Privacy policy
Hampers.com
Who we are
Clearwater Hampers Limited (trading as hampers.com) respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from), purchase from us and tell you about your privacy rights and how the law protects you.
This privacy notice aims to give you information on how Clearwater Hampers Limited collects and processes your personal data, including any data you may provide when you sign up to our marketing emails or purchase a product from Clearwater Hampers Limited. By using our services, you acknowledge and agree that Clearwater Hampers Limited’s collection, usage and disclosure of this personal information is governed by this policy.
To the extent that Clearwater Hampers Limited processes your personal information as “data processor” or “service provider” under certain data privacy or protection laws (including the Data Protection Act 2018) and the EU or United Kingdom (“UK”) General Data Protection Regulation.
We reserve the right to change our Privacy, Cookies and Data Policy at any time. If any changes are significant, we will let you know by email.
Types of Data
Personal data means any information about an individual from which that person can be identified. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
· Identity Data such as names;
· Contact Data such as address;
· Financial Data such as card details;
· Transaction Data such as products and services you have purchased from us;
· Technical Data such as your internet protocol (IP) address;
· Profile Data such as survey responses;
· Usage Data such as how you interact with and use our website(s); and
· Marketing and Communications Data includes your preferences in receiving marketing from us.
We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity.
How your personal data collected
You may give us your personal data by filling in online forms or by corresponding with us by post, phone, email or otherwise. 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 and other similar technologies. We can collect information from third parties or publicly available sources.
Who is Responsible for Processing your Personal Data?
Where we are the “controller” of the personal data that we keep and use, Clearwater Hampers Limited (company number 06167203) is the legal entity responsible for how your personal data is collected, stored and processed. (In this privacy notice, Clearwater Hampers Limited is collectively referred to as “Clearwater Hampers", "we", "us" or "our"). Clearwater Hampers Limited’s business address is 36 Innovation Drive, Milton Park, Abingdon, Oxfordshire, OX14 4RT (which is also our registered office). At Clearwater Hampers, the person with responsibility for our data protection compliance is our Data Protection Officer. They can be contacted via email at dpo@hampers.com or by phone at 01235 604552.
Managing your Personal Data
When you share your personal information with us, you have a right to expect that information to be treated with total confidentiality. Whether you have supplied your personal details online, by phone, by email or in a letter, we will use your personal data for the purposes explained in this privacy notice and for which they were initially collected, and only with a lawful reason to do so.
Our main reason for collecting personal information (which may include names, addresses, contact details including email addresses and business information) will be for the fulfilment of orders made by you for our hampers/goods, and for marketing our business to you in the ways more fully explained below. We will collect appropriate personal information for you and as necessary of the intended recipient of the hampers/goods that you are purchasing
Where someone is receiving a hamper/goods that was ordered by someone else, we will not use personal information of the recipient of the hampers/goods for any purposes other than as necessary to fulfil the order made by you (which may include gift messages to a recipient’s email address or mobile phone number if this service is requested by you during the checkout process), or if we need to contact the recipient regarding an issue with the order, its delivery or any item included in the order.
Most commonly, we will use your personal data in the following circumstances:
· in performance of a contract (the agreement to provide hampers/goods); and/or
· for our legitimate interests where your interests and fundamental rights do not override those legitimate interests; and/or
· with your consent.
It is your responsibility to ensure that your personal data provided to us is accurate and up to date. You can update your personal contact details, including email address and phone number, by visiting My Account online or, by calling our customer services team on 01235 833732.
Processing Your Personal Data Outside of the EU (EEA)
Clearwater Hampers is based in the UK and its business activities are run from our Abingdon office. Data is principally stored by us electronically and the servers that are used for our electronic storage are in the UK.
If your order is for delivery outside the EEA, it will be necessary to transfer your personal data outside the European Economic Area (currently includes all EU member states plus Iceland, Liechtenstein, and Norway) (the “EEA”) to complete (deliver) your order. We may transfer personal data outside of the EEA to processors acting on our behalf.
