Privacy Policy
Salugen Limited is committed to safeguarding your privacy. Contact our Data Protection Officer if you have any questions or problems regarding the use of your personal data and we will be happy to assist you.
Table of Contents
- Definitions used in this policy
- Other applicable terms and conditions
- Data protection principles we follow
- What rights do you have regarding your personal data
- What personal data we gather about you
- How we use your personal data
- Who else has access to your personal data
- How we secure your data
- Information about cookies
- Third party websites
- Updating information
- Jurisdiction and applicable law
- Changes to this policy
- Date this policy will be effective from
- Contact information
- Legal entity
1. Definitions
The following definitions may appear as either capitalised or not
- Personal data – any information relating to an identified or identifiable natural person
- Processing – any operation or set of operations which is performed on personal data or on sets of personal data
- Data subject – a natural person whose personal data is being processed
- Child – a natural person under 16 years of age.
- We/us/our/Salugen – Salugen Limited
- salugen.uk – Our website
- Agreement – A legally binding agreement or contract between us and a client (you)
- The client or client – You or another legal entity with whom we have a legally binding agreement or contract
- You – The client or another legal entity with whom we have a legally binding agreement or contract
- An event – An event that is out with our reasonable control
2. Other applicable terms and conditions
This policy forms part of our Terms and Conditions and should be read in conjunction with our:
The policies listed above contain but are not limited to information regarding the following subjects:
- Information about cookies
- Changes to the website
- Access to and availability of the website
- Website accounts and passwords
- Intellectual property rights
- Limitation of our liability for website use
- Viruses, Unauthorised access and DOS attacks
- Links to our website
- Third party websites
- Prohibited uses of our website
- Suspension and/or termination of services and legal action
- Our courses
- Our agreement
- Delivery of our courses
- Price of courses and other fees
- Payment methods
- Our liability
- Events out with our control
- Communications between you and us
- Other important terms and conditions
- Your right to cancel
- Your consumer right of return and refund
- Your implied rights
By agreeing to our privacy policy you also agree to these policies. In the event of any ambiguity that might arise as a result of terms used in our other policies, terms and conditions and this privacy policy, terms in Terms & Conditions shall prevail.
Our website uses cookies. By using our website and agreeing to this policy, you consent to our use of cookies in accordance with the terms of this policy and our Cookie Policy.
3. Data protection principles
We promise to adhere to the following data protection principles:
- Processing is lawful, fair, transparent. Our processing activities have lawful grounds. We always consider your rights before processing personal data. We will provide you information regarding processing upon request.
- Processing is limited. Our processing activities fit the purpose for which personal data was gathered.
- Processing is done with minimal data. We only gather and process the minimum amount of personal data required for any purpose.
- Processing is limited with a time period. We will not store your personal data for longer than needed.
- We will do our best to ensure the accuracy of data.
- We will do our best to ensure the integrity and confidentiality of data.
4. Data subject’s rights
The Data subject has the following rights:
- Right to information – meaning you have to right to know whether your personal data is being processed; what data is gathered, from where it is obtained and why and by whom it is processed.
- Right to access – meaning you have the right to access the data collected from/about you. This includes your right to request and obtain a copy of the personal data we hold about you.
- Right to rectification – meaning you have the right to request rectification of your personal data that is inaccurate or incomplete.
- Right to erasure – meaning in certain circumstances you can request for your personal data to be erased from our records.
- Right to restrict processing – meaning where certain conditions apply, you have the right to restrict the processing of your personal data.
- Right to object to processing – meaning in certain cases you have the right to object to processing of your personal data, for example in the case of direct marketing.
- Right to object to automated processing – meaning you have the right to object to automated processing, including profiling; and not to be subject to a decision based solely on automated processing. This right you can exercise whenever there is an outcome of profiling that produces legal effects concerning or significantly affecting you.
- Right to data portability – you have the right to obtain your personal data in a machine-readable format or if it is feasible, as a direct transfer from one processor to another.
- Right to lodge a complaint – in the event that we refuse your request under the rights of access, we will provide you with a reason as to why. If you are not satisfied with the way your request has been handled please contact us.
- Right to the help of a supervisory authority and the right to other legal remedies such as claiming damages.
- Right to withdraw consent – you have the right to withdraw any consent given for processing of your personal data.
You may instruct us to provide you with any personal information we hold about you. Provision of such information may be subject to:
the payment of a fee (currently fixed at £10.00); and
the supply of appropriate evidence of your identity (for this purpose, we will usually accept a photocopy/scan of your passport certified by a GP, police officer, solicitor or bank plus an original copy of a utility bill showing your current address. If you wish for original documents to be returned, please include a self addressed envelop stamped with sufficient postage for the return).
