Privacy Policy

1. General

This website is owned and operated by HG Innovation Limited (HG Innovation).

In this Privacy Policy, references to 'we', 'us' or 'our' are references to HG Innovation, and any reference to 'you', 'your' and 'yourself' is a reference to you as an individual who has a relationship with us or is in contact with us.

This Privacy Policy applies to you whenever you provide your personal data to us, including when you access [WEBSITE] (the "Website"), [shop with us in-store] or online or access our social media platforms.

Personal data includes any information allowing us to identify you as an individual, for example, your name, your email address or your telephone number. This Privacy Policy provides details in accordance with applicable data protection laws about how we collect, store, use and protect your personal data.

2. Your Privacy

Imiracle respect your privacy and are committed to protecting your personal data. We will use your personal data in accordance with all applicable laws and regulations that relate to data protection and privacy in the United Kingdom, including the UK General Data Protection Regulation ("UK GDPR") and the Data Protection Act 2018.

Unless otherwise stated, for the purposes of the applicable data protection laws in the United Kingdom, Imiracle are controllers in respect of your personal data collected via this website. In some instances, Imiracle will act as joint controllers of your personal data, and in others, Imiracle will act as separate and independent controllers of your personal data. Please see section 5 below for further detail regarding the different purposes for which we process your personal data as joint and separate controllers.

When using our Website, we will also place cookies on your device. Please see our Cookie Policy and section 10 below for more information about the cookies we use and how you can change your cookie settings. 

Please note, our supply of products (whether in store or online), our Website, our social media and other services we provide are not intended for use by anyone under the age of 18 years old and we do not knowingly collect personal data relating to anyone under the age of 18 years old.

If you are under the age of 18, you are not permitted to use our Website or access our products or services through any other available channel.

3. [What personal data we collect about you]

Depending on how you use our Website and which of our services and products you chose to use or buy, we collect the following types of personal data about you:

• your name
• your gender
• your birthday
• your email address
• your telephone number
• your shipping address
• your billing address
• your payment card information (including payment card number, expiration date, delivery address and billing address)
• your marketing preferences (i.e., whether you would like to receive information from us via email)
• commercial information, such as details of your orders and/or the products or services you have purchased, returned, or browsed, including your product preferences
• information contained in any communications with us, which includes emails and/or recordings of telephone calls when you contact us
• information about any devices you have used (including the manufacturer, model and operating system, IP address, browser type and mobile device identifiers)
• your location
• your social media account data
• online or network activity information, such as information regarding your interaction with our Website, digital properties, and advertisements, information about your browsing and search history on our Website and log file information which includes, but may not be limited to, your browser type, webpages you visit, and other electronic network activity
• audio information, such as recordings of your voice when you call our customer service team

4. How we obtain your personal data

We may collect or receive your personal data in the following ways:

• when you register an account with us;
• where you provide it to us directly, for example contact us or subscribe to receive our newsletter; and
• where we monitor your use of, or interactions with, our Website.

5. How we use your personal data

We will only use your personal data where we are permitted to do so by applicable data protection laws.

We have set out below the purposes for which we may process your personal data, and the legal basis that we rely on to do so:

Purpose of Processing	Our Legal Basis
To enable you to successfully order any of our products and process your payment information. We act as a separate, independent controller for this purpose.	Contractual necessity we use your personal data to meet our obligations under and fulfil our sales contract with you (for example, to deliver a product you have ordered).
To communicate with you about your order. We act as a separate, independent controller for this purpose.	Contractual necessity we use your personal data in order to meet our obligations under our contract with you (for example, to deliver a product you have ordered).
To respond to you and answer your queries or complaints. We act as a separate, independent controller for this purpose..	Legitimate interests we use your personal data to communicate with you and answer your query or complaint.
To monitor details of your visits to our Website(s) (including page views) for business and data analysis purposes. We act as a separate, independent controller for this purpose..	Legitimate interests we use your personal data to help us deliver the best quality of service to you and our other customers. Consent we may also use your personal data for this purpose where we have obtained your consent to do so.
To carry out security checks to protect against fraudulent transactions and to prevent and detect criminal activity. We act as a separate, independent controller for this purpose.	Legitimate interests we use your personal data to protect against unlawful activities. In some cases, we may also be under a legal obligation to disclose your personal data (for example, to law enforcement agencies).
To address any claims made against us. We act as a separate, independent controller for this purpose.	Legal proceedings we use your personal data to address any claims that are made against us. In some cases, we may also be under a legal obligation to use or disclose your personal data.
To comply with any legal obligation (including in connection with a court order). We act as a separate, independent controller for this purpose.	Legal obligation we use your personal data to comply with our legal obligations.
To improve our Websites and your customer experience. We act as a separate, independent controller for this purpose.	Legitimate interests we use your personal data to help us improve your experience on our Website(s). We also analyse Website browsing behaviour and ad effectiveness (including on third-party websites). Consent we may also use your personal data for this purpose where we have obtained your consent to do so.
To send you our newsletter whenever you subscribe. We act as a separate, independent controller for this purpose.	Consent we use your personal data to send you our newsletter only where we have obtained your consent to do so.
To manage cookies on our Websites. We act as a separate, independent controller for this purpose.	Consent we use cookies to improve the experience of visitors to our Websites, analyse site usage, and assist in our marketing efforts.

