Last updated: 22nd November 2021

Bower Collective Ltd | Company Number 11710324
The Court, Alhampton, Shepton Mallet, BA4 6PZ, United Kingdom

Website Privacy & Cookie Policy

Introduction

Important information and who we are

Welcome to Bower Collective Ltd’s Privacy, Cookie and Data Protection Policy (“Privacy & Cookie Policy”). At Bower Collective Ltd (“we”, “us”, or “our”) we are committed to protecting and respecting your privacy and Personal Data in compliance with the United Kingdom General Data Protection Regulation (“GDPR”), the Data Protection Act 2018 and all other mandatory laws and regulations of the United Kingdom.
This Privacy & Cookie Policy explains how we collect, process and keep your data safe. The Privacy & Cookie Policy will tell you how you can exercise your privacy rights.
The individuals from which we may gather and use data can include: Customers

This Privacy & Cookie Policy applies to all our employees and staff members and all Personal Data processed at any time by us.

Who is Your Data Controller

Bower Collective Ltd is your Data Controller and responsible for your Personal Data. We are not obliged by the GDPR to appoint a data protection officer and have not voluntarily appointed one at this time. Therefore, any inquiries about your data should either be sent to us on email at hello@bowercollective.com or sent in a letter to The Court, Alhampton, Shepton Mallet, BA4 6PZ, United Kingdom.
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.

Legal Basis for Data Collection

Types of Data

“Personal Data” 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 below. Not all of the following types of data will necessarily be collected from you but this is the full scope of data that we collect and when we collect it from you:

• Identity Data: This is data relating to your first name, last name, gender, date of birth.
• Profile Data: details of your shopping preferences and personal details (such as purchase history and household details that you have provided) which help us to recommend items of interest to you, and suggest product subscription frequencies or to send you or make available personalised offers.
• Contact Data: This is data relating to your phone number, addresses, email addresses, phone numbers.
• Marketing and Communications Data: This is your preferences in receiving marketing information and other information from us.
• Billing Data: This is information relating to your debit and credit card information such as the name attached to your payment details and your billing address.
• Transactional Data: Details of your interactions with us, including interactions through our website, by text message (SMS), email and through social media. For example, each order you have made, or when we text you to advise of an upcoming delivery, or keep notes if you have had a problem or incident, or if you have participated in research.
• Technical Data: This is your IP address, browser type and version, time zone setting and location, operating system and platform, and other technology on the devices you use to engage with us. We collect Technical data by using cookies and other similar technologies. Please refer to the cookies section below for further information regarding the cookies used on our website.
• Customer Support Data: This includes feedback and survey responses.
• Usage Data: information about how you use our website, products and services.

 

We also collect, use and share Aggregated Data such as the frequency at which people buy and use our products and the size of customer households. This information is used to make personalised recommendations on which products to buy and which frequencies to buy them at.

Aggregated Data could be derived from your Personal Data but is not considered Personal Data in law as this data will 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 & Cookie Policy.

We may also aggregate data to enable research or analysis so that we can better understand and serve you and others. For example, we may conduct research on your demographics and usage. Although this aggregated data may be based in part on Personal Data, it does not identify you personally. We may share this type of anonymous data with others, including service providers, our affiliates, agents and current and prospective business partners.

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.

Legal Basis for Collecting That Data

There are a number of justifiable reasons under the GDPR that allow collection and processing of Personal Data. The main avenues we rely on are:

• “Consent”: Certain situations allow us to collect your Personal Data, such as when you tick a box that confirms you are happy to receive email newsletters from us, or ‘opt in’ to a service.
• “Contractual Obligations”: We may require certain information from you in order to fulfil our contractual obligations and provide you with the promised service.
• “Legal Compliance”: We’re required by law to collect and process certain types of data, such as fraudulent activity or other illegal actions.
• “Legitimate Interest”: We might need to collect certain information from you to be able to meet our legitimate interests - this covers aspects that can be reasonably expected as part of running our business, that will not have a material impact on your rights, freedom or interests.

How We Use Your Personal Data

We will only use your Personal Data when the law allows us to. Set out below is a table containing the different types of Personal Data we collect and the lawful basis for processing that data. Please refer to the previous section for more information on the lawful basis listed in the table below.
Examples provided in the table below are indicative in nature and the purposes for which we use your data may be broader than described but we will never process your data without a legal basis for doing so and it is for a related purpose. For further inquiries please contact us.

