This policy describes how we collect and use personal data about you, in accordance with the Data Protection Act 2018
as amended by the Data Protection, Privacy and Electronic Communications (Amendments etc.) (EU Exit) Regulations
2019 which merge the previous requirements of that Act with the requirements of the General Data Protection
Regulation ((EU) 2016/679) (“UK GDPR”) and any other data protection and privacy laws and regulations applicable to
us or to our processing of your personal data (“Data Protection Legislation”).
This policy describes how we may collect and process personal data including about our customers; our employees,
consultants and job applicants (referred to together in this policy as “Employees”); our suppliers; and visitors to
this website https://vitalitycbd.co.uk (our “website”).
Certain paragraphs (2, 3 and 4) in this policy expressly contain specific information for different categories of
data subjects. The other paragraphs of this policy contain information relevant to everyone. Please read this policy
carefully so that you are fully aware of how and why we are using your personal data.
Our 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 this website, we encourage you to read
- ABOUT US
Vitality CBD Limited (“Vitality”, “we”, “us”, “our” and “ours”) is a UK registered
company with registered number 11612964 and with its registered office at Unit 19, Wainwright Street, Aston,
Birmingham, West Midlands, B6 5TJ on 9 October 2018.
We are registered as a data controller with the Information Commissioner’s Office under
the Data Protection Act 2018 with registration number ZA547724. For the purpose of the Data Protection Legislation
and this policy, we are the “data controller”. This means that we are responsible for deciding how we hold and use
personal data about you. We are required under the Data Protection Legislation to notify you of the information
- THE PERSONAL DATA WE COLLECT
The information we hold about you may include the following:
- Your personal details (such as your name, title, email address, address, telephone number and other contact
- Details of any contact we have had with you in relation to the provision of our products;
- Details of any products you have received from us;
- Our correspondence and communications with you;
- Bank account and payment details;
- Information about any complaints and enquiries you may have submitted to us;
- Information from any research or surveys conducted by us in which you may have participated including
entering into one of our promotions, e-casts, or trade and consumer shows;
- Information from any marketing activities to which you may have responded or in which you may have
- IP address, your login data (if applicable), browser type and version and other technology on the devices
you use to access our website.
We also collect, use and share “Aggregated Data” through Google Analytics 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
Except for as expressly set out in this policy, 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, information about
your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and
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 addition to the personal data listed under “Everyone” in this paragraph 2, we may
- your date of birth/age, gender, marital status and family details, emergency contact information,
photograph, electronic signature, national insurance number or equivalent and passport number;
- bank account details, payroll records and tax status information;
- information about your contract of employment (or services) including salary, annual leave, pension and
benefits information, start date and end date, location of employment or workplace, details of any benefits
you receive or have received and holiday entitlement;
- recruitment information including references and other information included in a CV or cover letter or as
part of the application process;
- employment records (including employee ID number, job titles, job duties, your telephone number and email
address, work history, working hours, sickness and other absence records, training records and information
relating to your performance and behaviour at work, records of disciplinary and grievance processes (whether
or not you were the main subject of those proceedings)
- records relating to your access to the Company’s information technology systems, including user profiles,
account and log-in information and access rights and information as to your interactions with those systems
We may also collect, store and use the following Special Categories of personal data:
- information about your health, including any medical condition, health and sickness records and doctor’s
If you are a customer then we will collect details about payments to and from you and
other details of products purchased from us.
We may collect health data from you over the phone in order to understand what you are
using our products for so that we may provide recommendations to you on how to use our products. We may use this
data to send you information on our products that we think you might like. Health data is classed as a Special
Category of Personal Data under Data Protection Legislation, and as such we need to have further justification to
process such personal data. We have set out the additional conditions under which we may process your health data in
paragraph 4. We may also use this data for internal research purposes, but when we do this, we will always anonymise
or pseudonymise your personal data so that it can no longer be associated with you.
- HOW WE MAY COLLECT YOUR PERSONAL DATA
We will collect and process information about you: (i) when you contact us by email,
telephone, post or social media; and (ii) from third parties (for example, from CBD marketplaces such as Alphagreen
If you submit an enquiry to us then, depending on the nature of your enquiry, we may
collect further details from you so as to understand the context in which you are making the enquiry and/or to
understand the products that may be of interest to you.
We will only collect personal data about you via our website, apart from your IP
address and cookie data, when you contact us to request further information about our products or if you apply for a
position with us. On various occasions, including through forms on our website, we may invite or request you to
submit your contact details and other information about yourself or to send us emails, each of which will identify
We collect information about employees through our application and recruitment process
during the course of your employment/engagement and after its termination. Some of this information is collected
directly from you (for example, in forms that you are asked to complete). Other information is automatically
collected when you use or otherwise interact with our systems; created by colleagues (for example, in the appraisal
process, in the course of an internal investigation or where your role in a particular activity is described in an
internal document); or provided to us by third parties (for example, when we conduct background checks such as
If you are or become a customer then we will collect and process information about you
when you request information about our products, and when you buy our products.
