Cheeky Wipes Privacy Policy

Cheeky Wipes is a trading name of Cheeky Baby Products Limited (hereinafter “the company” “we”), an online retailer registered in England and Wales, Company Registration 07547735 located at 98 Sutton Road, Seaford, East Sussex, BN25 4QJ.

Cheeky Baby Products Limited is registered as a 'Data Controller' with the Information Commissioner's Office (ICO) under the UK General Data Protection Regulation, as we collect and process personal information about you. This privacy policy/statement/notice with the UK General Data Protection Regulation (UK GDPR) and Data Protection Act 2018.

This privacy notice will inform you about:

• what personal information we collect, how we collect it, use it, store it, share it, and dispose of it.
• how we process any personal information including special category data you have voluntarily provided to us relating directly to you or any other third-party individual’s information you may have provided via our websites relating to reusable sanitary wear, baby products & intimate health.

We collect personal data for the following purposes:

• deliver our products or services.
• confirm your identity to provide some services.
• contact you by post, email or telephone.
• understand your needs to provide the services/products that you request.
• understand what we can do for you and inform you of other relevant services and benefits.
• obtain your opinion about our services.
• update your customer record.
• help us to build up a picture of how we are performing at delivering services to you and what our other customers need.
• prevent and detect fraud and corruption in our company.
• allow us to undertake statutory functions efficiently and effectively.
• make sure we meet our statutory obligations including those related to diversity and equalities.

Providing you with a product or service may be impossible unless we have enough information.

Your information will be processed for the following purposes:

• for the service or products, you requested, and to monitor and improve our performance in responding to your request.

• to allow us to be able to communicate and provide services and products appropriate to your needs.
• to ensure that we meet our legal obligations.
• where necessary for the law enforcement functions.
• to prevent and detect fraud or crime.
• to process financial transactions including grants, payments and benefits involving the company.
• where necessary to protect individuals from harm or injury.
• to allow the statistical analysis of data so we can plan the provision of services.

We will not pass any personal data on to third parties, other than those who either process information on our behalf, or because of a legal requirement, and will only do so, after we have ensured that adequate organisational and technical measures are in place to protect the data.

We will not disclose any information that you provide to us, to anyone else without your permission, except in situations where disclosure is required by law, or where we have good reason to believe that failing to share the information would put a person at risk.

We will only keep personal data in identifiable form as long as is necessary for the purposes for which it is collected, or where we have a legal obligation to do so. Once we no longer need personal data it shall be deleted or rendered permanently anonymous.

We may process your information overseas using web services that are hosted outside the European Economic Area, but only with data processing agreements that meet our obligations under the UK General Data Protection Regulation.

Legal basis for processing your personal information

There are a number of legal reasons why we need to collect and use your personal information.

Generally, we collect and use personal information where:

• you, or your legal representative, have given consent.

• you have entered into a contract with us.
• it is necessary to perform our statutory duties.
• it is necessary to protect someone in an emergency.
• it is required by law.
• it is necessary for employment purposes.
• it is necessary to deliver health or social care services.
• you have made your information publicly available.
• it is necessary for legal cases.
• it is to the benefit of society as a whole.
• it is necessary to protect public health.
• it is necessary for archiving, research, or statistical purposes.

If we process your information entirely from your ‘Consent’ (i.e. non-statutory service), you have the right to withdraw it at any time. If you want to withdraw your consent, please contact customers@cheekywipes.com and tell us which service or products you are using so we can deal with your request.

Information sharing

We may, occasionally, need to share your information with third parties that provide services. These providers are obliged to keep your details securely and use them only to fulfil a justified need.

We may disclose information to other partners where it is necessary, either to comply with a legal obligation, or where permitted under the UK  General Data Protection Regulation e.g. where the disclosure is necessary for the purposes of the prevention and/or detection of crime or fraud.

