Data Protection

Clearly Basics Limited (“Clearly Basics”) has created this privacy policy about the way in which we collect, use and protect (personal) data in order to demonstrate that we take data protection very seriously.
In this statement we inform you about how Clearly Basics handles your personal data. This privacy policy applies to all personal data collected by Clearly Basics for the online services offered. Clearly Basics Limited acts as the controller within the meaning of the General Data Protection Regulation (GDPR) and as the controller for the processing of data within the meaning of the General Data Protection Regulation (GDPR).
When you visit our website, you automatically leave certain data there. The data we collect and keep from you depends on how you use the www.tryclearly.co.uk website. Below you will find more information on the following topics:
  1. Which personal data is processed for what purpose, what is the legal basis for the processing and to whom do we pass this data on:
    • when you use the website?
    • when you order the newsletter or request information material?
    • when you create a user account and shop in our webshop?
    • when you use customer service?
    • when you leave a review of a product?
  2. How is your data protected?
  3. How long is your data kept?
  4. How can you view, correct and change your data and what other rights do you have?
  5. Our contact details and changes to the privacy policy
  1. What personal data is processed for what purpose and to whom do we pass this data on, if applicable?
As part of the Clearly Basics services, certain personal data is collected. What data this is depends on how you use our website and/or our webshop. You can use our website in the following ways:
    1. You only visit our website;
    2. You order our newsletter or request information material;
    3. You create a user account (and shop in our webshop);
    4. You shop in our webshop without creating a user account or logging in;
    5. You shop in our webshop but do not complete the ordering process;
    6. you chat with us via the website;
    7. You provide us with feedback via our website;
    8. You take advantage of customer service.
Below we describe which data we process for each type of use, why and on what legal basis we do this and to which third parties we may pass the data on. We will never share your information with third parties other than those listed below without your consent. Under no circumstances will we sell your data to third parties.
    1. You just visit our website
Read our cookie statement
    1. You order our newsletter or request information material
If you subscribe to a Clearly Basics newsletter or request informational materials from us, we will use your personal information to inform you about our products and services. If you purchase a Clearly Basics product and leave your information, for example by asking a question, we may inform you about other Clearly Basics products in the future.
You can unsubscribe from the newsletter at any time by unsubscribing or sending an email to hello@tryclearly.com
DATA PROCESSED
We process the following data:
      • First and Last Name;
      • When ordering the newsletter: email address;
      • When requesting information material: depending on how you request which material: home/delivery address, telephone number, IP address, email address;
      • When ordering the newsletter, you can also voluntarily provide your date of birth and gender.
PURPOSE OF DATA PROCESSING
Paula's Choice uses your data for the following purpose: Delivery of the newsletter or information material, also taking your age and gender into account.
WHAT LEGAL BASIS
When ordering our newsletter and requesting information material, you clearly
give us your consent to process the aforementioned data using the opt-in
procedure, so that we can send you the newsletter and/or information material. You
have the right to withdraw this consent at any time by sending an email to
hello@tryclearly.com
DISCLOSURE TO THIRD PARTIES
We share this information with:
      1. the third parties who manage our mailing lists and send newsletters;
      2. the third parties we commission to deliver the information material.
c. You create a user account (and shop in our webshop)
To place an order on our website, you can register as a customer on tryclearly.co.uk. You create a user account that is secured with a password and linked to your email address. You enter your data yourself and can change it yourself at any time after logging into your user account.
DATA PROCESSED
We process the following data:
      • First and Last Name;
      • residential/delivery address;
      • E-mail address;
      • telephone number;
      • IP address;
      • Products you have viewed in the past 60 days;
      • products you have ordered;
      • Your last visit and your last login.
We do not process payment data. Payments in our webshop are processed by a payment service provider (Shopify). Shopify enables secure payment processing in different ways. You enter your credit card or bank account details exclusively on these secure pages and then complete the ordering process here. We only receive a message from Shopify that your payment has been received, but we are not informed of your credit card number or your account number. If you decide to pay via Paypal or Klarna, the above also applies; In this case, however, we also register your date of birth, as it is required to authenticate your payment; this information will be passed on to Klarna.
PURPOSE OF DATA PROCESSING
Clearly Basics uses your data for the following purposes:·      
      • We use the data that you store in your user account to process your orders, i.e. to fulfill the contract with you.
      • We use your IP address, email address and information about your online behavior to improve our online services, our products and your experience while visiting our website. For further information, including how to refuse cookies, please see our Cookie Statement.
LEGAL BASIS
The processing of the above data is necessary to carry out your order, that is, to fulfill the contract with you.
DISCLOSURE TO THIRD PARTIES
We share this information with:
      • our partners who prepare, ship and deliver your order to you;
      • our partners who improve your online shopping experience;
      • our partners who process your payment;
      • our partners who manage the database that stores all order and customer data for our website.
CUSTOM AUDIENCE TARGETING
If you order products from us and have given us permission to do so, we can also use your email address for individual target group targeting via Facebook and Google. Clearly Basics creates a custom audience by uploading its customers' email addresses into an advertising tool. This group can then be linked to a specific Facebook campaign: only these Facebook users see the campaign. If you no longer want to be part of a custom audience advertising tool, you can inform us at any time to the following email address: hello@clearlybasics.com

