Privacy Policy

Brooks Harper Ltd understands that your privacy is important to you and that you care about how your personal data is used. Werespect and value the privacy of everyone who visits Our websites, https://sniffandtickle.com and https://barketplace.sniffandtickle.com, and will only collect and use personal data in ways that are described here, and in a way that is consistent with ourobligations and your rights under the law.

Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of this Privacy Policy is requested when you use Our sites and when you create an Account.

1. Definitions and Interpretation

In this Policy the following terms shall have the following meanings: 

“Account” means an account required to access and/or use certain areas and features of Our Sites;
“Cookie” means a small text file placed on your computer or device by Our Sites when you visit certain parts of Our Sites and/or when you use certain features of Our Sites. Details of the Cookies used by Our Sites are set out in Part 14, below; and
“Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;

2. Information About Us

Our Sites is owned and operated by Brooks Harper Ltd, a limited company registered in England under company number 11600275.

Registered address: 2 Farmerie Road, Sudbury, CO10 8HA

Main trading address: 2 Farmerie Road, Sudbury, CO10 8HA

VAT number: GB 307 6728 90

Data Protection Officer: Gavin Harper

Email address: [email protected]

Telephone number: +44 1440 786828

Postal address: 2 Farmerie Road, Sudbury, CO10 8HA

3. What Does This Policy Cover?

This Privacy Policy applies only to your use of Our Sites. Our Sites may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.

4. What Is Personal Data?

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

5. What Are My Rights?

Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:

a) The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact usto find out more or to ask any questions using the details in Part 15.

b) The right to access the personal data we hold about you. Part 13 will tell you how to do this.

c) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact ususing the details in Part 15 to find out more.

d) The right to be forgotten, i.e. the right to ask usto delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 15 to find out more.

e) The right to restrict (i.e. prevent) the processing of your personal data.

f) The right to object to us using your personal data for a particular purpose or purposes.

g) The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.

h) The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.

i) Rights relating to automated decision-making and profiling. We do not use your personal data in this way.

For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 15.

It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 15.

6. What Data Do You Collect and How?

Depending upon your use of Our Sites, wemay collect and hold some or all of the personal and non-personal data set out in the table below, using the methods also set out in the table. Please also see Part 14 for more information about Our use of Cookies and similar technologies] Wedo not collect any ‘special category’ or ‘sensitive’ personal dataorpersonal data relating to childrenordata relating to criminal convictions and/or offences.

Data Collected How We Collect the Data
Identity Information including Name & Title. During Account Creation or at point of Checkout for purchases.
Contact information including Address, Email address, Phone number. During Account Creation or at point of Checkout for purchases or when registering for our newsletter.
Business information including Business Name. During Account creation, for Vendors & Sellers on Our site only.
Profile information including Preferences, Login details, Site Usage History. During Account creation and in cookies used while on our site if you have accepted them.
Technical information including IP address, Browser type and version, operating system. Webserver logs and analytics software.
Data from third parties including technical information, contact information, profile information. Search Engine and Social Media analytics platforms.

7. How Do You Use My Personal Data?

Under the Data Protection Legislation, wemust always have a lawful basis for using personal data. The following table describes how wemay use your personal data, and Our lawful bases for doing so:

What We Do What Data We Use Our Lawful Basis
Registering you on Our Sites. Identity and Contact information. Consent.
Providing and managing your Account. Profile, Identity, and Contact information. Consent.
Providing and managing your access to Our Sites. Profile, Identity, and Contact information. Consent.
Administering Our business. Contact information. Consent.
Supplying products orservices to you. Identity, and Contact information. Consent.
Managing payments for Ourproducts orservices. Identity, and Contact information.. Contractual necessity.
Communicating with you. Contact information. Consent.
Supplying you with information by Email that you have opted-in-to (you may opt-out at any time by unsubscribing using the link at the bottom of any of our Newsletters. Contact Information. Consent.

With your permission and/or where permitted by law, wemay also use your personal data for marketing purposes, which may include contacting you by emailwith information, news, and offers on Ourproductsorservices. You will not be sent any unlawful marketing or spam. Wewill always work to fully protect your rights and comply with Our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.Wewill always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time.

Third Parties (including Mailchimp, Awin, Facebook and Google) whose content appears on Our Sites may use third-party Cookies, as detailed below in Part 14. Please refer to Part 14 for more information on controlling cookies. Please note that wedo not control the activities of such third parties, nor the data that they collect and use themselves, and weadvise you to check the privacy policies of any such third parties.

Wewill only use your personal data for the purpose(s) for which it was originally collected unless wereasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If wedo use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 15.

If weneed to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, wewill inform you and explain the legal basis which allows usto do so.

