HomePrivacy policy

Privacy Policy

Issue Date: May 2018

Last Update: February 2024

1. INTRODUCTION

This Privacy Policy (the "Privacy Policy") provides detailed information on how Eden Springs UK Limited ("EDEN") uses and protects your personal data when browsing our websites (the "Websites"), as well as your rights in this respect.

This Privacy Policy applies to the processing of personal data provided by you or that we obtain from you when you access and use the Websites, be it for browsing the Websites, purchasing our products or services, requesting information from us, contacting us, submitting an application or making use of the functionalities or services available on the Websites. 

EDEN respects your right to privacy and complies with the current legislation on personal data protection, including the UK GDPR and the Data Protection Act 2018, as well as any other rules that may develop or supplement these in the future. 

We recommend that you carefully review our Privacy Policy to ensure that you understand how your personal data is used when browsing the Websites.

2. WHO IS RESPONSIBLE FOR PROCESSING YOUR DATA?

The data controller is the legal person that determines the purposes and means of the processing of personal data. In other words, the controller decides how and for what purpose personal data are processed. 

For the purposes of this Privacy Policy, the data controller is EDEN: Eden Springs UK Limited, with registered office address at The Pinnacle, 170 Midsummer Boulevard, Milton Keynes, United Kingdom, MK9 1FE, registered in England and Wales with registered company number 04063744.

 

3. WHO CAN YOU CONTACT AT EDEN REGARDING THE PROTECTION OF YOUR PERSONAL DATA?

If you have any questions or wish to receive more information regarding the processing or protection of your personal data, you may contact us via any of the following:

Data controller: Eden Springs UK Limited

Postal address: 3 Livingstone Boulevard, Glasgow G72

Telephone: 0800 011 4531

You may also contact us by email at GDPR.Inquiries@edensprings.co.uk

 

4. WHAT IS PERSONAL DATA? 

Personal data is any information relating to an identified or identifiable natural person. 

 

5. WHAT PERSONAL DATA ARE PROCESSED BY EDEN?

For the purposes laid out in this Privacy Policy, EDEN collects and processes the following personal data:

a. Identifying data: name and surname.

b. Contact information: postal address, email address, landline telephone number, mobile telephone number. 

c. Transaction data: information on purchases, orders, contracts, billing and collection, payment methods, bank details, debit or credit card details, delivery instructions (only if you have opted to provide any such delivery instructions) and any other data relating to your transactions with us.

d. Electronic data: IP address, device type and ID, browser type and language, domain through which the Websites are accessed, browsing information, Website activity. 

EDEN does not intentionally collect information on minors, except with the express consent of their parents or legal guardians. You guarantee to be over 16 years old.  If you know or suspect that EDEN has personal data of minors, please contact us through any of the channels indicated in section 3 of this Privacy Policy WHO CAN YOU CONTACT AT EDEN REGARDING THE PROTECTION OF YOUR PERSONAL DATA? and this information will be removed.

6. COLLECTION AND OBTENTION OF PERSONAL DATA

EDEN collects and processes personal data that you provide us when interacting with our Websites, in particular when:

  • requesting information or quotes for our products and services; 
  • subscribing to our newsletter;
  • registering to our Customer Zone or renewing access to the Customer Zone;
  • checking service availability for your home or location;
  • acquiring and paying for EDEN products or services;
  • using your stored payment information for future transactions (in all cases of recurring deliveries, and for One-Time Delivery if you have consented to this);
  • requesting technical assistance or assistance relating to EDEN's services;
  • sending us your CV with the aim of taking part in recruitment processes. 

You are only obliged to provide personal data that is necessary for EDEN to provide you services or make available to you the functionalities of the Websites that you have requested. 

For example, if you wish to receive EDEN's newsletter, it will be necessary for you to provide us with your email address. If you request information from us or would like us to contact you, you must provide us with the contact information needed for these purposes. If you wish to acquire any product or service that EDEN makes available on its Websites, it will be necessary that you provide, all the information required on the order page of the Websites, although you will not be required to tick any voluntary check-boxes relating to marketing or the storage of your payment information.  If you do not provide the required personal data, it would not be possible for us to provide you with our goods and services.