d. You shop in our webshop without creating a user account or logging in

In order to place an order on our website, it is not necessary for you to register as a customer. You enter the data that we need to process your order and you can change this data yourself at any time.
DATA PROCESSED
We process the following data:
      • First and Last Name;
      • residential/delivery address;
      • E-mail address;
      • telephone number;
      • IP address;
      • products you have ordered;
We do not process payment data. Payments in our webshop are processed by a payment service provider (Shopify). Shopify enables secure payment processing in different ways. You enter your credit card or bank account details exclusively on these secure pages and then complete the ordering process here. We only receive a message from Shopify that your payment has been received, but we are not informed of your credit card number or your account number. If you decide to pay via Paypal or Klarna, the above also applies; In this case, however, we also register your date of birth, as it is required to authenticate your payment; this information will be passed on to Klarna.
PURPOSE OF DATA PROCESSING
Clearly Basics uses your data for the following purposes:·      
      • We use the data that you store in your user account to process your orders, i.e. to fulfill the contract with you.
      • We use your IP address, email address and information about your online behavior to improve our online services, our products and your experience while visiting our website. For further information, including how to refuse cookies, please see our Cookie Statement.
LEGAL BASIS
The processing of the above data is necessary to carry out your order, that is, to fulfill the contract with you.
DISCLOSURE TO THIRD PARTIES
We share this information with:
      • our partners who prepare, ship and deliver your order to you;
      • our partners who improve your online shopping experience;
      • our partners who process your payment;
      • our partners who provide database for our website.
CUSTOM AUDIENCE TARGETING
If you order products from us and have given us permission to do so, we can also use your email address for individual target group targeting via Facebook and Google. Clearly Basics creates a custom audience by uploading its customers' email addresses into an advertising tool. This group can then be linked to a specific Facebook campaign: only these Facebook users see the campaign. If you no longer want to be part of a custom audience advertising tool, you can inform us at any time to the following email address: hello@clearlybasics.com

e. You shop in our webshop but do not complete the ordering process

If you add products to your shopping cart in our webshop but do not complete your order for any reason but have already left your email address (for example by logging into your user account), we may remind you that you Have not yet completed your order. In this case, we will send you an email listing the products that were in your shopping cart.
DATA PROCESSED
We process the following data:
      • E-mail address;
      • telephone number;
      • IP address;
      • Products that you have added to your shopping cart but not yet paid for.
PURPOSE OF DATA PROCESSING
Paula's Choice uses your data for the following purposes:
      • We use the information provided to us to help you complete your order by email or telephone.
      • We use your IP address and information about your online behavior to improve our online services, our products and your experience on our website. For further information, including how to refuse cookies, please see our Cookie Statement .
LEGAL BASIS
The processing of the above data is necessary so that we can determine that no errors have occurred in your ordering process.
DISCLOSURE TO THIRD PARTIES
We share this information with: our partners who send you the email reminding you of the contents of your shopping cart.

f. You chat with us via the website

If you spend a long time on a website, the chat function may be activated. If you have any questions, you can also start the chat with our customer service yourself from our website. You enter a (fictitious) chat name.
DATA PROCESSED
We process the following data:
      • your chat name;
      • Your email address (optional), if you provide it yourself;
      • IP address;
      • the duration of your visit to our website.
PURPOSE OF DATA PROCESSING
Paula's Choice uses your data for the following purposes:
      • We use your data to chat with you and advise you about our products and use of the website.
      • We use your IP address and information about your online behavior to improve our online services, our products and your experience on our website. For further information, including how to refuse cookies, please see our Cookie Statement .
LEGAL BASIS
The processing of the above data is necessary so that we can chat with you and, if necessary, advise you about our products and the use of our website and in this way improve our services. If you provide us with data in the chat itself, such as your email address, you agree that this data will be used for the purpose stated in this statement.
DISCLOSURE TO THIRD PARTIES
We share this information with: Our partners who provide the chat software we use to communicate with you.

