Privacy & Cookies Policy
1.1 We are committed to safeguarding the privacy of our website visitors and as well as other customers; in this policy we explain how we will handle your personal data.
1.2 This policy applies where we are acting as a data controller with respect to your personal data; in other words, where we determine the purposes and means of the processing of that personal data.
1.4 In this policy, "we", "us" and "our" refer to Four Square Healthcare Ltd. For more information about us, see Section 15.
2. How we use your personal data
2.1 In this Section 2 we have set out:
(a) the general categories of personal data that we may process;
(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
(c) the purposes for which we may process personal data; and
(d) the legal bases of the processing.
2.2 We may process data about your use of our website ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your website use. The source of the usage data is our Website analytics tracking system, Analytics and Adwords programs by search engines like Google and Bing. This usage data may be processed for the purposes of analysing the use of the website and for monitoring and improving our website. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.
2.3 We may process your account data ("account data"). The account data may include your name, address(es), telephone number(s), company name (optional) and email address. The source of the account data is you or your employer. The account data may be processed for providing our goods and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract
2.4 We may process information contained in any enquiry you submit to us regarding goods and/or services ("enquiry data"). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. This will be the enquiries received by us through email, website, telephone, post and also includes uncompleted/abandoned carts over our website (which is a form of quotation). The legal basis for this processing is contract.
2.5 We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website ("transaction data"). The transaction data may include your name, contact details, billing and shipping addresses, order ID or order reference, details of goods and services bought, order delivery tracking reference and delivery service provider, payment details – mode of payment, card details or email address linked to paypal account, as applicable. The transaction data may be processed for the purpose of supplying the purchased goods and services including keeping you informed on the status of the shipment(s) (included in our contract with you) and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
2.6 We may process your “account data” and “transaction data” for the purpose of customer benefits and loyalty programs as well for requesting your reviews and testimonials. We may process information that you post for publication such as your reviews and testimonials of our products (supplied) and/or service (provided) ("publication data") on our website or over any other online or offline mediums. We may request for such reviews and testimonials for marketing purposes. The legal basis for this processing is our legitimate interests, namely, marketing.
2.7 We may process your name and email address information that you provide us for the purpose of subscribing to our email notifications and/or newsletters ("notification data"). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent.
2.8 We may process information contained in or relating to any communication that you send to us ("correspondence data"). The correspondence data may include the communication content and metadata associated with the communication. Our website may generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you as per the communication content received and record-keeping. Depending on the nature of communication content, the legal basis for this processing is contract or our legitimate interests, namely, the proper administration of our website and business and communications with users.
2.9 We may process name and contact details data for the purpose of contacting the past customer and potential customers to sell our products and/or services. The source of data will be the customer itself, a referral by another customer or potential customer and or data gathered through our search of potential customers. The lawful basis for this processing is legitimate interest, namely, commercial interest.
2.10 For customers or potential customers visiting our website from outside UK, we may process their ‘metadata’, ‘enquiry data’ and/or ‘transaction data’ explained above to provide a localized experience by showing the website content in their local language, local currency (if possible) and much cheaper courier charges. The data shall be processed for the purpose of increasing sales and the lawful basis is our legitimate interest, namely, commercial interest and changes to contract once that customer places a order or adds item(s) to their cart but leaves without completing it because of any reason.
2.10 We may process ‘transaction data’ including mode of payment but excluding any other card details and metadata like IP address and your IP Geolocation for the purpose of fraud prevention. The source of this data is the data provided by you and website analytics tracking system. The legal basis for this processing is our legitimate interests, namely, commercial interest and also wider public interest by discouraging illegal use of someone’s else card details.
2.11 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
2.12 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely, the proper protection of our business against risks.
2.13 In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
3. Providing your personal data to others
3.1 We may disclose your personal data to any member of our company (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.
