Spotlight Oral Care Privacy Policy

At Spotlight Oral Care, our customers' privacy is a top priority.  We appreciate that you put your trust in us when you provide us with your information and we do not take this lightly. We regularly audit our own procedures to ensure that your data is kept secure and is accessible and used only for the purposes agreed.

We have written our Privacy Policy and related documents in plain, easy to understand language. We want you to read our policies and understand fully the steps we take to protect your privacy.

If, after reading the policy, you have further questions, please do not hesitate to contact us.

WHO CONTROLS YOUR PERSONAL DATA?

Spotlight Oral Care Ltd is the company that is responsible for your information under this Privacy Policy (the “data controller”). We are located at:

Spotlight Oral Care Ltd
Block 2 Harris House
Small IDA Business Park
Tuam Road
Galway
Ireland


WHAT PERSONAL DATA DO WE COLLECT?

The type of data we collect about you includes:

Identity Data including your first name, last name, username, address

Contact Data including your billing address, delivery address, email address and telephone numbers.

Financial Data including payment card details. This is collected by 3rd party payment gateway. Spotlight Oral Care does not receive or store any financial data.

Transactional Data including details about payments for products or services you have purchased from us

Technical Data including IP address, your login data, browser type, operating system and platform, as well as your journey through our digital platform (such as the links you click on and the searches you make), which videos you have watched, what content you like and share, and information collected in any forms you complete. We may also analyse which marketing activity led to your taking specific action on our digital platforms.

Profile Data includes your login and password, purchases or orders made by you, your interests, favourites, feedback and survey responses.

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

Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature.


HOW IS YOUR PERSONAL DATA IS COLLECTED?

Direct Interactions

You may give us your data by filling in forms, using our website, ordering products, or from corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

  • Sign up or order from our website
  • Enter a competition or promotion
  • Sign up to our mailing list
  • Complete a survey / give us some feedback

Automated Technologies or Interactions

As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our Cookie Policy below for further details.


How we Store/Process Your Data

We use a number of 3rd party systems to help us provide you with the best possible service. We refer to these as our Data Processors. We have rigid procedures in place to vett any third party supplier.

If you sign-up or opt-in to receive emails from Spotlight Oral Care, data will be shared with our CRM provider HubSpot. You have full control over what emails you receive from us and can unsubscribe at any stage by clicking the Unsubscribe link contained on every email.

HubSpot have a robust Privacy Policy in place which you can read here: HubSpot DPA

When you purchase a product or gift voucher online we will ask for your name, email, phone number, and postal address. This data is securely stored by our E-Commerce partner, Shopify. 

For online transactions, All credit/debit card details are processed securely by Shop Pay (formly Shopify Pay), Google Pay, PayPal or Apple Pay; depending on your selection. Spotlight Oral Care does not receive or store any online card details. 

All our fulfilment is handled by 2Flow Logistics from their base in Dublin, Ireland.

HubSpot, Shopify, Shop Pay (formly Shopify Pay), Google Pay, PayPal, Apple Pay, and 2Flow Logistics act as data processors on behalf of Spotlight Oral Care. 

We have worked with them to ensure they adhere to our privacy principles and GDPR and have implemented appropriate technological measures to secure data.

 

Collection and Use of Personal Information

The information that you provide on the Spotlight Oral Care website will be used only for its stated purpose. By sending us an e-mail message, you may be sending us personal information such as your name, address, and e-mail address.

We may store your name, address, and e-mail address in order to respond to your request or otherwise resolve the subject matter of the e-mail.

Spotlight Oral Care will make no attempt to identify individual visitors, or to associate technical details with any individual. It is our policy never to disclose such technical information in respect of individual website visitors to any third party, unless obliged to disclose such information by a rule of law.


Collection and Use of Technical Information

We may collect and store general information for statistical purposes. For example, we may count the number of visitors to the different pages of our website to help make them more useful to visitors. This information does not identify you personally. We automatically collect and store only the following information about your visit:

  1. the Internet domain (for example, ‘xcompany.com’ if you use a private Internet access account), and IP address (an IP address is a number that is automatically assigned to your computer whenever you are surfing the Web) from which you access our website
  2. the type of browser and operating system used to access our site
  3. the date and time you access our site
  4. the pages you visit
  5. if you visited this Spotlight Oral Care’s website from a link on another website, the address of that website

In short the technical information will be used only by Spotlight Oral Care, and only for statistical and other administrative purposes.

Cookies

This website uses “cookie” technology. A cookie is a small piece of data or a small text file stored by the browser on your computer, at the request of our server. We may use cookies to deliver content specific to your interests and to save your personal preferences so you do not have to re-enter them each time you connect to our website – our cookies are not available to other websites.

In particular cookies enable us:

  • to measure visitor traffic to our website and their usage patterns
  • to store information about your preferences, and so allow us to customise our website according to your individual interests
  • to speed up your searches
  • to recognise you when you return to our website

Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit allaboutcookies.org.

Disabling Cookies

You are always free to decline such cookies if your browser permits, or to ask your browser to indicate when a cookie is being sent. You can also delete cookie files from your computer at your discretion.


Targeted Advertising

We may also use third-party platforms, including platforms operated by social networks, such as Google, Facebook, and Instagram, to show you interest-based ads. We may convert your email address, telephone number or other information into a unique value which can be matched by those third parties with a user on their platform or with other data they may have collected from you. 

