Privacy & Cookie Policy

This Privacy & Cookie Policy (“Policy”) outlines Dr Maria Devine’s (the “Company”/“we”/“us”) practices with respect to information we may collect, store, use and share from users who access our website drmariadevine.com and other sites we own and operate, including its subdomains (“Website”/“Site”), or otherwise share personal information with us.

By visiting our Site and/or purchasing something from us, you engage in our “Service” and agree to be bound by this Policy, including those additional terms and conditions and policies referenced herein and/or available by hyperlink. This Policy applies to all users of the Site, including without limitation users who are browsers, vendors, customers, merchants, and /or contributors of content (“User”/“Users”).

For the purpose of the Data Protection Act 2018 (the “Act”/“UK GDPR”) and the EU General Data Protection Regulation 2016/679 (“EU GDPR”), the data controller and data processor is Maria Devine registered in Otford, Sevenoaks, Kent, TN14 5PF, United Kingdom.

Information We Collect

We collect two types of data and information from Users:

  1. Non-personal information is unidentified and non-identifiable information pertaining to a User, which may be made available or gathered via your use of the Site. We are not aware of the identity of a User from which the non-personal information was collected.

    Non-personal information which is being collected may include your aggregated usage information and technical information transmitted by your device, including certain software and hardware information (e.g. the type and version of browser, the operating system your device uses, language preferences, access time, etc.) in order to enhance the functionality of our Site. We may also collect information on your activity on the Site (e.g. pages viewed, online browsing, clicks, actions, etc.).

    Additionally, if you encounter certain errors while using the site, we may automatically collect data about the error and the circumstances surrounding its occurrence. This data may include technical details about your device, what you were trying to do when the error happened, and other technical information relating to the problem. You may or may not receive notice of such errors, even in the moment they occur, that they have occurred, or what the nature of the error is. Please be aware that while this information may not be personally identifying by itself, it may be possible to combine it with other data to personally identify an individual.

    Non-personal data we collect can depend on the individual settings of your device and software. We recommend checking the policies of your device manufacturer or software provider to learn what information they make available to us.

  2. Personal data or personal information is any information that identifies an individual or may with reasonable effort identify an individual. The personal data we collect about you depends on the particular ways we interact with to you. We may collect the following personal data:

    • Full name and contact details, including email address, telephone number, physical address and other information;

    • Information to check and verify User’s identity, e.g. date of birth;

    • Billing information, payment card information and transaction details;

    • Responses to competitions, contests, sweepstakes and surveys;

    • Particular information about how you use our Site, IT, communication and other systems;

    • Device information, including geolocation data, Internet Protocol (IP) address, unique identifiers (e.g. MAC address and UUID) and other information which relates to your activity through the Site and which can identify you.

User-Generated Content

We consider “user-generated content” to be reviews, ratings, images, audio and video materials voluntarily supplied to us by Users for the purpose of publication on our Site or re-publishing on our social media channels. All user-generated content is associated with the account or email address used to submit the materials.

Please be aware that any content you submit for the purpose of publication will be public after posting (and subsequent review or vetting process). Once published, it may be accessible to third parties not covered under this Policy.

Legitimate Reasons for Processing Your Personal Data

A legitimate reason or legitimate interest is when we have a business or commercial reason to use your personal data. We only collect, store, use and share your personal information when we have a legitimate reason for doing so. In which instance we only collect personal information that is reasonably necessary to provide our Services to you.

Collection and Use of Personal Data

We collect most of your information directly from you—in person, by telephone, text or email and/or via our Site when you do any of the following:

  • Use a mobile device or web browser to access our content;

  • Contact us via email, social media or on any similar technologies;

  • Sign up to receive updates from us via email or social media channels;

  • Register for an account;

  • Purchase any products and/or services from us;

  • Purchase a subscription and/or membership from us;

  • Enter any of our competitions, contests, sweepstakes and/or surveys;

  • When you mention us on social media.

We may also collect information:

  • From publicly accessible sources, public registers, third party providers and services (e.g. traffic analytics vendors);

  • Directly from a third party (e.g. your representative is engaged with);

  • From cookies on our Site.

