PRIVACY POLICY
We value your privacy and are committed to protecting it. At Browtasia, our approach is to handle your personal information responsibly and in line with relevant laws and regulations. This applies to any details we collect through our website, https://www.browtasia.com, as well as any other platforms we manage.
Personal information refers to any data that can identify you as an individual. This may include details such as your name, contact information, date of birth, payment information, the devices you use, and how you interact with our website or online services.
Please note that our website may include links to third-party sites or services. These external sites are not covered by our Privacy Policy, and we recommend reviewing their own policies to understand how they handle your information. Once you leave our website, their terms and practices will apply instead of ours.
This Privacy Policy took effect on 9 October 2023.
Last reviewed and updated: 9 October 2023.
INFORMATION WE COLLECT
The information we gather generally falls into two types: information you give us directly and information we collect automatically.
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Information you provide directly includes any details you intentionally share with us, such as when you sign up for services, take part in promotions, or otherwise engage with our brand.
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Information collected automatically refers to data your devices send to us on their own while you access or use our website, products, or services.
When you visit our website, our servers may automatically record information that your web browser typically provides. This can include details such as your device’s IP address, browser type and version, the pages you view, the date and time of your visit, how long you spend on each page, and other similar information about your browsing activity.
If you experience certain errors while using the site, we may also capture data related to the error and the circumstances in which it occurred. This might involve technical details about your device, what action you were taking at the time, and other diagnostic information. You may not always be notified when such data is collected, even if the error occurs in real time.
Please note that while this information on its own does not usually identify you personally, it may be possible to connect it with other data to identify you.
LOG DATA
PERSONAL INFORMATION
We may request certain personal details from you: for example, when you sign up for our newsletter or reach out to us directly. The information we collect could include:
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Full name
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Email address
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Social media handles or profiles
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Date of birth
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Contact number (phone or mobile)
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Residential or mailing address
We collect and use your personal information solely when we have a valid reason to do so. In such cases, we limit the collection to only what is reasonably necessary to deliver our services to you.
LEGITIMATE REASONS FOR PROCESSING YOUR PERSONAL INFORMATION
We may collect personal information from you in a variety of ways when you interact with our website, including when you:
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Create an account
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Take part in competitions, contests, surveys, or sweepstakes
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Subscribe to updates through email or social media
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Access our content via a mobile device or web browser
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Contact us through email, social platforms, or similar communication tools
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Tag, mention, or interact with us on social media
We may collect, store, use, and share this information for the following purposes. Your data will not be processed in ways that are incompatible with these purposes:
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To provide the essential features and functionality of our platform
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To personalise and tailor your experience on our site
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To fulfil product orders and deliver services to you
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To stay in touch and communicate with you directly
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To support analytics, research, and business development, including improving our website, apps, and social channels
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To run marketing campaigns and share promotional content about our own products or carefully selected third parties we believe may interest you
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To maintain accurate records and manage administrative tasks
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To operate competitions, sweepstakes, or provide additional benefits
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To comply with legal requirements and resolve disputes if they arise
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To credit or attribute content you share (such as comments or posts) that we publish on our website
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To carry out technical checks and improvements to our website, apps, and digital platforms
In some cases, we may combine personal information you’ve provided with data collected automatically or insights gathered from trusted external sources. For instance, we may merge market research findings with information about how users interact with our site in order to refine and improve your overall experience.
COLLECTION AND USE OF INFORMATION
When we collect, process, and store personal information, we take commercially reasonable measures to safeguard it against loss, theft, unauthorised access, disclosure, copying, misuse, or alteration.
While we make every effort to protect the information you share with us, please be aware that no method of electronic transmission or storage can ever be completely secure. As such, we cannot guarantee absolute protection of your data.
You are also responsible for helping keep your information secure—for example, by choosing strong, unique passwords and keeping them confidential when accessing your accounts or personal details through our services.
SECURITY OF YOUR PERSONAL INFORMATION
We will retain your personal data only for as long as is necessary to fulfil the purposes for which it was collected, as set out in this Privacy Policy, and to comply with our legal, regulatory, and contractual obligations. The specific retention period may vary depending on the context in which the information was provided. For example, where you have created an account, we will keep your details for as long as your account remains active.
When personal data is no longer required, we will ensure it is securely deleted or irreversibly anonymised so that you can no longer be identified from it.
