Privacy Policy

Policy version: 7 November 2024

www.naritiveglobal.com (our website) is provided by Centennial Capital Limited, company incorporated in Ireland and of which Naritive Limited, a company incorporated in the United Kingdom and trading as Naritive is a subsidiary (‘we’, ‘our’ or ‘us’). We are the controller of personal data obtained about visitors to our website, through their use of our website or otherwise, meaning we are the organisation legally responsible for deciding how and for what purposes it is used.

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share any information relating to you where you are identified or identifiable (your personal data) in connection with your use of our website. It also explains your rights in relation to your personal data and how to contact us or a relevant regulator in the event you have a complaint or would like further information about our use of your personal data.

We collect, use and are responsible for certain personal data about you. When we do so we are subject to the EU General Data Protection Regulation (GDPR) in relation to goods and services we offer to individuals and our wider operations across the European Economic Area (EEA) and in the UK. This privacy policy has been prepared in light of our obligations under the GDPR, and the related national legislation in Ireland, the Data Protection Act 2018, together with other EU and Irish laws relating to privacy and data protection. Together, these laws are referred to as Data Protection Law in this policy.

Given the nature of our website, we do not expect to collect the personal data of anyone under 13 years old. If you are aware that any personal data of anyone under 13 years old has been shared with our website please let us know so that we can delete that data.

This version of our privacy policy is primarily written for adults, including parents and guardians of child users.

This privacy policy is divided into the following sections:

What this policy applies to
Personal data we collect about you
How your personal data is collected
How and why we use your personal data
Marketing
Who we share your personal data with
How long your personal data will be kept
Transferring your personal data out of the EEA and UK
Cookies and other tracking technologies
Your rights
Keeping your personal data secure
How to complain
Changes to this privacy policy
How to contact us
Do you need extra help?

What this policy applies to

This privacy policy relates to your use of our website only.

Throughout our website we may link to other websites owned and operated by certain trusted third parties. Those third party websites may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to those third party websites, please consult their privacy policies.

Personal data we collect about you

The personal data we collect about you depends on the particular activities carried out through our website. We will collect and use the following types of personal data about you:

Type of personal data	Details and examples
Contact information	your name, address and contact information, including email address and telephone number and company details.
Delivery information	any delivery addresses specified for your order and any other information given such as delivery instructions.
Gender information	Your gender may be inferred if you choose a title in the information you give us, such as Mr or Ms but we do not have any legitimate interest in such data.
Location information	information about your location if you choose to give this to us. This information will comprise your country only
Usage information	your activities on, and use of, our website, which includes · Log data: We collect information about your interactions with our website, such as your IP address, browser type, operating system, referring URLs, pages visited, and date/time stamps of visits. · Device information: We collect information about the device you use to access our website, such as the device type, unique device identifiers, and operating system. · Cookies and similar technologies: We use cookies and similar tracking technologies to collect information about your browsing activity and preferences. This includes first-party cookies (set by our website) and third-party cookies (set by other websites). We utilize Google Analytics 4 to analyze website traffic. This involves the use of cookies to collect data about your use of the website, such as pages visited, time spent on pages, and links clicked. This data is aggregated and anonymized to help us understand website usage patterns and improve our website. information about the services we provide to you your contact history, purchase history and saved items information about how you use our website and technology systems, which includes · User interactions: We collect data on how you interact with our website features, such as buttons clicked, forms filled out, and content viewed. · Performance data: We collect data on website performance, such as page load times and error rates, to improve the user experience. · Aggregated and anonymized data: We may aggregate and anonymize data collected through Google Analytics 4 to analyze trends and improve our website without identifying individual users.

You must provide this personal data in order to use our website and the services on it unless we tell you that you have a choice.

Sometimes you can choose if you want to give us your personal data and let us use it. Where that is the case we will tell you and give you the choice before you give the personal data to us. We will also tell you whether declining to share that personal data will have any effect on your use of our website or any services on it.

We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below.

How your personal data is collected

We collect personal data from you:

directly, when you enter or send us information, such as when you register with us, contact us (including via email), send us feedback, purchase products or services via our website, post material to our website and complete customer surveys or participate in competitions via our website, and indirectly, such as your browsing activity while on our website; we will collect information indirectly using the technologies explained in the section on ‘Cookies and other tracking technologies’ below

How and why we use your personal data

Under data protection law, we can only use your personal data if we have a proper justification, eg:

where you have given consent to comply with our legal and regulatory obligations for the performance of a contract with you or to take steps at your request before entering into a contract, or for our legitimate interests or those of a third party

These justifications are known as ‘lawful bases’ or ‘legal bases’ under Data Protection Law. A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You can obtain details of this assessment by contacting us (see ‘How to contact us’ below).

The table below explains what we use your personal data for and why.