We may withhold such personal information to the extent permitted by law.
You may instruct us not to process your personal information for marketing purposes by email at any time. In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt-out of the use of your personal information for marketing purposes.
5. Data we gather
We may collect, store and use the following kinds of personal information:
- information about your computer and about your visits to and use of this website (including your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation);
- information relating to any transactions carried out between you and us on or in relation to this website, including information relating to any purchases you make of our goods or services (including names, addresses, phone numbers, email addresses, credit or debit card details);
- information that you provide to us for the purpose of registering with us (including names, addresses, phone numbers, email addresses);
- information that you provide to us for the purpose of subscribing to our website services, email notifications and/or newsletters (including names, addresses, phone numbers, email addresses);
- any other information that you choose to send to us which you do not expressly consent to us storing and using.
Information you have provided us with
When visitors leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection. An anonymized string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/. After approval of your comment, your profile picture is visible to the public in the context of your comment.
If you upload images to publicly accessible parts of the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.
Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.
These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.
If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.
For users that register on our website (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (usernames cannot be changed at any time). Website administrators can also see and edit that information.
Information automatically collected about you
This includes information that is automatically stored by cookies and other session tools. For example, your shopping cart information, your IP address, your shopping history (if there is any) etc. This information is used to improve your customer experience. When you use our services or look at the contents of our website, your activities may be logged.
Information from our partners
We may at times gather information from our trusted partners with confirmation that they have legal grounds to share that information with us. This is either information you have provided them directly or that they have gathered about you on other legal grounds. See the list of our partners here.
Publicly available information
We might gather information about you that is publicly available.
Children
We do not intend to collect or knowingly collect information from children. We do not target children with our services. For the purposes of this policy a child is deemed to be a natural person under the age of 16.
5. How we use your personal data
We use your personal data in order to:
- provide our service to you. This includes for example registering your account; providing you with other products and services that you have requested; providing you with promotional items at your request and communicating with you in relation to those products and services; communicating and interacting with you; and notifying you of changes to any services;
- enhance your customer experience;
- fulfil an obligation under law or contract;
- administer the website;
- improve your browsing experience by personalising the website;
- enable your use of the services available on the website;
- send to you goods purchased via the website;
- send statements and invoices to you, and collect payments from you;
- send you general (non-marketing) communications;
- send you email notifications which you have specifically requested;
- send to you our newsletter, where you have specifically agreed to this, by email or similar technology (you can inform us at any time if you no longer wish to subscribe to our newsletter);
- provide third parties with statistical information about our users – but this information will be anonymised and not used to identify any individual user;
- deal with enquiries and complaints made by or about you relating to the website;
- deal with enquiries and complaints about how we handle your personal information;
On the grounds of entering into a contract or fulfilling contractual obligations, we process your personal data for the following purposes:
- to identify you;
- to provide you a service or to send/offer you a product;
- to communicate either for sales or invoicing;
On the grounds of legitimate interest, we process your personal data for the following purposes:
- to send you personalized offers* (from us and/or our carefully selected partners);
- to administer and analyse our client base (purchasing behaviour and history) in order to improve the quality, variety, and availability of products/ services offered/provided;
- to conduct questionnaires concerning client satisfaction;
As long as you have not informed us otherwise, we consider offering you products/services that are similar to or the same as your purchasing history/browsing behaviour to be a legitimate interest.
With your consent we process your personal data for the following purposes:
- to send you newsletters and campaign offers (from us and/or our carefully selected partners);
- for other purposes we have asked your consent for;
We Process your personal data in order to fulfil obligations arising from law and/or use your personal data for purposes provided by law. We reserve the right to anonymise personal data gathered and to use any such data. We will use data outside the scope of this policy only when it is anonymised. We save your billing information and other information gathered about you for as long as needed for accounting purposes or other obligations deriving from law, but not longer than 7 years.
We might process your personal data for additional purposes that are not mentioned here, but are compatible with the original purpose for which the data was gathered. To do this, we will ensure that:
- we make every effort to inform you of further processing and additional purposes;
- the link between purposes, context and nature of personal data is suitable for further processing;
- further processing would not harm your interests and
- there would be appropriate safeguards in place for processing.
Visitor comments may be checked through an automated spam detection service.
We will inform you of any further processing and purposes.
We will never sell your data.
Where you submit personal information for publication on our website, we will publish and otherwise use that information in accordance with the license you grant to us.
We will not without your express consent provide your personal information to any third parties for the purpose of direct marketing.
