Forte Organics Ltd (“we”, “us”, “our”) takes the issue of safeguarding your privacy seriously.
Please read these documents carefully. By visiting our website or otherwise interacting with us in relation to Irene Forte Skincare products by, for example, ordering such products from us, you acknowledge the processing activities undertaken by us which are described in this Privacy Notice, our terms and any other related documents referenced herein.
Please note that any websites that may be linked to our websites are subject to their own privacy notice.
If you have any questions about this notice, please contact us by email at firstname.lastname@example.org or write to our office at 22 Chancery Lane, London, WC2A 1LS.
We may change this Privacy Notice from time to time and will let you know about any changes, including by posting them on our website. Your continued use of our website after any such changes have been made will amount to your acknowledgement of the amended notice.
This version of our privacy notice was published in November 2018.
1. What is Personal Information?
“Personal Information” or “Personal data” means any information relating to an identified or identifiable natural person (each a ‘data subject’). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or by one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Personal Information may include name; address; email address; phone number; IP address; location data; payment details; information about movements around our websites; information concerning your interests; purchases and product and service preferences; data captured in authentication and tracking logs; and information collected from cookies and similar technologies.
2. What personal information might we collect about you?
We may process the following personal data about you:
Information you give us. You may give us information about you by filling in forms, setting up a user account or profile, ordering a product, uploading information on our website, putting in an enquiry about one of our products or by communicating with us by email, phone or otherwise, e.g. by calling our customer service number. This information may include your name, email address, billing address, phone number, debit or credit card data, the content of any email you send to us and any other similar information. You are under no obligation to provide this information, but without it, we may not be able to provide you with some of our content, goods or information you may request.
Information we collect about you. With regard to each of your visits to our website we may collect:
- information that does not reveal your personal identity, for example, the type of destination you are seeking information on (we use this aggregated, anonymous data mainly for editorial purposes, but we do not connect it to any Personal Information, such as your name or your address);
- technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, date and time you access our website, and the Internet address of the website from which you linked directly to our website, browser plug-in types and versions, operating system and platform and similar information; and
- information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our website, pages you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.
- Information about minors. Forte Organics Ltd does not knowingly collect personally identifiable information via our websites from any person we actually know is a person under the age of 18.
- Information obtained from someone ordering a product on your behalf. If you are entering data on behalf of another person, you warrant to us that you are authorised by that person to enter their personal data into our system, and that information you enter is accurate and correct. If any non-compliance by you with respect to this provision results in any loss or damage being incurred by us, you may be required to compensate us in respect of such loss.
- Information about you obtained from third party sources. These third party sources may include Shopify Inc., which processes payments on our behalf, and other third parties.
3. Cookie Statement
What Are Cookies?
A cookie is a small piece of information which is sent to your browser and stored on your computer’s hard drive, mobile phone or other device.
You can set your browser to notify you when you receive a cookie. This enables you to decide if you want to accept it or not. However, some of the services and features offered through our website may not function properly if your cookies are disabled.
Cookies can be first party or third party cookies.
First party cookies are cookies that the website you are visiting places on your computer.
Third party cookies are cookies placed on your computer through the website but by third parties, such as Google.
The Cookies Placed On Our Website
We use the following cookies on our website. We may combine information from these types of cookies and technologies with information about you from any other source.
Strictly necessary cookies. These cookies are essential in order to enable you to move around our website and use its features. Without these cookies, services you have asked for cannot be provided. They are deleted when you close the browser. These are first party cookies.
Performance cookies. These cookies collect information in an anonymous form about how visitors use our website and apps. They allow us to recognise and count the number of visitors, see how visitors move around the site when they are using it and identify the regions that they are visiting from. These are first party cookies.
Functionality cookies. These cookies allow our website and apps to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. The information these cookies collect will be anonymised and they cannot track your browsing activity on other websites. These are first party cookies.
Analytics. We may use third party analytics services such as Google Analytics and other providers. These service providers help us analyse how users use our website and to identify user patterns. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. The information collected for this purpose (including your IP address and other information collected by automated means) will be disclosed to or collected directly by these service providers. On our behalf Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity and providing other services relating to website activity and internet activity in connection with the use of the website. These service providers may retain and use anonymised, aggregated data collected from users of our Website in connection with their own businesses, including in order to improve their products and services. For information on how to prevent these cookies please click here. In addition, authentication and tracking logs will be used to compile user statistics.
