Privacy Policy

Welcome to the FairBotanicals Limited privacy policy.

FairBotanicals Limited respects your privacy and is committed to protecting your personal data. This privacy policy explains how we handle your personal data when you visit our website (regardless of where you visit it from), outlines your privacy rights, and explains how the law protects you.

This website is intended for business customers only. If you are a consumer (an individual purchasing wholly or mainly for personal use), please do not use this website to make purchases.

Please use the Glossary at the end of this policy to understand the meaning of some of the terms used.

1. IMPORTANT INFORMATION AND WHO WE ARE

Purpose of this privacy policy

This privacy policy aims to give you information on how FairBotanicals Limited collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter, purchase a product, create an account, or contact us.

This website is not intended for children, and we do not knowingly collect data relating to children.

You must read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Controller

FairBotanicals Limited is the controller and is responsible for your personal data (collectively referred to as “FairBotanicals”, “we”, “us” or “our” in this privacy policy).

If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us using the details set out below.

Contact details

• Email address: info@fairbotanicals.eu
• Registered address: Unit 3D, North Point Business Park, Cork T23 AT2P, Ireland]

Supervisory authority

You have the right to make a complaint at any time to the Data Protection Commission (DPC), the Irish supervisory authority for data protection issues (www.dataprotection.ie). We would, however, appreciate the chance to deal with your concerns before you approach the DPC, so please contact us in the first instance.

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

We keep this privacy policy under regular review. We may update it from time to time, and the “Last Updated” date at the top of this policy will reflect any changes. The personal data we hold about you must be accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

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 policy of every website you visit. 

2. THE DATA WE COLLECT ABOUT YOU

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).

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

• Identity Data includes first name, last name, username or similar identifier, title, and company name.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes bank account and payment card details (processed by our payment processors – we do not store full 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 your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity.

We do not collect any Special Categories of 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.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

3. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you, including:

Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

• apply for our products or services;
• create an account on our website;
• subscribe to our service or publications;
• request marketing to be sent to you; • enter a competition, promotion or survey; or
• give us feedback or contact us.

Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our separate Cookie Policy for further details.

Third parties or publicly available sources. We may receive Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Stripe, PayPal, and shipping carriers based inside or outside the EU (with appropriate safeguards in place as described in Section 6 below).

4. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you (Art. 6(1) (b) GDPR).
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests (Art. 6(1) (f) GDPR).
• Where we need to comply with a legal obligation (Art. 6(1) (c) GDPR).

Generally, we do not rely on consent as a legal basis for processing your personal data, although we will get your consent before sending third-party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

Purpose/Activity	Type of data		Lawful basis for processing (including GDPR Article)
To register you as a new customer	(a)        Identity        (b)        Contact		Performance of a contract with you (Art. 6(1)(b))
To process and deliver your order including managing payments, fees, charges and collecting money owed to us	(a)        Identity             (b) Contact (c) Financial (d) Transaction (e) Marketing       and Communications		(a) Performance of a contract with you (Art. 6(1)(b)) (b) Necessary for our legitimate interests – to recover debts due to us (Art. 6(1)(f))
To manage our relationship with you including notifying you of changes to our terms or privacy policy and asking you to leave a review or take a survey	(a)        Identity             (b) Contact (c) Profile (d) Marketing       and Communications		(a) Performance of a contract with you (Art. 6(1)(b)) (b) Necessary to comply with a legal obligation (Art. 6(1)(c)) (c) Necessary for our legitimate interests – to keep our records updated and to study how customers use our products/services (Art. 6(1)(f))
To        administer       and
protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a)        Identity             (b) Contact (c) Technical		(a) Necessary for our legitimate interests – for running our business, provision of administration and IT services, network security, to prevent fraud (Art. 6(1)(f)) (b) Necessary        to         comply            with             a          legal obligation (Art. 6(1)(c))
To deliver relevant website content and advertisements to you and measure or understand the	(a)        Identity             (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical		Necessary for our legitimate interests – to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy (Art. 6(1)(f))
Purpose/Activity	Type of data		Lawful basis for processing (including GDPR Article)
effectiveness             of           our advertising
To use data analytics to improve         our           website, products/services, marketing, customer relationships and experiences	(a)      Technical Usage	(b)	Necessary for our legitimate interests – to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy (Art. 6(1)(f))
To make suggestions and recommendations to you about goods or services that may be of interest to you	(a)      Identity           (b) Contact (c) Technical (d) Usage (e) Profile (f)      Marketing           and Communications		Necessary for our legitimate interests – to develop our products/services and grow our business (Art. 6(1)(f))

Marketing

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods from us and you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by contacting us. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product purchase, warranty registration, product experience or other transactions.

