Privacy Policy

Important Information and Who We Are

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    1. Midnight Health is the data controller and responsible for your personal data. We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

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Midnight Health Ltd

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Southampton

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United Kingdom

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UKsales@midnightconsulting.co.uk

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The Personal Data We Collect About You

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    2. 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).

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

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• Identity Data: includes first name, last name, username or similar identifier, marital status, title, date of birth and gender.

• Contact Data: includes billing address, delivery address, email address and telephone numbers.

• Financial Data: includes bank account and payment 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, 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 our third parties and your communication preferences.

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We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature.

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How We Collect Your Personal Data

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    3. We use different methods to collect data from and about you including through:

• 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:

  • subscribe to our newsletter;

  • request marketing to be sent to you;

  • enter a competition, promotion or survey; or

  • 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 that use our cookies.

• Third parties or publicly available sources: We may receive personal data about you from various third parties and public sources as set out below:

  • Technical Data from analytics providers such as Google Analytics;

  • Contact and Financial Data from providers of technical, payment and delivery services;

  • Identity and Contact Data from publicly available sources such as Companies House.

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    4. How We Use Your Personal Data

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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:

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Where we need to perform the contract we are about to enter into or have entered into with you.

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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.

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Where we need to comply with a legal or regulatory obligation.

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Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to 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

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We have set out below, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

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Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

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Purpose/Activity Type of data Legal basis for processing including basis of legitimate interest To register you as a new customer Identity Contact Performance of a contract with you

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To process and deliver your order including: Manage payments, fees and charges Collect and recover money owed to us Identity Contact Financial Transaction Marketing and Communications Performance of a contract with you Necessary for our legitimate interests (to recover debts due to us)

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To manage our relationship with you which will include: Notifying you about changes to our terms or privacy policy Asking you to leave a review or take a survey Identity Contact Profile Marketing and Communications Performance of a contract with you Necessary to comply with a legal obligation Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

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To enable you to participate in a prize draw, competition or complete a survey Identity Contact Profile Usage Marketing and Communications Performance of a contract with you Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

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To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) Identity Contact Technical Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) Necessary to comply with a legal obligation

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To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you Identity Contact Profile Usage Marketing and Communications 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) To make suggestions and recommendations to you about goods or services that may be of interest to you Identity Contact Technical Usage Profile Necessary for our legitimate interests (to develop our products/services and grow our business)

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Marketing

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We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

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Promotional Offers from Us

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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).

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