Nonetheless, we may retain your personal information if required to comply with legal, regulatory, or accounting obligations, or for purposes of public interest archiving, scientific or historical research, or statistical analysis.
HOW LONG WE KEEP YOUR PERSONAL INFORMATION
CHILDREN'S PRIVACY
We use "cookies" to gather information about your activity on our website. A cookie is a small file stored on your device that is accessed each time you visit, allowing us to understand how you interact with our site. This helps us provide content and experiences tailored to your preferences.
For more details, please see our Cookie Policy.
USE OF COOKIES
In the event that Browtasia or its assets are acquired, or if we cease operations or enter bankruptcy, personal information we hold may be included among the assets transferred to the acquiring party. You acknowledge that such a transfer may occur, and that any successor entity may continue to process your personal information in accordance with this Privacy Policy, as permitted by applicable law.
BUSINESS TRANSFERS
Our website may contain links to third-party sites that we do not operate. Please note that we have no control over the content or privacy practices of these external sites and cannot be held responsible for how they handle your personal information.
LIMITS OF OUR POLICY
At our discretion, we may change our privacy policy to reflect updates to our business processes, current acceptable practices, or legislative or regulatory changes. If we decide to change this privacy policy, we will post the changes here at the same link by which you are accessing this privacy policy.
If the changes are significant, or if required by applicable law, we will contact you (based on your selected preferences for communications from us) and all our registered users with the new details and links to the updated or changed policy.
If required by law, we will get your permission or give you the opportunity to opt in to or opt out of, as applicable, any new uses of your personal information.
CHANGES TO THIS POLICY
Where you give us consent to collect and use your personal information for a specific purpose. You may withdraw your consent at any time using the facilities we provide; however this will not affect any use of your information that has already taken place. You may consent to providing your name and contact details for the purpose of entering a giveaway or promotion. While you may withdraw your entry at any time, this will not affect any selection or judging that has already taken place. If you have any further enquiries about how to withdraw your consent, please feel free to enquire using the details provided in the Contact Us section of this privacy policy.
For any questions or concerns regarding your privacy, you may contact us using the following details:
Our products and services are not intended for children under the age of 13, and we do not knowingly collect personal information from anyone under 13.
DISCLOSURE OF PERSONAL INFORMATION TO THIRD PARTIES
We may share your personal information with the following parties:
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Any parent, subsidiary, or affiliated company
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Third-party service providers who help us deliver our services, including but not limited to IT providers, data storage and hosting services, advertising networks, analytics tools, error monitoring services, debt recovery agencies, maintenance or technical support providers, professional advisors, and payment processors
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Our employees, contractors, and related entities
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Existing or potential business partners or agents
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Sponsors or promoters of any competitions, sweepstakes, or promotions we operate
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Credit reporting agencies, courts, tribunals, and regulatory bodies if you fail to pay for goods or services provided
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Law enforcement, courts, tribunals, and regulatory authorities when required by law or to protect, exercise, or defend our legal rights
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Third parties, including agents or subcontractors, who assist in providing information, products, services, or direct marketing to you
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Third parties involved in data collection or processing on our behalf
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Any entity that acquires, or to which we transfer, all or substantially all of our business or assets
YOUR RIGHTS AND CONTROLLING YOUR PERSONAL INFORMATION
Your Choice: By providing us with personal information, you acknowledge and agree that we may collect, store, use, and disclose it in accordance with this Privacy Policy. You are not required to provide personal information; however, withholding it may limit your ability to access certain features, products, or services on our website.
Information from Third Parties: If we obtain personal information about you from a third party, we will treat it in accordance with this Privacy Policy. If you are providing personal information about another person, you confirm that you have obtained their consent to share their information with us.
Marketing Consent: If you have previously consented to receive marketing communications from us, you may withdraw your consent at any time by contacting us using the details provided below.
Access to Your Data: You have the right to request information about the personal data we hold about you.
Correction: If you believe any personal information we hold is inaccurate, outdated, incomplete, irrelevant, or misleading, please contact us. We will take reasonable steps to correct any information found to be inaccurate or incomplete.
Non-Discrimination: Exercising your data protection rights will not result in discrimination. Unless your personal information is essential to provide a particular service or offer (e.g., user support), we will not deny you products or services, charge different prices, or provide a lower level of service for exercising your rights.