Where we need to disclose Special Category or confidential information such as medical details to other partners, we will do so only with your prior explicit consent or where we are legally required to.

We may disclose information when necessary to prevent risk of harm to an individual.

We have Information Sharing Agreements in place with other partners and external organisations to help deliver the best services for you. We do this to comply with UK Data Protection law and so you can be confident that they all comply with the same privacy principles as the local authority.

At no time will your information be passed to external organisations for marketing or sales purposes or for any commercial use without your express consent.

Detection and prevention of crime and fraud

We may use any of the information you provide to us for the prevention and detection of crime and fraud. We may also share this information with other bodies that are responsible for auditing and investigating our financial work and book.

The personal information we have collected from you will also be shared with fraud prevention agencies who will use it to prevent fraud and money-laundering and to verify your identity. If fraud is detected, you could be refused certain services, finance, or employment. Further details of how your information will be used by us and these fraud prevention agencies, and your data protection rights, can be found online.

In limited situations we may monitor and record electronic transactions (website, email and telephone conversations). This will only be used to prevent or detect a crime, or investigate or detect the unauthorised use of the telecommunications system and only as permitted by the Telecommunications (Lawful Business Practice) (Interception of Communications) Regulations 2000.

Telephone calls

Ordinarily we will inform you if we record or monitor any telephone calls you make to us. This will be used to increase your security, for our record keeping of the transaction and for our staff training purposes.

Emails

If you email us, we may keep a record of your email address, as well as your email for our records. For security reasons, we will not include any confidential information about you in any email we send to you. We would also suggest that you keep the amount of confidential information you send to us via email to a minimum and use our secure online services or by post.

Website

If you are a user with general public access, our website does not store or capture personal information but merely logs a number called your IP address which is automatically recognised by the system.

The system will record personal information if you:

• subscribe to or apply for services that require personal information.
• order our products.
• report a fault and give your contact details for us to respond.
• contact us and leave your details for us to respond.

We employ cookie technology to help log visitors to our website.

Children’s data

We are committed to protecting the privacy of children. Our services are not intended for children under the age of 16, and we do not knowingly collect personal data from them. If we discover that a child under 16 has provided us with personal information, we will take steps to delete such information from our systems. Parents or guardians who believe that their child has provided us with personal information should contact us immediately. 

Cookies

We sometimes place small data files on your computer. These are known as cookies and most websites do this. A cookie is a string of information that is sent by a website and stored on your hard drive or temporarily in your computer's memory. The information collected is used for the administration of the server and to improve the service provided by the web site. Cookies provide an audit trail of your browsing history, you can reject the use of cookies, but you may be asked for information again, e.g. to participate in a survey.

They improve browsing by:

• remembering who you are after you log in to the site.
• prefill some of the online forms with information you already gave to us, so you don’t need to keep entering it.
• measuring how you use the website to make your browsing experience more efficient and user-friendly.

Apart from the ones related to the login process our cookies aren’t used to identify you personally. They exist to make the site work better for you. You can manage and/or delete these small files as you wish.

The two cookies that are used within our software are as follows:

To learn more about cookies and how to manage them visit AboutCookies.org.

CCTV

We have installed CCTV systems at our premises used for the purposes of public and staff safety, and crime prevention and detection. In all locations, signs are displayed notifying you that CCTV is in operation and providing details of who to contact for further information about the scheme.

We will only disclose CCTV images to others who intend to use the images for the purposes stated above. CCTV images will not be released to the media for entertainment purposes or placed on the Internet.

Images captured by CCTV will not be kept for longer than necessary. However, on occasions, there may be a need to keep images for longer, for example when a crime is being investigated. You may make a request for CCTV images you appear in.

For more information about CCTV images please contact our Data Protection Officer at customers@cheekywipes.com

How we protect your information

The information you provide will be protected by adequate organisational and technical measures, to ensure it can't be seen by, accessed or disclosed to anyone who shouldn't.

