1. Introduction
2. Who we are
3. Acceptance of this Privacy Policy
4. What personal data we may collect & how we may use it
5. The types of personal data we collect
6. How we may collect your data
7. How long we may keep your personal data
8. Cookies
9. International transfers of personal data
10. Sharing your personal data
11. Advertising, marketing and your preferences
12. Klarna
13. Epsilon Abacus
14. Links to other sites
15. Changes
16. Right of access
17. Other rights
18. Making a complaint to a supervisory authority
19. Contact Us
20. Finally, a small request from Innate-Essence Limited

1. Introduction

Welcome to Innate-Essence Limited (“The Turmeric Co.”)’s Privacy Policy. Innate-Essence Limited respects your privacy and is committed to protecting your personal data.

It is vital that you read this Privacy Policy so that you are fully aware of how and why we are using your personal data.

This Privacy Policy (together with our terms and conditions and any other documents referred to in it) will inform you how Innate-Essence Limited uses your personal data when you ("you/your") interact with us through our website at https://theturmeric.co ("Website").

This includes when you use our products and services, sign up to our newsletter or partake in a competition. We will also disclose the safeguarding precautions we use to protect your data.

Our Website is not intended for use by children, and we do not knowingly collect any data relating to children.

This Privacy Policy was last updated on 1 April 2022.

Who we are

The mission of Innate-Essence Limited is to create the best tasting functional drinks that harness the power of natural ingredients, conveniently delivered, to support wellness-conscious individuals on their health journey.

You can read more about us here.

Our details are as follows:

• Our Website address is: https://theturmeric.co
• Our company name is Innate-Essence Limited
• Our registered address is Savoy House, Savoy Circus, London W3 7DA
• Our nominated representative is Data Protection Officer, Savoy House, Savoy Circus, London W3 7DA ]
• Please contact us here.

We respect your right to privacy and will only process personal information about you or provided by you in accordance with the Data Protection Legislation, which for the purposes of this Privacy Policy shall mean:

1. the retained EU law version of the General Data Protection Regulation ((EU) 2016/679) (UK GDPR), the Data Protection Act 2018 and any other national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK and then
2. any successor legislation to the UK GDPR or the Data Protection Act 2018 and other applicable privacy laws.

3. Acceptance of this Privacy Policy

Please check back regularly to keep informed of updates to this Privacy Policy.

Your acceptance of our Privacy Policy is deemed to occur upon your first use of our Website.

If you do not accept and agree with this Privacy Policy, you must stop using our Website immediately.

4. What personal data we may collect & how we may use it

There are many different ways in which we may collect data or receive data.

However, we may process your personal data on more than one legal basis, depending on how we are using it.

You can see an explanation of the main ways we may use your data in the table below:

What type of personal data are we collecting?	Purpose of processing	What lawful basis do we rely on to use your personal data?
Your name, email address and any other personal data you supply to us.	To provide you with updates on our activities, services and products, to record your marketing preferences and any feedback or responses for the purposes of improving our services.	With your consent.
Any personal data we collect as part of your Cookies settings, namely online identifiers (such as your cookie identifier, IP address, browser type. and version, time zone settings and location).	To allow us to operate our Website and ensure that its operation runs as smoothly as possible.	With your consent.
Billing address, shipping address, payment information, phone numbers.	To allow us to collect order information when you purchase goods through the Website.	With your consent.

5. The types of personal data we collect

'Personal data' refers to any information about an individual that identifies that person. It does not refer to any data where the identity of the subject has been removed.

The personal data that we collect falls into the following categories:

• Identity Data: title, gender, first name, last name, date of birth.
• Contact Data: billing address, delivery address, email address.
• Financial Data: payment card and direct debit/bank account details.
• Transaction Data: details about payment exchanges for our products and services.
• Profile Data: your username and password, orders made by you, your preferences, and feedback.
• Technical Data: your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions.
• Usage Data: how you use our website, products and services and content you contribute to our forum.
• Tracking Dara: information we or others collect about you from cookies and similar tracking technologies.
• Marketing and Communications Data: your preferences in receiving direct marketing and communications from us.

