111Direct Ltd Online Privacy Notice
Policy Updated April 2023
Trading as Simply Naturals Ltd and 111 Direct Ltd
Registered Member of the GDPR Check & Verify Register
1.1 We are committed to protecting the privacy and security of your Personal data. We have robust information security management systems in place to protect your personal data. We take the security of your information seriously and have implemented appropriate technical and organisational security measures to protect it against any unauthorised or unlawful processing and against any accidental loss, destruction, or damage.
1.3 This site is owned by Simply Naturals Ltd whose office is at Unit 1D Thorpe Court Egham Surrey TW20 8RX
1.4 Our Company registration number is 04288979. We are the ‘data controller’ of the personal information you provide to us.
1.5 We are registered as a Data controller with the Information Commissioners Office our registration number is: ZA 015706
1.6 We have appointed a Data Contact for the business who is Mr David Evans
1.7 You can contact our Data Contact at our postal address given above or via email at firstname.lastname@example.org if you have any queries regarding this policy.
1.8 We operate an Affiliate Marketing business in the Health and Wellbeing sector through Simply Naturals Ltd and a wholly owned subsidiary 111 Direct Ltd.
1.9 As a Data Controller, we will take all the necessary steps to comply with the GDPR and Data Protection Act 2018 and relevant legislation when handling any personal data which you may provide to us.
We are responsible for ensuring that data is processed:
1.9.1 Fairly and lawfully processed
1.9.2 Processed for limited purposes
1.9.3 Adequate, relevant and not excessive
1.9.4 Accurate and Secure
1.9.5 Not kept longer than necessary
1.9.6 Processed in accordance with your rights
1.9.7 Not transferred to countries outside the UK without safeguards
1.9.8 Processed in a manner that ensures appropriate security of the personal data
1.11 Please Note: This Online Privacy information is a precis of our detailed written policies which are held at our business premises. Please contact our Data Contact if you require further information regarding our data protection compliance procedures.
- Our Privacy Notice and Data Protection policies.
2.1 We are committed to protecting your personal data privacy and, in accordance with relevant data protection laws, we uphold strict security procedures for the collection, storage, use and disclosure of your personal information.
2.2 We have described below the personal information we may gather about you, the purposes we will hold it for and the limited categories of people to whom we may disclose it.
- What information do we collect and how may we use it?
3.1 During your visit to our site, we will only collect personal information that you choose to provide. If, for example, you contact us with an enquiry or request us to provide you with further information.
3.2 If you share other people’s data with us, for example if you refer business to us on behalf of another, you will need to check you have lawful authority to do so. E.G. The other party has consented to you providing us with their information. In such a case you are responsible for ensuring the transmission to us of the information is lawful and we may ask you for documentary evidence of this.
3.3 The other types and categories of data we may collect from you includes the following:
3.3.1 Identity data: name, username, title, date of birth. Contact data: billing and delivery address, email address, phone number.
3.3.2 Financial data: payment card details (processed by a third-party payment services provider and not stored by us).
3.3.3 Transaction data: details of products purchased, amounts, dates etc.
3.3.4 Technical data: IP address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform based on your Cookie preference choices.
3.3.5 Profile data: username and password, purchases or orders made by users.
3.3.6 Usage data: information about how users use our website, products and services.
3.3.7 Marketing and communications data: record of Website users preferences in receiving marketing from us about the products we sell.
- We may use the information you provide us with in the following ways:
4.1 To administer any account you have with us.
4.2 To perform our contractual obligations to you.
4.3 To respond to your queries and requests.
4.4 To communicate with you.
4.5 To ensure that the content of our site is presented in the most effective manner.
4.6 To provide you with any information, products and/or services requested from us.
4.7 To provide you with helpful information about our products or services.
4.8 To make improvements to the service we provide you.
4.9 We also reserve the right to disclose your personal information where we are required to do so by law, such as to assist in any disputes, claims or investigations relating to your account or contracts with us and to detect and prevent fraudulent transactions.
4.10 E-mail correspondence with us via our website and email addresses accessible through or obtained from this site may be recorded and/or monitored.
- How do we store and protect your data?
5.1 We have robust information security management systems in place to protect your personal data. We take the security of your information seriously and have implemented appropriate technical and organisational security measures to protect it against any unauthorised or unlawful processing and against any accidental loss, destruction, or damage.