We will not keep your information longer than it is needed or where the law states how long this should be kept. We will dispose of paper records or delete any electronic personal information in a secure way.

Cheeky Baby Products Limited ensures that international data transfers comply with the GDPR and the UK Data Protection Act 2018. When transferring personal data outside the European Economic Area, we implement standard contractual clauses and other legal mechanisms to safeguard the data. We conduct regular assessments to ensure that these international partners provide an adequate level of data protection, consistent with UK and EU standards.

In the event of a data breach, we are committed to complying with the GDPR and UK Data Protection Act 2018 breach notification requirements. Should any breach occur that is likely to result in a risk to the rights and freedoms of individuals, we will notify the relevant supervisory authority within 72 hours of becoming aware of the breach. Affected individuals will also be informed without undue delay if the breach poses a high risk to their rights and freedoms.

Your rights

The UK General Data Protection Regulation requires Phat Pasty to ensure that any information we hold about you is correct. There may be situations where you find the information we hold is no longer accurate and you have the right to have this corrected.

You have the right to request that Cheeky Baby Products Ltd stop processing your personal data in relation to any of our services, however, this may affect service delivery to you. This right applies primarily to ‘Consent’ based services and not ‘Statutory’ service offerings.

Where possible we will seek to comply with your request but we may be required to hold or process information to comply with a legal requirement.

You also have the right to:

• correct the data we hold about you.
• get a copy of the data we hold, as well as the right to be forgotten (have your personal data deleted from our archives).
• have your personal information transferred to another information controller in a commonly used format (data portability).
• question decisions made about you by a computer, unless it's required for any contract you have entered into, required by law, or you have consented to it
• object if you are being profiled.

How we use your information

We will use your information for a number of purposes including the following:

• to send details and updates for the event you have entered
• to meet product orders, requests for services or information and to process *payments and any other requests you make of us;
• to send you carefully selected special offers and promotions from the service you are using by email. You can opt-out of these marketing messages at any time by sending an email to customers@cheekywipes.com, with the word ‘unsubscribe’ in the subject and including your full name. Please note that it may take up to two weeks to implement this change in your preferences. You will always be given a straightforward way to opt out of our marketing messages each time you receive a communication from us
• If you sign up to our SMS Marketing service via checkout or sign-up form, we will value your privacy and the information you consent to share. We may use this information to send you text notifications (for your order, including abandoned checkout reminders), text marketing offers, or transactional texts

Our website uses cookies to keep track of items you put into your shopping cart, including when you have abandoned your checkout. This information is used to determine when to send cart reminder messages via SMS.

• we may use your IP address to identify your location, the number of visits from different countries and also to block disruptive use;
• if we need to contact you for reasons related to the service you have signed up for e.g. to provide you with password reminders or to notify you that a particular service has been suspended for maintenance;
• to tell you about changes to our service;
• to personalise or improve the way our content and advertising is presented to you online:
• to analyse and improve the services we offer e.g. to provide you with the most user-friendly navigation experience or the most relevant information;
• to manage our competitions and contact the winners;
• to keep our records up to date;
• to invite you to participate in surveys about our services (participation is always voluntary);
• to enable other people or businesses to carry out work on our behalf;
• to show you relevant advertising on third party sites (e.g. Facebook, Instagram and Twitter). This may involve showing you carefully selected special offers and promotions;

*Payments

We provide paid products and/or services within the Service. In that case, we may use third-party services for payment processing (e.g. payment processors).

We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

The payment processors we work with are:

Stripe

Their Privacy Policy can be viewed at: Stripe Privacy & Data Retention Policy

PayPal

Their Privacy Policy can be viewed at https://www.paypal.com/uk/webapps/mpp/ua/privacy-prev

Klarna

“In order to offer you Klarna’s payment methods, we might in the checkout pass your personal data in the form of contact and order details to Klarna, in order for Klarna to assess whether you qualify for their payment methods and to tailor those payment methods for you.