3.2 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
3.3 We may disclose your name, address, contacts details, job title and employer (as applicable and relevant), to our suppliers or subcontractors insofar as reasonably necessary for fulfillment of the contract between you and us and/or taking steps, at your request, to enter into such a contract. An exhaustive list of such suppliers cannot be provided here because such suppliers can vary from time to time, depending on the products or services ordered. However, these are usually the manufacturers of furniture and capital goods and made to order items which will be delivered directly to the customers from them. For the purpose of delivery of ordered goods, we have to share your name, address and contact details with the delivery service providers such as Royal Mail, Parcelforce etc. In order to facilitate the fulfillment of our contract with you and keep you updated on the shipment status, we shall also share your name, contact details, delivery tracking reference and name of delivery service provider with applications like Aftership. This makes tracking easier by enabling the tracking of various shipments on a single platform i.e. our website and also sends the customer shipment status updates through automated emails and/or text messages.
3.4 Financial transactions relating to our website and orders through any other medium are handled by our payment services providers, Braintree and Paypal. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers' privacy policies and practices at https://www.paypal.com/webapps/mpp/ua/privacy-full
3.5 We may disclose your enquiry data to one or more third party suppliers of goods and services (an exhaustive list of suppliers cannot be provided and will vary depending on the product/services enquired) for the purpose of obtaining relevant quotations and checking products/services availability.
3.6 For customers visiting our website from outside of UK, we may share your ‘metadata’, ‘enquiry data’ and/or ‘transaction data’ explained above with Webinterpret to provide a localised experience and cheaper delivery of goods outside of the UK.
3.7 We may share your name and email address information ("notification data") provided by you for receiving our email notifications and/or newsletters with our email service provider called Rocket Science Group MailChimp.
3.8 We may share your “account data”, “transaction data” and “publication data” for marketing and customer benefit programs including but not limited to customer loyalty rewards, discounts, product and company reviews. The data shall be shared with specialist applications like ‘Smile.io’, ‘Just Uno’ and ‘ Feefo’.
3.9 We may share your ‘transaction data’ and metadata like IP address and your IP Geolocation with specialist applications like ‘Signifyd’ that are designed to prevent fraudulent payments to us.
3.10 All our sales are invoiced to the user from our accountancy software. The quotations in response to the enquiries are also done on the same software. The information on accountancy software is shared with our accountants.
3.11 In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
4. International transfers of your personal data
4.1 In this Section 4, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).
4.2 We have offices and warehouse in the UK only.
4.3 The hosting facilities for our website are situated in the USA. The European Commission has made an "adequacy decision" with respect to the data protection laws of USA. Transfers to the USA will be protected by appropriate safeguards, namely EU-US Privacy Shield Framework. Our hosting provider is a certified member of EU-US Privacy Shield. This framework protects the fundamental rights of anyone in the EU whose personal data is transferred to the United States for commercial purposes.
4.4 Our Payment Service Provider is a multinational company based in European Economic Area (EEA), USA and other countries outside the European Economic Area. Transfers to any of these countries will be protected by appropriate safeguards, namely, the use of standard data protection clauses adopted or approved by the European Commission, a copy of which can be obtained from us.
4.5 In regards to the product and company reviews collection and publishing service provider, ‘Feefo’ it is anticipated that Feefo may not process the data outside of the European Economic Area (“EEA”) and United Kingdom. In case any processing of Personal Data by Feefo takes place in any country outside the EEA (except if in a country or territory that is recognized under EU Data Protection Laws as providing adequate protection for Personal Data), the standard contractual clauses approved by the EU authorities under EU Data Protection Laws will apply.
4.6 The marketing services application/owner company ‘Smile.io’ stores and processes data in Canada. The European Commission has decided that Canada ensures an adequate level of protection of individuals’ Personal Information. ‘Smile.io’ may transfer your Personal Information to countries or territories with in the EEA or countries or territories that have been deemed by the European Commission to provide an adequate level of protection for personal information. Specific contracts approved by the European Commission which give Personal Information the same protection it has in the EU may be used when the data is transferred out of the EEA.
4.7 The fraud prevention application/ owner company ‘Signifyd’ that we employ for prevention of fraudulent payments to us is based in the USA. This processing is necessary for entering into and the performance of the contract between us and our customer. Signifyd is a certified member of EU-US Privacy Shield Framework and committed to safety and security of consumer data and upholding their rights. These transfers will also be protected by appropriate safeguards, namely, the use of standard data protection clauses adopted or approved by the European Commission, a copy of which can be obtained from us.