5.2 Data we receive and process is held by us in secure electronic devices and separate back up devices and servers.
5.3 Personal Data may also be held in encrypted 3rd party ‘Cloud’ Servers.
5.4 Further encrypted back ups of data may be held securely in offsite locations which are also subject to physical security at their location.
5.5 We will not sell, rent or otherwise disclose the personal information you provide to us through the site to third parties (other than as listed below) unless we are required to do so by law.
5.6 The Main Establishment for all of our Data Processing is the UK. We do not generally operate or transfer Personal Data outside of the United Kingdom.
5.7 Due to the operation of the Internet and other computer based applications Personal Data under our control may transit countries outside of the UK.
5.8 We will only transfer data outside the UK if adequate safeguards are in place in the destination country.
5.9 Where Personal Data is transferred to a third country or an international organisation we will ensure that an adequacy decision or similar authority exists between the UK and the relevant country or area.
5.10 Where no adequacy decision exists and we rely on the provisions of Standard Contractual Clauses or Binding Corporate Rules evidence of the safeguards provided thereby will be available upon request.
- Sharing Your Data
6.1 We may share your personal information with certain third parties who provide services to us or work on our behalf.
6.2 Such 3rd Parties only have access to the personal information they need to perform those services or work.
6.3 Such 3rd parties are bound by contractual arrangements with Ourselves in accordance with Data Protection legislation and are required to keep your personal information secure and confidential. They may only use it as permitted by us in accordance with our Privacy Policies.
6.4 If you have contracted with us we will share data only to the extent necessary for the performance of the contract, otherwise we will obtain specific additional consent from you before sharing your data.
6.5 The third parties who provide services on our behalf fall into the following categories:
6.5.1 Our partners providing logistics and external service support.
6.5.2 Our business partners or advisors for the purposes of completing a contract with you.
6.5.3 Marketing agencies appointed to provide services to us.
6.5.4 The service providers operating this site on our behalf.
6.5.5 Accountants, auditors, law firms, payment processors, information technology support providers.
6.5.6 Advertising services, analytics services, Computer Application and Software providers.
- How long do we store your data?
7.1 We will not keep your data for longer than is necessary for the relevant purposes set out in this Privacy Notice and our Company Compliance Policies.
7.2 Where you have purchased a product or service from us, we will hold your relevant personal details to enable us to administer the contract and provide such after-sales services as may be required.
7.3 Speculative enquiries for information, the data will be retained for 12 months, unless the Consent is rescinded, in case of a follow up enquiry. E.g. Website enquiries.
7.4 Affiliate Members and Staff data will be kept in line with their contractual arrangements our legal obligations and an additional seven years pursuant to HMRC requirements.
7.5 We also store other personal data in line with Regulatory and legal requirements we are subject to, in accordance with the law.
- Your Personal Data Rights
8.1 Under the UK General Data Protection Regulation (UK GDPR) and The Data Protection Act 2018 (DPA) you have a number of rights with regard to your personal data. To exercise any of your rights contact our Data Contact using the details given above.
8.2 You have the right to request from us access to and rectification or erasure of your personal data; the right to restrict processing; the right to object to processing as well as in certain circumstances the right to data portability as below.
8.3 In the event that you provide your data directly to us for the purpose of a contract, or in circumstances where you have provided your data by consent, you have the right to be provided with your data in a structured, machine-readable format. This is known as Data Portability.
8.4 Following a request relating to Data Portability we will transmit the relevant personal data to the data subject or their nominated data controller where it is possible and technically feasible for us to do so.
8.5 Where you have provided your data voluntarily by Consent you have the right to withdraw your Consent at any time. However, withdrawal of Consent does not affect the lawfulness of any processing of your data based on your Consent prior to its withdrawal.
8.6 You have the right to complain to the Data Regulator at the Information Commissioners Office on 0303 123 1113 or through their website www.ico.org.uk.
8.7 Where we need to process data for the purposes of entering into a Contract with you, if you fail to provide such data it may mean that we cannot establish legal relations between us and the contract may not be able to go ahead. We will inform you if this happens.
8.8 Automated decision making and profiling means making decisions without human intervention, usually with the use of a computer program or software. We may use automated decision making about you if it is necessary for entering into or performing a Contract with you or where you Consent to the actions.