Activity	Type of data	Legal Justification	Lawful basis for processing data
When you place an order with us	Identity data Contact data Billing data Transactional data Technical data Usage data Marketing and communications data	Consent Contractual obligation Legal compliance Legitimate interest	To process and send your order; To perform our legal duties; To ensure a great customer experience and be able to identify and solve technical or user experience problems; To provide marketing communications (consent)
When you create an account with us (including a regular occurring subscription)	Identity data Profile data Contact data Technical data Usage data	Consent Contractual obligation Legal compliance Legitimate interest	To provide you with a user account; To ensure the account performs well
When you sign up to receive marketing communications	Identity data Profile data Contact data Marketing and communications data	Consent Legitimate interest	To provide you with news about our business; To provide tailored offers and discounts; To advise you of partnership offers or competitions; To let you know about research studies you can take part in
When you contact us with an enquiry	Identity data Contact data Transactional data	Consent  Legitimate interest	To provide support on your query; To keep a record in case the issue or query arises again; So that we can contact you with regards to a resolution or update
When you participate in a competition or research	Identity data Profile data Contact data Marketing and communications data	Consent Contractual obligation	To let you know about the results of a competition or deliver a prize to you; To perform the research (via email survey or video call or other means); To provide compensation for research participation
If we have a legal obligation to contact you	Identity data Profile data Contact data Billing data Transactional data	Legal compliance Contractual obligation Legitimate interest	To let you know about changes to our terms of service or other policies; To let you know about product issues or website issues; To advise of any issues with your account billing and regular order (like out of stock items)
To administer and protect our business and our website from fraud and other illegal activities	Identity data Contact data Transactional data Technical data	Legal compliance Legitimate interest	To identify and prevent fraudulent activity; To adhere to our terms of sale
To use data analytics to improve our website, customer relationships and experiences.	Technical data Usage data	Legitimate interest	To understand how people use our website so that it can be improved; To understand the performance of products and make plans on the range we provide; To develop and grow our business
To make suggestions and recommendations to you about products and services that may be of interest to you.	Identity data Profile data Contact data Transactional data Technical data Usage data	Legitimate interest	To ensure you are aware of our full range of products; To grow and develop our business
To optimise our marketing on social platforms	Contact data	Legitimate interest	To exclude you from marketing campaigns that aren’t relevant; To identify people who are similar to you in social profile and may be interested in our products; To serve social media ads and offers that are relevant to you

 

Marketing and Content Updates

You will receive marketing and new content communications from us if you have created an account and chosen to opt into receiving those communications. From time to time we may make suggestions and recommendations to you about goods or services that may be of interest to you.

Changes 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.

Your Rights And How You Are Protected By Us

What Control Do I Have Over Bower Collective Ltd's Use Of My Personal Data?

You may delete your account at any time – this will remove your account page from our systems and our related software.
We do not guarantee the ability to delete all stored data (for example, we are legally obliged to store your purchase data for a period of time for the purposes of auditing and fraud prevention). If you would like us to delete/correct personally identifiable data, let us know and we will action your request as soon as practicable.
You can access information associated with your account by logging into your account you created with us.
Your account information will be protected by a password for your privacy and security. You need to prevent unauthorized access to your account and personal information by selecting and protecting your password appropriately and limiting access to your computer or device and by signing off after you have finished accessing your account.

How Does Bower Collective Ltd Protect Customer's Personal Data?

We are concerned with keeping your data secure and protecting it from inappropriate disclosure. Any Personal Data collected by us is only accessible by a limited number of employees who have special access rights to such systems and are bound by obligations of confidentiality. If and when we use subcontractors to store your data, we will not relinquish control of your Personal Data or expose it to security risks that would not have arisen had the data remained in our possession. However, unfortunately no transmission of data over the internet is guaranteed to be completely secure. It may be possible for third parties not under the control of Bower Collective Ltd to intercept or access transmissions or private communications unlawfully. While we strive to protect your Personal Data, we cannot ensure or warrant the security of any Personal Data you transmit to us. Any such transmission is done at your own risk. If you believe that your interaction with us is no longer secure, please contact us.

