SHIELD SOAP PRIVACY STATEMENT

Welcome to our privacy statement.

Summary

We respect your privacy and we are committed to protecting your personal data. This privacy statement will inform you how we use and look after your personal data when you are a Shield Soap customer or you:

Visit our website: https://www.shieldsoap.co.uk (regardless of where you visit it from) (“our site”).
Call us, write to us, or communicate with us in any way in relation to Shield Soap.

This statement also tells you about your privacy rights and how the law protects you.

When we say “we”, “us” or “Ceuta” that means the company Ceuta Healthcare Ltd. When we say “Shield” or “Shield Soap” that refers to the product and brand that is owned by Ceuta. Ceuta is part of a wider group of companies. The Ceuta Group of Companies is made up of different companies, details of which can be found here [http://www.ceutagroup.com/about/our-companies/]: This Shield Soap privacy statement is issued on behalf of Ceuta. If your communications with us relate to other Ceuta Group companies or Ceuta Group brands then we will, where appropriate, pass your personal data to them so they can handle your enquiry. Their specific privacy statement will also apply to how they process your data.

Where we collect information about you, if that information is about you, or can be used by us or organisations with which we work, to find out about you, it is known as “personal data”.

The law says that we have to tell you what types of personal data we have about you, what we use it for, why we are allowed to use it in that way, and what your legal rights are. That is what this document – called a “privacy statement” – is for. We also have to tell you some other things – those are all covered in this statement.

The rules about personal data are detailed and can be difficult to understand. If you need help understanding anything in this policy, please contact us at dataprotection@ceutagroup.com.

The simple version is this:

We collect information about you, including contact details (like your email address), when you give us that information on our site, when you call us, or communicate with us.
We treat all information we have about you very carefully. We do our best to make sure that information about you does not go to the wrong people or to people who might not look after that information properly.
If you ask us to do certain things with information about you, we usually have to do what you ask and you do not usually have to pay for this. Those things include:
- Give you a copy of information about you
- Put right any mistakes in the information we have about you
- Stop using or delete information about you

If you want to ask us to do any of these things, or you have any questions or worries, you can contact us at dataprotection@ceutagroup.com. You can also contact the organisation in charge of making sure we do the right things with your personal data – the Information Commissioner’s Office – by clicking here.

BACKGROUND

This policy is addressed to individuals who visit our Site, our Shield Soap customers, and other individuals that may deal with us, including individuals at our suppliers in relation to Shield Soap. In this policy we collectively refer to these categories of individuals as “you”.

Our privacy statement is provided in a layered format so you can click through the links below to take you to the specific sections set out below. Alternatively, you can contact us to ask for a copy.

Please also use the Glossary to understand the meaning of some of the terms used in this privacy statement.

1. Important information and who we are

Purpose of this privacy statement

This privacy statement aims to give you information on how we collect and process your personal data when you:

Visit our website: https://www.shieldsoap.co.uk (regardless of where you visit it from) (“our site”);
Call us, write to us, or communicate with us in any way in relation to Shield Soap.

Our site is not intended for children and we do not knowingly collect data relating to children on our site. We may collect information about children when a parent or guardian communicates with us in other ways about Shield Soap and provides that information to us.

It is important that you read this privacy statement together with any other data protection or privacy statement that we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy statement supplements other notices and privacy policies relating to your interaction with us in relation to Shield Soap and is not intended to override them.

Controller

Ceuta Healthcare Ltd (registered company number 2974951 with its registered head offices at Hill House, 41 Richmond Hill, Bournemouth, BH8 0PZ is the controller and responsible for your personal data (referred to as “Ceuta”, “we”, “us” or “our” in this privacy statement).

When we say “we”, “us” or “Ceuta” that means the company Ceuta Healthcare Ltd. When we say “Shield” or “Shield Soap” that refers to the product and brand that is owned by Ceuta. Ceuta is part of a wider group of companies. The Ceuta Group of Companies is made up of different companies, details of which can be found here: This Shield Soap privacy statement is issued on behalf of Ceuta. If your communications with us relate to other Ceuta Group companies or Ceuta Group brands then we will, where appropriate, pass your personal data to them so they can handle your enquiry. Their specific privacy statement will also apply to how they process your data.

