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BUTTERNUT BOX PRIVACY POLICY


1. OUR APPROACH TO PRIVACY
1.1 Dogmates Ltd, Dogmates (Ireland) Ltd and Dogmates (Netherlands) B.V. ("Butternut Box", "we", "our", or "us") are committed to protecting and respecting your privacy. This privacy policy sets out how we collect, store, process, transfer, share and use data that identifies or is associated with you ("personal information") and information regarding our use of cookies and similar technologies.
1.2 Butternut operates a service that allows you to tailor, select and order dog food for your dog using our website at https://butternutbox.com (the "Service").
1.3 This privacy policy applies to our Service. Before accessing or using our Service, please ensure that you have read and understood how we collect, store, use and disclose your personal information as described in this privacy policy.
1.4 Dogmates Ltd is the data controller of the personal information we hold about you if you are a customer in the United Kingdom, Dogmates (Ireland) Ltd if you are a customer in the Republic of Ireland and Dogmates (Netherlands) B.V. if you are a customer in the Netherlands or Belgium.


2. PERSONAL INFORMATION WE COLLECT ABOUT YOU AND HOW WE USE IT
2.1 We collect personal information that you voluntarily submit directly to us when you use our Service. This can include information you provide to us when you register for an account and user profile, fill in a form on our Service, create or edit your user profile on the Service, correspond with us by phone, e-mail or otherwise, subscribe to our mailing lists, newsletters or other forms of marketing communications, respond to a survey, post comments in forums, enter a promotion, or use some other feature of our Service. We may also collect personal information from third parties, such as social networks.
2.2 We will indicate to you where the provision of certain personal information is required in order for us to provide you certain features of the Service. If you choose not to provide such personal information, we may not be able to provide the Service to you or respond to your other requests.
2.3 The table at Annex 1 sets out the categories of personal information we collect about you and how we use that information. The table also lists the legal basis which we rely on to process the personal information and the recipients of the personal information.
2.4 We also automatically collect personal information indirectly about how you access and use the Service and information about the device you use to access the Service.
2.5 The table at Annex 2 sets out the categories of personal information we collect about you automatically and how we use that information. The table also lists the legal basis which we rely on to process the personal information and the recipients of the personal information.
2.6 We may link or combine the personal information we collect about you and the information we collect automatically. This allows us to provide you with a personalised experience regardless of how you interact with us.
2.7 We may anonymise and aggregate any of the personal information we collect (so that it does not directly identify you). We may use anonymised information for purposes that include testing our IT systems, research, data analysis, improving our Service and developing new products and features. We may also share such anonymised information with others.
2.8 We will store the personal information we collect about you for no longer than necessary for the purposes set out in Annex 1 and Annex 2 and in accordance with our legal obligations and legitimate business interests.


3. RECIPIENTS OF PERSONAL INFORMATION
3.1 In addition to the recipients listed in Annex 1 and Annex 2, we may also share your personal information with the following (as required in accordance with the uses set out in Annexes 1 and 2):
  (a) Service providers and advisors: we may share your personal information with third party vendors and other service providers that perform services for us or on our behalf, which may include providing mailing, email or chat services, fraud prevention, web hosting, or providing analytic services.
  (b) Purchasers and third parties in connection with a business transaction: your personal information may be disclosed to third parties in connection with a transaction, such as a merger, sale of assets or shares, reorganisation, financing, change of control or acquisition of all or a portion of our business.  
 (c) Law enforcement, regulators and other parties for legal reasons: we may share your personal information with third parties as required by law or if we reasonably believe that such action is necessary to (i) comply with the law and the reasonable requests of law enforcement; (ii) detect and investigate illegal activities and breaches of agreements, including our Terms of Use; and/or (iii) exercise or protect the rights, property, or personal safety of Butternut Box, its users or others.


4. MARKETING AND ADVERTISING
4.1 From time to time we may contact you with information about our products and services, including sending you marketing messages and asking for your feedback on your products and services.
4.2 Most marketing messages we send will be by email. For some marketing messages, we may use personal information we collect about you to help us determine the most relevant marketing information to share with you.
4.3 We will only send you marketing messages if you have given us your consent to do so. You can withdraw your consent at a later date by clicking on the unsubscribe link at the bottom of our marketing emails.
4.4 We may also ask third parties to send you messages asking for your feedback on our behalf. If you give us permission to do so, we may share your contact details with such parties for this purpose.


