Privacy Policy

Privacy Statement of DHBC Limited

1. We respect your privacy and are committed to protecting your personal data. This privacy notice tells you how we process your personal data when you visit our website or otherwise provide us with your personal data and tells you about your privacy rights.

Purpose of this privacy notice

2. This privacy notice sets out how we collect and process your personal data through your use of this website or by any other means. This website must only be used by persons who are 18 or over or you give us your consent to allow any of your minor dependants to use this website.

 

3. We may issue other privacy notices or fair processing notices on specific occasions when we are collecting or processing personal data about you so that you are aware of how and why we are using your data. This privacy notice and the other notices should be read together and do not override each other.

Controller

4. DHBC Limited is the controller and is responsible for your personal data (collectively referred to as "we", "us" or "our" in this privacy notice).

 

5. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact Diana on Anthony on +44 (0)1534 738737 or info@phytob.com.

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

6. 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.

The data we collect about you

7. 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).

 

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

• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us. 

• 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 this website. 

• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses. 

• Usage Data includes information about how you use our website, products and services. 

• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
• Health Data includes any relevant medical history provided by you to Diana or Anthony in a consultation which is recorded and any records generated by Diana or Anthony while providing services to you during a consultation.

 

9. 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. 


 

10. Other than health data disclosed by you, we do not collect any special category personal data about you (this 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). Nor do we collect any information about criminal convictions and offences. 


 

How is your personal data collected? 


 

11. We use different methods to collect data from and about you including through direct interactions. For example, you may give us your identity, contact and financial data by filling in forms or by corresponding with us by post, phone, email, through our website or otherwise.

 

How we use your personal data 


 

12. We will only use your personal data when the law allows us to. The purposes for which your personal data will be processed and the legal basis for it are as follows:

For customers purchasing products on our website or by phone

Purpose/activity	Type of data	Lawful basis for processing
To register you as a customer	Identity and contact data	Performance of a contract with you
To process and deliver your order including processing payments and collecting and recovering money owed to us	Identity, contact, financial and transaction data	Performance of a contract with you and necessary for our legitimate interests in recovering debts owed to us
To manage our relationship with you including notifying you about changes to our terms of business or privacy policy	Identity, contact, profile, usage and marketing and communications data	Performance of a contract with you, necessary to comply with a legal obligation and necessary for our legitimate interest to keep our records updated and to study how you use our products.
To enable you to participate in a prize draw, competition or asking you to leave a review or complete a survey	Identity, contact, profile, usage and marketing and communications data	Performance of a contract with you and necessary for our legitimate interest to study how you use our products 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)	Identity, contact and technical data	Necessary for our legitimate interests for running our business, provision of administration and IT services, network security and to prevent fraud and necessary to comply with a legal obligation
To deliver relevant content, advertisements and marketing materials to you and measure and understand the effectiveness of our advertising and marketing	Identity, contact, profile, usage, marketing and communications and technical	Necessary for our legitimate interests to study how customers use our products, to develop them, to grow our business and inform our marketing strategy
To use data analytics to improve our website, products, marketing, customer relationships and experiences	Technical and usage	Necessary for our legitimate interests to define types of customers for our products, 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 products that may be of interest to you	Identity, contact, technical, usage, profile	Necessary for our legitimate interests to develop our products and grow our business

 

 

 

 

 

For practitioners

Purpose/activity	Type of data	Lawful basis for processing
When purchasing products on our website or otherwise placing orders for products, all the purposes and activities set out in the previous table	When purchasing products on our website or otherwise placing orders for products, all the types of data set out in the previous table	When purchasing products on our website or otherwise placing orders for products, all the types of data set out in the previous table
To manage all aspects of administration relating to your being a Phytobiophysics practitioner including payment of subscriptions	Identity, contact, profile, financial and transaction data	Performance of a contract with you, necessary for our legitimate interests in running and developing the Institute of Phytobiophysics
To deliver relevant content, advertisements and marketing materials to you and measure and understand the effectiveness of our advertising and marketing	Identity, contact, profile, usage, marketing and communications and technical	Necessary for our legitimate interests to study how customers use our products, to develop them, to grow our business and inform our marketing strategy

 

For clients of Diana and Anthony

Purpose/activity	Type of data	Lawful basis for processing
To provide personal consultations	Identity, contact, health data	Your explicit consent, medical purposes, performance of a contract with you.
To process payments and collecting and recovering money owed to us	Identity, contact, financial and transaction data	Performance of a contract with you and necessary for our legitimate interests in recovering debts owed to us
To deliver relevant content, advertisements and marketing materials to you and measure and understand the effectiveness of our advertising and marketing	Identity, contact, profile, usage, marketing and communications and technical	Necessary for our legitimate interests to study how customers use our products, to develop them, to grow our business and inform our marketing strategy

 

13. 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. 


