Privacy Policy

BACKGROUND:

Round Square Ventures Ltd understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits this website, www.9active.com (“Our Site”) and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.

 

Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of this Privacy Policy is deemed to occur upon your first use of Our Site. If you do not accept and agree with this Privacy Policy, you must stop using Our Site immediately.

 

  1. Definitions and Interpretation 

In this Policy the following terms shall have the following meanings:  

 

“Account”

means an account required to access and/or use certain areas and features of Our Site;

“Cookie”

means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in Part 14, below; and

“Cookie Law”

means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;

 

  1. Information About Us

Our Site is operated by Round Square Ventures Ltd, a limited company registered in England under company number 07774289.

Registered address: 1-2 Broadgate, 2nd Floor, London EC2M 2QS, United Kingdom.

VAT number: GB231886789.

 

  1. What Does This Policy Cover?

This Privacy Policy applies only to your use of Our Site. Our Site may contain links to other websites. Please note that We have no control over how your data is collected, stored, or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to them.

 

  1. What Is Personal Data?

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

 

  1. What Are My Rights?

Under the Data Protection Legislation, you have the following rights, which We will always work to uphold:

        1. The right to be informed about Our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact Us to find out more or to ask any questions using the details in Part 15.
        2. The right to access the personal data We hold about you. Part 13 will tell you how to do this.
        3. The right to have your personal data rectified if any of your personal data held by Us is inaccurate or incomplete. Please contact Us using the details in Part 15 to find out more.
        4. The right to be forgotten, i.e. the right to ask Us to delete or otherwise dispose of any of your personal data that We hold. Please contact Us using the details in Part 15 to find out more.
        5. The right to restrict (i.e. prevent) the processing of your personal data.
        6. The right to object to Us using your personal data for a particular purpose or purposes.
        7. The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
        8. The right to data portability. This means that, if you have provided personal data to Us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask Us for a copy of that personal data to re-use with another service or business in many cases.
        9. Rights relating to automated decision-making and profiling.

For more information about Our use of your personal data or exercising your rights as outlined above, please contact Us using the details provided in Part 15.

It is important that your personal data is kept accurate and up-to-date. If any of the personal data We hold about you changes, please keep Us informed as long as We have that data.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about Our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact Us first, using the details in Part 15.

 

  1. What Data Do You Collect and How?

Depending upon your use of Our Site, We may collect and hold some or all of the personal and non-personal data set out in the table below, using the methods also set out in the table. Please also see Part 14 for more information about Our use of Cookies and similar technologies and Our Cookie Policy (https://www.9active.com/cookie-policy.html).

 

Data Collected

How We Collect the Data

Identity Information including name, title, date of birth, gender.

Account and order checkout pages.

Contact information including address, email address, telephone number.

Account and order checkout pages.

Business information including business name, job title, profession, business registration number, VAT number.

Seller registration, Account and order checkout pages.

Payment information including card details, bank account numbers.

Account and order checkout, Vendor pages.

Profile information including preferences, interests, login details, purchase history.

Account and order checkout pages, newsletter subscription, surveys/polls.

Technical information including IP address, browser type and version, operating system.

Google Analytics.

Data from third parties including technical information, contact information, profile information.

Google Analytics, Account and order checkout, and Vendor pages, newsletter subscription, surveys/polls.

 

  1. How Do You Use My Personal Data?

Under the Data Protection Legislation, We must always have a lawful basis for using personal data. The following table describes how We may use your personal data, and Our lawful bases for doing so:

 

What We Do

What Data We Use

Our Lawful Basis

Registering you on Our Site.

Email address, password

To provide access to Our Site. Option to use your email address to send you updates and/or news (which you can opt out from at any time).

Providing and managing your Account.

Name, address, email, date of birth, payment methods

Order fulfilment. Payments and refunds. Newsletter emails (which you can subscribe/unsubscribe from at any time). Special offers (which you can subscribe/unsubscribe from at any time).

Providing and managing your access to Our Site.

Name, address, email, date of birth, payment methods

To gain access to Our Site. Option to use your email address to send you updates and/or news (which you can opt out from at any time).

Personalising and tailoring your experience on Our Site.

Location, past order details

Customisation of top recommendations appearing on Our Site.

Administering Our Site.

Past order details, location, payment methods

Optimisation of Our Service.

Administering Our business.

Full personal details, contact details, past order details, payment methods

Order fulfilment. Accounting.

Supplying Our products AND/OR services to you.

Full personal details, contact details, past order details, payment methods

Order fulfilment. Accounting.

Managing payments for Our products AND/OR services.

Full personal details, order details, payment methods

Order fulfilment. Accounting.

Personalising and tailoring Our products AND/OR services for you.

Full personal details, contact details, past order details, payment methods

Product AND/OR service improvements.

Communicating with you.

Email, telephone number, address.

Order fulfilment. Dispute communication. Other communication according to what User has opted in for.

Supplying you with information by email that you have opted-in-to (you may opt-out at any time by choosing to do so in “My Account”.

Email address

Newsletter. Product updates. Site updates. Special offers.

 

With your permission and/or where permitted by law, We may also use your personal data for marketing purposes, which may include contacting you by email AND/OR telephone AND/OR text message AND/OR post with information, news, and offers on Our products AND/OR services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with Our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.

Third Parties (including Google Ads) whose content appears on Our Site may use third-party Cookies, as detailed below in Part 14. Please refer to Part 14 for more information on controlling cookies. Please note that We do not control the activities of such third parties, nor the data that they collect and use themselves, and We advise you to check the privacy policies of any such third parties.

