM partner is currently Shopify and Klaviyo – please see their relevant privacy notice at [Shopify Privacy Page Klaviyo Privacy Page].
- Professional advisers acting as processors or independent controllers including lawyers, bankers, auditors and insurers based in various jurisdictions from time to time (including UK, New Zealand and Australia) who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs (UK), Inland Revenue Department (NZ), or the Australian Tax Office, regulators and other authorities acting as processors or independent controllers based in the UK, New Zealand and Australia) who may require reporting of processing activities in certain circumstances.