We may collect, hold, use and disclose information for the following purposes:

  • To provide you with our Services and Site’s core features;

  • To enable you to customise and/or personalise your experience on our Site;

  • To process any transactional or ongoing payments;

  • To deliver products and/or services to you;

  • To contact and communicate with you;

  • For analytics, market research and business development, including to operate and improve our Site, associated applications and social media platforms;

  • For advertising and marketing, including to send you promotional information about our products and/or services and information about third parties that we consider may be of interest to you;

  • For internal record keeping and administrative purposes of the Company;

  • To run competitions, contests, sweepstakes and surveys and/or offer additional benefits to you;

  • To comply with our legal obligations and resolve any disputes that we may have;

  • To attribute any content (e.g. posts, comments and reviews) you submit that we publish on our Site;

  • For security and fraud prevention and to ensure that our Site is safe, secure and used in line with our terms and conditions and policies;

  • For technical assessment, including to operate and improve our Site, associated applications and social media platforms.

We may combine voluntarily provided and automatically collected personal information with general information or research data we receive from other trusted sources (e.g. if you provide us with your location we may combine this with general information about currency and language to provide you with an enhanced experience of our Site and Services).

Cookies

We and our trusted partners use cookies and other technologies in our related services, including when you visit our Site or access our Services.

A cookie is a small piece of data that our Site stores on your device and accesses each time you visit so we can understand how you use our Site. Cookies are very helpful and can be used for various different purposes. These purposes include allowing you to navigate between pages efficiently, enable automatic activation of certain features, remembering your preferences and making the interaction between you and our Services quicker and easier. Cookies are also used to help ensure that the advertisements you see are relevant to you and your interests and to compile statistical data on your use of our Services.

The Site uses the following types of cookies:

  • Session cookies (essential) which are stored only temporarily during a browsing session in order to allow normal use of the system and are deleted from your device when the browser is closed;

  • First-party or persistent cookies (essential) which are read only by the Site, saved on your computer for a fixed period and are not deleted when the browser is closed. Such cookies are used where we need to know who you are for repeat visits (e.g. to allow us to store your preferences for the next sign-in);

  • Third-party or tracking cookies (non-essential) which are set by other online services who run content on the page you are viewing (e.g. by third party analytics companies who monitor and analyse our web access).

Cookies do not contain any information that personally identifies you but personal data that we hold about you may be associated with the information stored in and obtained from cookies.

You may remove or block the cookies by following the instructions of your device and/or browser preferences; however, if you choose to disable cookies, some features of our Site may not operate properly and your online experience may be limited.

Children’s Privacy

We do not aim any of our products or services directly at children under the age of 13 and we do not knowingly collect personal data about children under 13.

Who We Share Your Personal Data with

We will always treat your personal data with the utmost respect and never sell or share it with third parties, unless required by law or set in this Policy.

We may share your personal data with:

  • a parent, subsidiary or affiliate of our company;

  • our employees, contractors and/or related entities;

  • our existing or potential business partners and agents;

  • sponsors or promoters of any competitions, contests and sweepstakes we run;

  • an entity that buys, or to which we transfer all or substantially all of our assets and business;

  • credit reporting agencies, courts, tribunals and regulatory authorities in the event you fail to pay for products or services we have provided to you;

  • courts, tribunals, regulatory authorities and law enforcement officers as required by law and in connection with any actual or prospective legal proceedings or in order to establish, exercise or defend our legal rights;

  • third parties, including agents or sub-contractors, who assist us in providing information, products, services or direct marketing to you;

  • third-party service providers for the purpose of enabling them to provide their services, including (without limitation) IT service providers, data storage, hosting and server providers, ad networks, analytics, error loggers, debt collectors, maintenance or problem-solving providers, marketing or advertising providers, professional advisors and payment systems operators;

  • third parties to collect and process data.

Third parties we currently use include:

  • Google Analytics

  • Google Search Console

  • Google Adsense

  • Google Payments

  • Stripe

  • PayPal

  • Apple Pay

  • Klarna

  • MailChimp

  • Zapier

Squarespace:

Our Company operates through the platform provided by Squarespace, including their e-commerce tools which enable the smooth processing of orders and transactions. As such, our operation comes under the influence of Squarespace Privacy Policy and Squarespace Cookie Policy.

Google Analytics and Google Search Console:

We endeavour to continuously enhance our online service to ensure an exquisite shopping experience for our customers. To achieve this, we incorporate Google Analytics and Google Search Console. These tools aid us in understanding user behaviour, trends and other insights which in turn help us refine our service. Information collected by these tools is solely for analytical purposes and is handled according to Google Privacy Policy.

MailChimp:

To keep our customers updated with the latest collections, offers and events, we employ MailChimp for our e-marketing efforts. When subscribing to our newsletter, the email provided will be stored in the MailChimp database. You may opt out of these emails at any time by clicking on the “unsubscribe” link included in every email. For more information, we recommend viewing MailChimp Privacy Policy.