We use the following automated systems for carrying out certain kinds of decision-making AND/OR profiling. If at any point you wish to query any action that We take on the basis of this or wish to request ‘human intervention’ (i.e. have someone review the action themselves, rather than relying only on the automated method), the Data Protection Legislation gives you the right to do so. Please contact Us to find out more using the details in Part 15.

  • The following automated decision-making methods may be used:
    • Google Ads, which chooses to show certain ads according to your browsing history, language, gender, and/or location.
    • Facebook ads, which chooses to show certain ads according to your browsing history, language, gender, and/or location.
  • The following automated profiling may take place:
    • Google Analytics, which collects information such as your location, which pages you visit on our site, order history, location, IP address, browser type and version, operating system, and/or language, which help us improve our product/service offering.

We will only use your personal data for the purpose(s) for which it was originally collected unless We reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If We do use your personal data in this way and you wish Us to explain how the new purpose is compatible with the original, please contact Us using the details in Part 15.

If We need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, We will inform you and explain the legal basis which allows Us to do so.

In some circumstances, where permitted or required by law, We may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.

 

  1. How Long Will You Keep My Personal Data?

We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):

 

Type of Data

How Long We Keep It

Identity Information including name, title, date of birth, gender.

10 years

Contact information including address, email address, telephone number.

10 years

Business information including business name, job title, profession.

10 years

Payment information including card details, bank account numbers.

10 years

Profile information including preferences and interests, username and password, purchase history.

10 years

Technical information including IP address, browser type and version, operating system.

10 years

 

  1. How and Where Do You Store or Transfer My Personal Data?

We will store or transfer some of your personal data within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the Data Protection Legislation, GDPR, and/or to equivalent standards by law.

AND/OR

We may store or transfer some or all of your personal data in countries that are not part of the European Economic Area (the “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein). These are known as “third countries” and may not have data protection laws that are as strong as those in the UK and/or the EEA. This means that We will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation as follows.

We share your data within the group of companies of which we are a part. Where this involves the transfer of personal data outside the EEA, Our group ensures that personal data is protected by requiring all companies within the group to follow the same rules with respect to personal data usage. These are known as “binding corporate rules”. More information on binding corporate rules is available from the European Commission.]

AND/OR

Where We transfer your data to a third party based in the US, the data may be protected if they are part of the EU-US Privacy Shield. This requires that third party to provide data protection to standards similar to those in Europe. More information is available from the European Commission.

Please contact Us using the details below in Part 15 for further information about the particular data protection mechanisms used by Us when transferring your personal data to a third country.

The security of your personal data is essential to Us, and to protect your data, We take a number of important measures, including the following:

  • limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;
  • procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so;

 

  1. Do You Share My Personal Data?

We will not share any of your personal data with any third parties for any purposes, subject to the following exceptions.

If We sell, transfer, or merge parts of Our business or assets, your personal data may be transferred to a third party. Any new owner of Our business may continue to use your personal data in the same way(s) that We have used it, as specified in this Privacy Policy.

In some limited circumstances, We may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

We may share your personal data with other companies in Our group for business analysis purposes. This includes subsidiaries AND/OR our holding company and its subsidiaries.

We may sometimes contract with the following third parties to supply certain products AND/OR services.

 

Recipient

Activity Carried Out

Sector

Location

Payment Service Provider

Processing payments on Our Site

Order fulfilment

UK

Vendor

Processing order

Order fulfilment

All locations as mentioned in Part 9

Shipping service provider

Processing order

Order fulfilment

All locations as mentioned in Part 9

 

 

If any of your personal data is shared with a third party, as described above, We will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, Our obligations, and the third party’s obligations under the law, as described above in Part 9.

If any personal data is transferred outside of the EEA, We will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation, as explained above in Part 9.

If We sell, transfer, or merge parts of Our business or assets, your personal data may be transferred to a third party. Any new owner of Our business may continue to use your personal data in the same way(s) that We have used it, as specified in this Privacy Policy.

In some limited circumstances, We may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

 

  1. How Can I Control My Personal Data?
      1. In addition to your rights under the Data Protection Legislation, set out in Part 5, when you submit personal data via Our Site, you may be given options to restrict Our use of your personal data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails, at the point of providing your details and by managing your Account).
      2. You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.

 

  1. Can I Withhold Information?

You may access certain areas of Our Site without providing any personal data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.

You may restrict Our use of Cookies. For more information, see Part 14 and Our Cookie Policy (https://www.9active.com/cookie-policy.html).

 

  1. How Can I Access My Personal Data?

If you want to know what personal data We have about you, you can ask Us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 15.

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover Our administrative costs in responding.

We will respond to your subject access request within 30 calendar days of receiving it. Normally, We aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date We receive your request. You will be kept fully informed of Our progress.

 

  1. How Do You Use Cookies?

Our Site may place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by Us and are used only by Us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve Our products AND/OR services. By using Our Site you may also receive certain third-party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, and/or parties other than Us. Third-party Cookies are used on Our Site for order fulfilment and website analysis. For more details, please refer to Our Cookie Policy (https://www.9active.com/cookie-policy.html).

 

  1. How Do I Contact You?

To contact Us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details:

Email address: admin@9active.com.

 

  1. Changes to this Privacy Policy

We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if We change Our business in a way that affects personal data protection.

Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date. This Privacy Policy was last updated on 01 October 2018.