Introduction

This Policy explains who we are, why and how we process personal data collected through your use of the website and, if you are the subject of any of the personal data concerned, what rights you have and how to get in touch with us if you need to.

This Policy supplements other notices on the Website, including our Website Terms and Conditions of Use and should be read alongside such terms. This Policy is not intended to override or replace these terms.

By visiting or otherwise using our website, you agree to its terms (including as amended from time to time) and this Policy. If, for any reason, you do not agree to the terms of this Policy, please stop using the Website.

We reserve the right to revise or amend this Policy at any time to reflect changes to our business or changes in the law. Where these changes are significant, we will endeavor to let users of the website know, most likely by way of showing you a notification when you next log in to the website. However, it is users' responsibility to check this Policy before each use of the Website and to make yourself aware of any changes. For ease of reference the top of this Policy indicates the date on which it was last updated.

What information can we collect?

What is personal data?

Where this Policy refers to 'personal data' it is referring to data about you from which you could be identified - such as your name, your date of birth, your contact details (including your email address) and your institutional address.

By law all organizations who process your personal data are obliged to process your personal data in certain ways and to ensure that you are given an appropriate amount of information about how they use it. You also have various rights to seek information from those organizations about how they are using your data, and to prevent them from processing it unlawfully. For more information about these rights, please see the 'Your Rights' section of this Policy.

What types of data we collect from you when you use the Website

The personal data we collect from you depends on precisely what details you volunteer to us as you interact with the Website but may include:

• Identity Data which includes your name, date of birth and gender.
• Contact Data which includes your e-mail address, phone number, billing address and delivery address.
• Transaction Data which includes details about payments that you have made and details about the products or services that those transactions relate to.
• Profile Data which includes your username and password, yourpreferences, feedback and survey responses including any personal data contained in content that you upload to the Website.
• Location Data which includes data about where you access the Website from.
• Usage Data which includes information about how you use and engage with the Website.
• Marketing and Communications Data which includes your preferences in receiving marketing from us (i.e. whether you have subscribed to receive any marketing communications from us and our third parties) including information about the kind of products and/or services that we believe you are most likely to be interested in.

Certain types of personal data are categorized as sensitive and need more protection. For example: information about your race or ethnic origins, political opinions, sexual orientation, religious beliefs, health information, biometric and genetic data. There are also special rules about the use of criminal information (information about criminal convictions or allegations about criminal convictions). Collectively 'special category personal data'.

We will not usually collect special category personal data and we will only process this type of personal data about you if we have a valid reason for doing so and only if the law allows us to do so. One example where we may collect special category personal data from you is if we perform any diversity monitoring about engagement with the Website.

How is your personal information collected?

Direct interactions with us

When you use the website, you are likely to provide a certain amount of personal data to us. This could be in response to various questions and forms which we present to you as part of the process of setting up your account . This will include Identity, Contact data as you will provide us with details about your name and location as part of creating your account.

We may also collect, store and use any personal data about you that you otherwise provide, disclose or volunteer to us and/or upload to the Website (for example: by subscribing to our headlines-by-email or any other service; subscribing to our publications or newsletters; applying for a product or service; requesting promotional materials or marketing to be sent to you; taking part in an online survey; filling in a form or questionnaire that we present to you; posting a comment or otherwise messaging on the Website; when you report a problem with the Website or otherwise give us feedback; or when you contact us by e-mail, telephone or by post).

Use of the Website

When you use the Website to interact with content we will collect both the data that you upload to it (which may be included in mails that you send, or content that you upload) as well as data about how you are interacting with the website and with other users.Please always remember that most things posted on the Website are publicly viewable.

Automated technologies or interactions

We will also collect personal data about you and various information about the technology you use through the use of technologies such as cookies and server logs when you visit and interact with the Website. The following are examples of information we may collect:

• Information about your device, browser or operating system;
• Information about links that you click and pages, content or products you view on the Website;
• Records of download errors and/or broken links;

We use the data described above for several different reasons. Firstly, we use it to ensure that the Website works properly, it is secure and that you are able to receive the full benefit of it. Second, we use the data to monitor online traffic and user participation across the Website which helps us to improve the Website's functionality, optimize the ways that it operates, and to focus our time and creativity on the products and/or services. We undertake both of these activities because we have a legitimate interest in doing so.

How and why do we use/share your personal data?

Lawful basis for processing your information

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 you have asked us to do so, or consented to us doing so;
• Where we need to do so in order to perform a contract we have entered into with you;
• Where it is necessary for our legitimate interests (or those of a third party) and your fundamental rights do not override those interests; and
• Where we need to comply with a legal or regulatory obligation.

Marketing and Advertising

We may use your personal 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.

You will only receive marketing communications from us (such as e-mails) if you have requested information from us or purchased strains or services from us or via the Website and you have not opted out of receiving that marketing at the time of purchase or when you registered to receive a service (such as our headlines-by-email service).

Opting Out of Marketing

To unsubscribe from marketing messages at any time, please click on the unsubscribe link at the bottom of any marketing messages. You may also contact us directly if you do not wish to receive any marketing materials from us.