In some cases, countries outside the UK and EEA may not have such well-developed data protection laws as those in the UK and EEA. However, we will put in place adequate protections that require your personal data to be kept secure, confidential and to be processed only and strictly in line with the terms of this privacy notice and any relevant data protection laws. This may include by use of the standard contractual clauses adopted by the Information Commissioner’s Office (“ICO”) or the European Commission to protect personal data.
Using Your Personal Data for Marketing Purposes
We may use your contact details (including your email, mobile number and home address) to send you details of our latest products, promotions and other marketing messages (including by email and SMS) to keep you aware of what we're up to and to help you see and find our products. This would include sending details of special offers and promotions from hampers.com. We also use marketing profiling techniques to determine product offers that may be of interest to you, whether that be by email, SMS or social media. For further information on how we use your personal data to keep you informed about our products and promotions and how you can change your marketing preferences, click the relevant sections below.
Once we have collected your personal data, we will always give you an easy way to opt-out of receiving marketing messages. We have lots of ways you can stop marketing messages in the future; the best way to do this is through your Customer Account on hampers.com or to click on the 'unsubscribe' link in any email you receive from us.
hampers.com also use features provided by our advertising companies (such as Google or Facebook) and Shopify marketplace to collect and share with them personal information you enter on our Site (such as a phone number or email address) in hashed form (e.g. Facebook “audience matching” or Google’s “enhanced conversions”). We use this information to connect your account with these companies with your activities on our site to (i) enhance measurement of our advertisements and (ii) identify groups of alike customers to optimise our own marketing campaigns.
Our use of Machine Learning
One of the ways in which we are able to help you or will be able to help you use our services is by using techniques like “machine learning” now or in the future (some laws, including certain EEA and UK laws, may refer to this as “automated decision-making”) to help us improve our services. If and when we use machine learning, we either still have a human being involved in the process (therefore making the decision making not fully automated) or use machine learning in ways that do not have legal or similarly significant effects.
Obtaining your Consent for Marketing Purposes
We generally process your information when we need to do so in order to fulfil a contractual obligation (for example, processing payments), or where we or someone we work with needs to use your personal information for a reason related to their business (for example, to provide you with a service). Laws in the EEA and in the UK call these “legitimate interests” which include:
- preventing risk and fraud
- IT Security
- providing and improving our products and services
- providing reporting and analytics
- testing out features or additional services
- assisting with marketing, advertising or other communications.
We only process your personal information for these legitimate interests whilst keeping in mind and balancing potential risks to your privacy. We also ensure that our privacy practices are transparent, offering you control over your personal information (where appropriate), limiting any information we keep and what we do with such information, limiting who we send your information to and how long we keep your information, and the technical measures we use to protect your information.
Where we do rely on your consent to process your personal information we will make it clear that we are asking for your consent. Where we rely on consent, you can withdraw this at any time by telling us that you wish to do so. You will also have the right to withdraw this consent at any time by changing your communication choices, opting out of any communications or by contacting us directly.
Social Media
We will use your email address to send you targeted marketing information about our product offers and promotions via social media platforms. To do this, we will share your email address in a secure manner with social media organisations, who will match our advertising requirements to your social media profile. We have a legitimate business interest to send you product information via social media which we believe is of relevance to you; this is known as Interest-Based Advertising. However, should you wish to exercise your right to stop targeted social media marketing, you can do this at any time by changing your marketing preferences.
We actively use social media platforms as a way of connecting and getting closer to our customers to hear and understand what our customers think about us and our products and services. Occasionally, we may contact you directly via those social media platforms if we would like to share your comments or pictures with other customers or publish them in our marketing materials. We will always ask you if you are happy for us to use your data in this way and will keep any data that you provide to us, such as email address, confidential and secure.
Marketplace
Note that we work with Shopify. See “Sharing Your Personal Data With Third Party Processors & Partners” below.
Third Party Marketing
We will not share your personal data with third party companies for the purpose of them marketing their products and services to you, apart from as set out above.