Change of purpose

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.

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.

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.

5. YOUR RIGHTS AS A DATA SUBJECT

Under the EU General Data Protection Regulation (GDPR), you have the following rights as a data subject (Articles 15–22 GDPR):

Right	Description	GDPR Article
Right of access	You have the right to obtain confirmation as to whether we process personal data concerning you, and to request a copy of that personal data.	Art. 15
Right to rectification	You have the right to obtain the rectification of inaccurate personal data concerning you and to have incomplete personal data completed.	Art. 16
Right to erasure (right to be forgotten)	You have the right to obtain the erasure of personal data concerning you under certain circumstances (e.g., where the data is no longer necessary for the purposes for which it was collected).	Art. 17
Right to restriction of processing	You have the right to obtain restriction of processing under certain circumstances (e.g., where you contest the accuracy of the data).	Art. 18
Right     to            data portability	You have the right to receive your personal data in a structured, commonly used and machine-readable format and to transmit that data to another controller.	Art. 20
Right to object	You have the right to object to processing of your personal data based on legitimate interests or for direct marketing purposes (see Section 6 below).	Art. 21
Right	Description	GDPR Article
Rights related to automated decisionmaking	You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you. We do not use automated decision-making.	Art. 22

No fee is usually required

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 could refuse to comply with your request in these circumstances.

What we may need from you

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.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally, it could 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.

To exercise any of these rights, please contact us at info@fairbotanicals.eu.

6. RIGHT TO OBJECT (ART. 21 GDPR)

You have specific rights to object to our processing of your personal data in certain circumstances.

Direct marketing

If we process your personal data for direct marketing purposes, you have the right to object to such processing at any time, without stating any reason. If you object, we will cease processing your personal data for direct marketing purposes immediately.

Legitimate interests

If we process your personal data based on legitimate interests (Art. 6(1) (f) GDPR), you have the right to object to such processing for reasons arising from your specific situation. We will then terminate processing unless we can demonstrate compelling legitimate grounds for the processing that override your rights and freedoms, or unless the processing is required for the establishment, exercise or defence of legal claims.

How to object

To exercise your right to object, please contact us at info@fairbotanicals.eu or by post to FairBotanicals registered address, Unit 3D, North Point Business Park, Cork T23 AT2P, Ireland.

7. DISCLOSURES OF YOUR PERSONAL DATA

We may share your personal data with the parties set out below for the purposes set out in the table in Section 4 above:

• Internal Third Parties: None – FairBotanicals does not share personal data with other group companies.
• External Third Parties as set out in the Glossary below.
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

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 for specified purposes and in accordance with our instructions.

8. INTERNATIONAL TRANSFERS

We may transfer your personal data outside the European Economic Area (EEA) to third-party service providers (such as payment processors, analytics providers, or shipping carriers) or to suppliers in sourcing origin countries.

When we transfer your personal data outside the EEA, we ensure a similar degree of protection is afforded to it by implementing at least one of the following safeguards:

• Adequacy decisions: Transferring to countries that have been deemed to provide an adequate level of protection by the European Commission (e.g., under the EU-US Data Privacy Framework for certified US entities); or
• Standard Contractual Clauses (SCCs): Using specific contracts approved by the European Commission which give personal data the same protection it has in Europe.

Transfers to the United States: Where we transfer data to service providers in the United States, we rely on the EU-US Data Privacy Framework (for certified entities) or Standard Contractual Clauses, as applicable.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data outside the EEA.

9. DATA SECURITY

We have put in place appropriate technical and organisational security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

Secure data transfer: All data exchange to and from our website is encrypted using the HTTPS protocol. We use current encryption standards to protect your personal data during transmission.

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 on our instructions, and they are subject to a duty of confidentiality.

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.