Where Your Personal Data Is Held

You personal data may be held at our offices, in our emails, on our secure CRM systems and on our cloud accounts as well at our partners, affiliates, third party agencies, service providers, representatives and agents as described in this Policy. Some of these third parties may be based outside the UK/EEA.

The personal information we collect is stored and/or processed in the United Kingdom or where we or our partners, affiliates, third party agencies, service providers, representatives and agents maintain facilities.

The countries to which we store, process or transfer your personal data may not have the same data protection laws as the country in which you initially provided the information. If we transfer your personal data to third parties in other countries: (i) we will perform those transfers in accordance with the requirements of applicable law; and (ii) we will protect the transferred personal data in accordance with this Policy.

How Long We Keep Your Personal Data

We keep your personal data only for as long as needed for the purpose for which it is used. This time period may depend on what we are using your information for, in accordance with this Policy (e.g. if you have provided us with personal information as part of creating an account with us we may retain this information for the duration your account exists on our systems).

If your personal information is no longer required for the purpose for which it is used we will delete it or make it anonymous by removing all details that identify you.

However, if necessary, we may retain your personal information for our compliance with a legal, accounting and/or reporting obligation or for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes.

Security

We protect your personal data within commercially acceptable means to prevent its loss and theft as well as unauthorised access, disclosure, copying, use or modification. In the event of a suspected data security breach, we will notify you and any applicable regulator of such an event where we are legally required to do so.

Although we will do our best to protect the personal information you provide to us, we advise that no method of electronic transmission or storage is 100% secure and no one can guarantee absolute data security.

You are responsible for selecting any password and its overall security strength as well as for ensuring the security of your own information within the bounds of our Services (e.g. ensuring any passwords associated with accessing your personal information and accounts are secure and confidential).

Limits of Our Policy

In the event our Site contains links to third-party sites and services, please be aware that those sites and services have their own privacy policies. After following a link to any third-party content, you should read their posted privacy policy information about how they collect, store, use and share personal information. This Policy does not apply to any of your activities after you leave our Site.

Business Transfers

If we or our assets are acquired or in the unlikely event that we go out of business or enter bankruptcy we would include data, including your personal information, among the assets transferred to any parties who acquire us. You acknowledge that such transfers may occur and that any parties who acquire us may, to the extent permitted by applicable law, continue to use your personal information according to this Policy which they will be required to assume as it is the basis for any ownership or use rights we have over such information.

Your Rights

  • Your choice: By providing personal data to us, you understand we will collect, store, use and share your personal information in accordance with this Policy. You do not have to provide personal information to us, however, if you do not, it may affect your use of our Site or the products and/or services offered on or through it.

  • Information from third parties: If we receive personal information about you from a third party, we will protect it as set out in this Policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us.

  • Marketing permission: If you have previously agreed to us using your personal information for direct marketing purposes you may change your mind at any time by contacting us using the details below.

  • Access: You may request details of the personal information that we hold about you.

  • Correction: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details below. We will take reasonable steps to correct any information found to be inaccurate, incomplete, misleading or out of date.

  • Non-discrimination: We will not discriminate against you for exercising any of your rights over your personal information. Unless your personal information is required to provide you with a particular service or offer (for example processing and fulfilling orders), we will not deny you products or services and/or charge you different prices or rates for products or services, including through granting discounts or other benefits or imposing penalties, or provide you with a different level or quality of products or services.

  • Notification of data breaches: We will comply with laws applicable to us in respect of any data breach.

  • Complaints: If you believe that we have breached a relevant data protection law and wish to make a complaint, please contact us using the details below and provide us with full details of the alleged breach. We will promptly investigate your complaint and respond to you in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint. You also have the right to contact a regulatory body or data protection authority in relation to your complaint.

  • Unsubscribe: To unsubscribe from our email database or opt out of communications (including marketing communications), please use opt-out facilities provided in the communication or contact us using the details below. Please be aware that we may need to request specific information from you to help us confirm your identity.

Complaints

Please get in touch with us if you have any queries or concerns about our use of your personal data. We hope we will be able to resolve any issues you may have.

You also have the right to lodge a complaint with the Information Commissioner in the UK by visiting their website or by calling them at 0303 123 1113.

Additional Disclosures for Australian Privacy Act Compliance (AU)

International Transfers of Personal Information

Where the disclosure of your personal information is solely subject to Australian privacy laws, you acknowledge that some third parties may not be regulated by the Australian Privacy Act and the Australian Privacy Principles in the Privacy Act. You acknowledge that if any such third party engages in any act or practice that contravenes the Australian Privacy Principles, it would not be accountable under the Australian Privacy Act, and you will not be able to seek redress under the Australian Privacy Act.

