Last Updated: March 2024
Version 1.0
Creature Comforts Limited is committed to protecting and respecting your privacy.
We take your privacy seriously and are committed to protecting your personal data. This privacy notice explains how we collect, use, and store your information in accordance with the General Data Protection Regulation (GDPR).
Controller
For the purposes of the General Data Protection Regulation (EU) the data controller is Creature Comforts Limited of, Creature Comforts, 13th Floor Capital House, 25 Chapel Street London, NW1 5DH
Contact Us
Email address: privacy@creaturecomforts.co.uk
Postal address: Creature Comforts, 13th Floor Capital House, 25 Chapel Street London, NW1 5DH
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 http://www.ico.org.uk, or the equivalent regulatory authority in your country. However, we would like to deal with your concerns before you approach the ICO (or other regulator) so please contact us in the first instance.
Changes to the privacy notice and your duty to inform us of changes
Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by email.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third-party links
Our website and apps may include links to third-party websites, plug-ins and applications. Clicking on those links may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements.
Information we may collect from you
Personal data, or personal information, means any information related to an identifiable person. 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 as follows:
- Identity Data - includes first name, last name
- Contact Data - includes billing address, delivery address, email address and telephone numbers.
- Financial Data - includes bank account and payment card details.
- Transaction Data - includes details about payments to and from you and other details of products and services you have purchased from us.
- Technical Data - includes 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 and our apps.
- Profile Data - includes your purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data - includes information about how you use our website, apps, products and services.
- Marketing and Communications Data - includes your preferences in receiving marketing from us and your communication preferences.
Special Category Data
Special Category Data (SCD) is personal data that can reveal your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, or genetic data, biometric data, or data concerning your health, sex life or sexual orientation, that needs more protection because it is sensitive.
We do not usually collect or process Special Category Data (SCD). In the event that it becomes necessary to do so, we will seek the appropriate consent beforehand.
How your personal data is collected
We use different methods to collect data from and about you including through:
Information you give us
You may give us your Identity, Contact and Financial Data by filling in forms on our site or on our social media pages or profiles, or by corresponding with us by phone, email, in app or otherwise. This includes personal data you provide when you:
- Enter any of our clinics;
- Apply for our products or services;
- Create an account on our website or by downloading and using our app;
- Subscribe to our service or one of our memberships
- Request marketing to be sent to you;
- Enter a competition, promotion or survey;
- Give us some feedback; or
- When you apply for a job position.
Information we collect about you when you visit any of our clinic locations
For training, safety and monitoring purposes, please note that we may use CCTV at our Creature Comfort site locations and video and audio recording during in person and video consultations.
The use of the CCTV system and video and audio recordings is overseen by our Data Protection Officer who can be contacted at privacy@creaturecomforts.co.uk or by using the contact details in the ‘Contact Us’ section above.
We are aware that images of recognisable individuals, such as colleagues and site visitors (“data subjects”), captured by the CCTV system constitute ‘personal data’, use of which is governed by data protection law (“the law”).
We will ensure that our use of the CCTV system and the personal data that it captures complies with the law.
The cameras are in operation 24 hours a day, 7 days a week. The images captured by the CCTV System will not be stored for any longer than is required in order to achieve the purposes identified above. CCTV footage will automatically be deleted on a rolling basis, unless specific images are required to be retained in order to deal with an incident or in order to respond to a request by an individual made under the law.
Further information, please see our CCTV Privacy Notice
Information we receive from other sources
We may receive personal data about you from various third parties and public sources as set out below:
- Technical Data from the analytics providers
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services;
- Identity and Contact Data from selected business partners
Cookies and similar technologies
What are cookies
Cookies are small text files that are stored on your computer or phone when you visit some websites, which help to provide you with a more tailored experience whenever you visit the website.
How we use cookies
We use cookies on our website and our iOS and Android apps to help inform us on how to improve the experience and to make them easier for you to use.
Cookies set by us
A list of cookies used on our Website is shown below, along with a brief description explaining what we use these for.
| Cookie | Purpose |
|---|
| Strictly necessary cookies | These are cookies that are required for the essential operation of our Website such as to authenticate users and prevent fraudulent use. |
| Analytical/performance cookies | They allow us to recognise and count the number of visitors and to see how visitors move around our Website when they are using it. This helps us to improve the way our Website works, for example, by ensuring that users are finding what they are looking for easily. |
| Functionality cookies | These are used to recognise you when you return to our Website. This enables us to personalise our content for you and remember your preferences (for example, your choice of location). |
| Targeting cookies | These cookies record your visit to our Website, the pages you have visited and the links you have followed. We will use this information to make our Website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose. |
Cookies set by third party services
We also work with a selection of third parties to help us improve our website experience. They may collect the following cookies:
| Cookie | Purpose |
|---|
| Amplitude | Used to collect information about how visitors use our site. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited. |
| Google Analytics | Google Analytics uses cookies to collect data that helps us understand how people are using our site and where they came from. We use this information to identify how and where we can improve the customer experience. |
| Google Adwords & Double click | Conversion and remarketing cookies used to track, report and optimise our marketing on Google platforms. |
| Google Tag Manager | Tag Manager cookies track user behaviour on the website and enable us to manage cookies and their performance. |
| Braze | Braze uses cookies to identify anonymous users, track events and activity, understand user devices, and store opt out preferences. |
| Facebook | Facebook uses cookies to track paid advertising activity. We use the information collected by these cookies to help us determine where our ads will be most effective and to improve targeting. The information collected through these cookies is anonymous and does not identify individuals or their details. |
| Stripe | Stripe uses cookies for authentication purposes, so you don’t have to login to use their services. They also use cookies to learn things about computers and web browsers for fraud prevention purposes. |
Other than strictly necessary cookies, we will only use cookies to the extent that you give us your consent to do so. If you do not wish to receive cookies at all, most browsers will also allow you to change your cookie settings to reject all cookies. These settings will typically be found in the "options" or "preferences" menu of your browser.