If not all the required information is provided or if we receive an unusual or incorrect response, we will not be able to process your request or provide you with the corresponding service or functionality.  

In any event, you guarantee and are liable for the truthfulness, accuracy, validity and authenticity of the personal data provided and undertake to keep them duly updated.

It is not necessary to provide us with your personal data to browse the Websites. However, when visiting our Websites, EDEN collects, automatically and through cookies, depending on your browser specific settings and your cookie consent selections, the following information:  IP address, device type and ID, browser type and language, domain through which the Websites are accessed, browsing information, Website activity. For more information, please refer to our Cookies Policy at www.edensprings.co.uk.

 

7. WHAT DO WE USE YOUR PERSONAL DATA FOR?  PURPOSES AND LEGAL BASIS FOR DATA PROCESSING

In general, the personal data you provide to us and that we obtain from you are used to process your requests and transactions, to provide you with high-quality service and to inform you about opportunities we believe may interest you. 

Below are the specific purposes for which we process your personal data:

 

  1. To provide you with information you request, including quotes of products and services. In this case, our legitimate interests in responding to customer requests is the legal basis for processing your data.
  2. To send you our newsletter with information, promotions, campaigns and news on products and services of Eden Group and products and services of third parties marketed and distributed by EDEN. In this case, your consent is the legal basis for processing your data.
  3. To check service availability at your home or location. In this case, the need to take steps, at your request, prior to entering into a contract is the legal basis for processing your data.
  4. To register you as a customer, process your transactions, manage the contractual relationship with you, send you relevant customer service information on products and services, provide information on your customer account, send notifications of orders, provide for delivery, maintenance, invoicing, billing, collections and payments, process transactions and payment methods, as well as to provide any other service communication or communications related to your contract and transactions. In this case, the legal basis for processing your data is, if you are a residential customer, the performance of the product sales contract or the service provision contract with EDEN; and, if you are a corporate customer, our legitimate interests in contracting and providing our services to the company at which you are employed or provide services to.
  5. To create an account to provide you with access to the Customer Zone, to renew access to the Customer Zone and to provide you with access to the information and services available therein, for the management of loyalty programmes, discounts and promotions, performing satisfaction surveys or surveys relating to products and services marketed and distributed by EDEN. In this case, the legal basis for processing your data is, our legitimate interests in providing an enhanced level of customer service and additional service features to our customers and monitoring and making improvements to our products and services.
  6. To respond to requests for technical support or support relating to EDEN's services. In this case, our legitimate interests in ensuring that our customers are able to access our services as intended, is the legal basis for processing your data.
  7. To store your data and contact you regarding recruitment and staff selection processes at EDEN, as well as to manage your participation in said processes. In this case, your consent is the legal basis for processing your data.
  8. To send you marketing communications in relation to our products and services and products and services of third parties marketed and distributed by EDEN, coupons, offers (including customized offers) and recommendations of our products and services as well as of products and services of third parties marketed and distributed by EDEN, according to your interests and based on a profile developed by us, by phone, post, email, SMS and MMS. In this case, our legitimate interests in promoting the products and services that we can provide to you is the legal basis for processing your data, except for in any cases where the law requires that we obtain your consent for this, in which case our legal basis will be consent.
  9. To guarantee the security of our Websites and of the information on our Websites. In this case, the legal basis for processing your data is our legitimate interests in providing a secure environment and preventing harm to EDEN's systems and to the users' information, as well as unauthorized access to and misuse of EDEN's systems and users' information.
  10. For internal management purposes: planning, resource allocation, policy development, quality improvement, strategic analysis, marketing strategy and commercial development, monitoring, audit, compliance with legal obligations and, adoption, where appropriate, of legal measures, evaluation and reporting. In this case, the legal basis for processing your data is our legitimate interests in understanding and analysing the development of our business, improving our products and services, and exploring ways to develop and enhance our business.
  11. With regard to the use and purpose of cookies, please refer to our Cookies Policy at www.edensprings.co.uk.  Where we process your data using cookies, your consent is the legal basis for processing your data, except where the relevant cookies are strictly necessary for a service requested by the subscriber/user or for the sole purpose of carrying out the transmission of a communication over an electronic communications network. In this case,  the legal basis for processing your data will be our legitimate interests in providing the relevant Website functionality.

