PRIVACY POLICY

Introduction

We at CBDLifeUK. (“we”, “us” or “our”) are committed to protecting your personal privacy. This Privacy Policy (“policy”) applies to our website, including our associated mobile applications (“apps”), owned and controlled by us.

This policy describes how we collect, guard and use the personally identifiable information (“personal information”) you (“user”, “you”, “your” or “data subject”) may provide on our website and through any of its products or services (collectively, “websites” or “services”). It also outlines the choices accessible to you regarding our use of your personal information and how you can access and renew this information.

This policy does not apply to the practices of companies that we do not own or manage, or to individuals that we do not employ or manage. We understand that you are conscious of and care about your own personal privacy interests, and we take this seriously. This policy also describes our policies and practices regarding its collection and use of your personal data and sets forth your privacy rights. We acknowledge that information privacy is an ongoing responsibility, and so we will from time to time update this policy as we undertake new personal data practices or adopt new privacy policies.

General Data Protection Regulation is of a particularly high priority for the management of this website. The use of the internet pages of our website is possible without any indication of personal data; however, if a data subject wants to use special enterprise services via our website, processing of personal data could become essential. If the processing of personal data is required and there is no statutory basis for such processing, we generally obtain consent from the data subject.

The processing of personal data, such as the name, address, country, e-mail address, or telephone number of a data subject shall always be in line with the General Data Protection Regulation, and in accordance with the country-specific data protection regulations applicable to our website. By means of this data protection declaration, we would like to acquaint the general public of the nature, scope, and purpose of the personal data we collect, manage and process. Moreover, data subjects are informed, by means of this data protection declaration, of the rights to which they are entitled.

As the controller, we have implemented numerous technical and organisational measures to ensure a complete protection of personal data processed through this website. Nonetheless, Internet-based data transmissions may in principle have security clefts, so faultless protection may not be guaranteed. For this reason, every data subject is free to transfer personal data to us via alternative means, e.g. by telephone.

Please note that, by utilising our website, you consent to the data practices described in this policy. If you do not agree with the data practices described in this policy, you should not use our website.

Owner and Data Controller

Controller for the purposes of the General Data Protection Regulation, other data protection laws applicable in Member states of the European Union and other provisions related to data protection is:

CBDLife UK, 20-22 Wenlock Road, London, N1 7GU

Office e-mail: info@cbdlifeuk.com

1. Definitions

Our data protection declaration is based on the terms used by the European legislator for the adoption of the General Data Protection Regulation. Our data protection declaration should be legible and understandable for the general public, as well as our customers and business partners. To ensure this, we would like to first explain the terminology used. In this data protection declaration, we use, inter alia, the following terms:

1.1. Collection of general data and information

Our website collects a series of general data and information when a data subject or automated system calls up the website. This general data and information are stored in the server log files.

Collected may be:

  • the browser types and versions used,
  • the operating system used by the accessing system,
  • the website from which an accessing system reaches our website (so-called referrers),
  • the sub-websites,
  • the date and time of access to the Internet site,
  • an Internet protocol address (IP address),
  • the Internet service provider of the accessing system, and
  • any other similar data and information that may be used in the event of attacks on our information technology systems.

When using these general data and information, we do not draw any conclusions about the data subject. Rather, this information is needed to:

  • deliver the content of our website correctly,
  • optimise the content of our website as well as its advertisement,
  • ensure the long-term viability of our information technology systems and website technology, and
  • provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack.

Accordingly, we analyse anonymously collected data and information statistically, with the purpose of increasing the data protection and data security of our enterprise and to ensure an optimal level of protection for the personal data we process.

The anonymous data of the server log files are stored separately from all personal data provided by a data subject.

2. Key terms and principles

Before we get into the detail, here is a quick overview of some of the core elements of data protection and General Data Protection Regulation.

2.1. Data subject

A data subject is an individual whose personal data is stored by an organisation. A data subject is someone who can be identified by the data stored — i.e. the data includes their name, date of birth or address, email address. A user ID number can also be classified as personal data as the number can be linked to a specific person. Under the General Data Protection Regulation, there are several additions including IP addresses and location data.

Someone who cannot be identified by the data stored, or someone who has died, is not a data subject.