Please note that if you choose to refuse cookies you may not be able to use the full functionality of our Service.
Tracking technologies in our emails
Our emails may contain tracking pixels that identify if and when you have opened an email that we have sent you, how many times you have read it and whether you have clicked on any links in that email. This helps us measure the effectiveness of our service and marketing emails.
Most popular email clients will allow you to block these pixels by disabling certain external images in emails. You can do this through the settings on your email client. Some browsers also give you the option of downloading and installing extensions that block pixels and other tracking technologies.
Internet based advertising
We participate in internet-based advertising and use third party advertising companies to serve you targeted advertisements based on your browsing history and use of the Website. We may share, or we may permit third party online advertising networks, social media companies and other third party services to collect information about your use of the Website over time so that they may display ads on the Website, on other websites, apps or services you may use (including Facebook), and on other devices you may use.
Typically, but not always, this information is collected through cookies and similar tracking technologies. These third parties may collect, or we may share, mobile identifiers, such as the ID for Advertising for iOS (IDFA), Google Advertising ID, as well as your device's IP address, information about other applications on your device, your location, information about your use of the Website, email address or hashed data and information about which advertisements you have seen or clicked on.
We and our third-party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics and market research.
Use of personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you and to provide you with the information, products and services that you request from us.
- To provide you with information about other goods or services we offer that are similar to those that you have already purchased or enquired about.
- To provide you with information about goods or services we feel may interest you. We will only contact you with information about goods and services similar to those which were the subject of a previous sale or negotiations of sale to you.
- To comply with a legal or regulatory obligation, including exchanging information with other companies and organisations for the purposes of fraud protection.
- To administer, operate and improve our site and ensure it is presented in the most effective manner; as part of our efforts to keep our site safe and secure;
- Where you opt out of receiving marketing messages, we may still process your personal data where we have a lawful basis for doing so, for example fulfilling orders you place with us, or services we provide for you and your pet.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
| Purpose / activity | Type of data | Lawful basis for processing | |
|---|
| To register you as a new customer |
(a) Identity
(b) Contact
| Performance of a contract with you | |
|
To process and deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
|
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications
|
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
| |
|
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey
|
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications
|
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
| |
| To enable you to partake in a prize draw, competition or complete a survey |
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
|
(a) 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) Identity
(b) Contact
(c) Technical
|
(a) 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)
(b) Necessary to comply with a legal obligation, such as the payment of corporation tax, or if compelled by order of a Court, or as part of legal proceedings. | |
| To deliver relevant website and app content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you |
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical
| Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) | |
| To use data analytics to improve our website, products/services, marketing, customer relationships and experiences |
(a) Technical
(b) 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) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
| Necessary for our legitimate interests (to develop our products/services and grow our business) | |
| To assess whether you are suitable for a job at the company |
(a) Identity
(b) Contact
(c) Profile
|
(a) Necessary for our legitimate interest
(b) Performance of a contract with you
| |
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in the table above.
- Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- Other carefully selected third parties who provide services to Creature Comforts Limited including (but not limited to): website applications, order processing, customer services, file storage, courier and other shipping partners, event management, payment processing, communication applications, marketing communications campaign management, analytic tools, mapping tools and social media.
- HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
- In the event that we sell or buy (or plan to sell or buy) any business or assets or seek investment from a third party investor, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets, or investor, as the case may be. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Data security
We have put in place appropriate security measures to help prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Data retention
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see Request erasure below for further information.
In some circumstances we may anonymise your personal data so that it can no longer be associated with you and therefore no longer qualifies as personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data:
- 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 the 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 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, such as where we are obliged by law, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. An example of this may be where we have obligations to process your Financial data for the purposes of complying with our tax obligations. Your marketing preferences can be amended by you at any time via your account settings, or when you receive further email communication from us.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- 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.
- The right to be informed. You have the right to be told what personal data is collected about you, why, who is collecting the data, how long it will be held, how you can file a complaint and with whom your data will be shared.
- Rights in relation to automated decision making and profiling. You have particular rights in relation to automated decision making and profiling to reduce the risk that a potentially damaging decision is taken without human intervention. You can object to your personal data being used for profiling, direct marketing or research purposes.
For further information on your individual rights, please visit: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you. We may need to request specific information from you to help us confirm your identity and ensure your 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.
Time limit to respond. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
International data transfer
We do not routinely transfer personal data outside of the EU or EEA. Occasionally, data we collect may be transferred to, and stored at, a country outside of the European Economic Area (EEA). This means it might also be processed by staff operating outside of the EEA who work for one of our suppliers.
Where information is provided to a Third Party, either in or outside the EEA, we will ensure that it and any of its agents and/or suppliers take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Notice.