Opting Out Of Marketing Communications

You can ask us to stop sending you marketing messages at any time by clicking unsubscribe in emails or by contacting hello@bowercollective.com.
Where you opt out of receiving these marketing messages, we will continue to retain other Personal Data provided to us as a result of interactions with us not related to your marketing preferences.

How To Request Your Data and The Process For Obtaining it

You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, if your request is clearly unfounded, we could refuse to comply with your request.
We may need to request specific information from you to help us confirm your identity and ensure you have the 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.

Your Data and Third Parties

Third Parties

We may share personal data about you:

1. with third parties who are directly involved in dealing with any request or enquiry made by you;
2. where such disclosure is required by law;
3. with third parties who are providing us with professional advice;
4. where the disclosure is in connection with any criminal investigation, legal proceedings or prospective legal proceedings where permitted by law;
5. where the disclosure is in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk);
6. where we are required to enforce our Terms and Conditions of Sale or our Terms of Use; or
7. where we have stated or informed you otherwise (e.g. in this policy or on our website)
8. for postal marketing where you have consented for us to do so.

We work with Epsilon Abacus (registered as Epsilon International UK Ltd), a company that manages the Abacus Alliance on behalf of UK retailers and charities. The participating retailers are active in the clothing, collectables, food & wine, gardening, gadgets & entertainment, health & beauty, household goods, home interiors and travel categories. These retailers and charities share information about their customers and supporters and what they buy or donate. Epsilon Abacus processes this information as a processor on behalf of these companies to help them understand individuals’ behaviour and preferences. Epsilon combines information provided by participating retailers and charities with third party data. From this combined information, these companies (including ourselves) can tailor their communications, sending individuals suitable offers and appeals that should be of interest to them. You can learn more about how Epsilon Abacus processes your personal information in their Privacy Policy, which is available here: https://www.epsilon.com/abacus/services-privacy-policy.

We may also disclose your personal data to third parties in the event that we sell or buy any business or assets (in which case we may disclose your personal data to the prospective seller or buyer of such business or assets) or if we or substantially all of our assets are acquired by a third party, in which case personal data held by us about our clients and subscribers will be one of the transferred assets.

How Long Will We Retain Your Data For?

We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for. We may retain your Personal Data for a longer period than usual in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

Age Limit For Our Users

You must not use Bower Collective Ltd unless you are aged 16 or older. If you are under 16 and you access Bower Collective Ltd by lying about your age, you must immediately stop using Bower Collective Ltd.
This website is not intended for children and we do not knowingly collect data relating to children. 

International Transfer Of Data

Your information may be stored and processed in the US or other countries or jurisdictions outside the US where Bower Collective Ltd has facilities. We are currently storing data in the EU and so, by using Bower Collective Ltd, you are permitting and consenting to the transfer of information, including Personal Data, outside of the US.

Cookies

Our website uses "cookies" to ensure you receive the best possible visitor experience. Cookies are small files which are sent by a web server to an individual's computer which are then stored on that computer's hard drive. A cookie contains text, and is like an identification card which can only be translated by the server it originated from.

Cookies cannot tell us personal information and are instead used for things like remembering which items you placed in your basket or how many times you have viewed our newsletter signup form. For further information about cookies and how they are used, please visit www.aboutcookies.org.

Our website uses the following cookies for the following purposes:

