We would like you to feel comfortable visiting our Website. It is very important to us to protect your privacy when your personal data are processed.
www.daisybelle.ie (the Website) is a Website operated by Pemberton Marketing International Limited (we, us, our). We are a member of the Phoenix Group Ireland (Group).
- what information we collect about you;
- how we, and our Group companies may use that information; and
- the steps we take to ensure that your information is kept secure. We also explain your rights and how to contact us.
We are the Data Controller: Pemberton International Ltd t/a daisybelle, United Drug House, Magna Drive, Magna Business Park, Citywest Road, D24XKE5, Dublin, Ireland, Tel: +353 1 463 2300, email: firstname.lastname@example.org
Our Data Protection Officer will be happy to assist you with any concerns regarding data protection (see section Contact below).
As part of providing the platform for our online store, Shopify International Limited (Shopify Ireland) may transfer personal data to MaxMind, a transfer fraud detection service that processes personal data to help us avoid fraudulent transactions. In this capacity, MaxMind acts as an independent data controller with regards to your personal data that they may processed. You can find more information about MaxMind’s privacy practices here: www.maxmind.com/en/privacy-policy
Personal data means any information relating to an identified or identifiable natural person who can be identified, directly or indirectly, in particular, by reference to an identifier. Identifiers can include, for example, a name, an identification number, location data, an online identifier, an IP address or one or more factors specific to the physical, physiological, genetic, psychological, economic, cultural or social identity of that natural person (hereafter referred to jointly as data).
Personal data that we collect and why
Orders and your Daisybelle account information
- Examples of data collected: name, billing address, delivery address, payment information (including credit card numbers), email address, and phone number, order data, receipt data, date of birth.
- Purpose of collection: to provide products or services to you to fulfil any orders you place with us through our Website or our mobile applications, for example to:
- create and maintain your customer account once you become a registered customer;
- process your payment information, arrange for delivery, and provide you with invoices and/or order confirmations (If we don’t collect your data during checkout, we won’t be able to process your order);
- communicate with you in respect of product and services;
- screen our orders for potential risk or fraud;
- continuously improve our service to you by monitoring telephone calls which we receive at our branches and call centres for the purposes of staff training, quality control and service improvement;
- we may (when you consent) use your data, preferences and details of your transactions to keep you informed about relevant products and services including tailored special offers, discounts, promotions, events, competitions and so on. For this purpose, you will be asked to “opt-in” and we will not process your data unless you explicitly authorise us to do so. Of course, you are free to opt out of hearing from us by any of these channels at any time;
- manage and administer the Daisy Points Scheme; to communicate information to Daisy Points Scheme members; to use information relating to sets or groups of Members, without identifying Members, to enhance our understanding of the use of Daisy Points Scheme and enable us to improve our Service in general;
- capture your product reviews, for example when you buy goods and services from us we may follow it up with an enquiry about your experience of the product to help us gauge customer satisfaction. You are not obligated to leave reviews and ratings but this facility would enable you to get your views of the product across should you wish to do so;
- to notify you about changes to our services and to send you service emails relating to the activities you have asked us to undertake on your behalf;
- to communicate with you in the event that any services requested are unavailable or if there is a query or problem with your order.
- Source of collection: data is provided by you for example by: creating an account with us; filling in forms on our Website; by interacting with us by e-mail, telephone or otherwise; when you purchase products and/or services from us; when you reply to an email; by entering a competition, promotion or survey.
Customer support information
- Examples of data collected: name, billing address, delivery address, payment information (including credit card numbers), email address, and phone number, order data, receipt data, and any other data you provide to us when seeking customer support.
- Purpose of collection:
- to provide customer support: to respond to your queries, refund requests and complaints. Handling the information, you submit to us, enables us to respond effectively. We may also keep a record of these queries to inform any future communications between us and to demonstrate how we communicated with you throughout. We do this on the basis of our contractual obligations to you, our legal obligations and our legitimate interests in providing you with the best service;
- to allow you to participate in interactive features of our services, when you choose to do so;
- to resolve any disputes, if you lawfully exercise your rights or if you wish to dispute any part of our service offering;
- to communicate with you in the event that any services requested are unavailable or if there is a query or problem with your order.
