Privacy policy
OUR PRIVACY POLICY
Welcome to the Hebe Health and Beauty Limited (trading as “Kurami”) Privacy Policy Kurami respects your privacy and is committed to protecting your personal data. This privacy policy 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 tell you about your privacy rights and how the law protects you. By using our website, you acknowledge that you have read this Privacy Policy.
1. IMPORTANT INFORMATION AND WHO WE ARE
1.1. Purpose of this privacy policy
This privacy policy aims to give you information on how Kurami collects and processes your personal data through your use of this website, including any data you may provide through this website when you purchase a product or service or take part in a competition.
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 policy together with any other privacy policy or fair processing policy 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 policy supplements other notices and privacy policies and is not intended to override them.
1.2. Controller
Kurami (Hebe Health and Beauty Limited) is the controller and responsible for your personal data (collectively referred to as "we", "us" or "our" in this privacy policy. The term ‘Controller’ when used within this policy has the same meaning as within the Data Protection Laws.
1.3. Contact Details
If you have any questions about this privacy policy or our privacy practices, please contact us using the following details: info@kurami.co.uk.
1.4. Your right to complain
If you have any concerns about how we collect, use, store, share, delete or otherwise handle your personal data, please contact us in the first instance at info@kurami.co.uk and address your complaint to our Customer Experience Team.
We will acknowledge receipt of your data protection complaint within 30 days. We will then take appropriate steps to investigate and respond without undue delay, including making any relevant internal enquiries. We will tell you the outcome of your complaint once our review is complete.
You also 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.
1.5. Changes to this policy
We keep our privacy policy under regular review. 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.
1.6. 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 policy of every website you visit.
2. THE DATA WE COLLECT ABOUT YOU
2.1. Personal 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 as follows:
- “Identity Data” includes first 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 products and services you have purchased from us.
- “Technical Data” includes 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.
2.2. We 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. 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 policy.
2.3. 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, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
We may collect dietary preferences, allergy information, intolerance information, health-related preferences or other health-related information where you choose to provide this to us, or where it is relevant to your order, membership, customer account, customer service enquiry, meal preferences or delivery needs.
We use this information to prepare and deliver suitable meals, manage customer preferences, respond to enquiries, support customer safety, improve our dishes and menus, and provide our services appropriately.
Please only provide health-related information where it is relevant to your order, preferences, membership, account or enquiry.
We do not use dietary, allergy or health-related information for marketing segmentation.
2.4. 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.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
3.1. We use different methods to collect data from and about you including through:
3.1.1. Direct Interactions: You may give us your personal data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
3.1.1.1. apply for our products or services;
3.1.1.2. create an account on our website;
3.1.1.3. subscribe to our service or publications;
3.1.1.4. request marketing to be sent to you;
3.1.1.5. enter a competition, promotion or survey; or
3.1.1.6. give us feedback or contact us.
3.1.2. Automated technologies or interactions: As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies. Our use of cookies is dealt with below in this policy.
4. HOW WE USE YOUR PERSONAL DATA
4.1.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:
4.1.1. where we need to perform the contract we are about to enter into or have entered into with you
4.1.2. 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; and/or
4.1.3. where we need to comply with a legal obligation.
4.2. Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before 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 and requesting that we do so.
5. PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
5.1. 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.
5.2. 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(s) 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 you |
|
To process and deliver your order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us
To manage dietary preferences, allergy information, intolerance information, health-related preferences, delivery instructions and other information relevant to your order, membership, account or enquiry. |
(a) Identity (b) Contact (c) Financial (d) Transaction (e)Marketing and Communications
(a) Identity. (b) Contact. (c) Profile. (d) Transaction. (e) Dietary, allergy and health-related information where provided by you. (f) Delivery instructions. |
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us)
(a) Performance of a contract with you. (b) Necessary for our legitimate interests, including providing suitable meals, managing customer preferences, supporting customer safety, improving our menus and dishes, and responding to enquiries. (c) Explicit consent, where required by applicable data protection law. |
|
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 reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation |
|
To 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) |
6. MARKETING
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. If you wish to update your marketing preferences at any point please login and update the ‘My Details’ section.
We use Klaviyo and similar tools to manage email and SMS marketing, newsletter sign-ups, abandoned cart emails, browse abandonment emails, win-back campaigns, customer segmentation and marketing communications. You can unsubscribe or opt out of marketing communications at any time by using the unsubscribe link or opt-out instructions in our communications, or by contacting us at info@kurami.co.uk.