The purpose we use your information for	How we use your information for this purpose	What information we use for this purpose	Legal justification
Creating and managing your account with us	We associate you and your use of our website with the account information that you provide to us when you create an account and input this into our internal account management system. This allows you to log in and use your account on our website	Account information Contact information	To perform our contract with you or to take steps at your request before entering into a contract
Providing products and/or services to you	We use your information to allow you make purchases on our website and provide customer services to you.	Account information Contact information Delivery information Usage information	To perform our contract with you or to take steps at your request before entering into a contract
Enforcing legal rights or defend or undertake legal proceedings	Where your information pertains to an issue that is the subject of legal proceedings, that may be taken by us against third parties or by third parties against us, including regulatory investigations, we will use your information to advance our case in these proceedings. This may mean your information is referred to in court documents, in correspondence or in discussions with the party against whom we are taking/defending the proceeding.	Account information Contact information Usage information	Depending on the circumstances: to comply with our legal and regulatory obligations in other cases, for our legitimate interests, ie to protect our business, interests and rights
Improving and developing our website and customer service	We retain and evaluate information on your recent visits to our website and how you move around different sections of our website for analytics purposes to understand how people use our website so that we can make it more intuitive or to check our website is working as intended	Usage information Location information	Depending on the circumstances: your consent as gathered by the separate cookies tool on our website—see ‘Cookies and other tracking technologies’ below where we are not required to obtain your consent and do not do so, for our legitimate interests, ie to be as efficient as we can so we can deliver the best service to you at the best price If you have provided such a consent you may withdraw it at any time by adoperations@naritiveglobal.com (this will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn)
Communications with you not related to marketing.	We use your contact information to make sure you are informed about things that we are required to tell you about or that you need to know about in order to use our website.	Account information Contact information Usage information	Depending on the circumstances: to comply with our legal and regulatory obligations in other cases, for our legitimate interests, ie to be as efficient as we can so we can deliver the best service to you at the best price]
Statistical analysis to help us understand our customer base	We monitor your browsing data as part of Google Analytics 4 (GA4).	Location information Usage information	For our legitimate interests, ie to be as efficient as we can so we can deliver the best service to you at the best price
Marketing our services to existing and former customers	We address and send communications to you that promote our services as described in ‘Marketing’ below	Account information Contact information Location information	For our legitimate interests, ie to promote our business to existing and former customers See ‘Marketing’ below for further information

Marketing

We will use your personal data to send you updates (by email, text message, telephone or post) about our products AND/OR services, including exclusive offers, promotions or new products AND/OR services.

We have a legitimate interest in using your personal data for marketing purposes (see above ‘How and why we use your personal data’). This means we do not rely on your consent as our justification to send you marketing information. If we change our marketing approach in the future, or if other laws apply so that consent is needed, we will ask for this separately and clearly.

You have the right to opt out of receiving marketing communications at any time by:

contacting us at adoperations@naritiveglobal.com

We may ask you to confirm or update your marketing preferences if you ask us to provide further products or services in the future, or if there are changes in the law, regulation, or the structure of our business.

We will always treat your personal data with the utmost respect and never sell OR share it with other organisations outside the Centennial Group for marketing purposes.

For more information on your right to object at any time to your personal data being used for marketing purposes, see ‘Your rights’ below.

Who we share your personal data with

We routinely share personal data with:

other third parties we use to help us run our business, eg marketing agencies or website hosts and website analytics providers

We only allow those organisations to handle your personal data if we are satisfied they take appropriate measures to protect your personal data.

We or the third parties mentioned above occasionally also share personal data with:

our external auditors, eg in relation to the audit of our or their accounts, in which case the recipient of the information will be bound by confidentiality obligations
our and their professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations
law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations
other parties that have or may acquire control or ownership of our business (and our or their professional advisers) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised but this may not always be possible. The recipient of any of your personal data will be bound by confidentiality obligations

Who we share your personal data with—further information

If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).

How long your personal data will be kept

We will not keep your personal data for longer than we need it for the purpose for which it is used.

If you stop using your account we will delete or anonymise your account data after [seven] years.

Transferring your personal data out of the EEA and UK

The EEA, UK and other countries outside the EEA and the UK have differing data protection laws, some of which may provide lower levels of protection of privacy.

It is sometimes necessary for us to transfer your personal data to countries outside the EEA and the UK. In those cases we will comply with applicable EEA and UK laws designed to ensure the privacy of your personal data.

Under data protection laws, we can only transfer your personal data to a country outside the EEA/UK where:

in the case of transfers subject to the GDPR the European Commission has decided the particular country, region or sector ensures an adequate level of protection of personal data (known as an ‘adequacy decision) further to Article 45 of the GDPR. A list of countries the EU currently has adequacy regulations in relation to is available here. We rely on adequacy regulations for transfers to the following countries: South Africa.
in the case of transfers subject to UK data protection laws, the UK government has decided the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy regulation’) further to Article 45 of the UK GDPR. A list of countries the UK currently has adequacy regulations in relation to is available here. We rely on adequacy regulations for transfers to the following countries: South Africa.
there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you, or
a specific exception applies under relevant data protection law

Where we transfer your personal data outside the EEA we do so on the basis of an adequacy decision or (where this is not available) legally-approved standard data protection clauses issued further to Article 46(2) of the EU GDPR. In the event we cannot or choose not to continue to rely on either of those mechanisms at any time we will not transfer your personal data outside the EEA unless we can do so on the basis of an alternative mechanism or exception provided by applicable data protection law and reflected in an update to this policy.