- Source of collection: data is provided by you for example by: filling in forms on our Website; by interacting with us by e-mail, telephone or otherwise; when you reply to an email, when you report a problem with our Website.
- Examples of data collected: version of web browser, IP address, the country where the computer device is located, time zone, cookie information, internet connection, what sites or products you view, search terms, the advertisements you clicked on and other information about your visit and how you used and interact with our Website.
- Purpose of collection:
- to load the Website accurately for you;
- to perform analytics on the Website usage to optimise our Website (when you consent by selecting performance cookies);
- to keep our Website safe and secure.
- Source of collection: Collected automatically when you access our Website using cookies, log files, web beacons, tags, or pixels.
Compliance with law
- We may use your data to comply with applicable law, for example, in response to a request from a court or regulatory body, where such request is made in accordance with the law.
Social media and other contact information
- We may collect your social media username, if you interact with us through those channels, to help us respond to your comments, questions or feedback.
- We will also collect details of your interactions with us through our contact centres, online and when you use any of our mobile applications.
Information we receive from other sources
- We also work closely with third parties (including, for example, business partners, service providers, advertising networks, analytics providers, and search information providers) and may receive information about you from them. This may be combined with other information you provide to us, as described above.
Information about other people
We do not intentionally collect data from individuals under the age of 16. If you are the parent or guardian and believe your child has provided us with data, please contact us at the address below to request deletion.
As described above, we may use your data to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For example,:
- We may (if you consent) use your data, preferences and details of your transactions to keep you informed by email, web, text, telephone and through our contact centres about relevant products and services including tailored special offers, discounts, promotions, events, competitions and so on. For this purpose, you will be asked to “opt-in” and we will not process your data unless you explicitly authorize us to do so. Of course, you are free to opt out of hearing from us by any of these channels at any time.
- We also use analytics services which help us understand how customers use the Website including Google Analytics. See section below re Google Analytics. You can also read more about how Google uses your data here: https://policies.google.com/privacy?hl=en
- For the purpose of statistical analysis of the use of our Website, we use Google Analytics, a web analytics service provided by Google Ireland Limited (Parent: Google LLC) (Google) to help us understand how our customers use the Website. Google Analytics, uses a set of cookies to collect information and report site usage statistics without personally identifying individual visitors to Google. ‘_ga’ is the main cookie used by Google Analytics. ‘_ga’ enables a service to distinguish one user from another and lasts for two years. It is used by any site that implements Google Analytics, including Google services.
- The information generated by the cookie about your use of this Website is usually transferred to and stored by Google on servers in the USA. However, if IP anonymisation is activated on this website, your IP address will be shortened by Google beforehand within member states of the EU or the EEA. Only in exceptional cases will the full IP address be sent to a Google server in the USA and shortened there. On behalf of the operator of this Website, Google will use this information to evaluate your use of the Website, to compile reports on Website activity and to provide other services related to Website activity and internet usage to the Website operator. The IP address provided by your browser as part of Google Analytics will not be merged with other Google data.
- This website uses Google Analytics with the extension "_anonymizeIp ()". As a result, IP addresses are processed further in shortened form, making it impossible to link them to a specific individual.
- The information obtained as part of the static analysis of our Website will not be merged with your other data collected on the Website.
- You can prevent the collection of the data that are generated by the cookie and related to your use of the Website as well as the processing of these data by:
- changing your cookie preferences on our website by selecting Cookie Preferences at the bottom of the page or by changing your preferences in your browser software;
- downloading and installing the browser plugin available at the following link: http://tools.google.com/dlpage/gaoptout?hl=deor
- clicking on this link: https://tools.google.com/dlpage/gaoptout An opt-out cookie will then be stored on your device. If you delete your cookies, you must click the link again. However, please be aware that in this case you may not be able to use the full functionality of this Website.
- Ad Settings helps you to control ads that you see on Google services (such as Google Search or YouTube).
