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Last updated 09th April 2024
Introduction
Welcome to Yoppie’s privacy notice. Your privacy is important to us and we are committed to protecting your personal information.
Please read this privacy notice carefully as it contains important information about how we collect, store and process your personal information, when you register on our website (www.yoppie.com) (the “Website”), buy products or digital services from us via the Website, or otherwise contact us.
It is important that you read this privacy notice carefully.
We collect, use and are responsible for certain personal information about you. Where we do so, we are subject to data protection laws which apply to the United Kingdom and we are responsible as ‘controller’ of that personal information for the purposes of those laws.
Key terms
The following table sets out some key terms that are used throughout this privacy notice:
“We”, “us”, “our” or “Yoppie”
Phlo Technologies Ltd., a company incorporated in Scotland under company number SC496769 whose registered address is C/O Gillespie & Anderson, 147 Bath Street, Glasgow G2 4SN.
Personal information
Any information relating to an identified or identifiable individual
What are our contact details?
Our contact details are:
For more information about our privacy practises or this privacy notice, please contact us by email or by post using the above details.
What personal information does Yoppie collect about you?
If you contact us through our Website, register with us via our Website, place an order for our products via our Website or receive digital services from us (such as attending an online webinar hosted by us,) we will need to collect certain personal information about you in order to process and respond to your query, to set up your account following registration and to process your order or deliver our digital services to you. In particular we collect:
Processing your special category data
Where we process information about you including your gender, biological sex and Health Data, this constitutes “special category data”. We must ensure we are permitted to collect and process such special category data in accordance with data protection laws, which means:
If you request for us to provide our digital services to you or complete our online quiz to identify bespoke products most suitable to you, we will ask you for your consent to process the special category data. If you do not consent to provide this information, we will not collect it from you.
There may be circumstances where you disclose additional health information to us if you provide additional information in correspondence between us. Any additional personal information which is shared with us will not be shared by us and will be treated in confidence.
Special category data will only be stored by us for as long as necessary for the purposes set out in this Privacy Policy. We will not retain your special category data for longer than is necessary. If you require further information about the specific retention periods, please contact us.
How does Yoppie collect your personal information?
Most of the above personal information is collected directly from you. For example, when you:
We also collect personal information from you indirectly via:
How and why Yoppie uses your personal information
Under data protection law, we can only use your personal information if we have a proper reason for doing so, including:
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
The table below explains what we use your personal information for and our reasons for doing so. In some cases, we may use more than one legal basis for processing your personal information; this will depend on the specific purpose for which we are using your personal information.
What we use your personal information for
Type of data
Legal basis for processing
To provide our goods and digital services to you
Third-Party Links
Our Website and some emails from us, may include links to third-party websites, plug-ins and applications of interest. Clicking on those links or enabling those connections may allow third parties to collect or share personal information about you. We do not control these third-party websites and we do not accept any responsibility or liability for these policies, or for any personal information that may be collected through these websites or services. We encourage you to exercise caution and to read the privacy policies applicable to the website you visit.
Who does Yoppie collect Personal information from?
We collect Personal information from the following types of people to allow us to undertake our business:
Who we share your personal information with
Your personal information may be shared with:
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
Excluding the categories of third parties listed above, we will not share your personal information with any other third party.
How long do we keep your personal information for?
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for. Thereafter, we will keep your personal information for as long as is necessary to:
To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
We will not retain your personal information for longer than necessary for the purposes set out in this privacy notice.
When it is no longer necessary to retain your personal information, we will delete or anonymise it.
Transferring your personal information out of the UK and EEA
Due to the global nature of our business and in order to deliver our products to you, it is sometimes necessary for us to share your personal information outside the UK, for example:
Under data protection law, we can only transfer your personal information to a country or international organisation outside the UK where:
We may transfer your personal information to certain countries, on the basis of an adequacy decision. These include: all European Union countries, plus Iceland, Liechtenstein and Norway (collectively known as the ‘EEA’); Gibraltar; and Andorra, Argentina, Canada, Faroe Islands, Guernsey, Israel, Isle of Man, Japan, Jersey, New Zealand, Switzerland and Uruguay.
The list of countries that benefit from adequacy decisions will change from time to time. We will always seek to rely on an adequacy decision, where one exists.
Other countries or international organisations we are likely to transfer personal information to do not have the benefit of an adequacy decision. This does not necessarily mean they provide poor protection for personal information, but we must look at alternative grounds for transferring the personal information, such as ensuring appropriate safeguards are in place, including using standard contractual clauses.
Where there is no adequacy decision, we may transfer your personal information to another country or international organisation if we are satisfied the transfer complies with data protection law, appropriate safeguards are in place, and enforceable rights and effective legal remedies are available for data subjects. The safeguards will usually include using legally-approved standard data protection contract clauses.
In the absence of an adequacy decision or appropriate safeguards, we may transfer personal information to a third country or international organisation where an exception applies under relevant data protection law, including:
We may also transfer information for the purpose of our compelling legitimate interests, so long as those interests are not overridden by your interests, rights and freedoms. Specific conditions apply to such transfers and we will provide relevant information if and when we seek to transfer your personal information on this ground.
Security
Yoppie is committed to keeping your personal information safe and secure from unauthorised access to or unauthorised alterations, disclosure or destruction of personal information that we hold. Our security measures include:
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.
Cookies and other tracking technologies
A cookie is a small text file which is placed onto your device (e.g. computer, smartphone or other electronic device) when you use our Website. We use cookies on our Website. These help us recognise you and your device and store some information about your preferences or past actions.
For further information on our use of cookies, please see our Cookie Policy.
Marketing
We may use your personal information and would like to send you information about our products and services, competitions and special offers, which may be of interest to you. We may do this by post, email, telephone, text message (SMS) or push notification.
We have a legitimate interest in processing your personal information for promotional purposes (see above ‘How and why Yoppie uses your personal information’). This means we do not usually need your consent to send you marketing communications. However, where consent is needed, we will ask for this consent separately and clearly.
We will always treat your personal information with the utmost respect and never share it with other organisations outside of our company group for marketing purposes.
You have the right to “opt out” of receiving marketing communications at any time, and you can unsubscribe to marketing communications by contacting us at hello@yoppie.com or using the ‘unsubscribe’ link in emails.
Your rights
In accordance with applicable UK Data Protection Laws, you have a number of rights when it comes to your Personal information.
Access
The right to be provided with a copy of your personal information (the right of access).
Rectification
The right to require us to correct any mistakes in your personal information.
To be forgotten
The right to require us to delete your personal information—in certain situations.
Restriction of processing
The right to require us to restrict processing of your personal information—in certain circumstances, e.g. if you contest the accuracy of the data.
Data portability
The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations.
To object
The right to object:
—at any time to your personal information being processed for direct marketing (including profiling);
—in certain other situations to our continued processing of your personal information, e.g. processing carried out for the purpose of our legitimate interests.
Not to be subject to automated individual decision making
The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you.
If you would like to exercise any of your rights, please:
How to complain
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact our DPO in the first instance by email at dpo@wearephlo.com.
Changes to the privacy notice and keeping your data up to date
This version of our privacy notice was last updated on 09/04/2024. We may amend this privacy notice from time to time in order to reflect changes to our practices or for other operational, legal or regulatory reasons. Any such changes will be posted on this page and, where appropriate, notified to you by email. By accessing the Website or using our digital services after we make any changes to this privacy notice, you accept those changes.
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information required for us to deliver our products and digital services to you changes, during your relationship with us.
How to contact us
Please contact us by email or telephone if you have any questions about this privacy notice or the information we hold about you. Our contact details are set out at the start of this document.
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