When the basis for data processing is consent, you may withdraw it at any time by sending a communication to GDPR.Inquiries@edensprings.co.uk, including your name and address for communication and verification purposes and providing the necessary details to process your request. You may always contact us through any of the channels indicated in section 3 of this Privacy Policy: WHO CAN YOU CONTACT AT EDEN REGARDING THE PROTECTION OF YOUR PERSONAL DATA?

Bear in mind that receiving marketing information is not essential to maintain the relationship we have with you. If you prefer not to receive marketing communications, you may inform us at any time through the means indicated or opt-out at the link provided for these purposes in the marketing communications that you receive by email, or if the communications are provided by other means, through the procedure indicated for these purposes. 

In the case of One-Time Delivery customers, we will only store your debit or credit card details for future purchases if you consent to us doing so by using the checkbox provided. If you have consented to Eden storing your card details for future purchases, you can revoke this consent at any time (by contacting us through any of the channels indicated in section 3 of this Privacy Policy WHO CAN YOU CONTACT AT EDEN REGARDING THE PROTECTION OF YOUR PERSONAL DATA?). 

In the case of Periodic Supply (Rent Customer), it is necessary that EDEN stores and processes your card details (or bank details, as the case may be), due to the continued nature of the relationship and the periodic and systematic payment of services requested.

To what extent is decision-making automated?

EDEN does not use completely automated decision-making processes to engage in, develop or terminate a contractual relationship with you. If we were to use these processes in a specific case, we would inform you, communicate your rights in this respect and comply with our legal obligations in accordance with applicable regulations.

Will you use profiling?

With the aim of being able to offer you products and/or services in accordance with your interests and to improve your user experience, we may develop a "commercial profile" based on the information provided. However, automated decisions will not be taken based on said profile. 

8. WHO WILL WE SHARE YOUR PERSONAL DATA WITH?

We only use, transfer or share personal data with third parties in accordance with the terms laid out in this Privacy Policy. EDEN does not sell or rent your personal data to third parties and only communicates personal data to persons or entities if we obtain your prior consent or pursuant to or in accordance with applicable legislation when consent is not necessary for a specific transfer. 

We will share or give third parties access to your personal data when necessary to achieve one of the objectives described below and in accordance with current legislation: 

a. Our suppliers. EDEN shall communicate or allow access to your personal data to companies that provide services to us under a contract, when it is necessary to achieve one of the purposes described in section 7 of this Privacy Policy WHAT DO WE USE YOUR PERSONAL DATA FOR? - PURPOSES AND LEGAL BASES FOR DATA PROCESSING in respect of the following: IT and web platform services, management of orders and shipping, payment processing, email distribution, call centres, web positioning services, marketing, market analysis and organization of promotional campaigns. If any of these service providers needs to access your personal data, they will use it only to provide us with a service and according to our instructions. We also require them to keep the data confidential and secure and to return or destroy the data when they no longer need it. Some of these suppliers are located abroad, so these transfers may imply an international transfer of your personal data as described in section 8.d.

b. Legal obligations: EDEN may communicate your personal data when the transfer is necessary to comply with a legal obligation, including the transfer to competent authorities, judges and courts. This includes complying with requests made by authorities regarding the prevention of money laundering and the financing of terrorism.

c. Eden Group companies: EDEN shall allow access to your personal data to Eden Group companies for the purposes described in section 7.j) of this Privacy Policy WHAT DO WE USE YOUR PERSONAL DATA FOR?  PURPOSES AND LEGAL BASES FOR DATA PROCESSING, or when required for the establishment, exercise or defence of legal claims, or to comply with a statutory requirement. EDEN shall allow access to your personal data to companies belonging to Eden Group that provide services to us and act as data processor. Eden Group companies are located within and outside the UK, so these transfers may involve an international transfer of your personal data as described in section 8.d). For additional information about Eden Group and its structure, visit https://www.edensprings.co.uk/about-us/.