Opting out 


14. You can ask us or third parties to stop sending you marketing messages at any time by emailing us at info@phytob.com. 


Change of purpose 


15. 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 wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. 


 

16. 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. 


 

17. 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. 


Disclosures of your personal data 


18. We may have to share your personal data with the parties set out below for the purposes set out in the tables at paragraph 12 above:

• IT service providers;
• Payment gateways and payment transaction processors;
• Professional advisers including lawyers, bankers, auditors and insurers;
• Regulators and other taxing or authorities based in Jersey and other relevant jurisdictions which require reporting of processing activities in certain circumstances; or
• Third parties to whom we might sell, transfer or merge parts of our business or assets.

 

19. 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 (excluding health data) for specified purposes and in accordance with our instructions.

 

20. If you choose a direct payment gateway to complete your purchase, then **UK Chip and PIN by APACS (Administration) Limited** will process your credit card data.  It is encrypted through the Payment Card Industry Data Security Standard (PCI-DSS). Your purchase transaction data is stored only as long as is necessary to complete your purchase transaction. After that is complete, your purchase transaction information is deleted.  All direct payment gateways adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover.  PCI-DSS requirements help ensure the secure handling of credit card information by our store and its service providers.

 

21. Third-party service providers, such as payment gateways and other payment transaction processors, have their own privacy policies in respect to the information we are required to provide to them.  For these providers, we recommend that you read their privacy policies so you can understand the manner in which your personal data will be handled by them.

International transfers 


22. We will only transfer your personal data out of the EEA if:


• you have explicitly consented to the proposed transfer, after having been informed of the possible risks to you of such transfers;
• the transfer is necessary for (a) the performance of a contract between us; or (b) the implementation of pre-contractual measures taken at your request; or
• if the controller or processor has provided appropriate safeguards in accordance with data protection law and on condition that enforceable data subject rights and effective legal remedies for data subjects comparable to those under data protection law are available in that country or organization.

 

23. We will not transfer your health data to any third party unless you request and explicitly consent to the transfer.

Data security 


24. 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 (other than health data) on our instructions and they are subject to a duty of confidentiality. 


 

25. 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

26. 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.

 

27. 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.

 

28. 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.

Your legal rights

29. Under certain circumstances, you have rights under data protection laws in relation to your personal data. Your rights are 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: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) 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.

30. 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 if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

 

31. We may need to request specific 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. 


 

32. We try to respond to all legitimate requests within one month. Occasionally it may 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. 


Third-party links

33. This website may include links to third-party websites, plug-ins and applications.  Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of other websites you visit.

Cookies

34. We may need to gather information about your computer to help provide appropriate services or products to you.  The data gathered is solely statistical data, which may be shared with advertisers. No personal information will be shared about you and how you made use of our website.  Cookies are used to collect general online usage by using a cookie file.  If used, this cookie file is downloaded without prompting.  It will be placed on your hard drive with information transferred to the hard drive allowing the cookies to be used for data collection.  A cookie is used to improve any services/ products, or overall website characteristic we offer you.

 

35. By using our website, you are consenting to our setting Cookies and using the data collected by them for the purposes set out in our Cookie policy.

 

36. If you have previously browsed or used our websites and no longer wish to accept Cookies, you should be aware that some Cookies will have been set. You may delete these Cookies at any time by changing the Cookie settings on your computer. Further guidance on reviewing and amending these settings can be found through the Help section of your internet browser. Alternatively, in depth guidance on Cookies, and how to manage and remove them, can be found on allaboutCookies.org.

 

37. By declining cookies you may be limiting your access to sections of our website.  If our advertisers use cookies it will result from a click on their advertisement, and we do not have control over their cookies if used.

Complaints

38. If you would like to make a complaint:

• by email, email us at info@phytob.com; or
• by post, mail us at the Institute of Phytobiophysics, Le Prevot, La Grande Route de St Clement, St Clement, Jersey JE2 6QQ.

39. You have the right to make a complaint at any time to the Office of the Information Commissioner (OIC), the Jersey supervisory authority for data protection (www.oicjersey.org) whose address is at 2^nd Floor, 5 Castle Street, St Helier, Jersey JE2 3BT and whose contact telephone number is +44 (0)1534 716530.  We would, however, appreciate the chance to deal with your concerns before you approach the OIC so please contact us in the first instance.