Targeting or advertising cookies. These cookies allow us and our advertisers to deliver information more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of advertising campaigns. They remember that you have visited our website, the length of your visit, the ads you viewed and may help us in compiling your “utilisation profile”, using a pseudonym and without referring to you by name. These are persistent cookies which will be kept on your device until their expiration or earlier manual deletion.
Social Media cookies. These cookies together with social media plug-ins allow you to use functionalities of social media networks such as Facebook, Google’s +1 button, Twitter, Instagram and others on our website. These are persistent cookies which will be kept on your device until their expiration or earlier manual deletion. If you use these functionalities, the plug-in and its content are loaded directly from the social media provider’s servers and included in the website by your browser. If you log into your respective social media account at the time you interact with the social media plug-ins on our website, the social media provider will connect this information with your social media user profile. We cannot influence which personal data the social media provider will collect about you. Please see their privacy notices for further information.
Cookie Consent and Opting Out
We assume that you are happy for us to place cookies on your device. Most Internet browsers automatically accept cookies. However, if you, or another user of your device, wish to withdraw your consent at any time, you have the ability to accept or decline cookies by modifying your browser setting. If you choose to decline cookies, you may not be able to fully experience the interactive features of our website, our platforms and our services.
When you arrive on our website a pop-up message will appear asking for your consent to place advertising cookies on your device. In order to provide your consent, please click ‘I understand’. Once your consent has been provided, this message will not appear again when you revisit. If you, or another user of your device, wish to withdraw your consent at any time, you can do so by altering your browser settings. If you do not withdraw your consent we will assume that you are happy to receive cookies from our website.
In some instances, when you opt out, a new cookie (Opt-Out-Cookie) is placed in your web browser. This tells the third party provider to cease data collection from your browser and prevents advertisements from being delivered to you.
For more information about cookies please visit www.allaboutcookies.org.
4. Why do we capture and store your personal information?
We will only process your personal data, in accordance with applicable law, for the following purposes.
- Responding to your queries, comments, complaints and requests.
- Managing and administering your user account.
- Processing your orders.
- Delivering any products or information requested by you. We may then send electronic messages at appropriate intervals to the email address you gave us, which may also contain topic-specific advertisements along with editorial information on our products and services. Forte Organics Ltd follows a double-opt-in process and customers will have to validate their consent before we start sending communication. In deciding whether or not to join such lists, please note that they are only used for internal purposes and we do not sell or rent our subscription lists to anyone. You can unsubscribe at any time by email to email@example.com or clicking on any of our unsubscribe links.
- Providing you with a customised and premium service. Our goal is to provide you with a personalised customer service, whether you are a new or a returning customer. For these purposes we may create a profile including your user account as well as online session data. We store transaction information. This information may also include details of the number of products you have ordered.
- Verifying your identity, when required.
- Communicating with you about, and administering your participation in, special events, programmes, surveys, contests, sweepstakes, and other offers or promotion
- Displaying content on our websites, such as stories, product reviews, comments and photos, where these are provided by you.
- Allowing you to participate in interactive features of our apps and websites, when you choose to do so.
- Processing claims we receive in connection with our website and products.
- Implementing and enforcing our general terms and conditions of business or any other agreements concluded with you.
- Enabling our suppliers and service providers to carry out certain functions on our behalf, including the hosting of our websites, verification, technical, logistical or other functions, as may be required, in order to make available our website and products. For example, when you make an order your credit card number will be verified by the card provider, but we do not authorise any payments at this point.
- Administering financial operations, including debt recoveries.
- Sending you personalised marketing communications and alerts requested by you.
- Serving personalised advertising to your devices, including delivering ads based on your interests ascertained from your past searches, visits of subpages on our websites, and other data obtained through the use of “cookies” placed on your devices. Please see our Cookie Statement above.
- Ensuring the security of your user account and our business.
- Preventing or detecting fraud or abuses of our websites, products and services, for example, by requesting verification information in order to reset your account password.
- Administering technical aspects of our website, including troubleshooting, diagnosis of technical and service problems, testing, encryption and similar operation.