- HOW WE USE INFORMATION WE HOLD ABOUT YOU
We may process your personal data for purposes necessary for the performance of our
contract with you, or for steps preparatory to entering into a contract with you, and to comply with our legal
We may process your personal data for the purposes of our own legitimate interests
provided that those interests do not override any of your own interests, rights and freedoms which require the
protection of your personal data. Our legitimate interests are as follows:
- to keep our records updated;
- to study how customers use our products, to develop them and grow our business, and to inform our marketing
- 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;
- to define types of customers for our products and services, to keep our website updated and relevant.
We may process your personal data for certain additional purposes with your consent,
and in these limited circumstances where your consent is required for the processing of your personal data then (i)
we will request such consent from you separately, and (ii) you have the right to withdraw your consent to processing
for such specific purposes.
Please note that we may process your personal data on more than one lawful ground
depending on the specific purpose for which we are using your data.
We may use your information in order to:
- Carry out our obligations arising from any agreements entered into between you and us, including registering
you as a new customer, processing and delivering your order including managing payments and collecting and
recovering money owed to us;
- Provide you with information related to our products and our events and activities that you request from us
or which we feel may interest you, provided you have consented to be contacted for such purposes;
- Seek your thoughts and opinions on the products we provide, and to enable you to partake in a prize draw or
- Notify you about any changes to our products or terms of service;
- To use data analytics to improve our website, products, marketing, professional relationships and
- To administer and protect our business and this website;
- To deliver relevant website content and advertisements to you and measure or understand the effectiveness of
the advertising we serve to you;
In some circumstances we may anonymise or pseudonymise the personal data so that it can
no longer be associated with you, in which case we may use such information without further notice to you.
We may also process your personal data without your knowledge or consent, in accordance
with this policy, where we are legally required or permitted to do so.
We use employee personal data for legitimate business (provided your interests and
fundamental rights do not override those interests), human resource management and compliance purposes and to
perform our obligations under your employment contract, including:
- Operation of our business including risk management, accounting and auditing and business continuity
- Payroll operation and pension administration;
- Education and training;
- Operation of employee benefits, plans and insurances;
- To carry out human resource and legal/regulatory compliance functions, including assessing compliance with
your employment contract and related Company policies and dealing with disputes including accidents at work;
- The management of disciplinary procedures;
We may also use your personal data in the following situations, which are likely to be
- To protect your interests (or someone else’s interests) where you are not capable of giving consent.
- Where it is needed in the public interest or for official purposes.
Where we process Special Categories of personal data we need to have further
justification for such processing. We may only process special category personal data in the following
- Where we need to carry out our legal obligations or exercise rights in connection with employment law
obligations. We will use information about your physical or mental health, or disability status, to ensure
your health and safety in the workplace and to assess your fitness to work, to provide appropriate workplace
adjustments, to monitor and manage sickness absence and to administer benefits including statutory maternity
pay, statutory sick pay, pensions and permanent health insurance.
- Where it is needed in the public interest.
- In limited circumstances, with your explicit written consent.
- Less commonly, where it is necessary in relation to legal claims, where it is necessary to protect your
interests (or someone else’s interests) and you are not capable of giving your consent, or where you have
already made the information public.
We may process your health data (a Special Category of personal data) as described in
paragraph 2. In order to collect and process your health data we will require your explicit consent which we will
always collect over the phone before we request details of your health in connection to your use of our products.
Change of purpose
Where we need to use your personal data for another reason, other than for the purpose
for which we collected it, we will only use your personal data where that reason is compatible with the original
Should it be necessary to use your personal data for a new purpose, we will notify you
and communicate the legal basis which allows us to do so before starting any new processing.
- DATA RETENTION
We will only retain your personal data for as long as is necessary to fulfil the
purposes for which it is collected.
When assessing what retention period is appropriate for your personal data, we take
- The requirements of our business and the services provided;
- Any legal, accounting, or reporting requirements;
- The purposes for which we originally collected the personal data;
- The lawful grounds on which we based our processing;
- The types of personal data we have collected;
- The amount and categories of your personal data; and
- Whether the purpose of the processing could reasonably be fulfilled by other means.
If you are or become a customer, we normally retain personal for up to 13 months after
the date of your last order/booking. After this point, we may contact you by email to see if you'd like to remain on
our database, and delete your data thereafter if not. In certain circumstances we will retain personal data for
longer where it is necessary for us to do so for compliance with regulatory or other legal obligations, or for the
establishment, exercise or defence of legal claims, or where we agree with you to do so.
