Privacy Policy

This Privacy Notice explains in detail the types of personal data we may collect about you when you interact with us. It also explains how we’ll store and handle that data and keep it safe.

We know that there’s a lot of information here but we want you to be fully informed about your rights and how Turtle Doves Ltd uses your data.

We hope the following sections will answer any questions you have but if not, please do get in touch with us.

We’ll likely need to update this Privacy Policy from time to time. We’ll notify you of any significant changes, but you’re welcome to come back and check it whenever you wish.

When you are using the Turtle Doves Ltd website, Turtle Doves Ltd is the data controller.

The law on data protection sets out several different reasons for which a company may collect and process your data, including:

CONSENT

In specific situations, we can collect and process your data with your consent. For example, when you tick a box to receive email newsletters.

When collecting your data, we’ll always make clear to you which data is necessary for connection with a particular service.

CONTRACTUAL OBLIGATIONS

In certain circumstances, we’ll need your data to comply with our contractual obligations.

For example, if you order an item from us for home delivery, we’ll collect your address details to deliver your purchase and pass them to our courier.

LEGAL COMPLIANCE

If the law requires us to, we may need to collect and process your data.

For example, we can pass on details of people involved in fraud or other criminal activity affecting Turtle Doves Ltd to law enforcement agencies.

LEGITIMATE INTEREST

In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests

For example, we will use your purchase history to send you or make available personalised offers.

We also combine the shopping history of many customers to identify trends and ensure we can keep up with demand or develop new products/services.

We will also use your address details to send you direct marketing information by post, telling you about products and services that we think might interest you.

WHEN DO WE COLLECT YOUR DATA?

Once you visit any of our websites, use your account to buy products and services, or redeem vouchers from Turtle Doves Ltd on the phone or online.

Making an online purchase and checking out as a guest (in which case we just collect transaction-based data).

If you create an account with us.

On purchase of a product or service in our shop or by phone but don’t have (or don’t use) an account.

Engaging with us on social media.

Contacting us by any means with queries, complaints etc.

Entering prize draws or competitions.

Choosing to complete any surveys we send you.

Commenting on or reviewing our products and services.

Any individual may access personal data related to them, including opinions.

When you’ve given a third-party permission to share with us the information they hold with you.

WHAT SORT OF DATA DO WE COLLECT?

If you have a web account with us; your name, gender, date of birth, billing/delivery address, orders and receipts, email and telephone number. For your security, we’ll also keep an encrypted record of your login password.

Details of your interactions with us through contact centres or online.

For example, we collect notes from our conversations with you, details of any complaints or comments you make, details of purchases you made, items viewed or added to your basket, pages you visit and how and when you contact us.

Copies of documents you provide to prove your age or identity where the law requires this. (including your passport and driver’s licence). This will include details of your full name, address, date of birth and facial image. If you provide a passport, the data will also include your place of birth, gender and nationality.

Details of your shopping preferences.

Details of your visits to our websites and which site you came from to ours.

Information is gathered by the use of cookies in your web browser.

Personal details help us to recommend items of interest.

We’ll only ask for and use your data collected for recommending items of interest and to tailor your shopping experience with us. Of course, it’s always your choice whether you share such details with us.

Payment card information.

Your comments and product reviews.

To deliver the best possible web experience, we collect technical information about your internet connection and browser as well as the country and telephone code where your computer is located, the web pages viewed during your visit, the advertisements you clicked on, and any search terms you entered.

Your social media username, if you interact with us through those channels, to help us respond to your comments, questions or feedback.

HOW AND WHY DO WE USE YOUR DATA?

We want to give you the best possible customer experience. One way to achieve that is to get the richest picture we can of who you are by combining the data we have about you.

We then use this to offer you promotions, products and services that are most likely to interest you. In the case of loyalty scheme members, we’ll also offer you relevant rewards.

The data privacy law allows this as part of our legitimate interest in understanding our customers and providing the highest levels of service.

Of course, if you wish to change how we use your data, you’ll find details in the ‘What are my rights?’ section below.

Remember, if you choose not to share your data with us, or refuse certain contact permissions, we might not be able to provide some services you’ve asked for.

For example, if you’ve asked us to let you know when an item comes back into stock, we can’t do that if you’ve withdrawn your general consent to hear from us.

HERE'S HOW WE'LL USE YOUR DATA AND WHY:

To process any orders that you make by using our website. If we don’t collect your data during checkout, we won’t be able to process your order and comply with our legal obligations.

For example, your details may need to be passed to a third party to supply or deliver the product or service that you ordered and we may keep your details for a reasonable period afterwards to fulfil any contractual obligations such as refunds, guarantees and so on.

