Privacy and Cookies Policy

Introduction

We work hard to serve shoppers as best as we can. Looking after the personal data you share with us is a very important part of this. We want you to be confident that your data is safe and secure with us, and understand how we use it to offer you a better shopping experience.

This Privacy Notice explains in detail the types of personal data we may collect about you when you interact with us. It also explains how we'll store and handle that data, and keep it safe.

We know that there's a lot of information here, but we want you to be fully informed about your rights, and how URBAN RETREAT by Acti Labs LTD uses your data.

We hope the following sections will answer any questions you have but if not, please do get in touch with us.

It's likely that we'll need to update this Privacy Notice from time to time. Please come back and check it whenever you wish.

The terms 'we', 'us', are each intended as reference to URBAN RETREAT by Acti Labs LTD.

We will also refer to urban-retreat.com as 'our website' or 'the website'

The legal bases we rely on

The law on data protection sets out a number of different reasons for which a company may collect and process your personal data, including:

Consent

In specific situations, we can collect and process your data with your consent.

For example, when you tick a box to receive email newsletters.

When collecting your personal data, we'll always make clear to you which data is necessary in connection with a particular service.

Contractual obligations

In certain circumstances, we need your personal data to comply with our contractual obligations.

For example, if you order an item from us, we'll collect your address details to deliver your purchase, and pass them to our courier.

Legal compliance

If the law requires us to, we may need to collect and process your data.

For example, we can pass on details of people involved in fraud or other criminal activity affecting URBAN RETREAT by Acti Labs LTD to law enforcement.

Legitimate interest

In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests.

For example, we may use your purchase history to send you or make available personalised offers.

We also may combine the shopping history of many customers to identify trends and ensure we can keep up with demand, or develop new products/services.

When do we collect your personal data?

When you visit our website 'urban-retreat.com' , and use your account to buy products and services, or redeem vouchers.

When you make an online purchase and check out as a guest (in which case we just collect transaction-based data).

When you create an account with us.

When you engage with us on social media.

When you contact us by any means with queries, complaints etc.

When you enter prize draws or competitions.

When you request a personal shopper call.

When you choose to complete any surveys we send you.

When you comment on or review our products and services.

When you fill in any forms. For example a product returns form

When you've given a third party permission to share with us the information they hold about you.

What sort of personal data do we collect?

If you have a web account with us: your name, billing/delivery address, orders, email and telephone number. For your security, we'll also keep an encrypted record of your login password.

Details of your interactions with us through contact centres.

For example, we collect notes from our conversations with you, details of any complaints or comments you make, details of purchases you made, items viewed or added to your basket, wish list choices, voucher redemptions, web pages you visit and how and when you contact us.

Copies of documents you provide to prove your age or identity where the law requires this. (including your passport and driver's licence). This will include details of your full name, address, date of birth and facial image. If you provide a passport, the data will also include your place of birth, gender and nationality.

Details of your shopping preferences. For example, details of your visits to our website and which site you came from to ours.

Information gathered by the use of cookies in your web browser. Learn more about how we use cookies and similar technologies under the Cookies Section below.

Personal details which help us to recommend items of interest.

For example you might share information on your skin type which allows us to recommend appropriate skincare. (We'll only ask for and use your personal data collected for recommending items of interest and to customise your shopping experience with us. Of course, it's always your choice whether you share such details with us).

Payment card information.

Your comments and product reviews.

To deliver the best possible web experience, we collect technical information about your internet connection and browser as well as the country and telephone code where your computer is located, the web pages viewed during your visit, the advertisements you clicked on, and any search terms you entered. You can learn more about this under the Cookies Section below.

Your social media username, if you interact with us through those channels, to help us respond to your comments, questions or feedback.

How and why do we use your personal data?

We want to give you the best possible customer experience. One way to achieve that is to get the richest picture we can of who you are by combining the data we have about you.

We then use this to offer you promotions, products and services that are most likely to interest you.

The data privacy law allows this as part of our legitimate interest in understanding our customers and providing the highest levels of service.

Of course, if you wish to change how we use your data, you'll find details in the 'What are my rights?' section below.

Remember, if you choose not to share your personal data with us, or refuse certain contact permissions, we might not be able to provide some services you've asked for.

For example, if you've asked us to let you know when an item comes back into stock, we can't do that if you've elected to unsubscribe from our mailing list.

