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Privacy Policy

Privacy Policy

Sweat Guard Limited is a company within the Covestus group of companies. This  policy applies to all companies and trading divisions in the group.  

Covestus Limited is committed to protecting the privacy and security of personal data and we want you to feel assured about any information that you provide. This privacy policy explains how Covestus uses information that we collect about you  and your rights in relation to processing that information.

 It is important that you read this notice, together with any other documents we may provide when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.

 Your Legal Rights

 Personal data is data which relates to any living individual who can be identified from that data, or from that data and other information; such as an expression of opinion about the individual. The General Data Protection Regulation 2018 (GDPR) governs how personal data is managed by a "controller" or "processor". A data controller is a person (or business) who determines the way in which, personal data is processed. A data processor is anyone who processes personal data on behalf of the data controller (not including the data controller's own employees). A "Data Subject" is a person whose data is being processed.

 Covestus is both a controller and processor of personal data. This means that we are responsible for deciding how we hold and use personal information about you, whether you use our services directly or via a third-party.

 GDPR provides the following rights for you:

  • The right to be informed – COVESTUS must provide details (such as those provided in this privacy notice) of how COVESTUS processes information to the data subject. This information must be available at any time personal data is obtained.
  • The right of access – Data subjects have the right to know what information COVESTUS has in relation to them. Data subjects then have the right to access this information.
  • The right to rectification – Data subjects have the right request we update inaccurate or incomplete information that is being processed or stored by COVESTUS. We take reasonable steps to ensure that the information we hold about you is accurate and complete. However, if you do not believe this is the case, you can request for us to update or amend it.
  • The right to erasure – Data subjects have the right to request we delete any information COVESTUS have in relation to them. However, as a medical practice we also have a legal duty to retain medial records for a period of time in line with UK law and guidelines, or if we are bound by other legal obligations.
  • The right to restrict processing – Data subjects have the right to block or suppress COVESTUS processing their information. However, it may be necessary to keep your information in order to perform a task which is in the public interest or for the purposes of establishing, exercise or defending legal claims.
  • The right to data portability – Data subjects can request that COVESTUS make their information available to move, copy or transfer personal data easily from one environment to another.
  • The right to object – Data subjects can object to processing their information for activities such as marketing.

 All of the above rights are available to you regarding your personal data used by Covestus.

 Who is Collecting my Personal Data?

 Company Details: Covestus Limited is the registered business name for the following trading divisions, companies and services:

 

  • CovGuard Limited
  • DHP Healthcare Limited
  • SweatGuard Limited

 

Covestus Company Registration Number: 11667150

Company Registered Address: 1, Pulteney Road, Bath BA2 4HD, UK

Administration Address: as above

Tel: 02045 134000
Email: support@covestus.com

 Any information collected or produced as part of these services will be managed in accordance with Covestus’ Information Security Policy.

 Covestus’s ICO Registration Certificate is available upon request.

 What Information is Collected?

 Personal data, or personal information, 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).

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

  • Identity Dataincludes first name, maiden name, last name, username or similar identifier, marital status, title, date of band gender.
  • Contact Dataincludes billing address, delivery address, email address and telephone numbers.
  • Financial Dataincludes bank account and payment details.
  • Transaction Dataincludes details about payments to and from you and other details of products and services you have purchased from us.
  • Service Dataincludes details which relate to the services you have enquired about or may require from us.
  • Technical Dataincludes 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 website.
  • Profile Dataincludes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
  • Usage Dataincludes information about how you use our website, products and services.
  • Marketing and Communications Dataincludes [your preferences in receiving marketing from us and our third parties and your communication preferences].

 We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the 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 notice.

 We do not collect Special Categories of Personal Data about you (as defined in GDPR) such as details about your race or ethnicity, religious or philosophical beliefs, political opinons, sex life, sexual orientation, information about your health and genetic and biometric data.

 How is my Personal Data Collected?

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

  • Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us via our websites: https://sweatguard.co.uk; https://www.covguard.com http://www.dhphealthcare.co.uk (our “Sites”), by post, by telephone, email or otherwise. This includes personal data you provide when you:
    • apply for our products or services;
    • create an account on our website;
    • subscribe to our service or publications;
    • request marketing to be sent to you;
    • enter a competition, promotion or survey; or
    • give us some feedback.
  • Automated technologies or interactions. As you interact with our website, we may 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.

 We collect Device Information using the following technologies:

  • “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.
  • “Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps. 
  • “Web beacons”, “tags”, and “pixels” are electronic files used to record information about how you browse the Site.

How do we use your Personal Data? 

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

  • Where we need to perform the service 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 or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us using the contact details provided in this policy document.

 We use the Identity, Contact, Financial, Transaction and Service Data that we collect generally to fulfil any orders placed through the Site including processing your payment information, arranging for shipping, and providing you with invoices and/or order confirmations. Additionally, we use this data to: 
- Communicate with you; 
- Screen orders for potential risk or fraud; and 
- When in line with the preferences you have shared with us, provide you with information or advertising relating to our products or services. 

We use the Technical, Profile and Usage Data that we collect to help us screen for potential risk and fraud, and more generally to improve and optimize our Site. 

 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

Lawful basis for processing including basis of legitimate interest

To register you as a new customer/client

(a) Identity
(b) Contact

Performance of a contract with you

To process and deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us

(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications

(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey

(a) Identity
(b) Contact
(c) Profile
(d) Marketing and 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)

To enable you to complete a survey

(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications

(a) Performance of a contract with you
(b) 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 website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Identity
(b) Contact
(c) Technical

(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 deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

To use data analytics to improve our website, products/services, marketing, 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 website updated and relevant, to develop our business and to inform our marketing strategy)

To make suggestions and recommendations to you about goods or services that may be of interest to you

(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile

Necessary for our legitimate interests (to develop our products/services and grow our business)

 

 

Sharing your Personal Data 

We may have to share your personal data with the parties set out below for the purposes set out in the table above to external Third Parties including:

  • Service providers acting as processors including business partners, suppliers and sub-contractors for the performance of any contract we enter into with you. This may include laboratories.
  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
  • Organisations providing IT systems support and hosting in relation to the IT systems on which your information is stored.
  • Third party service providers for the purposes of storage of information and confidential destruction, third party marketing companies for the purpose of sending marketing emails, subject to obtaining appropriate consent.
  • HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers who require reporting of processing activities in certain circumstances.
  • 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 notice.

 For example, we use Shopify to power our online stores and you can read more about how Shopify uses your Personal Data here: https://www.shopify.com/legal/privacy. We also use Google Analytics to help us understand how our customers use the Sites, you can read more about how Google uses your Personal Data here: https://www.google.com/intl/en/policies/privacy/. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout

 Please note that we do not alter our Site’s data collection and use practices when we see a Do Not Track signal from your browser. 

 Finally, we may also share your Personal Data to comply with applicable laws and regulations.

 Where a third party data processor is used, by using data sharing agreements we ensure that they operate under contractual restrictions with regard to confidentiality and security, in addition to their obligations under Data Protection Laws. 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.

 Many of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

 Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
  • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

 

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

 Additionally, please note that your information may be transferred outside of Europe, including to Canada and the United States. 

 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 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.

 Data Retention

 We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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 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.

 In some circumstances you can ask us to delete your data.

 In some circumstances we may 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.

 Changes 
We may update this privacy policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons. 

 This version was last updated on 28 October 2020.

Further Information / Contact us

 For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e‑mail at support@covestus.com  by post using the details provided below: 

Covestus, Privacy Compliance Officer, Covestus Ltd., 1 Pulteney Road, Bath, BA2 4HD, UK