8.9 Please note we will retain and use your personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. If we need to use your data for a reason it was not collected and you are not aware of this, we will inform you and in appropriate cases obtain your further consent to such use.
8.10 If we process data about you but we have not obtained the data personally from you, we must provide you with the information described in this Privacy Notice and some additional information.
8.11 The additional information will be provided to you at least by the time we contact you and in any event within the space of one month after we obtain it.
8.12 If the processing is based on Legitimate Interests, you are entitled to know what and whose Legitimate Interests they are.
8.13 You are entitled to know the purpose of the processing, whether we or someone else is processing it and the categories of Personal Data involved.
8.14 You are entitled to know the source of the information and whether the source is publicly accessible.
8.15 There are some exceptions to this additional information rule. If we obtain your Personal Data from a source other than yourself, the additional information rules will apply unless:-
8.15.1 You already have the information regarding our processing; or
8.15.2 it would take a disproportionate effort or be impossible to provide you with it; or
8.15.3 you are already legally protected under separate provisions; or
8.15.4 we have a legal duty not to disclose it.
8.16 We use the lawful basis of Legitimate Interests for processing data in the following circumstances:
8.16.1: When processing data from our CCTV equipment.
8.16.2 When processing data using Video Conferencing software.
8.16.3 When processing data under the PECR Regulations for the ‘Soft opt in’.
8.17 Our Specific Legitimate Interests are:
220.127.116.11 To protect our business premises.
18.104.22.168 To protect the safety of our employees and visitors to the premises.
22.214.171.124 To assist lawful authorities in the prevention and detection of crime.
8.17.2 Video Conferencing
126.96.36.199 To facilitate efficient business video and telecommunications.
188.8.131.52 To protect the safety of our employees and participants on the call from unnecessary real world travelling.
184.108.40.206 To support our primary business objectives.
8.17.3 Soft Opt In
220.127.116.11 To promote efficient business marketing.
18.104.22.168 To increase sales of our products and services and support our primary business objectives.
22.214.171.124 To protect the personal data and the rights of our customers by using the correct procedures.
126.96.36.199 To support our primary business objectives.
8.18 Use of Third Party Computer Applications for Video conferencing: Where we engage with you Online using a Video Conferencing Application the lawful basis will be our Legitimate Interests and the following will apply:
8.18.1 All participants in Video conferencing will be given specific log in details.
8.18.3 As Data Controller we will manage the Personal Data shared by participants and restrict or control access as necessary for the security of other participants and to prevent cyber security issues such as Phishing.
8.18.4 Password access will be controlled by the Moderator and individual passwords issued where an increased risk is perceived such as large groups or public access.
8.18.5 A Legitimate Interest Assessment Test on Video Conferencing was conducted which concluded the use of Video Conferencing was in our legitimate interests.
- Lawful bases for data processing
9.1 We hold and process your data by lawfully allowed means, these include:
9.1.1 Your Consent: Consent is usually given by yourself when you contact us via this Website or personally when we discuss products or advice with you.
9.1.2 Contractual obligations: This occurs when you purchase products or services from us.
9.1.3 Legal Obligation: When the processing is necessary for us to comply with the Law.
9.1.4 Vital Interests: When the processing is necessary to protect someone’s life.
9.1.5 Public Task: When the processing is necessary for us to perform a task in the public interest or for an official function and the task or function has a clear basis in Law.
9.1.6 Legitimate Interests: When the processing is necessary for our legitimate interests or the legitimate interests of a third party unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests.
N.B. Legitimate Interests can only be used following the application of the prescribed three part Legitimate Interests Assessment Test and then only when a positive outcome is indicated by the conclusions of the test. All Legitimate Interests Assessment Tests will be documented, recorded and retained.
- Children’s data
10.1 Our site is not directed at children and should not be accessed by them.
10.2 We will not knowingly collect information from persons under 13 years of age without their parent’s or guardian’s consent.
10.3 If a Parent or Guardian of a person under 13 years of age discovers their child has engaged with our Website without their consent, please inform us immediately using the contact email provided above.
10.4 We have considered the elements of the AADC (Children’s code) in relation to our Online activity and concluded that we are not a relevant Information Society Service which is likely to be accessed by children.