To respond to your queries, refund requests and complaints. Handling the information you sent enables us to respond. We may also keep a record of these to inform any future communication with us and to demonstrate how we communicated with you throughout. We do this based on our contractual obligations to you, our legal obligations and our legitimate interests in providing you with the best service and understanding how we can improve our service based on your experience.

To protect our business and your account from fraud and other illegal activities. This includes using your data to maintain, update and safeguard your account. We’ll also monitor your browsing activity with you to quickly identify and resolve any problems and protect the integrity of the websites. We’ll do all of this as part of our legitimate interest.

For example, by checking your password when you log in and using automated monitoring of IP addresses to identify possible fraudulent logins from unexpected locations.

To process payments and prevent fraudulent transactions. We do this based on our legitimate business interests. This also helps to protect our customers from fraud.

With your consent, we will use your data, preferences and details of your transactions to keep you informed by email, web, text, telephone and through our contact centres about relevant products and services including tailored special offers, discounts, promotions, events, competitions and so on.

Of course, you are free to opt-out of hearing from us by any of these channels at any time.

To send you relevant, personalised communications by post about updates, offers, services and products. We’ll do this based on our legitimate business interests.

You are free to opt of hearing from us by post at any time.

To send you communications required by law or which are necessary to inform you about our changes to the services we provide you. For example, updates to this Privacy Notice, product recall notices, and legally required information relating to your orders. These service messages will not include any promotional content and do not require prior consent when sent by email or text message. If we do not use your data for these purposes, we would be unable to comply with our legal obligations.

To display the most interesting content to you on our websites.

For example, we might display a list of items you’ve recently looked at, or offer you recommendations based on your purchase history and any other data you’ve shared with us.

To administer any of our prize draws or competitions which you enter, based on your consent given at the time of entering.

To develop, test and improve the systems, services and products we provide to you. We’ll do this based on our legitimate business interests.

For example, we’ll record your browser’s Session ID to help us understand more when you leave us online feedback about any problems you’re having

To comply with our contractual or legal obligations to share data with law enforcement agencies.

For example, when a court order is submitted to share data with law enforcement agencies or a court of law.

To send you survey and feedback requests to help improve our services. These messages will not include any promotional content and do not require prior consent when sent by email or text message. We have a legitimate interest to do so as this helps make our products or services more relevant to you.

Of course, you are free to opt-out of receiving these requests from us at any time by updating your preferences in your online account.

To build a rich picture of who you are and what you like, and to inform our business decisions, we’ll combine data captured from across Turtle Doves, third parties and data from publicly-available lists as we have described in the section What Sort of Personal Data do we collect? We’ll do this based on our legitimate business interests.

For example, combining this data will help us personalise your experience and decide which inspiration or content to share with you.

Sometimes, we’ll need to share your details with a third party who is providing a service (such as delivery couriers).

Where your data may be processed.

Sometimes we need to share your data with third parties and suppliers outside the European Economic Area (EEA).

Protecting your data outside the EEA.

The EEA includes all EU Member countries as well as Iceland, Liechtenstein and Norway.

We may transfer personal data that we collect from you to third-party data processors in countries that are outside the EEA such as Australia or the USA.

For example, this might be required to fulfil your order, process your payment details or provide support services.

If we do this, we have procedures in place to ensure your data receives the same protection as if it were being processed inside the EEA. For example, our contracts with third parties stipulate the standards they must follow at all times. If you wish for more information about these contracts please contact our Data Protection Officer.

Any transfer of your data will follow applicable laws and we will treat the information under the guiding principles of this Privacy Notice.

WHAT ARE YOUR RIGHTS OVER YOUR DATA?

An overview of your different rights.
You have the right to request:

Access to the personal data we hold about you, free of charge in most cases.
The correction of your data when incorrect, out of date or incomplete.
That we stop using your data for direct marketing (either through specific channels, or all channels)

That we stop any consent-based processing of your data after you withdraw that consent.

You can contact us to request to exercise these rights at any time as follows:

To ask for your information please contact the Data Protection Officer, Turtle Doves Ltd, Unit 2, Lodge Way, Indian Queens Industrial Estate, St Columb, Cornwall, TR9 6TF, or email [email protected]. To ask for your information to be amended please update your online account or contact our customer services team.

If we choose not to action your request we will explain to you the reasons for our refusal.

Your right to withdraw consent.

Whenever you have given us your consent to use your data you have the right to change your mind at any time and withdraw that consent

WHERE WE RELY ON OUR LEGITIMATE INTEREST

In cases where we are processing your data based on our legitimate interest, you can ask us to stop for reasons connected to your situation.

We must then do so unless we believe we have legitimate overriding reasons to continue processing your data.

DIRECT MARKETING

You have the right to stop the use of your data for direct marketing activity through all channels, or selected channels. We must always comply with your request.

CHECKING YOUR IDENTITY

To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Notice.

