1. Privacy Policy

 

BACKGROUND:

 Aude Limited understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits this website, www.neandertal.co.uk (“Our Site”) and only collect and use your personal data as described in this Privacy Policy. Any personal data We collect will only be used as permitted by law.

Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of this Privacy Policy is requested at the point of purchase of any Neandertal products from our website.

1) Information About Us

Our Site is owned and operated by Aude Limited, a limited company registered in England under company number 10851145.

Registered address: 217 Richmond rd, 3NJ E8, London, United Kingdom
VAT number: GB 276358272
Data Protection Officer: Kentaro Yamada
Email address: [email protected]
Postal address: 217B Richmond rd, 3NJ E8, London, United Kingdom

 2) What Does This Policy Cover?

This Privacy Policy applies only to your use of Our Site. Our Site may contain links to other websites. Please note that We have no control over how your data is collected, stored, or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to them.

 3) What Is Personal Data?

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

4) What Are My Rights?

Under the Data Protection Legislation, you have the following rights, which We will always work to uphold:

The right to be informed about Our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 14.

    1. The right to access the personal data We hold about you. Part 13 will tell you how to do this.
    2. The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 14 to find out more.
    3. The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that We hold. Please contact us using the details in Part 14 to find out more.
    4. The right to restrict (i.e. prevent) the processing of your personal data.
    5. The right to object to us using your personal data for a particular purpose or purposes.
    6. The right to withdraw consent. This means that, if We are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
    7. The right to data portability. This means that, if you have provided personal data to us directly, We are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
    8. Rights relating to automated decision-making and profiling. We do not use your personal data in this way

For more information about Our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 14.

It is important that your personal data is kept accurate and up-to-date. If any of the personal data We hold about you changes, please keep us informed as long as We have that data.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about Our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. 

We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 14.

5) What Personal Data Do You Collect and How?

We will process following categories of personal data:

  • contact information such as e-mail address, telephone number and postal code
  • What products and offers you have clicked on

If you have a Neandertal account we will also process your data that you submitted when you set up your account or subscription. This data will include:

  • Your name.
  • Your address.
  • Your shopping history.
  • How you navigated and clicked while on Our site.

6) How Do You Use My Personal Data?

Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes how we may use your personal data, and our lawful bases for doing so:


What We Do What Data We Use Our Lawful Basis
Subscribing to Our Site. Your email address and your name. The processing of your personal data is based on your consent when you agree to direct marketing.
Supplying our products and services to you. Your email address, your name, your telephone number and your address. The processing of your personal data is based on your consent when you agree to direct marketing.
Communicating with you. Your email address and your name. The processing of your personal data is based on your consent when you agree to direct marketing.
Supplying you with information by email or post that you have opted-in-to (you may opt-out at any time). Your email address and your name. The processing of your personal data is based on your consent when you agree to direct marketing.


With your permission and/or where permitted by law, We may also use your personal data for marketing purposes, which may include contacting you by email with information, news, and offers on Our products or services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with Our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out. We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time

7) How Long Will You Keep My Personal Data?

We will keep your data for direct marketing until you withdraw your consent.

For email marketing we will consider you an inactive customer if you haven’t opened an email within the last two years.

After this time period your personal data will be deleted.

8) How and Where Do You Store My Data?

We will store some of your personal data in the UK. This means that it will be fully protected under the Data Protection Legislation.

We use Google Analytics Advertising Features. Read more about it and how you can opt out here: https://tools.google.com/dlpage/gaoptout/

Personal data security is essential to us, and to protect personal data, We take the following measures:

  •       limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;
  •       procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where We are legally required to do so;

 9) Do You Share My Personal Data?

We will not share any of your personal data with any third parties for any purposes, subject to the following exceptions:

If We sell, transfer, or merge parts of Our business or assets, your personal data may be transferred to a third party. Any new owner of Our business may continue to use your personal data in the same way that We have used it, as specified in this Privacy Policy (i.e. to communicate with you).

In some limited circumstances, We may be legally required to share certain personal data, which might include yours, if We are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

10) How Can I Control My Personal Data?

In addition to your rights under the Data Protection Legislation, set out in Part 5, when you submit personal data via Our Site, you may be given options to restrict Our use of your personal data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in Our emails.

You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.

 11) Can I Withhold Information?

You may access certain areas of Our Site without providing any personal data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.

 12) How Can I Access My Personal Data?

If you want to know what personal data We have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 14.

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover Our administrative costs in responding.

We will respond to your subject access request within less than one month and, in any case, not more than one month of receiving it. Normally, We aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date We receive your request. You will be kept fully informed of Our progress.

 13) How Do You Use Cookies?

Our Site may place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by us and are used only by us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve Our products and services. In addition, Our Site uses analytics services provided by Google Analytics, which also use Cookies. Website analytics refers to a set of tools used to collect and analyse usage statistics, enabling us to better understand how people use Our Site.

 14) How Do I Contact You?

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details in the email title, “(your name) Data Request”

Email address: [email protected]

Postal Address: 217B Richmond rd, 3NJ E8, London, United Kingdom.

15) Changes to this Privacy Policy

We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if We change Our business in a way that affects personal data protection.

Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date. This Privacy Policy was last updated on the 18th May 2020.