We are Millie’s Paws Ltd (“Millie’s Paws”, “we”, “us”, or “our”), a company registered in Scotland (Company No. SC412581), with a registered office at 1 Fraser Court, Rothienorman, Aberdeenshire, AB51 8SD. We are registered with Information Commissioner in accordance with the General Data Protection Regulation (the “Act”) Data Protection Registration no. ZA221630. For the purposes of the Act, we are the data controller of your personal data.

When you place an order with us or interact with our website, we may ask you certain information and you may submit personal data to us (for example your name, phone number, postal address, email address, contact and bank / credit card details).

We may also record which products you are interested in (browse history) and which products you purchase as well as customer traffic patterns and site use.

Some examples of how information may be collected by us:

Information you provide us – we receive and store information that you submit when using our website or that you provide us in any other way (for example by email or telephone). This information may be provided when ordering from us, entering competitions, registering an account on our website, accessing your account, querying order status or by submitting text/photo/video reviews of us and our products.

Information automatically provided – we receive, process and store certain information whenever you interact with our website. Like many websites, we use “cookies” (see “cookies” section below) and obtain certain information automatically when your web browser accesses our website. Information automatically received by us includes the IP address that your computer uses to connect to the internet, your computer, browser, operating system and internet connection details, purchase history, clickstream/path analysis of your journey through our website, and products you searched for. We may also use software tools to measure and collect session information, length of visits to certain pages, repeat visits and page interaction information (such as clicks).

Information from 3rd parties – we may receive information about you from other sources and add this to our account information. For example, we update address information using data from third parties.

Information is kept securely in accordance with our internal security policy and be used to;

process and deliver your order via the services of our nominated fulfilment partner/carrier, by placing an order you are giving permission to pass on the necessary details to our nominated fulfilment partner/carrier to enable delivery of your order. In order to dispatch your order, we will pass only the necessary data to the appropriate carrier for delivery and tracking;
provide customer support services to you;
provide you with an up to date, efficient and reliable service;
help prevent fraud;
open and run your customer account;
administer prize draws; or
provide a more personal shopping experience.

By placing an order via our website, accepting the terms and conditions and /or submitting your data to us you agree to this use. This meets the EU conditions for lawful processing and enables us to enter into and fulfil the contract of sale with you the data owner.

If after you opt-in, you change your mind, you may withdraw your consent for us to contact you, for the continued collection, use or disclosure of your information, at any time, by contacting us at woof@milliespaws.com or mailing us at Millie’s Paws Ltd, 9 Fraser Court, Rothienorman, Inverurie, Aberdeenshire, Scotland, AB51 8SD.

We use security measures to protect your details when you shop with us. We use SSL to encrypt all data sent to us and us to you. This protects your personal, card and other data from being read by others in transit.

Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

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.

We will engage selected system support partners from time to time as required in order to support and maintain our website’s security and integrity of data. Data may be transferred as required to fulfil the purpose of the engagement.

In order to fulfil your order, we may need to disclose some of your information to our delivery partners including but not limited to Royal Mail and DPD.

We have engaged WorldPay to act as our payment gateway provider. WorldPay host the payment field on our website which means they collect full payment details and manage the entire payment process. We do not store full details at all but receive partial payment details back from WorldPay for internal tracking only, it is not possible to process a payment with the details received back. This ensures PCI Compliance and supports the core GDPR concept of privacy by design.

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 if such business or assets.

If we or substantially all of our assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets.

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

Our site may, from time to time, contain links to and from the websites of partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

Under the terms of this policy and in accordance with GDPR legislation you have the following rights as regards to your personal data:

Right to be informed – you have the right to be informed of the collection and use of your personal data. Our privacy policy is a core part of satisfying this right.

Right of access – you have the right to know what personal data we have collected and what we intend to do with the data. The ways we may use your data are listed above in the section entitled ‘How We Use This Information’. If you wish to request details of the personal data we hold about you, this can be made by any communication method on our website or shown below.

Right to withdraw consent to marketing or any data processing – you have the right to withdraw your consent to Millie’s Paws Ltd using your data in all or specific ways. You can opt out of marketing communications at any time by selecting the option on your customer account under marketing preferences. There is also an ‘unsubscribe’ link contained at the end of every email communication. If you choose to withdraw all consent to any processing or usage of personal data, then please be aware that we will be unable to fulfil your orders. We require your consent to process and dispatch your order.

Right to rectification – if you believe that the information, we hold about you may be incorrect then you have the right to request that it is updated and amended. Please use your customer account to complete any changes or contact woof@milliespaws.com.

Right to erasure – you can choose what personal data you wish us to hold and have the right to remove this data in full or in part at any time. You can update your customer account data directly or you can contact us at woof@milliespaws.com for assistance.

Right to be forgotten – you have the right to request that any personal data that could be used to identify you and that is held by Millie’s Paws Ltd is permanently erased. This is an intractable request and once it has been made there is no way to reverse it. If you wish to have your data permanently deleted, then please contact us at woof@milliespaws.com for assistance. Please be aware that Millie’s Paws Ltd is legally obliged to retain documents/records for a period specified by law, please see the retention section below. If you make a request to have your data deleted, we will inform you of any documentation we are legally obliged to retain and explain the timeline. After this has expired, we commit to deleting this data too. We will action all requests if data deletion as quickly as possible but please allow a period of 30 days for all requests to take full effect.

Right to object to automated decision making – Millie’s Paws uses automation for some order processing for example fraud checking of orders. If you wish to object to automation of this date processing, then please be aware that we may not be able to process your order.