If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.

HOW CAN YOU STOP THE USE OF YOUR DATA FOR DIRECT MARKETING

You can stop direct marketing communications from us.

Click the ‘unsubscribe’ link in any email communication that we send you. We will then stop any further emails from that particular division.

Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated.

HOW WE PROTECT YOUR DATA

We know how much data security matters to all our customers. With this in mind, we treat your data with the utmost care and take all appropriate steps to protect it.

We secure access to all transactional areas of the websites using ‘HTTPS’ technology.

Access to personal data is password-protected, and sensitive data such as payment card information is secured and tokenized to ensure it is protected.

We regularly monitor our system for possible vulnerabilities and attacks, and we carry out penetration testing to identify ways to further strengthen security.

HOW LONG WILL WE KEEP YOUR DATA?

Whenever we process your data, we’ll only keep it for as long as necessary for the purpose for which it was collected.

At the end of that retention period, your data will either be deleted completely or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning.

Some examples of customer data retention periods:

ORDERS

When you place an order, we’ll keep the personal data you give us for seven years, so we can comply with our legal and contractual obligations.

INACTIVE ACCOUNTS

If you’ve not used your account for more than five years, it will be flagged as inactive and we’ll contact you to ask whether you want to keep it open. Unless you reply to say ‘yes’, we’ll close the account and delete or anonymise the personal data associated with it.

WHO DO WE SHARE YOUR DATA WITH?

We sometimes share your data with trusted third parties.

For example, delivery couriers, for fraud management, to handle complaints to help us personalise our offers to you and so on.

Here’s the policy we apply to those organisations to keep your data safe and protect your privacy:

We provide only the information they need to perform their specific services.

They may only use your data for the exact purposes we specify in our contract with them.

We work closely with them to ensure that your privacy is respected and protected at all times.

If we stop using their services any of your data held by them will either be deleted or rendered anonymous.

Examples of the kind of third parties we work with are:

IT companies who support our website and other business systems.

Operational companies such as delivery couriers.

Direct marketing companies who help us manage our electronic communications with you.

Google/Facebook to show you products that might interest you while you’re browsing the internet. This is based on either your marketing consent or your acceptance of cookies on our websites.

Data insight companies to ensure your details are up to date and accurate.

Sharing your data with third parties for their purposes:

We will only do this in very specific circumstances.

For example, if you enter a holiday competition and tick a box agreeing that the travel company can send you promotional information directly. Or if we run a joint event with a restaurant, and you agree to receive direct communications from them.

For fraud management, we may share information about fraudulent or potentially fraudulent activity on our premises or systems. This may include sharing data about individuals with law enforcement bodies.

We may also be required to disclose your data to the police or other enforcement, regulatory or Government body, in your country of origin or elsewhere, upon a valid request to do so. These requests are assessed on a case-by-case basis and consider the privacy of our customers.

We may, from time to time, expand, reduce or sell Turtle Doves Ltd and this may involve the transfer of divisions or the whole business to new owners. If this happens, your data will, where relevant, be transferred to the new owner or controlling party, under the terms of the Privacy Notice.

For further information, please contact our Data Protection Officer.

CONTACTING THE REGULATOR

If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your data, you have the right to complain to the Information Commissioner’s Office.

You can contact them by calling 0303 123 1113.

Or go online to www.ico.org.uk/concerns (opens in a new window, please note we can’t be responsible for the content of external websites)

If you are based outside the UK, you have the right to lodge your complaint with the relevant data protection regulator in your country of residence.

If you live outside the UK

By using our services or providing your data to us, you expressly consent to the processing of your data by us or on our behalf. Of course, you still have the right to ask us not to process your data in certain ways, and if you do so, we will respect your wishes.

Sometimes we’ll need to transfer your data between countries to enable us to supply the goods or services you’ve requested. In the ordinary course of business, we may transfer your data from your country of residence to ourselves and third parties located in the UK.

By dealing with us, you are giving your consent to this overseas use, transfer and disclosure of your data outside your country of residence for our ordinary business purposes.

This may occur because our information technology storage facilities and servers are located outside your country of residence and could include storage of your data on servers in the UK.

We’ll ensure that reasonable steps are taken to prevent third parties outside your country of residence from using your data in any way that’s not set out in this Privacy Notice. We will adequately protect the confidentiality and privacy of your data.

We can guarantee that any third parties process your data only for their legitimate interests. These third parties may be subject to different laws from those which apply in your country of residence. Please note that we do not take active steps to ensure that any overseas recipient of your data complies with the laws which apply in your country.

ANY QUESTIONS?

We hope this Privacy Notice has helped set out the way we handle your data and your rights to control it.

If you have any questions that haven’t been covered, please contact our Data Protection Officer who will be pleased to help you.

Or write to us at [email protected]