- Google Analytics stores data for up to 12 months. After the anonymisation of the IP address the information can no longer be traced back to you personally. There are no personal references in the reports that are created on the basis of Google Analytics.
- The Google Analytics Advertising Features enable Google Analytics to collect data about users to make advertising more engaging to users. Cookies like ‘NID’ and ‘SID’ can be used to help customise ads on Google properties, like Google Search, Youtube and Google partner websites. Any advertising cookies on our Website are not automatically accepted unless you consent for such cookies to be placed on your device.
- We will not identify our users or facilitate the merging of personally identifiable information with non-personally identifiable information collected through any Google advertising product or feature unless we have your prior affirmative (i.e., opt-in) consent to, that identification or merger.
Facebook and Instagram social plugins
- Our Website contains social plugins for Facebook and Instagram. The bookmarks are indicated by the respective logo. To enhance the protection of your data when visiting our Website, the respective social plugins are not fully incorporated in the Website; instead, HTML links are used.
- This ensures that, when you access our Website, no link is created to the servers of Facebook or Instagram and your data are not transmitted to them. If you click on any of the social plugins, Facebook or Instagram button, a new window will open in your browser and open the website of Facebook or Instagram, on which (after entering your login details, if necessary) you can click the like or share button, for example. In functional terms, the respective social plugin is equivalent to a hyperlink, meaning that neither we nor Facebook collect data about you on our Website.
- If you are already logged in to any of the social plugins, the respective social media platform will be notified that you have accessed the corresponding page on our Website and the respective platform may trace your visit to your account. Information about the purpose and scope of data collection and the further processing and use of your data by Facebook or Instagram, as well as your rights in this regard and the settings you can choose to protect your privacy, can be found in the privacy policies of Facebook and Instagram at:
- If you do not want Facebook or Instagram to gather data about you via our Website, before visiting our Website you must log out of these sites and delete any cookies they have placed on your PC.
Our Facebook and Instagram Page
- We want our social media pages to provide interesting and helpful information related not just to our business, but also to provide a platform for a community of people interested in our products.
- The data that you have entered on our social media presences are publicly accessible data (for example, comments, pictures, likes, messages to us, etc.) and are exclusively used by us to interact with you. We have a legitimate interest to provide you with appropriate platforms, on which we can share current information with you and you can contact us. Comments, pictures and likes made by you on our social media presences are stored by the operator of the social media presence, as long as our social media presence account exists or alternatively directly by the operator of the respective site for the given duration.
- Because you may want to share information about your health and various conditions which are often complicated, and almost always personal we cannot engage in public discussions of individuals' conditions and queries within our social media
- Please refrain from posting any personally identifiable information, such as your full name, address, PPS number, phone number or email address on our social media pages. In an effort to protect your privacy, we will delete any posts that include this information on our public wall. As a general rule, we will leave up comments that are critical of us, except when those comments become disruptive to the community.
- We reserve the right to remove any comments, including those that are obscene or offensive, derogatory or disparaging and that are based on an individual's sex, race, colour, religion, age, national origin, marital status, ancestry, sexual orientation, veteran status, disability, pregnancy or citizenship status or are threatening or defamatory.
- You can also refer to Facebook's Terms of Service for Facebook's advice on posting rules and guidelines: https://www.facebook.com/legal/terms
Lawful grounds for processing
To process your data lawfully we need to rely on one or more valid legal grounds. The grounds we may rely upon for the processing of your data include:
- your consent to particular processing activities. For example, where you have consented to us using your information for marketing purposes;
- your request for products or services necessitating steps including processing of your data to be taken prior to entering into contract with you and any processing that is necessary for the performance of such contract. For example, when you buy a product on the Website you are entering a contract and we need your information to fulfil the order;
- legitimate interests we pursue as a business, for example we have a legitimate interest in providing you with the best experience and make your shopping with us as easy and as attractive as possible, except where such interests are overridden by your interests and fundamental rights; and
- compliance with any legal obligation to which we are subject, for example, the processing for the purposes of complying with applicable law.