Cookie Name	Cookie Description
Universal Analytics (Google)	These cookies are used to collect information about how visitors use our website. We use the information to compile reports and to help us improve the website. The cookies collect information in an anonymous form, including the number of visitors to the website, where visitors have come to the website from and the pages they visited.
AdWords & AdSense (Google)	AdWords remarketing is a remarketing and behavioural targeting service provided by Google that connects a user's activity with the AdWords advertising network and the DoubleClick cookie. AdSense cookies are used by Google to check advertising efficiency across their services.
Facebook Ads remarketing and conversion tracking	Facebook Ads conversion tracking is an analytics service provided by Facebook that connects data from the Facebook advertising network with actions performed on this application. Facebook remarketing is a remarketing and behavioural targeting service provided by Facebook, Inc. that connects the user’s activity with the Facebook advertising network. The Facebook Like button and social widgets are services allowing interaction with the Facebook social network provided by Facebook, Inc.
TikTok Ads remarketing and conversion tracking	TikTok Ads conversion tracking is an analytics service provided by TikTok that connects data from the TikTok advertising network with actions performed on this application. TikTok remarketing is a remarketing and behavioural targeting service provided by TikTok, Inc. that connects the user’s activity with the TikTok advertising network.
FullStory	FullStory is an analytical tool that aggregates data on how our visitors use our website; it does not collect personal or sensitive data. Data includes which pages are visited, how people interact with the pages and technical data such as browser and device.
Mixpanel	Mixpanel is an analytical tool that aggregates data on how our visitors use our website; it does not collect personal or sensitive data. Data includes which pages are visited, how people interact with the pages and technical data such as browser and device.
Yotpo	Yotpo is a reviews platform used by online businesses. When you order from Bower Collective we may pass your details to Yotpo so you are able to write an impartial review of our products.
Trustpilot	Trustpilot is a reviews platform used by online businesses. When you order from Bower Collective we may pass your details to Trustpilot so you are able to write an impartial review of our company.
SmartWishlist	SmartWishlist is an application that uses a cookie to remember the items that you have added to your wishlist.
Mention Me	Cookies hosted by Mention Me Limited (mention-me.com) on our site collect information from users to operate our refer-a-friend program and related services. Mention Me Limited act as a service provider to Bower Collective and data processor. You can read Mention Me's privacy policy with full details on their cookie policy here
Rise.ai	Rise is an application which provides our store credit and gift card features. It uses a cookie to remember your personal voucher code and apply it on the basket and checkout pages.
Sleeknote	Sleeknote is an application which displays our newsletter sign up form and other relevant surveys and forms. It uses cookies to decide whether to show the forms to you.
Shopify	Shopify is the eCommerce application that our shop runs on. It uses cookies to help us understand how many people are visiting our site, what activities they perform so that we can analyse the overall performance of our business.
Searchanize	Searchanize is an application which powers the search feature on our website. It uses cookies to provide personalised search results based on your browsing history.
Bing	Bing is a search application used by Microsoft devices and we advertise on their platform. Cookies are used to check advertising efficiency across their services.
Klaviyo	Klaviyo is an application which we use to manage the sending of emails to our customers. It uses cookies to understand how our customers are engaging with the website and how our emails are performing.

 

Most internet browsers allow you to prevent cookies being stored on your computer. Alternatively you may be able to configure your browser to accept all cookies or to notify you when a cookie is offered by our server. You may also be able to delete all cookies currently stored on your web browser. Therefore unless you change your browser settings you will automatically accept cookies from our website. We may also collect information about where you are on the Internet (e.g. the URL you came from, IP address, and domain types like .co.uk and .com), your browser type, the country where your computer is located, the pages of our website that were viewed during your visit and any search terms that you entered on our website. We will use this information to administer our website, for internal operations (including troubleshooting, data analysis, testing, research, statistical and survey purposes) and as part of our efforts to keep our website safe and secure.

Notification Of Changes and Acceptance Of Policy

We keep our Privacy & Cookie Policy under review and will place any updates on this webpage. This version is dated 22 November 2021. By using Bower Collective Ltd, you consent to the collection and use of data by us as set out in this Privacy & Cookie Policy. Continued access or use of Bower Collective Ltd will constitute your express acceptance of any modifications to this Privacy & Cookie Policy.

Interpretation

All uses of the word "including" mean "including but not limited to" and the enumerated examples are not intended to in any way limit the term which they serve to illustrate. Any email addresses set out in this policy may be used solely for the purpose for which they are stated to be provided, and any unrelated correspondence will be ignored. Unless otherwise required by law, we reserve the right to not respond to emails, even if they relate to a legitimate subject matter for which we have provided an email address. As a matter of common sense, you are more likely to get a reply if your request or question is polite, reasonable and there is no relatively obvious other way to deal with or answer your concern or question (e.g. FAQs, other areas of our website etc.).

Our staff are not authorised to contract on behalf of Bower Collective Ltd, waive rights or make representations (whether contractual or otherwise). If anything contained in an email from a Bower Collective Ltd address contradicts anything in this policy, our terms or any official public announcement on our website, or is inconsistent with or amounts to a waiver of any Bower Collective Ltd rights, the email content will be read down to grant precedence to the latter. The only exception to this is genuine correspondence expressed to be from the Bower Collective Ltd legal department.