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Website privacy policy_Last Updated: June 26, 2018_
INTRODUCTION
Welcome to Debut Groups’ (“Debut”) privacy notice. This Privacy Policy applies to
our websites (www.debutgroup.com. www.benmoorsom.com,
www.neuroscaping.com) and our email newsletter subscription owned by
Debut. This Privacy Policy governs our data collection, processing and usage
practices. It also describes your choices regarding use, access and correction of
your personal information. If you do not agree with the data practices described
in this Privacy Policy, you should not use the websites or the newsletter
subscription service.
Debut respects your privacy and is committed to protecting your personal data.
This privacy notice will inform you as to how we look after your personal data when
you visit our website (regardless of where you visit it from) and will tell you about
your privacy rights and how the law protects you.
This privacy notice is provided in a layered format so you can click through to the
specific areas set out below. Alternatively, you can download a pdf version of the
policy here www.debutgroup.com/privacypolicy . Please also use the Glossary to
understand the meaning of some of the terms used in this privacy notice.
TABLE OF CONTENTS
Page
-i-1. IMPORTANT INFORMATION AND WHO WE ARE2. THE DATA WE COLLECT ABOUT YOU3. HOW IS YOUR PERSONAL DATA COLLECTED?
4. HOW WE USE YOUR PERSONAL DATA
5. DISCLOSURES OF YOUR PERSONAL DATA
6. INTERNATIONAL TRANSFERS
7. DATA SECURITY
8. DATA RETENTION
9. YOUR LEGAL RIGHTS
10. GLOSSARY1. IMPORTANT INFORMATION AND WHO WE ARE
PURPOSE OF THIS PRIVACY NOTICEThis privacy notice aims to give you information on how Debut collects and
processes your personal data through your use of this website, including any data
you may provide through this website when you sign up for our newsletter and/or
engage with Debut for the provision of services.
This website is not intended for children and we do not knowingly collect data
relating to children.
It is important that you read this privacy notice together with any other privacy
notice or fair processing notice we may provide on specific occasions when we
are collecting or processing personal data about you so that you are fully aware of
how and why we are using your data. This privacy notice supplements the other
notices and is not intended to override them.
CONTROLLER
Debut is made up of different legal entities, details of which can be found by
emailing info@debutgroup.com. This privacy notice is issued on behalf of the Debut
group of companies so when we mention “Debut”, “we”, “us” or “our” in this privacy
notice, we are referring to the relevant company in the Debut group of companies
responsible for processing your data. We will let you know which entity will be the
controller for your data when you purchase a service with us. Debut
Communications, Inc. is the controller and responsible for this website.
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.
CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF
CHANGES
This privacy policy was created on May 25, 2018. We periodically update this
Privacy Policy. We will post any privacy policy changes on this page and, if the
changes are significant, we will provide a more prominent notice by sending you
an email notification.
While we will notify you of any material changes to this Privacy Policy, we
encourage you to review this Privacy Policy periodically. We will also keep prior
versions of this Privacy Policy in an archive for your review.
If you have any questions about this Privacy Policy or our treatment of the
information you provide us, please write to us by email
at info@debutgroup.com or by mail to Debut Communications, Inc, 775A ThePage 2Queensway, Toronto, ON M8Z 1N1 Attn: Privacy.
The data protection law in the UK changed on May 25, 2018. This privacy notice
sets out your rights under the new laws. 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
This website may include links to third-party websites, plug-ins and applications.
Clicking on those links or enabling those connections 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. When you leave our website, we
encourage you to read the privacy notice of every website you visit.2. THE DATA WE COLLECT ABOUT YOUPersonal data, or personal information, 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 follows:
• Identity Data includes first name, maiden name, last name, username or
similar identifier, marital status, title, date of birth and gender.
• 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 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.
• Profile Data includes your username and password, purchases or orders
made by you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our website, products
and services.
• Marketing and Communications Data includes your preferences in
receiving marketing from us and our third parties and your communication
preferences.Page 3We also collect, use and share Aggregated Data such as statistical or demographic
data for any purpose. Aggregated Data may be derived from your personal data
but is not considered personal data in law as this data does not directly or indirectly
reveal your identity. For example, we may aggregate your Usage Data to calculate
the percentage of users accessing a specific website feature. 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 notice.
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 offenses.
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 services). In this case, we may have to cancel a
service you have with us but we will notify you if this is the case at the time.3. HOW IS YOUR PERSONAL DATA COLLECTED?We use different methods to collect data from and about you including through:
• Direct interactions. You may give us your Identity, Contact and Financial
Data by filling in forms or by corresponding with us by post, phone, email or
otherwise. This includes personal data you provide when you:
• apply for our services;
• create an account on our website;
• subscribe to our service or publications;
• request marketing to be sent to you;
• enter a competition, promotion or survey; or
• give us some feedback.
• Automated technologies or interactions. As you interact with our website,
we may automatically collect Technical Data about your equipment,
browsing actions and patterns. We collect this personal data by using
cookies, server logs and other similar technologies. We may also receive
Technical Data about you if you visit other websites employing our cookies.
Please see our cookie policy [www.debutgroup.com/cookiepolicy] for
further details.Page 4• Third parties or publicly available sources. We may receive personal data
about you from various third parties and public sources as set out below:
• Technical Data from the following parties: analytics providers;
advertising networks; and search information providers.
• Contact, Financial and Transaction Data from providers of technical,
payment and delivery services.
• Identity and Contact Data from data brokers or aggregators.
• Identity and Contact Data from publicly availably sources.4. HOW WE USE YOUR PERSONAL DATAWe 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.
• Where it is necessary for our legitimate interests (or those of a third party)
and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.