Additional Disclosures for General Data Protection Regulation Compliance (EU)

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

    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 provide a physical address for the purpose of receiving orders. While you may change or delete this address at any time, this will not affect orders that have already been sent.

    If you have any further enquiries about how to withdraw your consent, please feel free to enquire by contacting us using the details below.

  • Performance of a Contract or Transaction

    Where you have entered into a contract or transaction with us or in order to take preparatory steps prior to our entering into a contract or transaction with you. For example, if you purchase a product, service, or subscription from us, we may need to use your personal and payment information in order to process and deliver your order.

  • 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 by contacting us using the details below.

International Transfers Outside of the European Economic Area (“EEA”)

We will ensure that any transfer of personal information from countries in the EEA to countries outside the EEA will be protected by appropriate safeguards (e.g. 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.

  • Deletion

    You may have a right to request that we delete the personal information we hold about you at any time and we will take reasonable steps to delete your personal information from our current records. If you ask us to delete your personal information we will let you know how the deletion affects your use of our Site or Services. There may be exceptions to this right for specific legal reasons which, if applicable, we will set out for you in response to your request. If you terminate or delete your account we will delete your personal information within 14 days of the deletion of your account. Please be aware that search engines and similar third parties may still retain copies of your personal information that has been made public at least once, like certain profile information and public comments, even after you have deleted the information from our services or deactivated your account.

Additional Disclosures for California Compliance (US)

Personal Information Shared for Marketing Purposes

Under California Civil Code Section 1798.83, if you live in California and your business relationship with us is mainly for personal, family or household purposes you may ask us about the information we release to other organisations for their marketing purposes.

To make such a request, please contact us using the details provided below with “Request for California privacy information” in the subject line. You may make this type of request once every calendar year. We will email you a list of categories of personal information we revealed to other organisations for their marketing purposes in the last calendar year along with their names and addresses. Not all personal information shared in this way is covered by Section 1798.83 of the California Civil Code.

Do Not Track

Some browsers have a “Do Not Track” feature that lets you tell websites that you do not want to have your online activities tracked. At this time we do not respond to browser “Do Not Track” signals.

We adhere to the standards outlined in this privacy policy ensuring we collect and process personal information lawfully, fairly, transparently and with legitimate, legal reasons for doing so.

Cookies and Pixels

At all times you may decline cookies from our site if your browser permits. Most browsers allow you to activate settings on your browser to refuse the setting of all or some cookies. Accordingly, your ability to limit cookies is based only on your browser’s capabilities. Please refer to the Cookies section of this Policy for more information.

California Notice of Collection

In the past 12 months, we have collected the following categories of personal information enumerated in the California Consumer Privacy Act:

  • Identifiers, such as name, email address, phone number account name, IP address, and an ID or number assigned to your account;

  • Customer records such as billing and shipping address and payment card data;

  • Demographics, such as your age or gender. This category includes data that may qualify as protected classifications under other California or federal laws;

  • Commercial information such as products or services history and purchases;

  • Internet activity, such as your interactions with our service;

  • Audio or visual data, such as photos or videos you share with us voluntarily;

  • Geolocation data;

  • Inferences such as information about user interests, preferences and favorites.

Right to Know and Delete

If you are a California resident, you have rights to delete your personal information we collected and know certain information about our data practices in the preceding 12 months. In particular, you have the right to request the following from us:

  • The categories of personal information we have collected about you;

  • The categories of sources from which the personal information was collected;

  • The categories of personal information about you we disclosed for a business purpose or sold;

  • The categories of third parties to whom the personal information was disclosed for a business purpose or sold;

  • The business or commercial purpose for collecting or selling the personal information; and

  • The specific pieces of personal information we have collected about you.

To exercise any of these rights, please contact us using the details provided below.

Shine the Light

If you are a California resident, in addition to the rights discussed above, you have the right to request information from us regarding the manner in which we share certain personal information as defined by California’s “Shine the Light” with third parties and affiliates for their own direct marketing purposes.

To receive this information send us a request using the contact details provided below with “California Privacy Rights Request” in the subject line and include your name, street address, city, state and ZIP code.

Contact Us

For any questions or concerns regarding this Policy, you may contact us by visiting our Contact page.

Changes to This Policy

We reserve the right to modify this Policy at any time by publishing the revised version on our Site. The revised version will be effective immediately from the date of publication.

If the changes are significant or if required by applicable law we will notify our Users about such changes to this Policy.

Last updated: 1 January, 2024.