We may retain your e-mail address, or other contact details, on file should you ever 'opt-out' of receiving marketing messages from us. We will retain your contact details in order to ensure that we continue to honor and respect that opt-out request.

Sharing your personal data

We will not share your personal data with third parties in order for that third party to provide direct marketing communications to you. Such activity may have its own terms and conditions relating to the way in which your personal data may be used, which you will be notified of at the relevant time.

Links to third party sites

Where we provide links to third party websites, plug-ins and applications that are not affiliated with the Website such sites are out of our control and are not covered by this Policy. If you access third party sites using the links provided, the operators of these sites may collect personal data from you that could be used by them, in accordance with their own privacy policies. Please check these policies before you submit any personal data to those websites.

For how long do we keep your personal data?

We will hold your personal data on our systems only for as long as required to provide you with the services you have requested. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

Accordingly, you should expect us to keep your personal data for so long as you have a registered account on ourwebsite (whether that account is actively used or not). If you delete your account then we may need to keep some of the personal data associated with that account, or transactions for services made using it, for up to six years.

By law we have to keep basic information about our customers (including contact, identity, and transaction data) for six years after they cease being customers for compliance purposes. In some circumstances you can ask us to delete some or all of your data earlier: see 'Your Rights' below for further information.

We may also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data in law as this data will 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.

Security

We take the protection of your information very seriously. 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, including use of secure servers (on our premises or in secure third-party data centres), encryption (SSL) and passwords. If you have ever chosen a password, or we have given you one, which enables you to access certain parts of this Website, you are responsible for keeping this password confidential. We ask you not to share the password with anyone.

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.

Your Rights

The following information about your rights is relevant to you. This part of the Policy is a mandatory statement which summarizes certain law applicable in your jurisdiction. It is not a replacement for, nor an extension of, your legal rights so should be read only as a summary of that legislation. The following rights are in relation to your personal data held by us:

Right of Access

You may, at any time, request access to the personal data that we hold which relates to you.Please note that this right entitles you to receive a copy of the personal data that we hold about you in order to enable you to check that it is correct and to ensure that we are processing that personal data lawfully. It is not a right that allows you to request personal data about other people, or a right to request specific documents from us that do not relate to your personal data.

You can exercise this right at any time by writing to us and telling us that you are making a subject access request. You do not have to fill in a specific form to make this request.

Your Right to Rectification and Erasure

You may, at any time, request that we correct personal data that we hold about you which you believe is incorrect or inaccurate. You may also ask us to erase personal data if you do not believe that we need to continue retaining it.

Please note that we may ask you to verify any new data that you provide to us and may take our own steps to check that the new data you have supplied us with is right. Further, we are not always obliged to erase personal data when asked to do so if, for example, we have an ongoing legal obligation or need to continue processing that personal data.
You can exercise this right at any time by writing to us and telling us that you are making a request to have your personal data rectified or erased and on what basis you are making that request. If you want us to replace inaccurate data with new data, you should tell us what that new data is. You do not have to fill in a specific form to make this kind of request.

Your Right to Restrict Processing

Where we process your personal data on the basis of a legitimate interest (see the sections of this Policy which explain how and why we use your information) you are entitled to ask us to stop processing it in that way if you feel that our continuing to do so impacts on your fundamental rights and freedoms or if you feel that those legitimate interests are not valid.

You may also ask us to stop processing your personal data (a) if you dispute the accuracy of that personal data and want us verify that data's accuracy; (b) where it has been established that our use of the data is unlawful but you do not want us to erase it; (c) where we no longer need to process your personal data (and would otherwise dispose of it) but you wish for us to continue storing it in order to enable you to establish, exercise or defend legal claims.

We will comply with your request unless we have an ongoing legal obligation or need to continue processing personal data that you ask us to stop processing; a compelling overriding legitimate interest for such processing; or we need to continue processing your personal data to establish, exercise or defend a legal claim.

You can exercise this right at any time by writing to us and telling us that you are making a request to have us stop processing the relevant aspect of your personal data and describing which of the above conditions you believe is relevant to that request. You do not have to fill in a specific form to make this kind of request.

Your Right to stop receiving communications

Where we send you e-mail marketing communications (or other regulated electronic messages) you have the right to opt-out at any time. You can do this by using the 'unsubscribe' link that appears in the footer of each communication (or the equivalent mechanism in those communications).

Alternatively, if for any reason you cannot use those links, or if you would prefer to contact us directly - you can unsubscribe by writing to us and telling us which communications you would like us to stop sending you. Please note that if you request a change in this way it is likely to take longer for your request to take effect.

Exercising your rights

When you write to us making a request to exercise your rights we are entitled to ask you to prove that you are who you say you are. We may ask you to provide copies of relevant ID documents to help us to verify your identity.

It will help us to process your request if you clearly state which right you wish to exercise and, where relevant, why it is that you are exercising it. The clearer and more specific you can be, the faster and more efficiently we can deal with your request. If you do not provide us with sufficient information, then we may delay actioning your request until you have provided us with additional information.

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 could refuse to comply with your request in these circumstances.

We try to respond to all legitimate requests within one month. Occasionally it could 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.