If you have any questions about this privacy statement, including any requests to exercise your legal rights, please contact the Data Privacy Manager using our contact details below.

Contact details

If you have any questions about this privacy statement or our privacy practices, please contact our Data Privacy Manager in the following ways:

Full name of legal entity: Ceuta Healthcare Ltd

Email address: dataprotection@ceutagroup.com

Postal address: Hill House, 41 Richmond Hill, Bournemouth, BH8 0PZ

Telephone number: 0344 243 6661

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 we would encourage you to contact us in the first instance to discuss these.

Changes to the privacy statement and your duty to inform us of changes

Any changes that we make to this policy in the future will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to our privacy policy.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

This site, and information that we may post on our site may include links to third-party websites, social media platforms, plug-ins and applications, for your convenience and information. Clicking on those links or enabling those connections means you may leave our site and may allow third parties to collect or share data about you. We do not control these third-party websites, or third-party social media accounts or apps, and are not responsible, or liable, for how they process your personal data or for their privacy statements. For example, they may send their own cookies to users, collect data or solicit personal data from you. When you leave our site, we encourage you to read the privacy statement of every website, app and social media account that you use or visit.

2. The data we collect about you

When you contact us through our site, or communicate with us in relation to Shield Soap, you may provide us with personal data about you.

Personal data means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

Special Categories of Personal Data (“SCPD”) 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).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data includes name, initials, age/ age range/ date of birth, Country and gender.
Contact Data includes address, email address, telephone numbers and fax number.
Transaction and Incident Data includes details about Shield Soap products you have purchased from us, our suppliers or distributors or supplied on our behalf; and details about any adverse events or incidents, product complaints or enquiries in relation to our Shield Soap products (whether that is reported by you as the product user, or you have treated someone in relation to use of our product (e.g. you are a pharmacist, doctor, nurse or similar practitioner). This will include:
- Identity Data and Contact Data relevant to the relevant incident;
- Details about any incidents relating to those products including:
  - What the incident was (this may include relevant Special Category Personal Data details (e.g. relating to your health, medical condition, adverse reactions to the product, death, life threatening, birth defects, pregnancy and due date, lactation, abuse, misuse, overdose, hospitalisation, other medication taken etc.).
  - Product details (including product name, type, pack size, expiry date, quantity taken, when and how), product quality, effectiveness etc.
  - Whether you/ the product user have/has been advised to see a doctor and/or have actually seen a doctor relating to the incident.
  - Your/ the product users doctor’s details (including their name, telephone number and address).
  - The consent that has been obtained for us to contact your/ the product users doctor in relation to the incident, including providing them with special category personal data relating to the incident (as set out above).
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our site.
- Usage Data includes information about how you use our site, our products and services.
- Communications Data includes personal data included in your communications with us.

We also collect, use and share Aggregated Data 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 thew 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 treat the combined data as personal data which will be used in accordance with this privacy statement.

We do not collect any information about criminal convictions and offences relating to you.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, or we are processing your personal data to fulfil a request you have made or incident you have reported to us in relation to the product, 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) or we may not be able to otherwise comply with your request or deal with that incident. In this case, we may have to cancel a product or service you have with us or we wouldn’t be able to handle your complaint or incident properly but we will use reasonable efforts to notify you if this is the case at the time.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity Data and Contact Data by filling in online or offline forms or by corresponding with us by post, phone, email, or otherwise. This includes personal data you provide when you:
enquire about our products or services;
provide us with Transaction and Incident data;
agree to participate in market research;
give us feedback or contact us.
Automated technologies or interactions. As you interact with our site, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our Cookie Policy for further details
Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
Technical Data from the following parties: analytics providers such as Google.
Third party healthcare professionals, such as doctors, nurses, pharmacists and other similar professionals.

4. How we use your personal data

We will only use your personal data when the law allows us to do so. Most commonly, we will use your personal data in the following circumstances:

Where we need to perform the contract we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal obligation.

