Graceful Limited is committed to protecting and respecting your privacy. This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

For the purpose of this policy, the data controller is Graceful Limited.

Information we collect from you

We collect and process the following data about you:

• Information that you provide by filling in forms on our site www.graceful.day. This includes information provided at the time of registering to use our site, subscribing to our service, posting material or requesting further services. We may also ask you for information when you report a problem with our site.

• If you contact us, we may keep a record of that correspondence.

• Details of transactions you carry out through our site and of the fulfilment of your orders.

• Details of your visits to our site including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.

Marketing

Graceful would love to keep in touch with you. When you sign up to receive marketing and open an account with us, we will send you emails, postal marketing and SMS messages (where you have submitted your phone number). We will also display customised advertising when you log in to your social media profiles.

These messages will be Graceful specific; we do not sell your data or share it with other brands for advertising purposes; your data is used only to promote Graceful goods and offers when signing up to marketing.

Our marketing messages are sent via a specialist eCommerce marketing tool. You can opt-out of marketing at any time by clicking the unsubscribe link in your emails and SMS messages or by contacting us directly.

There will be occasions when Graceful sends administrative messages such as order updates; these messages are not deemed marketing and cannot be opted out of.

Marketing and administration emails you receive from Graceful contain a tracking pixel. This pixel lets us know things such as our email campaigns' open rates and click rates. The pixel also lets us know if an email has not been delivered to update our records and keep them current. When we analyse the data, we do so from an aggregated perspective, meaning that we report upon an overall number of open rates and click rates.

When a purchase is made, or you add an item to your cart, you will notice that the marketing preference box is pre-ticked. This is because we rely on a soft opt in to promote further, similar goods to you.

If you wish to opt-out of these messages, please untick this box at the cart stage; of course, you can unsubscribe from marketing at any point.

Should you place an item in the cart and not complete an order, Graceful will send you an abandoned cart message offering you the chance to complete your order. These messages are sent when you provide an email address to Graceful at the checkout stage or where you are logged in to your Graceful account.

Abandoned cart messages are sent using the soft opt-in method described above.
When you provide a postal address to Graceful we will send you postal marketing. Postal marketing can be opted out of by contacting our@graceful.day

Other advertising

We believe that advertising is more interesting to you when it is relevant. We customise the advertising that you see based upon your personal information.
We use personal information for this purpose including:

• the Information you voluntarily provide to us;

• geographic location information, which we may determine through your IP address, from your mobile device, or other ways;

• data we receive from third parties; or

• your visits to our website or your use of our services (commonly referred to as “Behavioural Advertising”) via the use of cookies.
  You can control how cookies are used via your browser.

IP addresses

We collect information about your computer, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual.

Cookies and our cookies policy

This section explains how and why we use cookies. Cookies are small text files placed on your device when you visit a website. We use cookies to recognise you and your preferences, enhance the performance of our website and collect analytical information.
Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.

It is our policy not to use “behavioural targeting” cookies as defined by the ICC Classifications. The cookies that we use fall within the strictly necessary, functionality and performance classifications.

This website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”) Google Analytics uses “cookies” to help the website analyse how uses use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. You can refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you might not be able to use the full functionality of this website. By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

For the avoidance of doubt, if at any time you wish to disable our cookies you can do so through the settings on your browser, but if you do so you will not be able to use certain important features of our service.

Our lawful basis for processing your data

We have set out a lawful basis for processing data in our Record of Processing Activities (ROPA). The ROPA guides how we process data.

Typically we rely on one of the following basis:
Consent, Legitimate Interests, Contract and Legal.

We rely on consent for activities such as cookie management and direct marketing when a legitimate interest does not apply. We rely on legitimate interests to fulfil customer orders and provide customer service.

We rely on contract when we have entered into or are negotiating a contract with a new or existing customer to provide them with subscription services on an ongoing basis.

We rely on legal to ensure we comply with the law, for example by sharing employee data with HMRC.

For more information, please contact us our@graceful.day

Your choices

You can choose not to provide us with personal data. If you choose to do this, you can continue to use the Graceful website and browse its pages, but we will not be able to process transactions or continue a relationship without personal data.