Generally we do not rely on consent as a legal basis for processing your personal
data other than in relation to sending third party direct marketing communications
to you via email or text message. You have the right to withdraw consent to
marketing at any time by contacting us.
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.
Note that we may process your personal data for more than one lawful ground
depending on the specific purpose for which we are using your data. Please
Contact us if you need details about the specific legal ground we are relying on to
process your personal data where more than one ground has been set out in the
table below.
Purpose/Activity Type of data Lawful basis for
processing including basis of
legitimate interest
To register you as a new
customer
(a) Identity
(b) Contact
Performance of a contract
with youPage 5To 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) Performance of a
contract with you
(b) 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
reorganization or group
restructuring exercise)
(b) Necessary to comply with
a legal obligationPage 6To deliver relevant website
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
(f) Marketing and
Communications
Necessary for our legitimate
interests (to develop our
products/services and grow
our business)
PROMOTIONAL OFFERS FROM US
We may use your Identity, Contact, Technical, Usage and Profile Data to form a
view on what we think you may want or need, or what may be of interest to you.
This is how we decide which products, services and offers may be relevant for you
(we call this marketing).
You will receive marketing communications from us if you have requested
information from us or purchased services from us or if you provided us with your
details when you entered a competition or registered for a promotion and, in each
case, you have not opted out of receiving that marketing.
THIRD-PARTY MARKETING
We will get your express opt-in consent before we share your personal data with
any company outside the Debut Group of companies for marketing purposes.
OPTING OUT
You can ask us or third parties to stop sending you marketing messages at any time
by logging into the website and checking or unchecking relevant boxes to adjustPage 7your marketing preferences or by following the opt-out links on any marketing
message sent to you or by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to
personal data provided to us as a result of a service purchase, service experience
or other transactions.
COOKIES
You can set your browser to refuse all or some browser cookies, or to alert you
when websites set or access cookies. If you disable or refuse cookies, please note
that some parts of this website may become inaccessible or not function properly.
For more information about the cookies we use, please see
www.debutgroup.com/cookiepolicy
CHANGE 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.5. DISCLOSURES OF YOUR PERSONAL DATAWe may have to share your personal data with the parties set out below for the
purposes set out in the table in paragraph 4 above.
• Internal Third Parties as set out in the Glossary.
• External Third Parties as set out in the Glossary.
• Specific third parties listed in the table in paragraph 4 above OR such as
ZOHO, Veritcal Response, Facebook, Instagram, Survey Monkey, MailChimp,
and Jotform.
• Third parties to whom we may choose to sell, transfer, or merge parts of our
business or our assets. 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.Page 8We 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.
6. INTERNATIONAL TRANSFERS
We share your personal data within the Debut group of companies. This will involve
transferring your data outside the European Economic Area (“EEA”).
Many of our external third parties are based outside the European Economic Area
(“EEA”) so their processing of your personal data will involve a transfer of data
outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar
degree of protection is afforded to it by ensuring at least one of the following
safeguards is implemented:
• We will only transfer your personal data to countries that have been deemed
to provide an adequate level of protection for personal data by the European
Commission. For further details, see European Commission: Adequacy of the
protection of personal data in non-EU countries.
• Where we use providers based in the US, we may transfer data to them if
they are part of the Privacy Shield which requires them to provide similar
protection to personal data shared between the Europe and the US. For
further details, see European Commission: EU-US Privacy Shield.
Please Contact us if you want further information on the specific mechanism used
by us when transferring your personal data out of the EEA.
7. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data
from being accidentally lost, used or accessed in an unauthorized 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.Page 98. DATA RETENTIONHOW LONG WILL YOU USE MY PERSONAL DATA FOR?
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
unauthorized 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.
Details of retention periods for different aspects of your personal data are
[available in our retention policy which you can request from us by Contacting us.
In some circumstances you can ask us to delete your data: see Request erasure
below for further information.
In some circumstances we may anonymize your personal data (so that it can no
longer be associated with you) for research or statistical purposes in which case
we may use this information indefinitely without further notice to you.9. YOUR LEGAL RIGHTSUnder certain circumstances, you have rights under data protection laws in relation
to your personal data. Please email info@debutgroup.com to find out more about
these rights:
• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.
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 isPage 10clearly 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.10. GLOSSARYLAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing
our business to enable us to give you the best service/product and the best and
most secure experience. We make sure we consider and balance any potential
impact on you (both positive and negative) and your rights before we process your
personal data for our legitimate interests. We do not use your personal data for
activities where our interests are overridden by the impact on you (unless we have
your consent or are otherwise required or permitted to by law). You can obtain
further information about how we assess our legitimate interests against any
potential impact on you in respect of specific activities by Contacting us.
Performance of Contract means processing your data where it is necessary for
the performance of a contract to which you are a party or to take steps at your
request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal
data where it is necessary for compliance with a legal or regulatory obligation that
we are subject to.
THIRD PARTIES
INTERNAL THIRD PARTIES
Other companies in the Debut group of companies.
EXTERNAL THIRD PARTIES
• Service providers acting as processors who provide IT and system
administration services.Page 11• Professional advisers acting as processors or joint controllers including
lawyers, bankers, auditors and insurers who provide consultancy, banking,
legal, insurance and accounting services.
YOUR LEGAL RIGHTS
You have the right to:
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, we may demonstrate that we have compelling legitimate grounds
to process your information which override your rights and freedoms.
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.
Withdraw consent at any time where we are relying on consent to process your
personal data. However, this will not affect the lawfulness of any processingPage 12carried out before you withdraw your consent. If you withdraw your consent, we
may not be able to provide certain products or services to you. We will advise you
if this is the case at the time you withdraw your consent.