To find out more about the types of lawful basis that we will rely on to process your personal data, refer to the Glossary at the end of this document.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sharing your personal data with your doctor.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/activity	Type of data	Legal basis for processing (including legitimate interest basis)
To manage our relationship with you including notifying you about changes to our terms or privacy statement.	(a) Identity (b) Contact (c) Communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
Responding to an enquiry or complaint, managing a reported product incident or completing incident reports which are reported to us	(a) Identity Data (b) Contact Data (c) Transaction and Incident Data	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to refer to on how customers use our products/services) (d) Consent
To enable you to complete a survey or market research	(a) Identity (b) Contact (d) Usage and (e) Communications	(a) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and our site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical (d) Communications Data	(a) Necessary for our legitimate interests (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) (b) Necessary to comply with a legal obligation
To use data analytics to improve our site, products/services, customer relationships and experiences	(a) Technical (b) Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our site updated and relevant, to develop our business and to inform our marketing strategy)

Automated Decision-Making

We do not make any decisions which could have a legal effect, or other significant effect on you, based solely on automated processing of your personal data.

Marketing

We do not use any personal data collected through our site or in the other ways set out in this Privacy Statement, to carry out any marketing and do not share any such personal data with third parties, including intra-group, for marketing purposes.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our site may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

If you would like to understand more about any of our purposes or, you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures of your personal data

All of our contractors, suppliers and staff (including volunteers, agents, temporary workers and casual workers) who process your personal data on our behalf (and therefore act as our processors) are subject to strict contractual requirements in relation to processing personal data.

We may share your personal data with the parties set out below for the purposes set out in the table Purposes for which we will use your personal data above.

Internal Third Parties as set out in the Glossary
External Third Parties as set out in the Glossary
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 business, then the new owners may use your personal data in the same way as set out in this privacy statement.

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 instructions.

6. International transfers

We do not transfer your personal data outside the United Kingdom or the European Economic Area (EEA).

7. Data security

We have a strong commitment to data security.

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We take appropriate steps to communicate and train our staff in relation to applicable data protection law.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to or via our site; any transmission is at your own risk.

If you would like to know more about our data security measures please contact us.

8. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us/ set out above.

By law we have to keep basic information about our customers for six years after they cease being customers for tax purposes.

We also keep records in the event of an adverse event/ incident or product complaint for as long as the product is part of our current portfolio plus 10 years and could be asked to refer those details to the regulatory authorities in relation to adverse reaction.

In some circumstances you can ask us to delete your data: see your legal rights below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data which we process as a controller. These rights are subject to specific requirements and limitations set out in the applicable data protection legislation and are summarised below:

Request access to the personal data that we hold about you and to check that it is being lawfully processed (commonly known as a “data subject access request”)
Request correction of the personal data that we hold about you if it is wrong and to complete it if it is incomplete.
Request erasure of your personal data, but we will retain your data for the purposes of dealing with any claims or where we have another legitimate reason to retain it.
Object to processing of your personal data – for example if we are processing it on the basis of a legitimate interest and that does not override your individual rights.
Request the restriction of processing of your personal data – you may, for example, want to do this while we consider your request to have it corrected.
To understand how and why we are processing your personal data, the legal basis for that processing, who we have disclosed it to and who we will disclose it to (which we have provided in this privacy statement).
To receive a copy of your personal data (or have it passed to a third party) in a common and structured electronic format (where the legal basis for our processing is your consent, or the processing is necessary for the performance of our contract with you).
To stop using your personal data for direct marketing.
Withdraw your consent to the processing of your personal data at any time if the lawful basis of the processing is your consent

If you wish to exercise any of the rights set out above, please Contact Us

You also have the right to complain to the Information Commissioner’s Office about our processing or our response to your requests and objections- www.ico.org/concerns/ or 0303 123 1113.

No fee usually required

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, or refuse your request, if your request is clearly unfounded, repetitive or excessive.

What we may need from you

We may need to request proportionate information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit 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.

10. Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

THIRD PARTIES

Internal Third Parties

None

External Third Parties

Service providers acting as processors based in the United Kingdom who provide IT and system administration services and our specialist regulatory advice supplier.
Professional advisers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, legal and insurance.
HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.
The Shield Soap manufacturer, where that is necessary for us and them to handle an adverse event/ incident or product complaint.

YOUR LEGAL RIGHTS

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

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 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.

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.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

If you want us to establish the data’s accuracy.
Where our use of the data is unlawful but you do not want us to erase it.
Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time 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.

Ceuta Healthcare Ltd is a company registered in England. Registered number: 2974951. Registered address: Hill House, 41 Richmond Hill, Bournemouth. BH2 6HS. VAT no. 684784084