Links to external websites
- Some sections of our Website contain links to the websites of third-party providers. These websites are subject to their own privacy policies. We are not responsible for their operation, including the handling of your data by third-party providers.
- If you send information to or via such third-party websites, you should check their privacy statements before sending them information that can be traced back to you as an individual.
- You are permitted to establish a link to our Website from other sites provided that, if we believe it would damage us or any of our Group companies or a daisybelle’s partner, you must remove the link immediately if we ask you to do so.
Sharing your data
There are circumstances where we wish to disclose or are compelled by law to disclose your personal data to third parties. This will only take place in accordance with the applicable law and for the purposes listed above. We may request that our subcontracted service partners assist us as processors of your data, in order to, for example, fulfil your order. Any processor that we contract to assist us in the processing of your data will be subject to a data processing agreement designed to protect your data at all times. These scenarios include disclosure to:
- our Group companies who may contact you by email, phone or post about other products and services (including those from other organisations) in which you may be interested (where you have consented to such communication);
- our outsourced service providers or suppliers to facilitate the provision of our products and/or services to you, for example:
- we use Shopify Ireland to power our online store. You can read more about how Shopify Ireland uses your data here: https://www.shopify.com/legal/privacy;
- we use DPD as courier services to deliver your order. You can read more about how DPD uses your data here: https://dpd.ie/Privacy-Policy;
- identity verification partners in order to verify your identity against public databases;
- manufacturers of the goods in the efforts to understand customer preferences, ensure satisfactory stock levels, to improve products and services and to calculate any volume discounts or rebates which may be applicable to your account (only statistical data is provided - the disclosed data will not directly identify you);
- subject to your consent, our marketing partners, who may contact you by post, email, telephone, SMS or by other means. If you do not wish to be contacted, you may unsubscribe by clicking “unsubscribe” in the message concerned;
- analytics and search engine providers that assist us in the improvement and optimisation of our Website. Your data are generally shared in a form that does not directly identify you;
- third party service providers and consultants in order to protect the security or integrity of our business, including our databases and systems and for business continuity reasons;
- another legal entity, on a temporary or permanent basis, for the purposes of a joint venture, collaboration, financing, sale, merger, reorganisation, change of legal form, dissolution or similar event. In the case of a merger or sale, your personal data will be permanently transferred to a successor company;
- public authorities where we are required by law to do so;
- if required, in order to receive legal advice; and
- any other third party where you have provided your consent.
Offers and opportunities
We would like to contact you and/or any person whose information you provide to us, to tell you and/or them about offers and opportunities that are available and about a range of other initiatives in a number of ways, including by post, telephone, text/picture/video message or by email. Details of how to opt-in to receiving details of offers are on relevant pages of our Website. You can change your mind at any time (see the section Contact below).
We take the security of personal information very seriously. We employ security technology to safeguard information and have procedures in place to ensure that our systems and databases are protected against unauthorised disclosure, use, loss and damage.
Updating and/or correcting your data
- We encourage you to promptly update your personal information if it If you are providing updates or corrections about another person, we may require you to provide us with proof that you are authorised to provide that information to us.
- You may be able to update or correct your personal information online in My Account area or by contacting us in writing or by email (see the section Contact below). Please include your name, address and/or email address when you contact us as this helps us to ensure that we accept amendments only from the correct person.
International transfer of data
- We may transfer your data to a third party in countries outside the country in which it was originally collected for further processing in accordance with the purposes set out above. In particular, your data may be transferred throughout our Group and to our outsourced service providers outside the EEA states or outside of countries subject to adequacy decision of the European Commission. In these circumstances we will ensure that appropriate measures are in place to protect your data and to comply with our obligations under the data protection law. This may mean that we enter into contracts in the form approved by the European Commission, and that we implement appropriate technical and organisational measures in respect of such transfers. If you would like to receive further details about measures we have taken in relation to the transfer of your data, or copies of the agreements that we have put in place in relation to transfers, please contact us using our contact details below.