2.2. Personal data (or Data)

Personal data means any information relating to an identified or identifiable natural person (“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 to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Any information regarding a natural person, a legal person, an institution or an association, which is, or can be, identified, even indirectly, by reference to any other information, including a personal identification number.

2.3. Controller or controller responsible for the processing (or owner)

Controller or controller responsible for the processing is the natural or legal person, public authority, agency or another body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.

The natural person, legal person, public administration or any another body, association or organisation with the right, also jointly with another Data Controller, to make decisions regarding the purposes, and the methods of processing of Personal Data and the means used, including the security measures concerning the operation and use of our website.

2.4. Data processor (or data supervisor)

Processing is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

A data processor is a legal individual, public authority, agency, or body which processes personal data on behalf of the controller.

The natural person, legal person, public administration or any other body, association or organisation authorised by the Data Controller to process the Personal Data in compliance with this policy.

2.5. Data controller

A data controller is the legal individual, public authority, agency or other body which, alone or jointly with others, determines the purposes of processing personal data.

Under the Data Protection Act (1998), only the data controller is liable for data protection. However, under General Data Protection Regulation, both processors and controllers will be held responsible. Processors will face more legal obligations, and therefore be at risk of fines for non-compliance.

2.6. Usage data

Information collected automatically from our website (or third-party services employed in our digital network), which can include:

  • the IP addresses or domain names of the computers utilised by the Users who use this website,
  • the URI addresses (Uniform Resource Identifier),
  • the time of the request,
  • the method utilised to submit the request to the server,
  • the size of the file received in response,
  • the numerical code indicating the status of the server’s answer (successful outcome, error, etc.),
  • the country of origin,
  • the features of the browser and the operating system utilised by the user,
  • the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited,
  • and other parameters about the device operating system and/or the user’s IT environment.

2.7. User

The individual using this website, which must coincide with or be authorised by the Data Subject, to whom the Personal Data refers.

2.8. Profiling

Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.

2.9. Pseudonymisation

Pseudonymisation is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.1.11. Recipient

The recipient is a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third-party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.

2.10. Third-party

Third-party is a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.

2.11. Consent

Consent of the data subject is any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

2.12. Website

The hardware or software means by which the Personal Data of the User is collected.

2.13. Restriction of processing

Restriction of processing is the marking of stored personal data with the aim of limiting their processing in the future.

2.14. Cookies

The pages of our website use cookies. Cookies are text files that are stored in a computer system via an Internet browser.

Many websites and servers use cookies. Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier of the cookie. It consists of a character string through which pages and servers can be assigned to the specific browser in which the cookie was stored. This allows visited websites and servers to differentiate the individual browser of the data subject from other browsers that contain other cookies. A specific browser can be recognised and identified using the unique cookie ID.

Through the use of cookies, we can provide the users of this website with more user-friendly services that would not be possible without the cookie setting.

By means of a cookie, the information and offers on our website can be optimised for the user in mind. Cookies allow us, as previously mentioned, to recognise our website users. The purpose of this recognition is to make it easier for users to utilise our website. The website user that uses cookies e.g. does not have to enter access data each time the website is accessed, because this is taken over by the website, and the cookie is thus stored on the user’s computer system.

Another example is the cookie of a shopping cart in an online shop. The online store remembers the articles that a customer has placed in the virtual shopping cart via a cookie.

The data subject may, at any time, prevent the setting of cookies through our website by means of corresponding settings of the browser used, and may thus permanently deny the setting of cookies. Moreover, already set cookies may be deleted at any time via browser or other software programs. This is possible in all popular browsers.

If the data subject deactivates the setting of cookies in the browser used, not all functions of our website may be entirely usable.

3. The Data Protection Act

The Data Protection Act was implemented by the United Kingdom government in 1998 to control how personal information is used by organisations and give legal rights to individuals.

The Data Protection Act includes strict ‘data protection principles’, stating that data must be:

  • used fairly and lawfully
  • used for limited, specifically stated, purposes
  • used in a way that is adequate, relevant and not excessive
  • accurate
  • kept for no longer than is absolutely necessary
  • handled according to people’s data protection rights
  • kept safe and secure
  • not transferred outside the European Economic Area without adequate protection

4. Our principles

We do our very best to protect your privacy by using security technology appropriately. This means:

  • we make sure that we have appropriate security measures to protect your information; and
  • we make sure that when we ask another organisation to provide a service for us, they have appropriate security measures.