7. PROMOTIONAL OFFERS FROM US
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think 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 if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.
8. THIRD-PARTY MARKETING
8.1. We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
8.2. 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 adjust your marketing preferences.
9. COOKIES
9.1. We use cookies and similar technologies on www.kurami.co.uk to operate the Site, improve your online experience, understand how customers use the Site, measure advertising performance and support marketing activity. Some cookies are strictly necessary for the Site to work. Other cookies, such as analytics, functionality and targeting cookies, may require your consent.
9.2. Cookies are small files of letters and numbers that are placed on your browser or the hard drive of your computer by websites that you visit if you agree. Cookies contain information that is transferred to your computer’s hard drive. They are widely used in order to make websites function properly, as well as to provide business and marketing information to the owners of the site. For example:
9.2.1. “Session cookies” expire at the end of the browser session and do not collect any user information.
9.2.2. “Permanent cookies” are saved onto your computer and are able to capture your preferences or activities on our Site.
9.2.3. To find out more about cookies in general, please see http://www.allaboutcookies.org/.
9.3. Kurami use cookies to allow us to improve the Site's content, functionality and speed, and their tracking ability also helps us to understand your likes and dislikes, which means we can respond quickly and adapt the Site accordingly. These technologies allow us to recognise your computer so that we can pre-complete data forms for you when you wish to purchase items and helps us to understand your likes and dislikes, which means we can respond quickly and adapt the Site accordingly. Cookies can only be read by the domain that placed them on your computer. This can include information about your use of the Site, the browser and device type you are accessing it from, and where you are in the world.
9.4. What are cookies? Cookies help to establish a user session and allow our server to correctly provide our Site users with the appropriate information, advertisements and services. We also use cookies to ensure that you obtain the information you request. We also use cookies to track the usage of our Site in order to improve the Site according to our customers' needs. Additionally, cookies allow us to pre-fill certain data fields with your information when you visit the Site to make a purchase, making the Site more convenient for you.
9.5. We use the following cookies on the Site:
9.5.1. Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
9.5.2. Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our Site when they are using it. This helps us to improve the way our Site works, for example, by ensuring that users are finding what they are looking for easily.
9.5.3. Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences.
9.5.4. 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.
9.6. You may delete your cookies. Please note that if you delete your cookies we will no longer know that you have opted out, so the banners from our third-party will reappear when you visit other selected websites.
9.7. The dropping of certain cookies is subject to your consent. When you first visit the Site, you are asked whether you agree to the installation of this type of cookie. Where cookies require consent, we will ask for your consent through our cookie banner or consent tool. You can accept or reject non-essential cookies where these options are made available. You can also manage or delete cookies through your browser settings. Please note that disabling some cookies may affect how the Site works.
9.8. You may refuse to accept cookies by altering the settings on your internet browser (for example Internet Explorer, Chrome and Firefox). Please note that if you choose not to permit cookies some areas of our Site may not function properly or be accessible.
9.9. Please note though, that if you delete your cookies:
9.9.1. we will no longer know that you've opted out of online behavioural advertising, so the banners from our third-party advertisers will reappear when you visit other selected websites; and
9.9.2. we will no longer automatically recognise that you have agreed to our privacy policy, cookies policy and the Site terms and conditions and will ask for confirmation of this.
9.10. Please note that third parties (including, for example, providers of email services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies. We may use cookies and similar technologies from Shopify, Google, Meta, Klaviyo, Pinterest and similar service providers. These technologies may help us understand website activity, measure marketing performance, support abandoned cart and browse abandonment communications, and show relevant advertising.
9.11. You may change the settings on your Internet browser to reject cookies at any time, but it will make your use of the Site less expedient.
9.12. What is online behavioural advertising/interest based advertising? Online behavioural advertising (also known as interest-based advertising) is a way of serving advertisements on the websites you visit and making them more relevant to you and your interests.
9.13. Shared interests are grouped together based upon previous web browsing activity and web users are then served advertising which matches their shared interests. In this way, advertising can be made as relevant and useful as possible. Relevant ads can also be delivered based upon the website content you have just been viewing. This is known as ‘retargeting’
9.14. How do you opt-out of online behavioural advertising? There are a number of sites which can help you opt out of online behavioural advertising from third party advertising agencies that operate online behavioural advertising for website publishers, such as, inter alia, http://www.youronlinechoices.com and http://www.networkadvertising.org/choices.