In some circumstances, where permitted or required by law, wemay process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.

8. How Long Will You Keep My Personal Data?

Wewill not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):

Type of Data How Long We Keep It
Identity Information including Name & Title. No fixed period. Will be kept until you close your account with Us or unsubscribe to Our newsletter.
Contact information including Address, Email address, Phone number. No fixed period. Will be kept until you close your account with Us or unsubscribe to Our newsletter.
Business information including Business name. No fixed period. Will be kept until you close your account.
Profile information including Preferences, Login details, Site Usage History. No fixed period. Will be kept until you close your account.
Technical information including IP address, Browser type and version, operating system. 30 calendar days.

9. How and Where Do You Store or Transfer My Personal Data?

Wewill only store or transfer your personal data within the UK. This means that it will be fully protected under the Data Protection Legislation.

The security of your personal data is essential to us, and to protect your data, wetake a number of important measures, including the following:

·      limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;

·      procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we arelegally required to do so;

10. Do You Share My Personal Data?

We may sometimes contract with the following third parties to supply certain productsorservices.

Recipient Activity Carried Out Sector Location
Sellers on our marketplace (otherwise known as ‘TheBARKetplace’).These sellers are Data Controllers and must have their own Privacy Policies in place to sell on Our site. Production & sale of goods. Suppliers & manufacturing. UK.

If any of your personal data is shared with a third party, as described above, wewill take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, Our obligations, and the third party’s obligations under the law, as described above in Part 9.

If wesell, transfer, or merge parts of Our business or assets, your personal data may be transferred to a third party. Any new owner of Our business may continue to use your personal data in the same way(s) that wehave used it, as specified in this Privacy Policy.

In some limited circumstances, wemay be legally required to share certain personal data, which might include yours, if we areinvolved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

11. How Can I Control My Personal Data?

11.1 In addition to your rights under the Data Protection Legislation, set out in Part 5, whenyou submit personal data via Our Sites, you may be given options to restrict Our use of your personal data. In particular, we aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from uswhich you may do by unsubscribing using the links provided in Our emails).

11.2 You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.

12. Can I Withhold Information?

You may access certain areas ofOur Sites without providing any personal data at all. However, to use all features and functions available on Our Sites you may be required to submit or allow for the collection of certain data.

You may restrict Our use of Cookies. For more information, see Part 14.

13. How Can I Access My Personal Data?

If you want to know what personal data we have about you, you can ask usfor details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 15.

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover Our administrative costs in responding.

We will respond to your subject access request within 14 calendar days and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of Our progress.

14. How Do You Use Cookies?

Our Sites may place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by usand are used only by us. We use Cookies to facilitate and improve your experience of Our Sites and to provide and improve Our products andservices. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.

By using Our Sites, you may also receive certain third-party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, and/or parties other than us. Third-party Cookies are used on Our Sites for usage statistics and marketing. For more details, please refer to the table below. These Cookies are not integral to the functioning of Our Sites and your use and experience of Our Sites will not be impaired by refusing consent to them.

All Cookies used by and on Our Sites are used in accordance with current Cookie Law.

Before Cookies are placed on your computer or device, you will be shown a Cookie Banner at the bottom of Our site requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling usto provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Sites may not function fully or as intended. You will be given the opportunity to allow only some Cookies and block other.

The following Cookies may be placed on your computer or device:

CookieTypeDurationDescription
Necessary
wc_fragments_#sessionsessionEnsures the shopping cart facility works as intended
wc_cart_hash_#sessionsessionEnsures Our shopping cart facility works as intended
Non Necessary
session-idpersistent16 yearsAmazon cookies are a mixture of session, tracking and unique ID cookies. These are only set when a visitor follows a link from the Sniff & Tickle Essentials Shop from Amazon and are controlled by Amazon. Additional cookies not listed here may be set by Amazon during their checkout procedures. These are necessary for the functionality of our shop.
i18n-prefspersistent16 yearsUsed to save language preferences
session-id-timepersistent16 yearsAmazon cookies are a mixture of session, tracking and unique ID cookies. These are only set when a visitor follows a link from the Sniff & Tickle Essentials Shop from Amazon and are controlled by Amazon. Additional cookies not listed here may be set by Amazon during their checkout procedures. These are necessary for the functionality of our shop.
csm-hitpersistent1 yearAmazon cookies are a mixture of session, tracking and unique ID cookies. These are only set when a visitor follows a link from the Sniff & Tickle Essentials Shop from Amazon and are controlled by Amazon. Additional cookies not listed here may be set by Amazon during their checkout procedures. These are necessary for the functionality of our shop.
x-wl-uidpersistent16 yearsAmazon cookies are a mixture of session, tracking and unique ID cookies. These are only set when a visitor follows a link from the Sniff & Tickle Essentials Shop from Amazon and are controlled by Amazon. Additional cookies not listed here may be set by Amazon during their checkout procedures. These are necessary for the functionality of our shop.
ubid-acbukpersistent16 yearsAmazon cookies are a mixture of session, tracking and unique ID cookies. These are only set when a visitor follows a link from the Sniff & Tickle Essentials Shop from Amazon and are controlled by Amazon. Additional cookies not listed here may be set by Amazon during their checkout procedures. These are necessary for the functionality of our shop.
session-tokenpersistent19 yearsAmazon cookies are a mixture of session, tracking and unique ID cookies. These are only set when a visitor follows a link from the Sniff & Tickle Essentials Shop from Amazon and are controlled by Amazon. Additional cookies not listed here may be set by Amazon during their checkout procedures. These are necessary for the functionality of our shop.
Statistics
collectsessionsession
Used to send data to Google Analytics about the visitor's device and behavior. Tracks the visitor across devices and marketing channels.
rc::csessionsessionGoogle Analytics Cookie
__utmtpersistent10 minuteGoogle Analytics Cookie
__utmapersistent2 yearGoogle Analytics Cookie
__utmcsession0 minuteGoogle Analytics Cookie
__utmzpersistent6 monthsGoogle Analytics Cookie
__utmvpersistent2 yearGoogle Analytics Cookie
_gapersistent2 yearGoogle Analytics Cookie
_gatsession1 minuteGoogle Analytics Cookie
_gidpersistent1 dayGoogle Analytics Cookie
__utmbpersistent30 minuteGoogle Analytics Cookie
Marketing
r/collectsessionsession
This cookie is used to send data to Google Analytics about the visitor's device and behavior. It tracks the v isitor across devices and marketing channels.
trsessionsession
Used by Facebook to deliver a series of advertisement products such as real time bidding from third party advertisers.
mailchimp_landing_sitepersistent1 monthMailchimp cookie
_AVESTA_ENVIRONMENTpersistentMailchimp cookie
frpersistent3 monthsFacebook pixel
_fbppersistent3 monthsFacebook Pixel
AWSESSpersistentSet when you see an advertisement and used to help us make sure we don't keep showing you the same advertisement. An ID for the advertisement you have seen.
PHPSESSIDsession0 minuteMailchimp cookie
GDPR
viewed_cookie_policypersistent1 hourDetermines whether the visitor has accepted the cookie consent box. This ensures that the cookie consent box will not be presented again upon re-entry.

Our Sites uses analytics services provided by Google. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling us to better understand how Our Sites is used. This, in turn, enables usto improve Our Sites and the productsandservicesoffered through it.

The analytics service(s) used by Our Sites use(s) Cookies to gather the required information. You do not have to allow usto use these Cookies, however whilst Our use of them does not pose any risk to your privacy or your safe use of Our Sites, it does enable usto continually improve Our Sites, making it a better and more useful experience for you.

The analytics service(s) used by Our Sites use(s) the following Cookies:

CookieTypeDurationDescription
__utmapersistent2 yearGoogle Analytics Cookie
__utmbpersistent30 minuteGoogle Analytics Cookie
__utmcsession0 minuteGoogle Analytics Cookie
__utmtpersistent10 minuteGoogle Analytics Cookie
__utmvpersistent2 yearGoogle Analytics Cookie
__utmzpersistent6 monthsGoogle Analytics Cookie
_gapersistent2 yearGoogle Analytics Cookie
_gatsession1 minuteGoogle Analytics Cookie
_gidpersistent1 dayGoogle Analytics Cookie
collectsessionsession
Used to send data to Google Analytics about the visitor's device and behavior. Tracks the visitor across devices and marketing channels.
rc::csessionsessionGoogle Analytics Cookie

In addition to the controls that we provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.

You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Sites more quickly and efficiently including, but not limited to, login and personalisation settings.

It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.

15. How Do I Contact You?

To contact usabout anything to do with your personal data and data protection, including to make a subject access request, please use the following details (for the attention of Gavin Harper):

Email address: [email protected]

Telephone number: +44 (0)1440 78 6828.

Postal Address: Brooks Harper Ltd, 2 Farmerie Road, Hundon, Sudbury, Suffolk, CO10 8HA.

16. Changes to this Privacy Policy

We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change Our business in a way that affects personal data protection.

Any changes will be immediately posted on Our Sites and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Sites following the alterations. We recommend that you check this page regularly to keep up-to-date. This Privacy Policy was last updated on 7th February 2019.