Here's how we'll use your personal data and why:

To process any orders that you make by using our website. If we don't collect your personal data during checkout, we won't be able to process your order and comply with our legal obligations.

For example, your details need to be passed to a courier to deliver the product that you ordered. In addition we may keep your details for a reasonable period afterwards in order to fulfil any contractual obligations such as refunds and so on.

To respond to your queries, refund requests and complaints. Handling the information you sent enables us to respond. We may also keep a record of this to inform any future communication with us and to demonstrate how we communicated with you throughout. We do this on the basis of our contractual obligations to you, our legal obligations and our legitimate interests in providing you with the best service and understanding how we can improve our service based on your experience.

If you choose to register an account or place your order with one of our sales ambassadors we may share the associated information with them, to establish or maintain our relationship with you, to contact you and respond to your requests and inquiries, to provide you with services you have requested. Both during the term of an Ambassador’s respective Independent Contractor Ambassador Agreement and indefinitely thereafter, an Ambassador shall not use Confidential Information for any purpose other than performing his or its obligations or exercising rights under his or its respective Independent Contractor Ambassador Agreement.

To protect our business and your account from fraud and other illegal activities. This includes using your personal data to maintain, update and safeguard your account. We'll also monitor your browsing activity with us to quickly identify and resolve any problems and protect the integrity of our websites. We'll do all of this as part of our legitimate interest.

For example, by checking your password when you login and using automated monitoring of IP addresses to identify possible fraudulent log-ins from unexpected locations.

To process payments and to prevent fraudulent transactions. We do this on the basis of our legitimate business interests. This also helps to protect our customers from fraud.

If we discover any criminal activity or alleged criminal activity through our fraud monitoring and suspicious transaction monitoring, we will process this data for the purposes of preventing or detecting unlawful acts. We aim is to protect the individuals we interact with from criminal activities.

With your consent, we will use your personal data, preferences and details of your transactions to keep you informed by email, web, text, telephone and through our contact centres about relevant products and services including tailored special offers, discounts, promotions, events, competitions and so on.

>Of course, you are free to opt out of hearing from us by any of these channels at any time.

To send you communications required by law or which are necessary to inform you about our changes to the services we provide you. These service messages will not include any promotional content and do not require prior consent when sent by email or text message. If we do not use your personal data for these purposes, we would be unable to comply with our legal obligations.

To display the most interesting content to you on our website, we'll use data we hold about your favourite products. We do so on the basis of your consent for our website to place cookies or similar technology on your device. For example, we might display a list of items you've recently looked at.

To administer any of our prize draws or competitions which you enter, based on your consent given at the time of entering.

To develop, test and improve the systems, services and products we provide to you. We'll do this on the basis of our legitimate business interests.

For example, we'll record your browser's Session ID to help us understand more when you leave us online feedback about any problems you're having.

To comply with our contractual or legal obligations to share data with law enforcement.

To send you survey and feedback requests to help improve our services. You are free to opt out of receiving these requests from us at any time by updating your preferences in your online account.

To process your personal shopper requests. For example we will need your name and phone number to contact you so that we can fulfil your request.

To build a picture of your preferences, and to inform our business decisions, we'll combine data captured from our website and third parties as we have described in the section 'What Sort of Personal Data do we collect?' We'll do this on the basis of our legitimate business interest.

For example, by combining this data, this will help us personalise your experience and decide which products and content to share with you. We also use anonymised data from customer purchase histories to identify trends in different areas of the country.

How we protect your personal data

We know how much data security matters to all our customers. With this in mind we will treat your data with the utmost care and take all appropriate steps to protect it.

We secure access to all transactional areas of our using 'https' technology.

Access to your personal data is password-protected, and sensitive data (such as payment card information) is secured by SSL encryption.

We regularly monitor our system for possible vulnerabilities and attacks, and we carry out penetration testing to identify ways to further strengthen security.

How long will we keep your personal data?

Whenever we collect or process your personal data, we'll only keep it for as long as is necessary for the purpose for which it was collected.

At the end of that retention period, your data will either be deleted completely or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning.

Who do we share your personal data with?

We sometimes share your personal data with trusted third parties. For example, we share your personal data with a courier to delivery your orders.

Here's the policy we apply to those organisations to keep your data safe and protect your privacy:

We provide only the information they need to perform their specific services.