g. You give us feedback via our website

If you would like to leave a review or otherwise provide feedback about our customer service or products, log in to your account on our website.
DATA PROCESSED
We process the following data:
      • Your (fictitious) name to be displayed with your review;
      • Your email address (this will not be displayed in your review on the website);
      • your feedback or the content of your review;
      • the number of stars with which you rate our product.
PURPOSE OF DATA PROCESSING
Paula's Choice uses your data for the following purposes:
      • We use your (fictitious) name, the number of stars you have given us and your feedback or rating to show other customers what you think of our products and services.
      • We may also use the information to find a solution to a problem you have reported.
LEGAL BASIS
The processing of the above data is necessary to publish your feedback or rating on our website and to possibly contact you in this context so that we can find a solution to your problem or complaint.
DISCLOSURE TO THIRD PARTIES
We share this information with:
      • our partners who manage the website;
      • our customer service who may be able to help you in the event of a complaint.
H. You take advantage of customer service
If you contact us, for example by asking customer service a question by email at hello@tryclearly.com, by telephone, via social media or by post, we will use your personal data to answer your question. Your question will then be saved in our customer service administration.
DATA PROCESSED
We process the following data:
      • your first and last name;
      • Depending on how you contact us: your telephone number, email address and/or postal address.
PURPOSE OF DATA PROCESSING
Clearly Basics uses your data for the following purposes:
We use the data to improve our services:
      • We use the data to support you in selecting products in our webshop.
      • We use the data to help you if you have questions or complaints about our products.
LEGAL BASIS
The processing of the above data is necessary to provide you with advice or to support you with questions and/or complaints, depending on the reason for your contact.
DISCLOSURE TO THIRD PARTIES
We share this information with: our partners who help us provide and carry out customer service.
2. How is your data protected?
Clearly Basics understands that storing your personal information securely is a high priority. The data stored in our database is protected using proven electronic security techniques in accordance with applicable data security standards.
You will only gain access to your user account if you have entered your email address and password correctly. All passwords and other sensitive information are protected by encryption and cannot be viewed by us.
Our websites and web applications are secured using SSL certificates. You can recognize this by a green lock symbol to the left of the web address in your browser's address bar. All data that you send and receive via our website is encrypted and unreadable for third parties. The exchange of data between our websites and our processing partners also takes place via secure connections.
3. How long is your data kept?
Paula's Choice will not retain your data longer than is legally permitted and necessary for the intended purpose. How long certain data may be retained depends on the type of data and the purpose for which it is processed.
4. How can you view, correct and change your data and what other rights do you have?

a. Access, correction and deletion of your data

Upon request, Clearly Basics can provide you with an overview of the personal information we hold about you.
If this data is incorrect or if its retention violates applicable law, we will change it or delete it at your request. Access, correction or deletion of data can be requested at any time by email (hello@tryclearly.com). Clearly Basics will then change or delete your data within four weeks of confirming the
request.

b. contradiction

If you do not agree to a certain type of processing of your data, you can object to the processing at any time by sending an email to hello@tryclearly.com. We will respond to your complaint as quickly as possible, but in any case within
four weeks.

c. Data portability

You are entitled to data portability. This means that you have the right to receive the personal data you have provided to us in a usable format for transferring it to another controller. If you would like to receive your data in such a form, please send an email to hello@tryclearly.com. We will contact you as soon as possible to discuss with you the format in which you would like to receive the data. We will respond to your request within four weeks, or in complex cases within three months of this meeting, and provide the requested data.

d. Revocation of consent given

If you have agreed to the processing of your personal data, you can revoke this consent at any time by sending an email to hello@tryclearly.com. We will respond and confirm your revocation as quickly as possible, but in any case within four weeks.

5. Contact details and changes to the privacy policy

If you have any questions or comments about this privacy policy, you can contact us as follows:
Clearly Basics Limited:
E-mail address: hello@tryclearly.com
Postal address: Irish Formation Connect Limited, 563316, Unit 3D North Point House, North Point Business Park, New Mallow Road Cork, Co. Cork, Ireland
This privacy policy may be changed by Clearly Basics from time to time as new developments arise and/or it is deemed necessary.