Any third party that communicates with you on our behalf must only do so for the purpose of carrying out the services and not for the purpose of direct marketing their own products and services. If you have any concerns about any of our third party processors and partners, please contact our customer services team at help@hampers.com 01235 833732.
Profiling
Profiling is a term used to describe a form of data processing where significant volumes of data made up of lots of different data types - such as browser history from Cookies, age, gender, size, transaction history, demographics and buying habits - are all used in an aggregated, anonymised and non-personalised form to evaluate and predict, based on statistical analysis, what customers may or may not want to purchase from us by assigning each customer to a profile type. We use this technique to understand what drives you to buy from us and the types of products you are most likely to be interested in whether that be by email or social media.
Interest Based Advertising
The data that we collect and use when you browse or shop online, including where we use cookies, uses your IP address as the unique identifier; however, it will not contain your name, home address or phone number. This enables us to offer our customers the best possible online user experience and equally allows us to improve the relevancy of our advertising. This allows us to provide you with more of the content you want to see.
Sharing Your Personal Data With Third Party Processors & Partners
In order to fulfil your order and as part of delivering our products and services to you, we will share your personal data with carefully chosen third party processors and partners who carry out a number of services on our behalf.
For example, we will use your personal contact details such as name, postal address, phone number and email address that you provide to us in respect of delivering products or services to you. We will share this information with our suppliers who directly despatch orders to you or our delivery partners who may contact you to arrange a convenient delivery time and provide you with updates as to when they will arrive. We will also share your personal information as set out in our marketing sections above.
[However, if a third-party requests any additional personal information that does not fit with any reasonable business needs we will refuse to share it unless you give us permission or we are legally required. When this request is legally required unless we are legally forbidden from doing so, we will tell you in advance.
Retention of Personal Data
We will keep personal data only for as long as is necessary to fulfil the purposes for which we collected it. Normally our retention period is not more than 7 years from the last time that you purchased hampers/goods from us, however, to determine the most appropriate retention period we consider matters such as the nature and sensitivity of your personal data, the amount and the purpose for which we retained such data and whether we can achieve those purposes by some other means. We will retain and use your personal information in order to comply with our own legal obligations including to resolve disputes and enforce our policies.
Any personal data will not be used for marketing if you have asked us to stop providing marketing to you (other than to the extent necessary to prevent you from receiving further marketing.
If you notify us that you wish to cease using our services and would like your personal data deleted, we shall delete your information or store your information in an aggregated and anonymised format.
Cookies – Using Your Personal Data to Improve Your Online Shopping Experience
We want to make sure that we only contact you with online content that you will find relevant and interesting. For this to work effectively, we collect information about your browsing activity using cookies when you are using our website. A cookie is a small text file which is placed onto your device (e.g. computer, smartphone or another electronic device) when you use our website. These cookies pass back to us your browsing information using your Internet Protocol ("IP") address as the identifier, which we combine with other anonymised, non-personalised and aggregated data, allowing us to determine what content and product information is most relevant to you when you are shopping online. In addition, we employ third party cookies in order to identify orders that can be attributed to our affiliates and partners, so that we may pay them a commission. We use the services of Rakuten Advertising for this purpose.
What cookies we use and why?
Some cookies are necessary to allow you to browse our website(s) including using its features. The use of these cookies is essential for our website(s) to function.
We also use functional cookies to remember choices you’ve made or information you’ve provided, for example the county you are in. This allows us to tailor your website experience specifically to your preferences.
We use tools to help us improve our website(s) (performance cookies).
We partner with Rakuten Advertising, who may collect personal information when you interact with our site. The collection and use of this information is subject to the Rakuten Advertising privacy policy located here: https://rakutenadvertising.com/legal-notices/services-privacy-policy/
The below companies may collect personal information when you refer from one of these companies or interact with our digital property, including IP addresses, digital identifiers, information about your web browsing and app usage and how you interact with our properties and ads for a variety of purposes, such as personalisation of offers or advertisements, analytics about how you engage with websites or ads and other commercial purposes. For more information about the collection, use and sale of your personal data and your rights, please use the below links.
https://rakutenadvertising.com/legal-notices/services-privacy-policy/
https://rakutenadvertising.com/legal-notices/services-privacy-rights-request-form/
How long do cookies remain on my computer or mobile device?