They may only use your data for the exact purposes we specify in our contract with them.

We work closely with them to ensure that your privacy is respected and protected at all times.

If we stop using their services, any of your data held by them will either be deleted or rendered anonymous.

Below is a list of some key 3^rd parties we currently share data with and why.

ANALYTICS

The services contained in this section enables us to monitor and analyse web traffic and can be used to keep track of User behaviour.

GOOGLE ANALYTICS (GOOGLE INC.)

Google Analytics is a web analysis service provided by Google Inc. ('Google'). Google utilizes the Data collected to track and examine the use of this Website, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.

Personal Data collected: Cookies and Usage Data. - Opt Out

GOOGLE ADWORDS CONVERSION TRACKING (GOOGLE INC.)

Google AdWords conversion tracking is an analytics service provided by Google Inc. that connects data from the Google AdWords advertising network with actions performed on this Website.

Personal Data collected: Cookies and Usage Data.

DISPLAYING CONTENT FROM EXTERNAL PLATFORMS

This type of service allows you to view content hosted on external platforms directly from the pages of our website and interact with them.
This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.

VIMEO VIDEO (VIMEO, LLC)

Vimeo is a video content visualization service provided by Vimeo, LLC that allows our website to incorporate content of this kind on its pages.

Personal Data collected: Cookies and Usage Data.

YOUTUBE VIDEO WIDGET (GOOGLE INC.)

YouTube is a video content visualization service provided by Google Inc. that allows our website to incorporate content of this kind on its pages.

Personal Data collected: Cookies and Usage Data.

HANDLING PAYMENTS

Payment processing services enable our website to process payments. To ensure greater security, our website shares only the information necessary to execute the transaction with the financial intermediaries handling the transaction.
Some of these services may also enable the sending of timed messages to the User, such as emails containing invoices or notifications concerning the payment.

SAGE PAY (SAGE PAY EUROPE LIMITED)

Sage Pay is a payment service provided by Sage Pay Europe Limited.

Personal Data collected: Billing and payment information

PAYPAL Commerce

Paypal Commerce is a payment service provided by Paypal

Personal Data collected: Billing and payment information

Authorize.Net

Authorize.Net is a payment service provided by VISA

Personal Data collected: Billing and payment information

Moneris

Moneris is a payment service provided by Moneris

Personal Data collected: Billing and payment information

OVH

An IT company who supports our website , email and other business systems.

INTERACTION WITH EXTERNAL SOCIAL NETWORKS AND PLATFORMS

This type of service allows interaction with social networks or other external platforms directly from the pages of our website.
The interaction and information obtained through our website are always subject to the User's privacy settings for each social network.
This type of service might still collect traffic data for the pages where the service is installed, even when Users do not use it.

FACEBOOK LIKE BUTTON AND SOCIAL WIDGETS (FACEBOOK, INC.)

The Facebook Like button and social widgets are services allowing interaction with the Facebook social network provided by Facebook, Inc.

Personal Data collected: Cookies and Usage Data.

ADDTHIS (ADDTHIS INC.)

AddThis is a service provided by Clearspring Technologies Inc., which displays a widget that allows interaction with social networks and external platforms as well as sharing the contents of this Website.
Depending on the configuration, this service can display widgets belonging to third parties such as the managers of social networks where interactions are shared. In this case, also the third parties that provide the widget will be informed of interactions and Usage Data on the pages where this service is installed.

Personal Data collected: Cookies and Usage Data.

MANAGING CONTACTS AND SENDING MESSAGES

This type of service makes it possible to manage email contacts to communicate with the User.
These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.

MAILCHIMP (THE ROCKET SCIENCE GROUP, LLC.)

MailChimp is an email address management and message sending service provided by The Rocket Science Group, LLC.

Personal Data collected: email address.

SENDGRID (SENDGRID)

Sendgrid is an email address management and message sending service provided by Sendgrid Inc.

Personal Data collected: email address.

MANAGING SUPPORT AND CONTACT REQUESTS

This service allows us to manage support and contact requests received via email or by other means, such as the contact form.
The Personal Data processed depend on the information provided by the User in the messages and the means used for communication (e.g. email address).

ZENDESK (ZENDESK)

Zendesk is a support and contact request management service provided by Zendesk Inc.