Where data is stored by the third parties listed at paragraph 6 the terms of which this
- DISCLOSURES OF YOUR PERSONAL DATA
We may share your personal data with the parties set out below for the purposes set out
in paragraph 4.
- Customer payment details with Shopify International Limited (https://www.shopify.com/legal/privacy);
- Customer personal information with Klaviyo Ltd who provide marketing services
- Customer personal details with Trustpilot (https://legal.trustpilot.com/end-user-privacy-terms);
- Customer payment details with TrustPayments;
- Employee personal information with Siamais Ltd (who provide HR services for us)
- 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
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
- TRANSFERRING INFORMATION OUTSIDE THE UNITED KINGDOM (UK)
Certain of our service providers to whom we will transfer your personal data will hold
your personal data on their services located outside the UK. For example, Shopify International Limited, a company
registered in Ireland, use servers located in the USA and Canada and they host our customer database. We may also
share your personal data with third party service provider Mailchimp, who will hold your personal data on their
servers in the USA. Apart from this, we will not ordinarily transfer the personal data we collect about you outside
of the UK. However, if any third parties (including Shopify International Limited and Mailchimp) by whom your
personal data are to be processed are based outside the UK so that their processing of your personal data will
involve a transfer of data outside the UK we will ensure a similar degree of protection is afforded to it by
ensuring that at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of
protection for personal data through Adequacy Regulations made under Section 17A of the Data Protection Act
- Where we use certain service providers, we may use specific contracts approved by the Information
Commissioner’s Office which give personal data the same protection it has in the UK.
Please contact us if you want further information on the specific mechanism to be used
by us if we are to transfer your personal data outside of the UK.
- DATA SECURITY
We have put in place commercially reasonable and appropriate security measures to
prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or
disclosed. For example:
- we ensure your personal data is stored on secure servers;
- payment details are encrypted and made using SSL technology
We have put in place procedures to deal with any suspected data security breach and
will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
- YOUR RIGHTS
Under certain circumstances, by law you have the right to:
- Request access to your personal data. This enables you to receive details of the personal data we hold about
you and to check that we are processing it lawfully.
- Request correction of the personal data that we hold about you.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where
there is no good reason for us continuing to process it. You also have the right to ask us to delete or
remove your personal data where you have exercised your right to object to processing (see below).
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a
third party) and there is something about your particular situation which makes you want to object to
processing on this ground. You also have the right to object where we are processing your personal data for
direct marketing purposes.
- Request the restriction of processing of your personal data. This enables you to ask us to suspend the
processing of personal data about you, for example if you want us to establish its accuracy or the reason
for processing it.
- Request the transfer of your personal data to another party.
We have the capacity to extract your personal data from our databases and provide it to
you in a structured, commonly-used way (typically by .csv file).
If you wish to exercise any of your rights at any time, please contact us on the
details contained at the beginning of this policy in the first instance. We will require you to verify your identity
to us before we provide any personal data, and reserve the right to ask you to specify the types of personal data to
which your request relates.
Where you wish to exercise any of your rights, they may be subject to payment of a
nominal administration fee (to cover our costs incurred in processing your request) and any clarification we may
reasonably require in relation to your request. Such fees may be charged where we consider (acting reasonably) that
your request is excessive, unfounded or repetitive. Alternatively, we may refuse to comply with the request in such
We may need to request specific information from you to help us confirm your identity
and ensure your right to access the information (or to exercise any of your other rights). This is another
appropriate security measure to ensure that personal data is not disclosed to any person who has no right to receive
- RIGHT TO WITHDRAW CONSENT
In those circumstances where you may have provided your consent to the collection,
processing and transfer of your personal data for a specific purpose (for example, in relation to direct marketing
that you have indicated you would like to receive from us), you have the right to withdraw your consent for that
specific processing at any time. To withdraw your consent, please contact us on the details contained at the
beginning of this policy.
Where you object to and opt out of receiving direct marketing messages from us, this
will not apply to personal data provided to us as a result of a product purchase, warranty registration,
product/service experience or other transactions.
out on our website.
- YOUR DUTY TO INFORM US OF CHANGES
It is important that the personal data we hold about you is accurate and current. Should
your personal data change, please notify us of any changes of which we need to be made aware by contacting us at the
details contained at the beginning of this policy.
- CHANGES TO THIS POLICY
publishing an updated version on our website at http://baklavashop.ba/?CBD=pages/cbd-privacy-policy.
- CONTACT US
If you have any questions regarding this policy or if you would like to speak to us about
the manner in which we process your personal data, please contact us on the details contained at the beginning of
You also have the right to make a complaint to the Information Commissioner’s Office
(ICO: www.ico.org.uk), the UK supervisory authority for data protection issues,
at any time. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so
please contact us in the first instance.
This policy was last updated on: 16 June 2021