We will respect your privacy. You should receive marketing (whether by e-mail, post, SMS or telephone) only from us and, if you agree, from other organisations we have carefully chosen. We will make sure it is clear when you can make these choices, for example, we have boxes you need to tick if you want to receive marketing and you can change your preferences if you no longer want to receive it. Notwithstanding, we may e-mail you occasionally with information or inquiries about your registration, your subscription account or postings, for example, with reminders, warnings or copyright requests.

We will collect and use individual user details only if we have your permission or we have sensible business reasons for doing so, such as collecting enough information to manage subscriptions.

  • We will be clear in our dealings with you as to what information about you we will collect and how we will use it.
  • We will use personal data information only for the purposes for which it was originally collected and we will make sure we delete it securely.

Our website is accessible via the internet, meaning that people around the world who access our website can see anything you publish on the website, for example, comments about an article.

If we or our service providers transfer any information out of the European Economic Area, it will only be done with the relevant protection being in place.

5. Types of Data collected

Among the types of Personal Data that we collect, by itself or through third parties, there are: Cookies, Usage Data, company name, address, country, city, unique device identifiers for advertising (Google Advertiser ID or IDFA, for example), first name, last name, e-mail address, password, username and website.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this policy or by specific explanation texts displayed prior to the Data collection.

The Personal Data may be freely provided by the user, or, in case of Usage Data, collected automatically when using our website.

All Data requested by our website is mandatory and failure to provide this Data may make it impossible for us to provide our services. In cases where our website specifically states that some Data is not mandatory, users are free not to communicate this Data without any consequences on the availability or the functioning of the service.

Any use of Cookies — or of other tracking tools — by our website or by the owners of third-party services used by our website serves the purpose of providing the service required by the user, in addition to any other purposes described in the present document and in the Cookie Policy, if available.

Users are responsible for any third-party Personal Data obtained, published or shared through our website and confirm that they have the third-party’s consent to provide the Data to the Owner.

We collect information on you:

  • when you register or become a member of our website, and when you browse the website, or
  • through cookies,
  • if you choose to reveal information in postings, and
  • when you enter sales promotions and competitions.

Certain services that we provide may involve us collecting additional information (membership, for example), such as where you are, so the service can be provided as designed. This may also apply to certain mobile applications that you download, or which we provide.

6. Mode and place of processing the Data

We process the Data of users in a proper manner and shall take appropriate security measures to prevent unauthorised access, disclosure, modification, or unauthorised destruction of the Data.

The Data processing is carried out using computers and/or IT-enabled tools, following organisational procedures and modes strictly related to the purposes indicated. In addition to the Data Controller, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of the site (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, e-mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by us. The updated list of these parties may be requested from the Data Controller at any given time.

6.1. Place

The Data is processed at the Data Controller’s operating offices and in any other places where the parties involved in the processing are located.

6.2. Retention time

The Data is kept for the time necessary to provide the service requested by the user, or stated by the purposes outlined in this document, and the user can always request that the Data Controller suspend or remove the data.

6.3. Routine erasure and blocking of personal data

The data controller shall process and store the personal data of the data subject only for the period necessary to achieve the purpose of storage, or as far as this is granted by the European legislator or other legislators in laws or regulations to which the controller is subject to.

If the storage purpose is not applicable, or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data are routinely blocked or erased in accordance with legal requirements.

7. The use of the collected Data

The Data concerning the user is collected to allow us to provide our services, as well as for the following purposes:

  • Advertising,
  • Contacting the user,
  • SPAM protection,
  • Analytics,
  • Remarketing and behavioural targeting,
  • Commercial affiliation,
  • Interaction with external social networks and platforms,
  • Registration and authentication,
  • Content commenting,
  • Content performance and features testing (A/B testing),
  • Displaying content from external platforms,
  • Handling payments gateways,
  • Hosting and backend infrastructure,
  • Infrastructure monitoring,
  • Interaction with data collection platforms and other third-parties,
  • Managing contacts and sending messages, and
  • Tag Management.