Personal Data collected: Email address, name and contact request

Deliveries

This service allows us to send orders to customers

Royal Mail

Royal Mail is a courier service provider. Delivery address information is shared with Royal Mail for orders destined within the UK. This allows them to deliver the customers order and notify them of delivery updates.

Fedex Cross Border

Fedex Cross Border is a courier service provider. Delivery address information is shared with Fedex Cross Border for orders destined outside of UK Mainland, or orders paid for in USD or CAD currency. This allows them to deliver the customers order and notify them of delivery updates.

Sharing your data with third parties for their own purposes:

We will only do this in very specific circumstances, for example:

For fraud management, we may share information about fraudulent or potentially fraudulent activity in our premises or systems. This may include sharing data about individuals with law enforcement bodies.

We may also be required to disclose your personal data to the police or other enforcement, regulatory or Government body, in your country of origin or elsewhere, upon a valid request to do so. These requests are assessed on a case-by-case basis and take the privacy of our customers into consideration.

We may, expand, reduce or sell URBAN RETREAT by Acti Labs LTD and this may involve the transfer of divisions or the whole business to new owners. If this happens, your personal data will, where relevant, be transferred to the new owner or controlling party, under the terms of this Privacy Notice.

For further information, please contact our Data Protection Officer.

Where your personal data may be processed

Sometimes we will need to share your personal data with third parties and suppliers outside the European Economic Area (EEA), such as the USA & Canada.

Orders placed from outside the EEA

If you are based outside the EEA and place an order with us, we will transfer the personal data that we collect from you to URBAN RETREAT by Acti Labs LTD in the UK.

Protecting your data outside the EEA

The EEA includes all EU Member countries as well as Iceland, Liechtenstein and Norway. We may transfer personal data that we collect from you to third-party data processors in countries that are outside the EEA.

For example, this might be required in order to fulfil your order, process your payment details or provide support services.

If we do this, we have procedures in place to ensure your data receives the same protection as if it were being processed inside the EEA. For example, our contracts with third parties stipulate the standards they must follow at all times.

Any transfer of your personal data will follow applicable laws and we will treat the information under the guiding principles of this Privacy Notice.

What are your rights over your personal data?

An overview of your different rights

You have the right to request:

Access to the personal data we hold about you, free of charge in most cases.

The correction of your personal data when incorrect, out of date or incomplete.

That we stop using your personal data for direct marketing (either through specific channels, or all channels).

That we stop any consent-based processing of your personal data after you withdraw that consent.

Review by a Partner of any decision made based solely on automatic processing of your data (i.e. where no human has yet reviewed the outcome and criteria for the decision).

You have the right to request a copy of any information about you that URBAN RETREAT by Acti Labs LTD holds at any time, and also to have that information corrected if it is inaccurate. To ask for your information, please contact 'URBAN RETREAT by Acti Labs LTD Data Protection Officer', The Stables Shipton Bridge Farm, Widdington, Saffron Walden, Essex, CB11 3SU, or email support@urban-retreat.com. Your information can be amended by using your online account.

If we choose not to action your request we will explain to you the reasons for our refusal.

Your right to withdraw consent

Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent by emailing data@urban-retreat.com

Your Right to be forgotten

You have the right to have us delete your details from all our system. If you would like us to do this please email data@urban-retreat.com

Where we rely on our legitimate interest

In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.

Direct marketing

You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We must always comply with your request.

Checking your identity

To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Notice. If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.

How can you stop the use of your personal data for direct marketing?

There are several ways you can stop direct marketing communications from us:

Click the 'unsubscribe' link in any email communication that we send you.

Contacting the Regulator

If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the Information Commissioner's Office.

You can contact them by calling 0303 123 1113.

Or go online to www.ico.org.uk/concerns (please note we can't be responsible for the content of external websites)

If you are based outside the UK, you have the right to lodge your complaint with the relevant data protection regulator in your country of residence. Details can be found under the section named : ' If you live outside the UK'

If you live outside the UK

For all non-UK customers

By using our services or providing your personal data to us, you expressly consent to the processing of your personal data by us or on our behalf. Of course, you still have the right to ask us not to process your data in certain ways, and if you do so, we will respect your wishes.

Sometimes we'll need to transfer your personal data between countries to enable us to supply the goods or services you've requested. In the ordinary course of business, we may transfer your personal data from your country of residence to ourselves and to third parties located in the UK.