Data Breach Notification: We will comply with applicable laws regarding the notification of personal data breaches.
Complaints: If you believe we have violated any data protection law, you may file a complaint by contacting us with full details of the issue. We will investigate promptly and provide a written response outlining the outcome and any corrective actions. You also have the right to contact a relevant data protection authority regarding your complaint.
Unsubscribing/Opt-Out: To unsubscribe from our mailing list or opt out of communications, including marketing messages, please use the contact details provided below or the opt-out mechanism included in the communication. We may request information to verify your identity before processing your request.
ADDITIONAL DISCLOSURES FOR GENERAL DATA PROTECTION REGULATION (GDPR) COMPLIANCE (EU)
Data Controller / Data Processor
The GDPR distinguishes between organisations that process personal information for their own purposes (known as "data controllers") and organisations that process personal information on behalf of other organisations (known as "data processors"). We, A Selfish Soul Ltd., located at the address provided in our Contact Us section, are a Data Controller and/or Processor with respect to the personal information you provide to us.
Legal Bases for Processing Your Personal Information
We will only collect and use your personal information when we have a legal right to do so. In which case, we will collect and use your personal information lawfully, fairly, and in a transparent manner. If we seek your consent to process your personal information, and you are under 16 years of age, we will seek your parent or legal guardian’s consent to process your personal information for that specific purpose.
Our lawful bases depend on the services you use and how you use them. This means we only collect and use your information on the following grounds:
CONSENT FROM YOU
PERFORMANCE OF A CONTRACT OR TRANSACTION
When you enter into a contract or transaction with us, or when we take steps in preparation for doing so, we may need to collect personal information. For example, if you contact us with an enquiry, we may require your name and contact details to provide a response.
OUR LEGITIMATE INTERESTS
Where we assess it is necessary for our legitimate interests, such as for us to provide, operate, improve and communicate our services. We consider our legitimate interests to include research and development, understanding our audience, marketing and promoting our services, measures taken to operate our services efficiently, marketing analysis, and measures taken to protect our legal rights and interests.
COMPLIANCE WITH LAW
In some cases, we may have a legal obligation to use or keep your personal information. Such cases may include (but are not limited to) court orders, criminal investigations, government requests, and regulatory obligations. If you have any further enquiries about how we retain personal information in order to comply with the law, please feel free to enquire using the details provided in the Contact Us section of this privacy policy.
INTERNATIONAL TRANSFERS OUTSIDE OF THE EUROPEAN ECONOMIC AREA (EEA)
We will ensure that any transfer of personal information from countries in the European Economic Area (EEA) to countries outside the EEA will be protected by appropriate safeguards, for example by using standard data protection clauses approved by the European Commission, or the use of binding corporate rules or other legally accepted means.
YOUR RIGHTS AND CONTROLLING YOUR PERSONAL INFORMATION
Restrict: You have the right to request that we restrict the processing of your personal information if (i) you are concerned about the accuracy of your personal information; (ii) you believe your personal information has been unlawfully processed; (iii) you need us to maintain the personal information solely for the purpose of a legal claim; or (iv) we are in the process of considering your objection in relation to processing on the basis of legitimate interests.
Objecting to processing: You have the right to object to processing of your personal information that is based on our legitimate interests or public interest. If this is done, we must provide compelling legitimate grounds for the processing which overrides your interests, rights, and freedoms, in order to proceed with the processing of your personal information.
Data portability: You may have the right to request a copy of the personal information we hold about you. Where possible, we will provide this information in CSV format or other easily readable machine format. You may also have the right to request that we transfer this personal information to a third party.
ADDITIONAL DISCLOSURES FOR UK GENERAL DATA PROTECTION REGULATION (UK GDPR) COMPLIANCE (UK)
Data Controller / Data Processor
Under GDPR, a “data controller” is an organisation that determines the purposes and means of processing personal information, while a “data processor” handles personal information on behalf of another organisation. For the purposes of this Privacy Policy, Browtasia acts as a Data Controller for the personal information you provide to us and complies with all applicable data controller obligations under GDPR.
Personal Information from Third Parties
We may receive personal information about you from third parties who have your consent to share it with us. For example, if you purchase a product or service through a partner business and provide permission for us to use your details to complete the transaction.