We also collect, use and share Aggregated Data such as statistical or demographic data. This data may come from your personal data, but is not deemed as ‘personal’ data in law as it does not reveal your identity. An example of this would be analysing any Usage Data to calculate the percentage of users accessing a certain Website feature to evaluate and improve it.

Please note, if you choose not to share personal data with us, or refuse certain permissions, we may not be able to provide the products or services that you have asked for.

6. How we may collect your data

Data may be gathered when you interact with us, automatically, or from third parties.

Your personal data may also be collected from the following sources:

• Through cookies or similar tracking technologies that we have set on our Website; and/or
• When you provide us with personal information through our contact form.
• When you make a purchase or attempt to make a purchase through the Website.

Some of this data may be shared with us by filling in forms or interacting with us by post, phone, email, or social media.

For more information on our use of cookies and/or similar tracking technologies, see the “Cookies” section below.

7. How long we may keep your personal data

We will only use your personal data when the law allows us to, and we will not keep your personal data any longer than we think is necessary. When deciding how long to keep your personal data, we consider factors such as:

• Our contractual rights and obligations in relation to the personal data involved;
• Legal obligations under applicable law to retain data for a certain period of time;
• Whether we relied on your consent to use the personal data, but you have since withdrawn your consent;
• Statute of limitation under applicable law(s);
• Our legitimate interests;
• Fraud and risk management;
• Potential disputes; and
• Guidelines issued by relevant data protection authorities.

8. Cookies

A cookie is a small file of text that is stored on your browser or the hard drive of your computer.

When you browse our Website, we automatically receive your computer’s internet protocol (IP) address. We may collect data about how you interact with our Website through the use of Cookies, or other similar tracking technologies (collectively referred to as “Cookies”).

We use Cookies to distinguish you from other users of our Website. It helps us to remember your preferences. When you visit our Website, Cookies allow us to keep track of how many times you’ve visited us, how long you’ve visited us for and what you’ve done whilst you’ve been on our Website.

None of the Cookies we use are used to identify you as an individual. They typically collect anonymous identifiers associated with your device, browser, referring site URLs, time or usage information.

We use the following types of cookies:

• Strictly necessary Cookies

  These are required for the operation of our Site, Tools and/or Services. They tell us if you’ve consented to the placement of functionality or analytical/performance Cookies, let you log into secure areas of our website, let us authenticate you when you sign-on to use any of our Services, and help us distinguish you from other users of our Site, Tools and/or Services. The functionality of our Services would be affected if these cookies are disabled.

• Functionality or preference Cookies

  These are used to recognise you when you return to our website so we can personalise our content for you (such as your country or language preferences).

• Analytical/performance Cookies

  These enable us to count the number of unique visitors to our Site and/or Tools and to see how users interact with our Site, Tools and/or Services by collecting information such as network requests, console logs, text entered and mouse movements. We use this information to help improve our Site Tools and/or Services and your experience. For example, we can use these Cookies to understand what areas of our website are not being used by users and make improvements.

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use Cookies, over which we have no control. These Cookies are likely to be analytical/performance cookies or targeting cookies.

9. International transfers of personal data

We share your personal data within Innate-Essence Limited.

Any personal data that you provide will not generally be transferred to, or outside of the UK. We will take reasonable steps to ensure that your personal data is handled securely and in accordance with our Privacy Policy. If we do need to transfer outside of the UK, we will only do so if:

• It is to a country that has been deemed to provide an adequate level of protection for personal data by the ICO; or
• We have entered into a standard contractual clause approved by the ICO, which gives the personal data the same protection it has in the UK, with the recipient of the data.