Sharing your information with others

Generally, we will only use your information within Cheeky Baby Products in order to provide the product you have requested.

We will only disclose your information to third parties where we need to do so in order to provide a service you have requested or improve the service that you receive. We will also disclose your information to third parties when the disclosure is required or permitted by law (for example to government bodies and law enforcement agencies). Please note that if you post or send offensive, inappropriate or objectionable content anywhere on our services, or otherwise engage in any disruptive behaviour, we may use your information to stop such behaviour. In this instance we may use your information to inform relevant third parties such as your employer, school e-mail/internet provider or law enforcement agencies about the content and your behaviour.

We require all third parties with whom we share your information to treat it with the same protection we do. Unless you consent we also require that they do not use your information for their own business purposes.

Text messaging originator opt-in data and consent will not be shared with any third parties.

These third parties have access to your information only to perform requested tasks on our behalf and are obligated not to disclose or use it for any other purpose;

Webmaster http://www.bluepark.co.uk/privacy/

Mention Me

https://www.mention-me.com/
Email: gdpr@mention-me.com

Operation of refer-a-friend programme 

Processing customer email addresses and certain order data for the purposes of: 

• Enrolling customers onto our refer-afriend programme; 
• Monitoring the programme and safeguarding against gaming or fraudulent use of the programme; 
• Communicating with customers in connection with operation of the programme and delivery of rewards; 
• Reporting to [Controller] on the performance of the programme

Klaviyo

https://klaviyo.com/

Operation of Email and SMS Marketing services 

Processing newsletter & SMS sign-up consent, customer email addresses and certain order data for the purposes of: 

• Enrolling customers onto our Email & SMS Marketing service
• Communicating with customers in connection with operation of the service, including browse abandon and cart abandon programmes
• Reporting to Cheeky Baby Products Ltd on the performance of the programme

Procedures for securing compliance

Accountability principle

The controller Cheeky Baby Products Limited shall be responsible for, and be able to demonstrate compliance with the rules and principles this policy sets. Our Data Protection Officer is responsible for monitoring our compliance with this policy.

We will:

• ensure that records are kept of all personal data processing activities and that these are provided to the Information Commissioner on request.
• carry out a Data Protection Impact Assessment for any high-risk personal data processing, and consult the Information Commissioner if appropriate.
• ensure that a Data Protection Officer is appointed to provide independent advice and monitoring of the department’s personal data handling and that this person has access to report to the highest management level of the department.
• have in place internal processes to ensure that personal data is only collected, used or handled in a way that is compliant with data protection law.

Data controller’s policies as regards retention and erasure of personal data.

We will ensure, where special category or criminal convictions personal data is processed, that:

• there is a record of that processing, and that record will set out, where possible, the envisaged time limits for erasure of the different categories of data.
• where we no longer require special category or criminal convictions personal data for the purpose for which it was collected, we will delete it or render it permanently anonymous.
• data subjects receive full privacy information about how their data will be handled, and this will include the period for which the personal data will be stored, or if that is not possible, the criteria used to determine that period.

This policy will be retained for the duration of our processing and for a minimum of 6 months after processing ceases.

Additional special category processing

We process special category personal data in other instances where it is not a requirement to keep an appropriate policy document. Our processing of such data respects the rights and interests of the data subjects. We provide clear and transparent information about why we process personal data including our lawful basis for processing in our privacy notice.

If you have any questions or concerns don’t hesitate to contact our Compliance Officer at customers@cheekywipes.com 

This privacy policy may be updated from time to time so you should check it each time you submit information to any of our services. The date of the most recent revisions will appear at the bottom of this page.

If you have any questions or comments about this privacy policy please contact:

Cheeky Wipes, 98 Sutton Road, Seaford, East Sussex, BN25 4QJ
Tel: +447308130406
Email: customers@cheekywipes.com

Last updated: Nov 2024