We will not share your personal information with others for marketing purposes unless you have given us your permission. If we have your permission, we will share your information only with other organisations we have chosen carefully.

If you are a registered user and attend an event organised by an event partner, data may be shared for event administration purposes.

We may make other organisations’ services available, through our website, although we are not necessarily operating these websites. We process any information which we collect when you access a service provided by another organisation under this policy. The information these other organisations collect is governed by their own privacy policies.

We can access and release personal information to keep relevant laws and government requests, to operate our systems properly and to protect both us and our users.

Any other organisations who access your information in the course of providing services on our behalf will be governed by strict contractual restrictions to make sure that they protect your information and keep to general data protection regulation and privacy laws which apply. We may also independently audit these service providers to make sure that they meet our standards. We may use service providers to help us run these websites (or services available on the websites), some of whom may be based outside the European Economic Area.

Some of our website pages use plugins from other organisations (such as the ‘Facebook Recommend’ function). These other organisations may use information about your visit to our websites on their pages. If you browse these pages while still also logged in to your account with us, the information they collect may be connected to your account on their website.

For more information on how these organisations use information, please read their privacy policies.

The Personal Data used for each purpose is outlined in the specific sections of this document.

8. Analytics

The services contained in this section enable us to monitor and analyse web traffic and can be used to keep track of user behaviour.

8.1. Google Analytics (Google Inc.)

Google Analytics is an analysis service provided by Google Inc. (“Google”). Google utilises the Data collected to track and examine the use of our website, to prepare reports on its activities and share them with other Google services.

We use Google Analytics on our website for anonymous reporting of website usage and for advertising on the website. Furthermore, Google may use the Data collected to contextualise and personalise the advertisements of its own advertising network.

8.2. Facebook Ads conversion tracking (Facebook, Inc.)

Facebook Ads conversion tracking is an analytics service provided by Facebook, Inc. that connects data from the Facebook advertising network with actions performed on our website.

Personal Data collected: Cookies and Usage Data.

Place of processing: United States of America

8.3. Facebook Analytics for Apps (Facebook, Inc.)

Facebook Analytics for Apps is an analytics service provided by Facebook, Inc.

Personal Data collected: Usage Data and various types of Data as specified in the privacy policy of the service.

Place of processing: United States of America

8.4. Google AdWords conversion tracking (Google Inc.)

Google AdWords conversion tracking is an analytics service provided by Google Inc. that connects data from the Google AdWords advertising network with actions performed on our website.

Personal Data collected: Cookies and Usage Data.

Place of processing: United States of America

8.5. Twitter Ads conversion tracking (Twitter, Inc.)

Twitter Ads conversion tracking is an analytics service provided by Twitter, Inc. that connects data from the Twitter advertising network with actions performed on our website.

Personal Data collected: Cookies and Usage Data.

Place of processing: United States of America

8.6. Google Analytics with anonymised IP (Google Inc.)

Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilises the Data collected to track and examine the use of and performance of our website, also to prepare reports on its activities and share them with other Google services.

Google may use the Data collected to contextualise and personalise the advertisements of its own advertising network.

This integration of Google Analytics anonymises your IP address. It works by shortening users’ IP addresses within member states of the European Union or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases will the complete IP address be sent to a Google server and shortened within the United States of America.

Personal Data collected: Cookies and Usage Data.

Place of processing: United States of America

9. Data protection provisions about the application and use of Google Analytics (with anonymization function)

On this website, we have integrated the component of Google Analytics (with the anonymiser function). Google Analytics is an analytics service. Analytics is the collection, gathering, and analysis of data about the behaviour of visitors to websites. An analysis service collects, inter alia, data about the website from which a person has come (the so-called referrer), which sub-pages were visited, or how often and for what duration a sub-page was viewed. Analytics are mainly used for the optimisation of a website and in order to carry out a cost-benefit analysis of digital advertising.

The operator of the Google Analytics component is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, United States of America.

For the analytics, through Google Analytics the controller uses the application “_gat. _anonymizeIp”. By means of this application, the IP address of the connection of the data subject is abridged by Google and anonymised when accessing our websites from a Member State of the European Union or another Contracting State to the Agreement on the European Economic Area.

The purpose of the Google Analytics component is to analyse the traffic on our website. Google uses the collected data an