d. International data transfers. Your data may be disclosed to other companies within the Eden Group and to data processors, within and outside the UK. In some cases, the laws of countries outside the UK do not provide the same level of protection of your personal data as those of the UK. However, to the extent that your personal data is transferred outside the UK, such transfers will be based on adequacy regulations or in the event that there are no applicable adequacy regulations in place in respect of the location to which personal data will be transferred, standard contractual clauses adopted by the UK Government. For additional information on data transfers, or to obtain a copy of the standard contractual clauses (where these are used) contact us through any of the channels indicated in section 3 of this Privacy Policy WHO CAN YOU CONTACT AT EDEN REGARDING THE PROTECTION OF YOUR PERSONAL DATA? Any standard contractual clauses that we provide will be redacted to remove commercial information and personal data. 

 

9. WHAT MEASURES DO WE APPLY TO KEEP YOUR PERSONAL DATA SAFE?

EDEN takes the appropriate technical and organisational measures in accordance with current regulations to protect your personal data against any misuse, destruction, loss, accidental or illicit modification, disclosure or unauthorised access, including the measures necessary to deal with any suspected data breaches. 

The Websites have a log-in system, with a username and password, through which only authorised users can access the private Customer Zone area. EDEN shall not use this information at any time for any use other than maintenance of the mentioned Customer Zone, to manage the business relationship with you, as well as to offer any services available in the Customer Zone. 

You agree to keep and use the username with due care and diligence. The use of the password is personal and non-transferable and the transfer of the password to third parties is not allowed, not even temporarily. In that regard, you must take the necessary measures to safeguard your password, preventing its use by third parties. Accordingly, you are solely responsible for the use of your password and EDEN shall not be liable in respect of any loss or damage connected with the misuse of your password. 

If you are aware of or suspect that your password is being used by third parties or that personal data may be being misused or accessed without authorization, please notify us as soon as possible through any of the channels indicated in section 3 of this Privacy Policy WHO CAN YOU CONTACT AT EDEN REGARDING THE PROTECTION OF YOUR PERSONAL DATA?  

 

10. HOW LONG DO WE RETAIN YOUR DATA?

EDEN shall retain your personal data for the time necessary to fulfil the purposes for which they were collected, or while you do not exercise your right to erasure or to withdraw your consent.

The data will be subsequently deleted, unless a longer retention period is required or permitted by law (for instance, for the establishment, exercise or defence of legal claims) in which case they will be duly retained as long as required before deleting them.

To determine an appropriate retention period of your data, we apply the following criteria:

  1. The data necessary to provide you with the information you request, including quotes of products and services, shall be retained for the time necessary to attend to and process said requests, in accordance with the applicable legal provisions and the statute of limitations periods laid down in the legislation. 
  2. The data necessary to send you the newsletter shall be retained so long as you do not withdraw your consent or inform us of your wish to not continue receiving it, in accordance with the applicable legal provisions and the statute of limitations periods laid down in the legislation.
  3. The data required to register in our Customer Zone shall be retained during the term of the contract with EDEN, so long as you do not unsubscribe to the private area, in accordance with the applicable legal provisions and the statute of limitations periods laid down in the legislation.
  4. The data necessary to check the availability of service at your home or location shall be retained so long as it is strictly necessary for these purposes, in accordance with the applicable legal provisions and the statute of limitations periods laid down in the legislation.
  5. The data related to the acquisition of EDEN products and services in the context of a contractual relationship shall be retained during the term of the contract with EDEN or for the time necessary to exercise the rights and comply with the obligations of the contract with EDEN, in accordance with the applicable legal provisions and the statute of limitations periods laid down in the legislation. 
  6. The data necessary to attend to your requests for technical support or those related to EDEN products and services shall be retained for the time necessary to attend to and process said requests, in accordance with the applicable legal provisions and the statute of limitations periods laid down in the legislation. 
  7. When you consent to receive marketing communications, your data shall be retained so long as you do not withdraw your consent or inform us of your wish to not continue receiving these communications, in accordance with the applicable legal provisions and the statute of limitations periods laid down in the legislation. 
  8. The data sent with a view to participate in recruitment/staff selection processes shall be retained on a general basis for 3 years, in accordance with the applicable legal provisions and the statute of limitations periods laid down in the legislation.
  9. When cookies are placed on your device, the data shall be retained in accordance with the applicable legal requirements and the recommendations made by the competent authorities. 