 

Where we process information on the basis that it is in our legitimate interests as a business to do so, we will consider your interests also. We will weigh up our business interests with your interests to ensure they are fairly balanced.

6. How long we keep your personal data

We will retain your personal data only for as long as is necessary to fulfil the purposes for which we are using it and where the respective legal basis applies, in accordance with our retention policy.

The period for which we keep your personal data will be determined by a number of criteria, including the purposes for which we are using it, the amount and sensitivity of the information, the potential risk of any unauthorised use or disclosure of the information, and whether we have a legal and/or regulatory obligation to retain it.

7. How we secure your information

We take great care in maintaining the security of our Website and your personal data. To ensure that we keep your information secure we use technical security measures such as encryption, access controls, firewalls and logging, and we have organisational security controls in place such as security policies and procedures and third-party supplier risk assessments. To take full advantage of all security features available to you, you should use an up-to-date browser.

8. Who we share your personal data with

We may share your personal data with other members of the HG Innovation group on a need-to-know basis when required for our business to function. Where a legal basis exists to do so, members of the HG Innovation group may also use the personal data we share with them to improve their websites or applications (e.g. EB Mate), for aftersales purposes, member management purposes, analysis purposes and to offer you products that they believe may be of interest to you.

We may need to share certain personal data if we receive a request for information from a government department, the police or other enforcement agency. If this happens, we will ensure that there is a proper legal basis for providing your personal information to the organisation asking for it before doing so.

We may also disclose your personal data to certain third-party service providers to carry out certain activities on our behalf. We require any such third parties to treat your personal data as confidential and to fully comply with all applicable data protection laws, and we conduct a full assessment of these third parties' processes and procedures prior to sharing any data. Examples of our third-party service providers include:

• Shipping service providers such as [UPS or Parcelforce UK1(Next Working Day)]. When you place an order on our Website, we share certain personal data with third party shipping service providers to fulfil and deliver your order.
• Cloud service providers such as [Amazon Web Services (AWS)]. When using our Website, we share certain personal data with our cloud service providers to ensure that your data is kept secure.
• IT service providers. We share certain personal data with our IT service providers to keep our systems secure. Each of the external companies we work with has been selected by us for their ability to provide what we need to our required specification, including their ability to handle data (including your personal data) securely and appropriately.
• Web analytics service providers such as [Google Analytics]. When using the Website, we share certain personal data with our web analytics service providers to improve your user experience.
•  Marketing tool providers such as Mailchimp. When using our Website, we share certain personal data with our email marketing provider to create and share personalised email marketing with you where you have opted in to receive such marketing.
• Location tool providers such as Google Map. When using Store Locator, we may share certain personal data with the location tool provider to find your location and recommend nearby stores to you.

These third-party service providers have access to the personal data needed to perform their functions but may not use it for other purposes. We may use the information we receive from third parties to supplement, improve and add to our database of customer details, for purposes such as fraud prevention.

We may also share your information with other partners when we have your express consent to do so.

9. Where your personal data will be processed

Your personal data may be transferred to, and stored and processed in, one or more countries outside of the UK, including countries which do not provide equivalent protection for personal data.

In these circumstances, we will take reasonable steps and implement appropriate measures to ensure that your personal data is adequately protected in accordance with applicable data protection laws (including the UK GDPR and Data Protection Act 2018).

These measures generally include:

• where the transfer is to a country that has been deemed to provide an adequate level of protection under applicable data protection laws; 
• where the recipient of the transfer has agreed to an approved data transfer agreement in the form of the UK International Data Transfer Agreement; or
• where the transfer is otherwise permitted by applicable data protection laws.