9.15. Please note that opting out of online behavioural advertising using those services:
9.15.1. does not mean that the advertising of our products and services on our the Site will stop being personalised to your interests;
9.15.2. may not stop all online behavioural advertising because it only applies to those third party advertising agencies that have signed up to those services; and
9.15.3. does not mean that there will be no more advertising on the Site or other websites you access. However, the advertising that you do see is likely to be less relevant to your interests.
9.16. In addition, deleting browser cookies can remove your opt out preferences, so you may need to opt out again.
9.17. What is the duration of cookies used? The duration of the cookie depends on the type of cookie used and whether it is a “session” or “persistent” cookie. “Session” cookies expire at the end of the browser session and “Permanent” cookies are saved on your device for a period of time ranging from 30 minutes to two years from the date they are downloaded to your device.
10. CHANGE OF PURPOSE
10.1. 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.
10.2. 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.
10.3. 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.
11. DISCLOSURES OF YOUR PERSONAL DATA
11.1. We may share your personal data with the parties set out below for the purposes set out in the table in Section 5 above:
11.1.1. external Third Parties, including service providers and business partners who support our e-commerce platform, payment processing, email and SMS marketing, analytics, advertising, subscription and loyalty services, review services, delivery and courier services, customer service, accounting, payroll, IT, website development, social media and marketing support. Please also refer to those set out in the Glossary; and
11.1.2. 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 policy.
11.2. 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.
12. INTERNATIONAL TRANSFERS
Some of our service providers, systems, contractors or business partners may process, access or store personal data outside the United Kingdom.
Where personal data is transferred internationally, we take steps designed to ensure that appropriate safeguards are in place. These may include reliance on UK adequacy regulations, standard contractual clauses, the UK International Data Transfer Agreement, the UK Addendum, transfer risk assessments, the UK-US Data Bridge where applicable, or other safeguards permitted under applicable data protection law.
We also aim to limit international access to personal data to what is necessary for the relevant service or business purpose.
13. DATA SECURITY
13.1. We have put in place appropriate security measures to 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.
13.2. 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.
14. DATA RETENTION
14.1. We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including to provide our services, manage customer accounts, process orders, deal with enquiries, handle complaints, comply with legal, regulatory, tax, accounting and reporting requirements, and protect our legal rights.
14.2. The period for which we keep personal data will depend on the type of data, the reason we collected it, whether you have an active customer account or ongoing relationship with us, whether we are required to keep it for legal, tax, accounting or regulatory reasons, and whether it may be needed in connection with a complaint, dispute, data protection request or legal claim. 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.
14.3. 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, regulatory, tax, accounting or other requirements.
14.4. We may retain personal data for longer where required by law, where a complaint or dispute is ongoing, or where we reasonably believe the information may be needed in connection with legal claims.
15. YOUR LEGAL RIGHTS
15.1. Under certain circumstances, you have rights under Data Protection Laws in relation to your personal data, these rights include but are not limited to:-
15.1.1. request access to your personal data.
15.1.2. request correction of your personal data.
15.1.3. request erasure of your personal data.
15.1.4. object to processing of your personal data.
15.1.5. request restriction of processing your personal data.
15.1.6. request transfer of your personal data.
15.1.7. right to withdraw consent where we are relying on consent as a ground for processing.
15.2. If you wish to exercise any of the rights set out above, please contact us at info@kurami.co.uk. Our Customer Experience Team will handle data protection requests and may ask for information to confirm your identity before responding.
15.3. What we may need from you: if you choose to exercise any of the above rights 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.
15.4. 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 accordingly.
GLOSSARY
“Data Protection Laws” means laws applicable in the UK relating to data protection and privacy, including the UK GDPR, the Data Protection Act 2018, the Privacy and Electronic Communications Regulations, and any applicable amendments or replacement legislation and (at the time of writing) General Data Protection Regulation (EU) 2016/679 (GDPR);
“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 obligation” means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to; and
“External Third Parties” may mean the following:
- service providers acting as processors who provide IT, hosting, e-commerce, payment processing, marketing, analytics, advertising, subscription, loyalty, review, customer service, delivery, courier, accounting, professional, website development, social media, marketing and system administration services to Kurami.
- professional advisers acting as processors or joint controllers including lawyers, accountants, auditors, insurers and business advisers.
- HM Revenue & Customs, regulators, public authorities and other bodies who require reporting of processing activities in certain circumstances.
- contractors, consultants and agencies who support our business operations, marketing, advertising, website, customer service or technology systems.