11. WHAT ARE YOUR RIGHTS WITH RESPECT TO THE PROCESSING OF YOUR PERSONAL DATA?

In accordance with the applicable legislation, you have specific rights with regard to the collection and processing of your personal data. 

These rights are the following:

  1. Right to information: You have the right to be informed about the use and processing of your personal data in a concise, transparent, intelligible and easily accessible manner, and with clear and simple language. 
  2. Right of access: You have the right to request from us, at any time, that we confirm if we are processing your personal data, that we provide you with access to said data and to the information about the processing of them, and to obtain a copy of said data. The copy of your personal data that we provide you shall be free, although the request for additional copies could be subject to a reasonable fee based on administrative costs. On our part, we may request that you give proof of your identity or require more information from you in order to handle your request. 
  3. Right to rectification: You have the right to request the rectification of inaccurate, outdated or incomplete personal data that concerns you. You may also request that any personal data that may be incomplete is completed, including by means of providing a supplementary statement.
  4. Right to erasure: You have the right to request the erasure of your personal data when, among other things, the data are no longer necessary for the purposes for which they were collected or processed. However, this right is not absolute so that EDEN may continue to keep them, duly blocked, in those cases laid down in the applicable regulations.
  5. Right to restriction of processing: You have the right to request that we restrict the processing of your personal data, which means that we may continue storing them, but may not continue processing them if any of the following conditions is met:

- that you contest the accuracy of the data, during a period that allows us to verify the accuracy of said data;

- the processing is unlawful and you oppose the erasure of the data and request the restriction of their use instead; 

- EDEN no longer needs the data for the purposes of processing, but you need us to keep it for the establishment, exercise or defence of legal claims; 

- You have objected to the processing, pending the verification whether EDEN's legitimate grounds override yours.

  1. Right to data portability: You have the right to have your data transferred to another data controller in a structured, commonly used and machine-readable format. This right is applied when the processing of your personal data is based on consent or on the execution of a contract, and said processing is carried out by automated means.
  2. Right to object: This right allows you to object to the processing of your personal data, including profiling. We shall no longer process your data unless we demonstrate compelling legitimate grounds for the processing or for the establishment, exercise or defence of legal claims.
  3. Right to withdraw consent: In those cases in which we have obtained your consent to process your personal data in connection with certain activities (for example, with the aim to send you marketing information), you may withdraw it at any time. 
  4. The right to lodge a complaint with a supervisory authority: You have the right to lodge a complaint with the UK Information Commissioner’s Office at https://ico.org.uk/concerns/.

You may exercise your rights by sending a communication to GDPR.Inquiries@edensprings.co.uk, including your name and address for communication and verification purposes and providing the necessary details to process your request.

If you wish to withdraw the consent given to receive marketing communications, you may inform us at any time through the means indicated or opt-out at the link provided for these purposes in the marketing communications that you receive by email, or if the communications are provided by other means, through the procedure indicated for these purposes.

If your requests are manifestly unfounded or excessive, in particular because of their repetitive character, we may either charge a reasonable fee, considering the relevant administrative costs, or we may not act on the request.

For further information on your rights you may contact us through any of the channels indicated in section 3 of this Privacy Policy, WHO CAN YOU CONTACT AT EDEN REGARDING THE PROTECTION OF YOUR PERSONAL DATA?

 

12. AMENDMENTS

EDEN may amend this Privacy Policy to adapt it to the changes that the Websites may undergo or in relation to the processing of your personal data or as required by law, from time to time. Any such updates will be posted by EDEN on the Websites as they occur.