To address concerns about transfers from the UK to countries not considered adequate by the UK, we have implemented appropriate measures to protect your personal data. Please contact us using the details in section 13 below if you want further information on the specific safeguards which we use when transferring your personal data out of the UK.

10. Links to third party sites

From time to time, we may provide links to other sites on our Website. This Privacy Policy only covers our Website and it does not cover links to other sites nor information collected by parties that own and control those sites or their use of cookies when you leave our Websites. 

This Privacy Policy does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating any website or service to which our services link. The inclusion of a link on our Website does not imply endorsement of the linked site or service by us or by our affiliates. In addition, we are not responsible for the information collection, use, disclosure, or security policies or practices of other organisations, such as Facebook, Apple, Google, Microsoft, or any other application developer, application provider, social media platform provider, operating system provider, wireless service provider, or device manufacturer, including with respect to any personal data you disclose to other organisations through or in connection with the applications or our social media pages.

11.Cookies and similar technologies

Cookies are small text files that are stored on your computer or other device by websites that you visit. This Website uses cookies in order to make it easier to use, to support the provision of information and functionality to you, as well as to provide us with information about how the Website is used so that we can make sure it is as up to date and as accurate as we can. We also use cookies to assess whether our online adverts reflect the interests of our Website users.

Further information about the types of cookies that are used on our Website is set out below:

Essential cookies	These cookies are essential for the use of the features and services on our Website. If you block these cookies, we cannot guarantee access to the services provided through our Website or be sure how the Websites will perform during your visit.
Functional cookies	These cookies allow our Website to remember choices you make, such as your log in details or language preferences, and any customisations you make to pages on our Websites during your visit.
Performance & Analytics cookies	These cookies help us understand how people use our Website. They collect information such as which pages on our Website visitors go to most often, which features they use, and which websites people have visited before they visit ours. We use this information to improve our Website and provide a better user experience.

 

12. Your Rights

Under certain circumstances and in accordance with the applicable data protection laws, you may have the right to ask us to:

• Confirm what personal data we hold about you and provide you with a copy of that data.
• Correct any personal data that is inaccurate.
• Remove your personal data where there is no good reason for us to continue to hold it.
• Temporarily stop using your personal data where you are questioning or objecting to our right to use that data (and in other limited circumstances where that right is applicable) based on legitimate interests.
• Stop using your personal data (unless we can demonstrate a valid reason why we need to continue to use that data, for example, in respect of a product warranty).
• Provide you with the personal data that you have provided to us, in a structured and commonly-used electronic format, or transmit that information directly to another company if that is technically feasible. This applies where we are using your personal data on the basis of your consent or because it is necessary to perform a contract with you (see section 5 above).

If you have any questions about our use of your personal data, please contact us using the details provided in section 13 below.

Please note, our security procedures mean that we may request proof of identity before we are able to disclose your personal data to you or comply with other requests.

Right not to be subject to automated decision-making, including profiling

Automated decision-making takes place when an electronic system uses an individual's personal data to make a decision about that individual without any human intervention which then produces legal effects concerning or significantly affects that individual. We do not currently use this type of automated decision making in our business in relation to you.

However, we do use automated processing so that we can show you personalised adverts whilst browsing our Website. Your personal data may be processed with automated methods to understand which shops you usually purchase our products, whether you have made a purchase recently, which products you purchase and/or which products you might be interested in hearing about in future. This data may include things like your age, gender and purchasing history or preferences. 

Right to lodge a complaint with a supervisory authority

Without prejudice to any other administrative or judicial remedy, you also have the right to make a complaint to the supervisory authority if you’re not happy with how we’ve handled your personal information. 

For further information on your right to lodge a complaint with a supervisory authority in the UK, please visit the ICO website at: https://ico.org.uk/make-a-complaint/data-protection-complaints/data-protection-complaints/ 

13. How to contact us

If you have any questions about this Privacy Policy or how we process your personal data, please contact us via the contact details listed below:

Imiracle

Name: [lukey.he] (Imiracle Data Protection Officer) Email: [lukey.he@heavengifts.com]

14. Changes to this Privacy Policy

The LAST UPDATED text at the top of this Privacy Policy indicates when it was last revised. 

Any changes will become effective when we post the revised Privacy Policy on this website’s home page. We recommend that you re-visit this policy from time to time to learn of any such changes.