There are several types of cookies and the time that a cookie remains on your computer or mobile device depends on whether it is a “persistent” or “session” cookie. Session cookies last until you stop browsing and persistent cookies last until they expire or are deleted, both help advance functionality for the user. See the section below on how to control cookies and for more information on removing them before they expire.
Controlling your personal information
You may choose to restrict the collection or use of your personal information in different ways. Remember that removing or blocking cookies can impact your user experience and parts of our website(s) may no longer be operate.
Most browsers automatically accept cookies, but you can choose whether or not to accept cookies through your browser controls, often found in your browser’s “Tools” or “Preferences” menu. More information on how to modify your browser settings or how to block, manage or filter cookies can be found in your browser’s help file.
[Most third-party advertising and other tracking services mentioned above such as Rakuten Advertising offer you the opportunity to opt out of their tracking systems. You can read more about the information they collect and how to opt out through the privacy policy links above.]
Keeping your personal information secure
We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
We review our security measures from time to time and reserve the right to make any amendments and you agree that any such changes to our security measures will replace prior versions as at the date that we publish them. This version was last updated on 28th January 2025 Historic versions can be obtained by contacting us.
No method of transfer over the Internet, and method of electronic storage can never be totally secure. We therefore cannot guarantee the absolute security of your personal information.
Right to Complain
If you are located in the UK, you have the right to complain to the Information Commissioner, which you can do by contacting the ICO directly. Full contact details, including a helpline number, can be found on the ICO website (www.ico.org.uk).
If you are located within the EEA you also have the right to lodge a complaint with your local data protection or privacy authority at any time (even if your data process was outside your country).
This website also has useful information on your rights and our obligations. However, please raise any concerns or issues with us first so that we may deal with this as quickly as possible for you.
Time to respond
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.
Your Rights
Under certain circumstances, you have the right by law to request:
· access to your personal data. This enables you to ask to receive a copy of the personal data that we hold about you and to check that we are lawfully processing it (Right to be informed);
· right not to be subject to automated processing. Individuals have the right not to be subject to decisions based solely on automated processing, including profiling, which significantly affects them;
· erasure of your personal data (Right to be forgotten);
· object to processing of your personal data where we are relying on our legitimate interest 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 information for direct marketing purposes (Objection);
· correction or amendment of the personal data that we hold about you (Rectification);
· right to withdraw your consent (if that is the lawful basis for our use of your personal data) (Withdrawal);
· restriction of processing of your personal data (Restriction); and
· transfer of your personal data including to another party (Portability).
We shall not charge you more or provide you with a different level of service if you chose to exercise any of these rights. However, please note that a number of these rights apply only in certain circumstances, and these rights may be limited by law.
It is important to note that we may need to verify your identity before processing any requests. In some cases, it may be necessary to collect additional information to verify your identity, such as your email address, telephone number or a government issued ID.
Right of Access (to be Informed)
You may wish to access a copy of the personal data we hold about you - known as a Subject Access Request. You can do so by submitting a request in writing to the Data Protection Manager. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
Alternatively, we may refuse to comply with your request in these circumstances. We will respond to your Subject Access Request as soon as possible and, in any event, within the statutory 30 days. However, in the event that we need more information from you to verify your identity, which we must do to ensure we disclose your personal data to the right person, the 30-day response period will only commence from the time that we have validated your identity. Occasionally it may 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.
Right of Erasure (to be forgotten)
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 successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Right to Object to Processing (Objection)
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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Right to Request Correction (Rectification)
This enables you to have any incomplete or inaccurate personal data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Right to Withdraw Consent (Withdrawal)
This arises where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Rights relating to Automated Processing
Individuals have the right not to be subject to decisions based solely on automated processing, including profiling, which significantly affects them. It is important to note that there are legal exceptions to this where safeguards are put in place and where consent is obtained.