- For example, Shopify Ireland will initially process your data in Ireland and then transfer it outside of Europe for storage and further processing, including to Canada and the United States. For more information on how Shopify data transfers comply with the GDPR, see Shopify’s GDPR Whitepaper:
Retention of data
- We may keep an anonymised form of your data, which will no longer refer to you, for statistical purposes without time limits, to the extent that we have a legitimate and lawful interest in doing so.
- You have a right to: access, rectify, erase, restrict, transport, and object to the processing of your data. You also have the right to lodge a complaint with the relevant data protection authority if you believe that your data are not being processed in accordance with applicable data protection law.
- Right to rectification. You may request that we rectify any inaccurate and/or complete any incomplete data.
- Right to withdraw consent. You may, as permitted by applicable law, withdraw your consent to the processing of your data at any time. Such withdrawal will not affect the lawfulness of processing based on your previous consent. Please note that if you withdraw your consent, you may not be able to benefit from certain service features for which the processing of your data is essential.
- Right to object to processing, including automated processing and profiling. You may, as permitted by applicable law, request that we stop processing your data. In relation to automated processing and profiling, you may object to the processing and you will have the right to obtain human intervention. See Automated decision making below.
- Right to erasure. You may request that we erase your data and we will comply, unless there is a lawful reason for not doing so. For example, there may be an overriding legitimate ground for keeping your data, such as, a legal obligation that we have to comply with, or if retention is necessary for us to comply with our legal obligations.
- Right to data portability. In certain circumstances, you may request that we provide your data to you in a structured, commonly used and machine-readable format and have it transferred to another provider of the same or similar services. We will comply with such transfer as far as it is technically feasible. Please note that a transfer to another provider does not imply erasure of your data which may still be required for legitimate and lawful purposes.
- Your right to lodge a complaint with the supervisory authority. We suggest that you contact us about any questions or if you have a complaint in relation to how we process your data. However, you do have the right to contact the relevant supervisory authority To contact the Data Protection Commissioner in Ireland:
Office of the Data Protection Commissioner, Canal House, Station Road, Portarlington, Co. Laois, R32 AP23, Ireland, Tel: +353 (0761) 104 800, LoCall: 1890 25 22 31, Fax: +353 57 868 4757, Email: email@example.com
- Right to make subject access request (SAR). Data subjects may, where permitted by applicable law, request copies of their data. If you would like to make a SAR, i.e. a request for copies of the data we hold about you, you may do so by writing to:
David Lawless, Data Protection Officer, Phoenix Group Ireland, Magna House, Magna Business Park, Citywest, Dublin 24, email: firstname.lastname@example.org The request should make clear that a SAR is being made. You may also be required to submit a proof of your identity.
Automated decision making
- If you are a resident of the EEA, you have the right to object to processing based solely on automated decision-making (which includes profiling), when that decision-making has a legal effect on you or otherwise significantly affects you.
- We do not engage in fully automated decision-making that has a legal or otherwise significant effect using your data.
- Our processor Shopify Ireland uses limited automated decision-making to prevent fraud that does not have a legal or otherwise significant effect on you.
- Services that include elements of automated decision-making include:
- Temporary denylist of IP addresses associated with repeated failed transactions. This denylist persists for a small number of hours.
- Temporary denylist of credit cards associated with denylisted IP addresses. This denylist persists for a small number of days.
- You can change your cookie preferences at any time here: Cookie Preferences
- Most browsers automatically accept cookies, but you can usually change your browser to prevent cookies being stored. Please note, if you do turn cookies off this will limit the service that we are able to provide to you and may affect your visitor experience.
- For further information on cookies and how to switch them off see org
Do not track
Please note that because there is no consistent industry understanding of how to respond to “Do Not Track” signals, we do not alter our data collection and usage practices when we detect such a signal from your browser.
Changes to our Policies
For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e-mail at: email@example.com or by post to: David Lawless, Data Protection Officer, United Drug House, Magna Drive, Magna Business Park, Citywest Road, D24XKE5, Dublin, Ireland.
Last updated: 20/05/2022