6. Who else can access your personal data
We may disclose information about you to any of our employees, officers, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes as set out in this policy.
In addition, we may disclose your personal information:
- to the extent that we are required to do so by law;
- in connection with any legal proceedings or prospective legal proceedings;
- in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk);
- to the purchaser (or prospective purchaser) of any business or asset which we are (or are contemplating) selling.
- Except as provided in this policy, we will not provide your information to third parties.
We share your data with:
Our current processing partners:
- None
Our current business partners:
- None
Connected third parties:
- None
We only work with processing partners who are able to ensure adequate levels of protection to your personal data. We disclose your personal data to third parties or public officials when we are legally obliged to do so. We might disclose your personal data to third parties if you have consented to it or if there are other legal grounds for it.
8. How we secure your data
We do our best to keep your personal data safe. We use industry standard safe protocols and practices for communication, transfer and storage of data (such as HTTPS). We use anonymising and pseudonymising where suitable. We monitor our systems for possible vulnerabilities and attacks.
Information that we collect may be stored and processed in and transferred between any of the countries in which we operate in order to enable us to use the information in accordance with this policy.
Subject and without prejudice to clauses 3, 4, 5 & 6, information which you provide will not be transferred outside the European Economic Area without your express consent and will be stored according to EU and UK law. Where discrepancies or ambiguities arise UK law will take precedence.
Personal information that you submit for publication on the website will be published on the internet and may be available, via the internet, around the world. We cannot prevent the use or misuse of such information by others.
You expressly agree to such transfers of personal information.
Even though we try our best, we cannot guarantee the security of information. However, we will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information.
We will store all the personal information you provide on our secured and firewall protected servers.
Data transmission over the internet is inherently insecure, and we cannot guarantee its security. Where appropriate, all electronic transactions you make to or receive from us will be encrypted using SSL technology.
You are responsible for keeping any website login password and user details confidential. These should never be shared with anyone. We will never ask you for your password (except when you log in to the website). We will do everything we reasonably can to prevent security breaches and to assist authorities should any breaches occur.
9. Cookies and other technologies we use
We use cookies and/or similar technologies to analyse customer behaviour, administer the website, track users’ movements on the site, and to collect information about users. This is done in order to personalise and enhance your experience with us. Please see our Cookie Policy for further information.
We use Google Analytics to measure traffic on our website. Google has their own Privacy Policy which you can review here. If you’d like to opt out of tracking by Google Analytics, visit the Google Analytics opt-out page.
Please read our Cookie Policy for more information.
10. Third party websites
The website contains links to other websites. We are not responsible for the privacy policies or practices of third party websites. Please see our Terms and Conditions. for more information.
11. Updating information
Please let us know if the personal information which we hold about you needs to be corrected or updated by emailing Customer Service.
12. Jurisdiction and applicable law
Any dispute or claim arising out of this policy or in connection with it or its subject matter or formation (including disputes or claims arising outside the scope of this policy) shall be governed by and construed in accordance with the law of Scotland.
We both irrevocably agree that the courts of Scotland will have exclusive jurisdiction to settle any dispute or claim which arises out of or in connection with this policy or its subject matter or formation (including disputes or claims arising outside the scope of this policy).
13. Changes to this privacy policy
We reserve the right to update and make changes to this policy from time-to-time by posting a new version on our website. You should check this page occasionally to ensure you are happy with any changes.
If any provision within this policy and other policies mentioned herein is held by any competent authority to be invalid or unenforceable (in whole or in part) the validity of the other provisions of these terms and conditions and the remainder of the provision in question shall not be affected.
We may also notify you of changes to this policy by email.
14. Date this policy will be effective from
Effective from: 1st March 2022 (01.03.2022)
15. Contact Information
Data Protection Officer
If you have any questions regarding processing of your personal data, your rights regarding your personal data or this privacy policy, contact our Data Protection Officer or by post to: The Data Controller, Salugen Limited, Easter Buchat, Glenbuchat, Strathdon. AB36 8TQ
Data controller
The data controller responsible in respect of the information collected on this website is Salugen Limited.
Supervisory Authority
You can contact the Supervisory Authority here:
Website: https://ico.org.uk
Email: international.team@ico.org.uk
Phone: +44 1625 545 745
16. Legal Entity
Salugen Limited
Registered company no: SC487249 (Scotland)
Registered address: Easter Buchat, Glenbuchat, Strathdon. AB36 8TQ
Nature Nurture® is a registered trademark wholly owned by Salugen Limited.
Nature Nurture is a business name of Salugen Limited.