10.5 There is nothing on our Website which could be damaging to children who view the pages or the pictures.
10.6 The products on our Website are only available and relevant to adults over the age of 18 years.
10.7 We protect the rights of the child in accordance with the UNCRC and the AADC by using self-certifying Age Gate Technology on pages where payments can be made.
- Third Party Websites
11.1 From time to time our site may contain links to and from the websites of our suppliers or other third party sites.
11.2 If you visit any of these sites you should confirm they have their own privacy policies and you should check these before submitting any personal data on their site. We cannot accept any responsibility or liability for the policies on any other Websites.
12 Data Access
12.1 You have rights of access to the data we hold about you. Should you wish to exercise these rights please contact our Data Contact whose details are given above.
12.2 There is usually no charge for the Data Access service. As soon as we are satisfied as to your identity, we will send you, without delay and in any case within one Month, the Personal Data we hold relating to you, which we are legally obliged to provide.
12.3 We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights).
12.4 This is another appropriate security measure to ensure that your Personal Data is not disclosed to anyone who has no right to receive it.
12.5 In the event we need more time to gather the requested information we will let you know without delay and in any event within one month.
12.6 A fee may be payable for Data Access services if the request(s) are manifestly unfounded or excessive or repetitive in nature. Alternatively, we may choose to ignore this type of request. In these cases we will inform you of our decision and if applicable any fee that may be required.
12.7 Please contact us if you believe that any personal data or information which we hold about you is incorrect or incomplete. Any information or data which is found to be incorrect will be corrected as soon as practicable.
12.8 Please contact us if you wish to have your personal data removed entirely from our systems. As soon as we are satisfied as to your identity and the data is not required to be kept for any other lawful reason or purpose it will be removed from our systems forthwith.
12.9 If you so wish, your Data will be provided to you electronically in a commonly used format such as email.
12.10 If you are unhappy with any of the responses given to you by us you may complain about us to the regulator at the Information Commissioners Office on 0303 123 1113 or through their website www.ico.org.uk.
- Business Transfer or Sale
13.2 It may be necessary to transfer your data to a Company that is negotiating with us for the purchase of our business but only where it is necessary to evaluate the business purchase transaction.
13.3 In the case of a pre-sale transfer of personal data, the data would be kept safe during the negotiations and destroyed by the third party if the sale or merger did not go ahead.
- Other Regulatory Matters
14.1.1 We understand the pervasive effect of Data Protection considerations across all aspects of business and wish to create a Culture of Compliance by design within our Organisation.
14.1.2 Consequently, we have made assessments regarding certain other Regulatory areas which require data protection scrutiny to determine whether they affect our Organisation.
14.2 Anti-Money Laundering
14.2.1 We have assessed our responsibilities under the Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017 (The Regulations) as follows:
14.2.2. We are not a Regulated Organisation registered with HMRC or The FCA.
14.2.3. We are not an exempted Organisation under Article 15 of The Regulations.
14.2.4 We are not an Organisation described in Article 8(2)a–8(2)k of The Regulations.
14.2.5 We are not required to engage a Money Laundering Reporting Officer (MLRO).
14.2.6 We do not receive payments for goods in cash generally and specifically we will not accept payments in cash in excess of €10,000 either paid directly to us or into a bank account controlled by us.
14.3 Modern Slavery
14.3.1 We have assessed our responsibilities under the Modern Slavery Act 2015 (The Act) as follows:
14.3.2 We fully support the aims and objectives of The Act.
14.3.3 We are not required to publish a Modern Slavery & Human Trafficking statement under Section 54 of The Act.
14.3.4 During recruitment of our staff we ensure adherence to all regulations including the proof of right to work in the UK requirement.
14.3.5 We remain vigilant for evidence of Modern Slavery & Human Trafficking within our organisation and supply chains and maintain a zero tolerance policy towards such activity.
14.4 Staff Training
14.4.1 We have updated our staff training to include reference to the areas of law in this section of our documentation.
15 Changes to this policy.
15.1 There may be developments in how we use your data according to changes in the Law.
15.3 Any revised terms shall take effect as at the date of posting.
15.4 If you don’t find your concern addressed here, feel free to contact us by e-mailing our Data Contact at the contact details given above.