Welcome to Hytro Limited’s Privacy and Cookies Notice. This Notice informs you how we look after your personal data, in accordance with the EU General Data Protection Regulation (GDPR), when you visit our website (regardless of where you visit it from) and tells you about your privacy rights and how the law protects you. 

Hytro Limited (“we”, “us” or “our”) is the controller and responsible for your personal data.

If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact dataprotection@hytro.com.  

While we welcome the opportunity to resolve any issue you may have with our handling of your personal data, you have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). 

1. The data we collect about you

Personal data, means any information about an individual from which that person can be identified.

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

Identity Data	Including first name, last name, similar identifier.
Contact Data	Including billing address, delivery address, email address and telephone numbers.
Financial Data	Including bank account and payment card details.
Transaction Data	Including details about payments to and from you and other details of products and services you have purchased from us.
Technical Data	Including 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	Including your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
Marketing and Communications Data	Including your preferences in receiving marketing from us.

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.

2. How is your personal data collected?

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 email or otherwise. This includes personal data you provide when you purchase our products or create an account on our website.
• 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. 
• Contact, Financial and Transaction Data from providers of technical, payment services such as Stripe (Apple Pay, Google Pay, Microsoft Pay, Visapay, Masterpass, Amex, Debit/Credit cards), PayPal, Klarna and/or others.
• Transaction Data from our fulfilment provider, Channel Fusion (https://www.channelfusion.co.uk/) and/or one or more other providers.

3. How we use your personal data

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.
• 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.
• Where we need to comply with a legal obligation.

Below describe all of 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).

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. 

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new customer	Identity, Contact	Performance of a contract with you
To process and deliver your order including:   (a) managing payments, fees and charges; (b) collecting and recovering money owed to us	Identity, Contact, Financial, Transaction, Marketing and Communications	(i) Performance of a contract with you    (ii) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include:   (a) notifying you about changes to our terms or privacy policy	Identity, Contact, Profile	(i) Performance of a contract with you    (ii) Necessary to comply with a legal obligation (iii) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
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	(i) 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)   (iii) Necessary to comply with a legal obligation
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	Technical	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)

Marketing 

You may 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. You can ask us to stop sending you marketing messages at any time by contacting us at any time. 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.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. 

We only use cookies that are strictly necessary. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.

 More information about the cookies we use is set out in a table below: 

Cookie	Description	Duration	Type
__atuvc	This cookie is set by Addthis to make sure you see the updated count if you share a page and return to it before our share count cache is updated.	1 year	Functional
__atuvs	This cookie is set by Addthis to make sure you see the updated count if you share a page and return to it before our share count cache is updated.	30 minutes	Functional
_ga	This cookie is installed by Google Analytics. The cookie is used to calculate visitor, session, campaign data and keep track of site usage for the site’s analytics report. The cookies store information anonymously and assign a randomly generated number to identify unique visitors.	2 years	Analytics
_gid	This cookie is installed by Google Analytics. The cookie is used to store information of how visitors use a website and helps in creating an analytics report of how the website is doing. The data collected including the number visitors, the source where they have come from, and the pages visited in an anonymous form.	1 day	Analytics
_gat_gtag_UA_159948501_1	Google uses this cookie to distinguish users.	1 minute	Analytics
_gat_UA-159948501-1	This is a pattern type cookie set by Google Analytics, where the pattern element on the name contains the unique identity number of the account or website it relates to. It appears to be a variation of the _gat cookie which is used to limit the amount of data recorded by Google on high traffic volume websites.	1 minute	Performance
uvc	The cookie is set by addthis.com to determine the usage of Addthis.com service.	1 year	Analytics
loc	This cookie is set by Addthis. This is a geolocation cookie to understand where the users sharing the information are located.	1 year	Advertisement
_fbp	This cookie is set by Facebook to deliver advertisement when they are on Facebook or a digital platform powered by Facebook advertising after visiting this website.	2 months	Advertisement
fr	The cookie is set by Facebook to show relevant advertisements to the users and measure and improve the advertisements. The cookie also tracks the behaviour of the user across the web on sites that have Facebook pixel or Facebook social plugin.	2 months	Advertisement

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.

4. 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 above.

• Payment provider: Stripe (Apple Pay, Google Pay, Microsoft Pay, Visapay, Masterpass, Amex, Debit/Credit cards), PayPal, Klarna and any other payment provider that we accept. 
• Order and fulfilment provider or returns: Channel Fusion (https://www.channelfusion.co.uk/) and any other provider we may use. 

Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. 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.

5. International transfers

We do not transfer your personal data outside the European Economic Area (EEA).

6. Data security

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

7. Data retention

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. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

8. Your legal rights

Under certain circumstances, you have rights under data protection laws, including the GDPR, in relation to your personal data in certain circumstances to: 

• request access to your personal data;
• request correction of your personal data;
• request erasure of your personal data;
• object to processing of your personal data;
• request restriction of processing your personal data;
• request transfer of your personal data; and
• exercise your right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us on dataprotection@hytro.com.