- For internal business operations, including data analysis, research, trend analysis, statistical and survey purposes, for example to gather demographic information about our users, determine how much time users spend on webpages of our website and to gather information on how our users navigate through our website. We may wish to contact customers to conduct surveys or focus groups to receive your views on our products and delivery. Occasionally we will combine information from a number of customers to better understand trends and customer expectations. When this occurs, all identifiers are removed and the aggregate information cannot be linked to any specific
- Developing and improving our website and products and determining the effectiveness of our business efforts, for example, by reviewing demand for websites and products and user comments or other contributions.
- To comply with applicable law, for example, in response to a request from a court or regulatory body, where such request is made in accordance with the law. We also record information to comply with financial reporting requirements, including those imposed by auditors and government regulators. We may also collect certain information as required by local laws.
5. Legal basis for processing
The legal basis for our processing of your personal data for the purposes described above will typically include:
- processing necessary to fulfil a contract, such as website terms or terms of supply, that we have in place with you, such as the processing for the purposes set out in paragraphs (a.), (b.), (c.), (d.), (e.), (f.), (g.), (h.), (i.), (j.), (k.), (l.) and (m.);
- processing necessary for our or a third party’s legitimate interests, such as the processing for the purposes set out in paragraphs (f.), (g.), (h.), (j.), (k.), (n.), (o.), (p.), (q.), (r.), (s.) and (t.), unless consent is required under applicable law;
- your consent, such as the processing for the purposes set out in paragraphs (n.) and (o.), where such consent is required under applicable law;
- processing necessary for compliance with a legal obligation to which we are subject, such as the processing for the purposes set out in paragraph (u.); and
- other applicable legal grounds for processing.
6. Disclosure of your information
There are circumstances in which we wish to disclose or are compelled to disclose your personal data to third parties. This will only take place in accordance with the applicable law and for the purposes listed above. These scenarios include disclosure as follows.
- To our subsidiaries, affiliates, branches or associated offices.
- To our outsourced suppliers and service providers in order for them to facilitate the provision of our website, products or content to our users. For example, when you place an order via our website, your information will be transferred to Shopify Inc. (for payment processing) and Green Fulfilment Ltd (for shipping) in order to process the order.
- To our analytics partners such as a customer relationship management company and/or a marketing and communications company for statistical and analysis purposes. For example, survey information may be collected by a third party under contract with us.
- To our advertising partners who enable us to deliver personalised ads to your devices or similar advertising. If you do not wish to receive such ads, please opt out using the tools explained in paragraph 3.
- Subject to your consent, to our marketing partners, who may contact you by post, email, telephone, SMS or by other means. If you do not wish to be contacted, you may unsubscribe at any time.
- To third party service providers and consultants, for example, in order to protect the security or integrity of our business, including our databases and systems and for incident response or business continuity reasons.
- To another legal entity, on a temporary or permanent basis, for the purposes of a joint venture, collaboration, financing, sale, merger, reorganisation, change of legal form, dissolution or similar event. In the case of a merger or sale, your personal data will be permanently transferred to a successor company or new owner.
- To public authorities where we are required by law to do so.
- To any other third party where you have provided your consent.
[Our website may feature blogs, forums and discussion groups. Please be aware that some or all of the information you provide (including Personal Information) in connection with these activities may be made publicly available.]
7. How is my Personal Information secured?
We endeavour to protect the privacy of your account and other Personal Information that we hold in our records. Unfortunately, we cannot always guarantee complete security. Unauthorised entry or use, hardware or software failures, and other factors, may compromise the security of user information. Also, while we endeavour to put adequate contractual protections in place we cannot guarantee the security of any Personal Information in databases hosted by third parties.
We store Personal Information in a secure location, be it a database, marketing and research database or a filing cabinet. Furthermore, we take steps to ensure that only designated individuals have access to this information.
Our website is hosted by Shopify Inc., which follows industry standards on information security management to safeguard sensitive information, such as financial information, intellectual property, employee details and any other personal information entrusted to it. Its information security systems apply to people, processes and information technology systems on a risk management basis.
Shopify Inc. performs annual audits to ensure its handling of your credit card information aligns with industry guidelines. It is certified as a PCI DSS Level 1 compliant service provider, and its platform is audited annually by a third-party qualified security assessor.
It is important for you to protect yourself against unauthorised access to your password and to your computer. Be sure to sign off when you have finished using a shared computer.