10. Sharing your personal data

We may be required to share your personal data in the following circumstances:

• If we reasonably consider that we are under a duty to disclose or share your personal data to comply with any legal obligation;
• We need to enforce or apply or terms and conditions and/or other agreements with you; and/or
• With third parties to whom we may sell, transfer or merge parts of our business or assets. If a change like this happens to our business, the new owners may use your personal data in the same way as set out in this privacy policy.

11. Advertising, marketing and your preferences

There are multiple ways in which you may see adverts for our products, and these may not be using your personal data – occasionally, we will buy advertising space on websites and across social media platforms. If you see these adverts, these may not be directed specifically at you.

We may use your personal data to form an idea as to what we think you may want or need, or what products may be of interest to you. This is a useful way for us to craft bespoke products, services and offers that may be relevant to you. This direct marketing may be carried out by email, text, or post.

For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at https://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.

You can opt-out of targeted advertising by using the links below:

• Facebook: https://www.facebook.com/settings/?tab=ads
• Google: https://www.google.com/settings/ads/anonymous
• Bing: https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads
• LinkedIn: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out
• Microsoft: https://account.microsoft.com/privacy/ad-settings/signedout
• Twitter: https://twitter.com/settings/account/personalization

Additionally, you can opt-out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: https://optout.aboutads.info.

12. Klarna

In order to be able to offer you Klarna’s payment options, we will pass to Klarna certain aspects of your personal information, such as contact and order details, in order for Klarna to assess whether you qualify for their payment options and to tailor the payment options for you.

General information on Klarna you can find here. Your personal data is handled in accordance with applicable data protection law and in accordance with the information in Klarna’s privacy policy.

13. Epsilon Abacus

We work with Epsilon Abacus (registered as Epsilon International UK Ltd), a company that manages the Abacus Alliance on behalf of UK retailers and charities. The participating retailers are active in the clothing, collectables, food & wine, gardening, gadgets & entertainment, health & beauty, household goods, home interiors and travel categories. These retailers and charities share information about their customers and supporters and what they buy or donate.

Epsilon Abacus processes this information as a processor on behalf of these companies to help them understand individuals’ behaviour and preferences. Epsilon combines information provided by participating retailers and charities with third party data. From this combined information, these companies can tailor their communications, sending individuals suitable offers and appeals that should be of interest to them.

Your personal data is handled in accordance with applicable data protection law. You can learn more about how Epsilon Abacus process personal information in accordance with the information in Epsilon Abacus’s privacy policy.

14. Links to other sites

Please note that our Privacy Policy will not apply to other websites that you get to via a link from our Website.

We have no control over how your data is collected, stored or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.

15. Changes

Your personal data will only be used for the purposes outlined when we collected it. This may change if we consider that we need to use it for another reason, and that reason is compatible with the original purpose.

If we change our Privacy Policy, we will post the changes on this page so please check this page for our current policy. Remember - your continued use of our Website will be interpreted as your express acceptance of any changes to our Privacy Policy.

16. Right of access

You have the right to ask us to provide any personal data we have collected about you.

Should you wish to do so, please email us at info@theturmeric.co to make a subject access request.

17. Other rights

In certain circumstances, you have the following additional rights under UK data protection law:

• request access to, deletion of or correction of your personal data held by us at no cost to you;
• request that your personal data be transferred to another person (data portability);
• be informed of what data processing is taking place;
• restrict processing;
• to object to the processing of your personal data; and
• complain to a supervisory authority.

18. Making a complaint to a supervisory authority

For peace of mind, you have the right to file a formal complaint to the Information Commissioner's Office at www.ico.org.uk, or to the relevant data protection supervisory authority in your country of residence if you are dissatisfied with the service we provide.

19. Contact Us

Should you have any questions about GDPR compliance or want to exercise any of your data subject rights, for now just drop us an email at info@theturmeric.co and keep an eye out for platform improvements that make it even easier to manage your data with us.

20. Finally, a small request from Innate-Essence Limited

It is important that the personal data we are provided with is accurate and up to date.

Please keep us informed if any of your data changes during your relationship with us.