Where we transfer your personal data outside the UK we do so on the basis of an adequacy regulation or (where this is not available) legally-approved standard data protection clauses recognised or issued further to Article 46(2) of the UK GDPR. In the event we cannot or choose not to continue to rely on either of those mechanisms at any time we will not transfer your personal data outside the UK unless we can do so on the basis of an alternative mechanism or exception provided by UK data protection law and reflected in an update to this policy.

Any changes to the destinations to which we send personal data or in the transfer mechanisms we rely on to transfer personal data internationally will be notified to you in accordance with the section on ‘Changes to this privacy policy’ below.

Transferring your personal data out of the EEA and UK—further information

If you would like further information about data transferred outside the EEA/UK, please contact us OR our Data Protection Officer (see ‘How to contact us’ below).

Cookies and other tracking technologies

A cookie is a small text file which is placed onto your device (eg computer, smartphone or other electronic device) when you use our website. We use cookies on our website. These help us recognise you and your device and store some information about your preferences or past actions.

For further information on our use of cookies, when we will request your consent before placing them and how to disable them, please see our Cookie Policy.

Your rights

You generally have the following rights, which you can usually exercise free of charge:

Access to a copy of your personal data	The right to be provided with a copy of your personal data
Rectification (also known as correction)	The right to require us to correct any mistakes or inaccuracies in your personal data
Erasure (also known as the right to be forgotten)	The right to require us to delete your personal data—in certain situations
Restriction	The right to require us to restrict our use of your personal data in certain circumstances, eg if you contest the accuracy of the data
Data portability	The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or to ask us to transmit that data to a third party—in certain situations
To object to use	The right to object: at any time to your personal data being used for direct marketing (including profiling) in certain other situations to our continued use of your personal data, eg where we use your personal data for our legitimate interests unless there are compelling legitimate grounds for the processing to continue or the processing is required for the establishment, exercise or defence of legal claims
Not to be subject to decisions without human involvement	The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you We do not make any such decisions based on data collected by our website
The right to withdraw consents	If you have provided us with a consent to use your personal data you have a right to withdraw that consent easily at any time and for any reason or none You may withdraw consents by contacting adoperations@naritiveglobal.com Withdrawing a consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn
The right to complain to your data protection supervisory authority	You are entitled to raise a concern with the data protection supervisory authority (ie regulator) in your country in relation to the manner in which an organisation has handled your personal data. We are based in Ireland where the data protection supervisory authority is the Data Protection Commission (DPC). Please see ‘How to Complain’ below.

For further information on each of those rights, including the circumstances in which they do and do not apply, please contact us (see ‘How to contact us’ below). You may also find it helpful to refer to the DPC’s webpage on your rights under the GDPR.

If you would like to exercise any of those rights, please email, call or write to us—see below: ‘How to contact us’. When contacting us please:

provide enough information to identify yourself eg your full name, address and customer or matter reference number and any additional identity information we may reasonably request from you, and
let us know which right(s) you want to exercise and the information to which your request relates

Keeping your personal data secure

We have appropriate security measures to prevent personal data from being accidentally lost or used or accessed unlawfully. We limit access to your personal data to those who have a genuine need to access it.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

How to complain

Please contact us if you have any queries or concerns about our use of your personal data (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.

As described above you have the right to lodge a complaint with:

our lead supervisory authority in the EEA, which is the Data Protection Commission (DPC). The DPC can be contacted via their website, which has an online complaints portal https://www.dataprotection.ie/en/individuals/exercising-your-rights/raising-concern-commission, by telephone on 01 7650100 or 1800 437 737, by email at info@dataprotection.ie or by post at Data Protection Commission, 21 Fitzwilliam Square South, Dublin 2, D02 RD28, Ireland
a relevant data protection supervisory authority in the EEA state where you live, where you work, or where the issue with our use of your personal data arose. For a list of EEA data protection supervisory authorities and their contact details see here
the Information Commissioner in the UK if that is where you live. The UK’s Information Commissioner may be contacted using the details at https://ico.org.uk/make-a-complaint or by telephone: 0303 123 1113

You are under no obligation to contact us before making a complaint to a data protection regulator, but we would appreciate the opportunity to address your concerns directly.

Changes to this privacy policy

We may change this privacy policy from time to time—when we make significant changes we will take steps to inform you, for example by including a prominent link to a description of those changes on our website for a reasonable period or by other means, such as email.

How to contact us

Individuals in the EEA

You can contact us if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.

Our contact details are shown below:

Our contact details

Our Data Protection Officer’s contact details

71-75 Shelton Street

Covent Garden

London

WC2H9JQ

adoperations@naritiveglobal.com

71-75 Shelton Street

Covent Garden

London

WC2H9JQ

adoperations@naritiveglobal.com

Individuals in the UK

We have appointed Alex Tsaperas to be our data protection representative within the UK. Their contact details are alex@naritiveglobal.com.

Individuals within the UK can also contact us directly (see above) or contact our UK representative.

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