We may also collect information that is publicly available, such as details from social media or messaging platforms. The availability of this data depends on both the platform’s privacy policies and your personal privacy settings.
Additional Uses of Personal Information
Beyond the purposes described above, we may use your personal information for marketing and market research, including analysing how visitors use our website, identifying areas for improvement, and enhancing user experience.
Retention and Anonymisation of Personal Information
If your personal information is no longer necessary for the purposes outlined, or if you exercise your rights under GDPR, we will securely delete it or anonymise it so you can no longer be identified.
However, we may retain personal information where necessary to comply with legal, accounting, or reporting obligations, or for purposes such as public interest archiving, scientific or historical research, or statistical analysis.
LEGAL BASES FOR PROCESSING YOUR PERSONAL INFORMATION
Under data protection and privacy laws, we may collect and use your personal data only on specific legal grounds. When we do so, we ensure your information is handled lawfully, fairly, and transparently. We do not directly market to anyone under 18 years of age.
The lawful basis for processing your data depends on the services you use and how you interact with us. These include:
1. Consent
Where you give us explicit consent to collect and use your personal information for a specific purpose, you may withdraw your consent at any time. This does not affect any processing carried out before withdrawal. For example, when you contact us, you provide consent for your name and email address to be used so we can respond. Similarly, if you agree to receive marketing communications, we will only send these while your consent remains valid. While you can request deletion of your contact details, emails already sent cannot be recalled.
2. Performance of a Contract
Where you enter into a contract or transaction with us, or take steps prior to entering one, we may process your personal information as necessary. For instance, we may require your name and contact details to respond to an enquiry.
3. Legitimate Interests
We may process your data when necessary for our legitimate interests, such as to operate, maintain, improve, and communicate our services. Legitimate interests include research and development, understanding our audience, marketing, analysing usage, and protecting our legal rights.
4. Legal Obligations
In certain situations, we may need to process or retain your personal information to comply with legal, regulatory, or government requirements. This may include court orders, criminal investigations, or statutory record-keeping obligations, such as retaining financial records for seven years.
International Transfers of Personal Data
Your personal data is stored and processed in the United Kingdom, which provides a level of protection comparable to UK GDPR.
Where we share data with third parties located outside the UK or European Economic Area (EEA), we ensure appropriate safeguards are in place, such as Standard Contractual Clauses (SCCs) or binding corporate rules, in line with the UK GDPR (Article 45).
Your Data Subject Rights
You have the following rights under GDPR:
Right to Restrict Processing: You may request that we limit how your personal data is processed if you believe it is inaccurate, unlawfully processed, needed only for legal claims, or pending consideration of your objection regarding legitimate interests.
Right to Object: You can object to the processing of your personal data based on legitimate interests or public interest. We must demonstrate compelling grounds to continue processing if you object.
Right to be Informed: You have the right to understand how we collect, process, share, and store your data.
Right of Access: You may request a copy of the personal information we hold about you by submitting a Data Subject Access Request (DSAR). We will respond within 30 calendar days.
Right to Erasure: In certain circumstances, you can request that we delete your personal data, including when it is no longer necessary, consent has been withdrawn, data is used for direct marketing and you object, or legislation requires deletion.
Right to Data Portability: You can request your data in a structured, machine-readable format and, where technically feasible, request transfer to another organisation. This right only applies to data you have directly provided to us electronically.
Right to Rectification: You may request correction or completion of any inaccurate or incomplete personal data we hold about you. This only applies to your own data.
Notification of Data Breaches: In the event of a data breach, we will investigate and notify the relevant authorities and, where appropriate, affected individuals in compliance with UK GDPR.
Complaints: You may lodge a complaint with the Information Commissioner’s Office (ICO) at any time (www.ico.org.uk). We encourage you to contact us first so we can address your concerns. Please provide full details of your complaint, and we will investigate promptly and respond in writing with the outcome and steps taken.
ENQUIRIES, REPORTS AND ESCALATIONS
If you have any questions about Browtasia’s privacy practices or wish to report a potential breach of your privacy, you can contact our Data Protection Officer using the contact details provided in the “Contact Us” section of this Privacy Policy.
If you are not satisfied with our response, you also have the right to raise your concern with the UK’s data protection authority, the Information Commissioner’s Office (ICO):
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire SK9 5AF
Telephone: 0303 123 1113 (local rate)
Website: www.ico.org.uk