This matching allows interest-based ads to be delivered on those platforms. To opt-out of these ads, you must change your preferences by clicking on the cookie control tool above and unselect the “targeting” setting. These platforms may have their own privacy notices or policies, which we strongly suggest you review.


 Facebook: Opt-out of Facebook remarketing here 

Google: Opt-out of Google remarketing here



Google Analytics

This website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”), to gather statistics on our website. The statistics we gather help us to provide a better web service for the visitors. For more information on Google Analytics, please visit Google’s website.

Google Analytics uses cookies to define user sessions, as well as to provide a number of key features in the Google Analytics reports. This means that the cookies are linked to our website domain(s), and we will only use that cookie data for statistical analysis related to your browsing behaviour on our websites. 

If you choose, you can opt out by turning off cookies in the preferences settings in your browser. You can opt-out from being tracked by Google Analytics by downloading and installing Google Analytics Opt-out Browser Add-on for your current web browser: Google Analytics Opt-out Browser Add-on

We may implement certain Google Analytics Advertising Features (including Re-marketing with Google Analytics; Google Display Network Impression Reporting or Google Analytics Demographics and Interest Reporting). You can opt-out of the Google Analytics Advertising Features through Google Ad settings or by visiting https://tools.google.com/dlpage/gaoptout/.


External Hyperlinks

On our website we may link to other websites that provide more information on a specific topic discussed on this website. By clicking any of those links, the contents of this privacy policy does not apply to your data processing on the websites that we link to. You must refer to the privacy policy on those websites which are out of our control. 

We will endeavour to link to reputable, well-maintained websites.

Spotlight Oral Care is not responsible for the content, availability or quality of any material contained on such sites and links to external sites should not be taken as an endorsement by Spotlight Oral Care.


Data Transfers

We may transfer the personal data we collect about you to our affiliates and third party service providers to countries other than the country in which the information was originally collected, where necessary to fulfill the purposes described in this Policy and your personal data may be processed and stored outside of your country of residence. 

When we transfer your information to other countries, we will protect that information in the manner described in this Privacy Policy. 


What Are Your Rights?

In line with GDPR and the Data Protection Act 2018 you have the right to:

  • To have your information updated or corrected 
  • To restrict the processing of your information
  • To object to direct marketing
  • To have your information deleted from our records
  • Make a Subject Access Request

Right to Rectification: You have the right to request rectification of your personal data if it is incorrect, including the right to have incomplete personal data completed.

If you have an account on our website, you can update your details by logging into it.

Right to Access: You have the right to request information about the personal data we hold about you at any time. 

Right to Portability: Whenever Spotlight Oral Care processes your personal data by automated means based on your consent or based on an agreement you have the right to get a copy of your data in a structured, commonly used and machine-readable format transferred to you or to another party. This only includes the personal data you have submitted to us. 


Right to Erasure: You have the right to erase any personal data processed by Spotlight Oral Care at any time, except for the following situations:

  • you are suspected of misuse of, or have misused our services within the past four years;
  • where the information is needed in exercise or defence of legal claims;
  • where the information is required to comply with any legal obligations; and
  • any other applicable exemption under Article 17(3) of General Data Protection Regulation (GDPR) (EU) 2016/679

Right to Object: You have the right to object to the processing of your personal data that is based on Spotlight Oral Care’s legitimate interests. Spotlight Oral Care will not continue to process your personal data unless we can demonstrate a legitimate basis for the process which overrides your interests and rights or due to legal claims.  

HOW CAN YOU EXERCISE YOUR RIGHTS?

We take data protection very seriously and have therefore dedicated a member of the Spotlight Oral Care team to handle your requests in relation to your rights stated above.

Exercising your rights is free of charge. We can, however, refuse or charge for any requests that are deemed excessive, repetitive and/or unreasonable.

We will need to verify your identity to comply with any request(s) to exercise your rights. We will need some personal information to do so, strictly for the purposes of identity verification. We will only ever comply with requests for the excision of rights with regards to your personal data by you only.

All requests should be resolved within one month. This, however, may take longer for requests that require a more complex resolution. We will inform you of any delays that may be required, along with justification.

You have the right to complain to the DPC if you are unhappy with how we process your personal data. DPC is a body that supervises and enforces privacy laws in Ireland. Please visit their website at https://www.dataprotection.ie/ for more information. We do request that you contact us first with any concerns. We recommend contacting DPC if you are still unsatisfied after attempting to resolve any issues with us directly.

Security and Data Breach Procedures

We take our customers' privacy seriously. We have put a number of systems in place to protect data, including site-wide encryption.

All online transactions are handled by Shop Pay (formerly Shopify Pay), Google Pay, PayPal or Apple Pay; depending on your selection. Spotlight Oral Care does not receive or store your card details. Our team regularly undergoes privacy training and puts your right to privacy first.

Our commitment to you is that, should a breach occur, all affected parties will be contacted without delay. We have a robust policy to handle such an occurrence and staff have been trained in best practice.

We are happy to answer any questions that you may have pertaining to our Data Protection or Privacy Policies, or the use of your information. 

Please email: dataprotection@spotlightoralcare.com

or write to us at: 

Spotlight Oral Care Ltd
Block 2 Harris House
Small IDA Business Park
Tuam Road
Galway
Ireland

This privacy policy was updated: 27th April 2020