4.8 The application/owner company ‘Aftership’ that we employ for providing shipment status alerts and tracking facility over our website is based in Hong Kong, China. Transfers to China will be protected by appropriate safeguards, namely, the use of standard data protection clauses adopted or approved by the European Commission, a copy of which can be obtained from us.
4.9 Our localised experience service provider is based in France and also has offices in other countries outside of the European Union. The Personal Data that Webinterpret collects from you and that you provide to Webinterpret is processed in Ireland and is stored on servers in Ireland and in the US. The Personal Data may also be transferred to any third parties but such transfers will only be made on the basis of the adequacy decision (should the service providers or their technical providers be located outside the EEA area.
4.10 Our email notifications/newsletter service provider ‘Rocket Science Group MailChimp’ is based in the USA. The European Commission has made an "adequacy decision" with respect to the data protection laws of USA. Transfers to the USA will be protected by appropriate safeguards, namely EU-US Privacy Shield framework programme. Rocket Science Group MailChimp is a certified member of EU-US Privacy shield. This framework protects the fundamental rights of anyone in the EU whose personal data is transferred to the United States for commercial purposes.
4.11 You acknowledge that personal data that you submit for publication through our website or services, may be available via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
5. Retaining and deleting personal data
5.1 This Section 5 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
5.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
5.3 We will retain your personal data as follows:
(a) Name, Address, Contact Details, order ID or order reference, details of goods and services bought, order delivery tracking reference and delivery service provider, payment details – mode of payment, card details or email address linked to paypal payment will be retained for a minimum period of 1 month following date of purchase or enquiry and for a maximum period of 6 years following April 5th after your date of purchase.
5.4 In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:
(a) the period of retention of any personal data mentioned above will be determined based on any legitimate interest being pending and the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
5.5 Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
6.1 We may update this policy from time to time by publishing a new version on our website.
6.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
6.3 We may notify you of significant changes to this policy by email, phone, post or through the private messaging system on our website.
7. Your rights
7.1 In this Section 7, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
7.2 Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
7.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. You can request access to your personal data by visiting your account on website (if you have it) or by emailing email@example.com
7.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
7.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for archiving purposes in the public interest, scientific research historical research or statistical purposes where erasure is likely to render impossible or seriously impair the achievement of that processing; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
7.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
7.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
7.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
7.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
7.10 To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,
and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
7.11 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
7.12 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
7.13 You may exercise any of your rights in relation to your personal data by written notice to us, in addition to the other methods specified in this Section 8.
8. Third party websites
8.1 Our website includes hyperlinks to, and details of, third party websites.
8.2 We have no control over, and are not responsible for, the privacy policies and practices of third parties.
9. Personal data of children
9.1 Our website and goods and services are targeted at persons over the age of 18 or under the guidance and supervision of persons aged 18 years of age where a particular products can be used on person under the age of 18 years.
9.2 If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.
10. Updating information
10.1 Please let us know if the personal information that we hold about you needs to be corrected or updated by emailing us at firstname.lastname@example.org
11. About cookies
11.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
11.2 Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
11.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
12. Cookies that we use
13. Cookies used by our service providers
14. Managing cookies
14.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(e) https://support.apple.com/kb/PH21411 (Safari); and
14.2 Blocking all cookies will have a negative impact upon the usability of many websites.
14.3 If you block cookies, you will not be able to use all the features on our website.
15. Our details
15.1 This website is owned and operated by Four Square Healthcare Ltd.
15.2 We are registered in England and Wales under registration number 08836396, and our registered office is at 70 Galleons Drive, Barking, Essex, IG11 0GU, UK.
15.3 Our principal place of business is at 4, GurTek Building, Unit 6, Rippleside Commercial Estate, Ripple Road, Barking, IG11 0RJ, UK.
15.4 You can contact us:
(a) by post, to the principal place of business address given above;
(b) by using our website contact form;
(c) by telephone, on [the contact number published on our website from time to time; or
(d) by email, using the email address published on our website from time to time.