You can block cookies by activating a setting on our cookie banner, allowing you to refuse cookies. You can also delete cookies through your browser settings. If you turn off cookies, you can continue to use the Graceful website and browse its pages. See the cookie section below for further detail.

You can opt-out of marketing by clicking the unsubscribe option in any marketing communications.

Where we store your personal data

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

Where we have given you (or where you have chosen) a password which enables you to access certain parts of this website you must keep this password confidential and secure.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Uses made of the information

We use information held about you in the following ways:

• To ensure that content from our site is presented in the most effective manner for you and for your computer.

• To provide you with information, products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes.

• To carry out our obligations arising from any contracts entered into between you and us.

• To allow you to participate in interactive features of our service, when you choose to do so.

• To notify you about changes to our service.

We also use your data to provide you with information about services which may be of interest to you and we may contact you about these by post or telephone.

Disclosure of your information

We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006. We may disclose your personal information to third parties:

• In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.

• If Graceful Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.

• If we are under a duty to disclose or share your personal data to comply with any legal obligation, or to enforce or apply our terms of use or terms and conditions of supply and other agreements; or to protect the rights, property, or safety of Graceful Limited, our customers, or others. This includes exchanging information with other companies and organisations for fraud protection and credit risk reduction.

Your rights

You have the right to ask us not to process your personal data for marketing purposes.

You can exercise your right to prevent such processing by contacting us at Graceful Limited 71-75 Shelton Street, London, WC2H 9JQ.

Access to information

The Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act.

Retention of your data

We carry out an annual data cleanse to ensure only relevant data is held. For further information regarding our retention periods, please contact us on our@graceful.day

Third Parties

Graceful works with third party companies to help you enjoy your products and for feedback and improvement purposes. Below we have provided a description of each process and the third parties we work with:

Website & Hosting

Specialist third party eCommerce host and provider to maintain the Graceful website

Customer Services & Feedback

Customer feedback is collected and used to improve the experience provided to you

Analytics

To ensure Graceful tailors its services

Marketing

Our marketing is managed by a specialist third party partner

Payment Processing

Graceful has chosen an industry standard provider to process your payments

Subscription Services

Graceful has partnered with a specialist subscription provider

Website Optimisation

Ensures customers enjoy an optimal shopping experience

Label Printing

Labels for orders are provided to ensure your order is delivered quickly

Delivery & Tracking

Graceful uses several different shipping companies

Data Security

Graceful works with a data security provider to ensure your data is kept safe

Email Verification

Graceful uses a third party provider for email verification

Customer Referrals

Graceful has partnered with a customer referral partner

Surveys

Graceful will occasionally carry out surveys with customers

If you would like a full list of processors, please contact our@graceful.day

Breaches

Should a breach of your data occur that is likely to result in harm to the rights and freedoms of you as an individual or group of individuals Graceful will notify you within 72 hours along with the ICO where applicable.

The California Consumer Privacy Act CCPA

This policy applies to all residents of California

For the purposes of the CCPA Graceful collects the following information

Name
Residential address
Browsing history and IP address
Phone number
Email address

Graceful collects this data to fulfil orders you have placed and send marketing messages and other processing described throughout this notice.

Graceful shares data with data processors and subprocessors who assist Graceful in providing you with products and marketing such as delivery companies and our marketing and analytical partners. A complete list of Graceful third parties is available on demand.

Graceful collects your data directly from you Graceful never buys or sells data we only process your data when freely given to us.

Graceful will never discriminate against you we provide the same products and pricing structure available to customers worldwide.

You have the right to be forgotten where applicable and where Graceful does not require your data to satisfy a particular law.

You have the right to access your data or ask us to amend it if it is incorrect.  Please email our@graceful.day  if you wish to do so.

Additional information

Graceful has not appointed a statutory Data Protection Officer as we are not required to by law. However, we have committed resources to manage our compliance with all applicable Data Protection laws.

A Record of Processing Activities ROPA in which the lawful basis for processing all of the Graceful customer data is maintained. Wherever Legitimate Interests is relied upon an impact assessment has been created available upon demand to those whose data is included.

This notice was created on the 25th November 2024 and is due for review no less than one calendar year from this date.