It is important to note that email communication are not secure. This is a risk inherent in the use of email. Please be aware of this when requesting information or sending forms to us by email (for example, from the “Contact Us” section of our web site). We recommend that you do not include any confidential information (i.e. credit card information) when using email. For your protection, our email responses to you will not include any confidential information.
Finally, to be prudent, please be sure to always close your browsers after browsing. Although the session will terminate after a short period of inactivity, it is best to close your browsers immediately upon completion.
8. Is my Personal Information transferred overseas?
We may transfer your information outside of the country in which it was collected for various reasons. These reasons include: the purpose of entering into or fulfilling a contract with you, processing on-line purchase transactions, replying to or taking actions in response to your enquiries or requests, enhancing personalization of services provided to you, communicating news and promotions to you relating to Forte Organics Ltd products and services and other products and services we think may be of interest to you, and statistical and analysis purposes.
Such transfer of data may be to a country which may not provide the same level of privacy protection as that provided by the country in which the information was collected. However, we will take reasonable steps (including entering into data transfer agreements based on the European Commission model clauses, where required) to ensure that your data is adequately protected by using appropriate technical, organisational, contractual or other lawful means. If you are located in the European Economic Area or the UK, you may contact us for a copy of the safeguards which we have put in place to protect your personal data and privacy rights in these circumstances.
9. How long is my Personal Information retained?
Your personal data will be retained for as long is reasonably necessary for the purposes listed above or as required by applicable local law. We will automatically delete your Personal Information if you have not ordered from us for a certain period of time. Please contact us for further details of applicable retention periods.
We may keep an anonymised form of your personal data, which will no longer refer to you, for statistical purposes without time limits, to the extent that we have a legitimate and lawful interest in doing so.
10. Your rights
If you wish to exercise any of your rights in relation to your Personal Information, please send your request via email to firstname.lastname@example.org.
Right to make subject access request (SAR)
We understand that you may like to know what Personal Information we hold about you. We are happy to assist you with your request. However, to protect your Personal Information we require that you prove your identity to us at the time your request is made. You may also make a request by email.
When you make a request, we will require you to produce some form of photo identification such as a passport or a driver's license and you may be asked to sign a request form. If the request is made in writing via email or letter we require other information so we can check them with our files and satisfy ourselves as to your identity.
The above information is required to create an audit trail of how the request has been handled. Where a request is made, any correspondence or application may be kept and added to your Personal Information.
Forte Organics Ltd will respond to any enquiries as soon as possible but no later than within the timeframes prescribed by law.
Forte Organics Ltd reserves the right to decline access to your Personal Information under certain circumstances, as permitted by law. If your Personal Information is not disclosed to you, you will be provided with the reasons for this non-disclosure.
Right to object to processing, including automated processing and profiling
If at any time you wish for your Personal Information to be deleted from our customer database and systems, or wish to not be part of our profiling module, please contact us.
Forte Organics Ltd will aim to respond to your enquiry within 72 hours. However it might take up to 7 days to have your profile deleted from all our systems.
Right to rectification
You may request that we rectify any inaccurate and/or complete any incomplete personal data.
Right to withdraw consent
You may, as permitted by applicable law, withdraw your consent to the processing of your Personal Data at any time. Such withdrawal will not affect the lawfulness of processing based on your previous consent. Please note that if you withdraw your consent, you may not be able to benefit certain service features for which the processing of your personal data is essential.
Right to erasure
You may request that we erase your Personal Data and we will comply, unless there is a lawful reason for not doing so. For example, there may be an overriding legitimate ground for keeping your Personal Data, such as, a legal obligation that we have to comply with, or if retention is necessary for us to comply with our legal obligations.
Right to data portability
In certain circumstances, you may request that we provide your personal data to you in a structured, commonly used and machine readable format and have it transferred to another provider of the same or similar services. Although we do not consider that this is relevant to our services, we will comply with such transfer request as required by law. Please note that a transfer to another provider does not imply erasure of your Personal Data which may still be required for legitimate and lawful purposes.
Your right to lodge a complaint with the supervisory authority
We suggest that you contact us about any questions or if you have a complaint in relation to how we process your Personal Data. However, you do have the right to contact the relevant supervisory authority directly. A list of EU national data protection authorities can be found here.