Consent – Millie’s Paws Ltd will specifically request your consent to use personal data in the following ways:

When placing an order, we will request your acceptance of our terms and conditions and consent to use the data you have provided to fulfil your order. In line with the core GDPR principle of minimisation, Millie’s Paws will only collect the data required to support and fulfil your order, if you choose not to give your consent then we will not be able to process your order.

When creating a customer account and placing an order we may offer you the opportunity to opt in to our marketing offers and emails. You may opt out of marketing communications at the point of account creation or at any subsequent time by selecting/deselecting the boxes in your customer account/email preferences. If you need assistance, please contact woof@milliespaws.com.

One of the core principles of GDPR is storage/retention of data and the regulation states to keep data only for as long as reasonably required. The regulation also states if there is a legal or statutory obligation to retain data, this supersedes GDPR for the period of legal/statutory obligation.

Millie’s Paws has reviewed all of its legal obligations and determines the following pieces of statute are applicable to data retention:

Companies Act 2006

HMRC Record Keeping Requirements

Based on this review adequate financial records will need to be kept for six complete financial years. To maintain adequate financial records, details of customer orders and supporting information will need to be retained.

After these periods, all Personally Identifiable Information will be removed.

The primary location for data stored by Millie’s Paws and used for the processing of orders is in the UK where only authorised personnel have access to the data.

The information 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 one of our suppliers. By submitting your personal information, you agree to this transfer, storing or processing. We will take all steps necessary to ensure that your data is treated securely and in accordance with this privacy policy.

Cookies are a technology which can be used to provide you with tailored information from our website. A cookie is an element of data that our website sends to your browser, which may then store it on your system. You can set your browser to notify you when you receive a cookie, giving you the chance to decide whether to accept it.

If you do not wish for us to use cookies when you use our website adjust your internet browser settings to not accept cookies. Please note that cookies allow you to take full advantage of the services we provide through our website and so we recommend that you leave them turned on in order to get the best browsing experience on our website.

We use the cookies for the following purposes:

operation of our website. These include, for example, cookies that allow you to log into our website or use the website’s shopping basket;
recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily;
completing the user’s current activity
reviewing browsing history in order to recommend more suitable products and more relevant marketing email communications.
research and development.

Our website uses cookies to keep track of how you use the shopping cart. This information may be used to offer assistance if you seem to be having problems, or to send special offers that relate to the products viewed, or to help us improve the website. We will not sell the information to third parties;

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.

To find out more about cookies including how to manage your cookie settings, please visit www.allaboutcookies.org.

The following list is not exhaustive but contains associated brands current core partners:

Facebook Advertising – We use Facebook Custom Audiences, Facebook Pixel and Facebook Adverts. When you visit our websites, remarketing tags are used to create a direct connection between your browser and the Facebook servers. Facebook will recognise that your IP address has visited our website and connects this information to your Facebook user account so that it can display relevant Facebook adverts. For more information on how Facebook collects and uses this data, and how to protect your privacy, see the Facebook Privacy Policy. You may exercise your right of withdrawal from Facebook Custom Audiences at Facebook Ad Settings.
Google Analytics - Our website uses Google Analytics, a web analytics service provided by Google, Inc („Google“). Google Analytics uses cookies – files which are stored on your computer and which allow an analysis of your use of the website. The information generated by these cookies is generally transferred to a Google server in the USA and stored there. This site uses IP anonymisation, meaning that your IP address is abridged within the European Union and any contracted states in the European Economic Area before it is sent to the USA. Only in exceptional cases with the full IP address be transferred to the Google server then abbreviated there. Google uses this information on behalf of the website owner to analyse your use of the website, compiling reports on website activity and to provide other services related to website usage and internet usage for the website operator. The IP address provided by your browser as part of Google Analytics will not be merged with other Google data. You can prevent cookies from being saved by setting your browser software accordingly. However, this may result in your not being able to fully utilise all the functions on our website. If you wish, you can also prevent Google from collecting and processing the data (including your IP address) by downloading and installing the browser plug-in available from Google Browser Plugin.

There are six lawful bases for processing personal data within the GDPR regulation, details of which can be found here . The following are the bases applicable to Millie’s Paws:

Contract – GDPR regulation states the contractual lawful basis for processing data is “processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.” This basis will be used in the fulfilment of orders placed via our website.
Consent – GDPR regulations state Consent is “the individual has given clear consent for you to process their personal data for a specific purpose.” This basis will be used in relation to send direct marketing communications where consent has been freely given for the specific purpose, is an affirmative step and confirmation.
Legitimate Interest – GDPR regulations state “the processing is necessary for your legitimate interests or the legitimate interests of a third party unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests.” This basis will be used for the protection of our customers and employees as well as promoting our products and services e.g. for relevant, targeted marketing emails to existing customers.

Millie’s Paws Ltd take their obligation under GDPR very seriously which is why a Data Protection Officer has been appointed. In addition to this, a comprehensive training programme has been constructed and rolled out to our team. This supports our commitment to protect our customer’s data and deliver a professional service.

We reserve the right to modify this privacy policy at any time, so please review it frequently. Changes and clarifications will take effect immediately upon their posting on the website. If we make material changes to this policy, we will notify you here that it has been updated, so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we use and/or disclose it.

By using this site, you represent that you are at least the age of majority in your place of residence, or that you are the age of majority in your place of residence and you have given us your consent to allow any of your minor dependents to use this site.

If you would like to: access, correct, amend or delete any personal information we have about you, register a complaint, or simply want more information contact our Privacy Compliance Officer at woof@milliespaws.com or by mail at Millie’s Paws Ltd, [Re: Privacy Compliance Officer], 9 Fraser Court, Rothienorman, Inverurie, Aberdeenshire, Scotland, AB51 8SD.

A small fee will be payable if you request details of personal information which we hold about you under the Data Protection Act 1998.  We will promptly correct any information found to be incorrect.