By dealing with us, you are giving your consent to this overseas use, transfer and disclosure of your personal data outside your country of residence for our ordinary business purposes.

This may occur because our information technology storage facilities and servers are located outside your country of residence, and could include storage of your personal data on servers in the UK.

We'll ensure that reasonable steps are taken to prevent third parties outside your country of residence using your personal data in any way that's not set out in this Privacy Notice. We'll also make sure we adequately protect the confidentiality and privacy of your personal data.

USA

To learn more about our cookies and website 'track' and 'do not track' practices please see our Cookies Notice.

Canada

As your data may be transferred to third parties outside Canada, local police or other enforcement, regulatory or Government bodies may have access to that data, with or without our knowledge.

The personal data we process may be accessed by people within URBAN RETREAT by Acti Labs LTD, or by our third-party service providers, who require access for the purposes indicated in this Privacy Notice, or as may be permitted or required by applicable law. The personal data we collect is largely held in the UK.

If you have any questions, please contact our Data Protection Officer.

If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal information, you have the right to lodge a complaint with the Office of the Privacy Commissioner of Canada or in some Canadian provinces, your local Privacy Commissioner.

Cookies and similar technologies

We use cookies and similar technologies, such as tags and pixels ('Cookies'), to personalise and improve your customer experience as you use our Website and to provide you with relevant online advertising. This section provides more information about Cookies, including how we use them and how you can exercise your choices about our use of Cookies.

How we use Cookies

Cookies are small data files that allow a website to collect and store a range of data on your desktop computer, laptop or mobile device.

Cookies help us to provide important features and functionality on our Website, and we use them to improve your customer experience. For example, we use Cookies to do the following:

Improve the way our Website works

Cookies allow us to improve the way our Website works so that we can personalise your experience and allow you to use many of its useful features.

For example, we use Cookies so we can remember your preferences and the contents of your shopping basket when you return to our Website.

Improve the performance of our Website

Cookies can help us to understand how our Website is being used, for example, by telling us if you get an error messages as you browse. These Cookies collect data that is mostly aggregated and anonymous.

Deliver relevant online advertising

We use Cookies to help us deliver online advertising that we believe is most relevant to you on our Website.

These Cookies may collect information about your online behaviour, such as your IP address, the website you arrived from and information about your purchase history or the content of your shopping basket. This means that you may see our adverts on other organisations' websites.

Measuring the effectiveness of our marketing communications, including online advertising

Cookies can tell us if you have seen a specific advert, and how long it has been since you have seen it. This information allows us to measure the effectiveness of our online advertising campaigns and control the number of times you are shown an advert.

We also use Cookies to measure the effectiveness of our marketing communications, for example by telling us if you have opened a marketing email that we have sent you

Your choices when it comes to Cookies

You can use your browser settings to accept or reject new Cookies and to delete existing Cookies. You can also set your browser to notify you each time new Cookies are placed on your computer or other device. Below you can learn about how to control cookie settings on popular web browsers:

If you choose to disable some or all Cookies, you may not be able to make full use of our Websites. For example, you may not be able to add items to your shopping basket, proceed to checkout, or use any of our products and services that require you to sign in.

Do not track (DNT) is a feature offered by some browsers, with some newer browsers offering it as default. If you enable it, it sends a signal to websites to request that your browsing isn't tracked, for example by third party ad or social networks, or analytic companies. You can opt out of tracking and analytics on this website by changing your settings in the Managing Cookies section on this page.

At present no industry-wide uniform standard has been agreed and adopted to determine how DNT requests should be managed, so our website doesn't currently respond to DNT requests. Until that standard is established, we'll continue to review DNT and other new technologies, but won't respond to DNT requests.

Where we display personalised adverts on other organisations' websites, the AdChoices icon will usually be displayed. Clicking on this icon will provide you with specific guidance on how to control your online advertising preferences. More information is available on the YourAdChoices (http:/ youradchoices.com/) website.

Any questions?

We hope this Privacy Notice has been helpful in setting out the way we handle your personal data and your rights to control it.

If you have any questions that haven't been covered, please contact our Data Protection Officer who will be pleased to help you:

Email us at support@urban-retreat.com

Or write to us at 'URBAN RETREAT by Acti Labs LTD Data Protection Officer', The Stables Shipton Bridge Farm, Widdington, Saffron Walden, Essex, CB11 3SU