10. DATA RETENTION

How long will we use your personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.

Specific retention periods

Type of Data	Retention Period	Legal Basis / Reason
Financial and Transaction Data (invoices, payment records)	Minimum 6 years following the end of the tax year to which they relate	Irish tax law requirements
Marketing           and Communications Data	Until you opt out or unsubscribe	Your consent / legitimate interest
Technical and Usage Data (Google Analytics)	2              months (as         per                 Google Analytics 4 default)	Legitimate interest
Account registration data	For the duration of your active account, plus 12 months after account closure	Contractual necessity
Customer            service correspondence	3 years from the date of last contact	Legitimate interest (to maintain service history)

Legal disputes and litigation

In the event of a legal dispute or potential litigation, we may retain your personal data for longer than the standard retention periods if required for the establishment, exercise or defence of legal claims. In such cases, data will be retained until the applicable statutory limitation period has expired (which may be up to six years for contractual claims under Irish law).

Determining retention periods

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, regulatory, tax, accounting or other requirements.

Anonymisation

In some circumstances we will 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.

11. COOKIES AND WEB TRACKING

Cookies

Our website uses cookies to distinguish you from other users. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.

For detailed information on the cookies we use, the purposes for which we use them, and how you can control them, please see our separate Cookie Policy available on our website.

Google Analytics 4

We use Google Analytics 4 (GA4), a web analytics service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (“Google”). GA4 uses cookies to help us analyse how visitors use our website.

IP Anonymisation: We have implemented IP anonymisation on our website. This means that your IP address is shortened by Google within Member States of the European Union or in other contracting states of the Agreement on the European Economic Area before being transmitted to Google servers. Only in exceptional cases will the full IP address be transmitted to a Google server in the United States and shortened there.

Use of data: Google will use this information on our behalf to evaluate your use of the website, to compile reports on website activity, and to provide us with other services relating to website and internet use.

Data retention: The data collected by Google Analytics 4 will be stored for a period of two months and will be automatically deleted thereafter.

Opt-out: You may prevent the collection of data generated by the cookie and relating to your use of the website (including your IP address) by Google, as well as the processing of this data by Google, by downloading and installing the browser plug-in available at: https://tools.google.com/dlpage/gaoptout.

For more information, please see Google’s Privacy Policy: https://policies.google.com/privacy.

12. GLOSSARY

Lawful bases (Article 6 GDPR)

Term	Meaning
Legitimate Interest (Art. 6(1)(f))	The interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests.
Performance of Contract (Art. 6(1)(b))	Processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply                with       a                 legal obligation (Art. 6(1)(c))	Processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

External third parties

Third Party	Purpose	Location	Safeguards
Stripe	Payment processing	EU / US	Standard Contractual Clauses + EU- US DPF
PayPal	Payment processing	EU / US	Standard Contractual Clauses + EU- US DPF
[Shipping carrier – e.g., DHL, FedEx, An Post]	Delivery of goods	EU / non-EU	Standard              Contractual                 Clauses (where applicable)
Google Analytics 4 (Google Ireland Limited)	Website analytics	EU / US	EU-US DPF + Standard Contractual Clauses
Hostinger	Website hosting	EU / US	EU-US DPF + Standard Contractual Clauses
Third Party	Purpose	Location	Safeguards
Revenue                 Commissioners (Ireland)	Tax compliance	Ireland	Legal obligation

13. CHILDREN

Our website is not intended for children, and we do not knowingly collect data relating to children. 

14. AUTOMATED DECISION-MAKING

We do not use fully automated decisionmaking, including profiling, that produces legal effects concerning you or similarly significantly affects you. 

15. CONTACT US

If you have any questions about this privacy policy, your rights, or how we handle your personal data, please contact us:

• Email: info@fairbotanicals.eu
• Postal address: FairBotanicals registered address, Unit 3D, North Point Business Park, Cork T23 AT2P, Ireland

You also have the right to lodge a complaint with the Data Protection Commission (DPC), the Irish supervisory authority:

• Website: dataprotection.ie
• Address: 21 Fitzwilliam Square South, Dublin 2, D02 RD28, Ireland

We would, however, appreciate the chance to deal with your concerns before you approach the DPC, so please contact us in the first instance.

FairBotanicals Limited