5. STORING AND TRANSFERRING YOUR PERSONAL INFORMATION
5.1 Security. We implement appropriate technical and organisational measures to protect your personal information against accidental or unlawful destruction, loss, change or damage. All personal information we collect will be stored on our secure servers. We will never send you unsolicited emails or contact you by phone requesting your account ID, password, credit or debit card information or national identification numbers.
5.2 International Transfers of your Personal Information. The personal information we collect may be transferred to and stored in countries outside of the jurisdiction you are in where we and our third party service providers have operations. If you are located in the European Union ("EU"), your personal information may be processed outside of the EU including in the United States; these international transfers of your personal information will be made pursuant to appropriate safeguards, such as standard data protection clauses adopted by the European Commission. If you wish to enquire further about these safeguards used, please contact us using the details set out at the end of this privacy policy.


6. YOUR RIGHTS IN RESPECT OF YOUR PERSONAL INFORMATION
6.1 In accordance with applicable privacy law, you have the following rights in respect of your personal information that we hold:
  (a) Right of access. You have the right to obtain:    
(i) confirmation of whether, and where, we are processing your personal information;    
(ii) information about the categories of personal information we are processing, the purposes for which we process your personal information and information as to how we determine applicable retention periods;    
(iii) information about the categories of recipients with whom we may share your personal information; and  
(iv) a copy of the personal information we hold about you.  
(b) Right of portability. You have the right, in certain circumstances, to receive a copy of the personal information you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal data to another person.  
(c) Right to rectification. You have the right to obtain rectification of any inaccurate or incomplete personal information we hold about you without undue delay.  
(d) Right to erasure. You have the right, in some circumstances, to require us to erase your personal information without undue delay if the continued processing of that personal information is not justified.  
(e) Right to restriction. You have the right, in some circumstances, to require us to limit the purposes for which we process your personal information if the continued processing of the personal information in this way is not justified, such as where the accuracy of the personal information is contested by you. 
(f) Right to object. You have a right to object to any processing based on our legitimate interests where there are grounds relating to your particular situation. There may be compelling reasons for continuing to process your personal information, and we will assess and inform you if that is the case. You can object to marketing activities for any reason.
6.2 If you wish to exercise one of these rights, please contact us using the contact details at the end of this privacy policy. You may also review and edit some of the personal information you have submitted to us by logging into your account on our website.
6.3 You also have the right to lodge a complaint to your national data protection authority. Further information about how to contact your local data protection authority is available at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.


7. COOKIES AND SIMILAR TECHNOLOGIES 
7.1 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 website.
7.2 Cookies are pieces of code that allow for personalisation of our website experience by saving your information such as user ID and other preferences. A cookie is a small data file that we transfer to your computer's hard disk for record-keeping purposes.
7.3 We use the following types of cookies:
  (a) Strictly necessary cookies. 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. 
  (b) Analytical/performance cookies. They allow us to 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. We may use third-party analytics tools such as Google Analytics, to help us measure traffic and usage trends for the Service and to understand more about the demographics of our users. You can learn more about Google’s practices at http://www.google.com/policies/privacy/partners, and view its currently available opt-out options at https://tools.google.com/dlpage/gaoptout. 
  (c) Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region). 
  (d) Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it, and the marketing messages we send to you more relevant to your interests. We may also share this information with third parties who provide a service to us for this purpose.
  (e) Third party cookies. Please be aware that advertisers and other third parties may use their own cookies tags when you click on an advertisement or link on our website. These third parties are responsible for setting out their own cookie and privacy policies.
7.4 The cookies we use are designed to help you get the most from the website but if you do not wish to receive cookies, most browsers allow you to change your cookie settings. Please note that if you choose to refuse cookies you may not be able to use the full functionality of our website. These settings will typically be found in the "options" or "preferences" menu of your browser. In order to understand these settings, the following links may be helpful, otherwise you should use the "Help" option in your browser for more details.
  (a) Cookie settings in Internet Explorer
  (b) Cookie settings in Firefox
  (c) Cookie settings in Chrome
  (d) Cookie settings in Safari web and iOS.
7.5 If you would like to find out more about cookies and other similar technologies, please visit www.allaboutcookies.org or the Network Advertising Initiative's online sources at www.networkadvertising.org.


8. INTEREST BASED ADVERTISING
8.1 We participate in interest-based advertising and use third party advertising companies to serve you targeted advertisements based on your online browsing history and your interests. To do this, we or our advertising partners may collect information about how you use or connect to our Service, or the types of other websites, social media services, content and ads that you (or others using your device) visit or view or connect to our Service so that we or our advertising partners may play or display ads on our Service, on other websites, apps or services you may use, and on other devices you may use. We do not enable this functionality on our iOS mobile application.
8.2 Typically, but not always, this information is collected through cookies and similar tracking technologies. We and our third party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics and market research.
8.3 We may also use certain forms of display advertising and other advanced features through Google Universal Analytics, such as Remarketing with Google Analytics, Google Display Network Impression Reporting, the DoubleClick Campaign Manager Integration, and Google Analytics Demographics and Interest Reporting. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the Doubleclick advertising cookie) or other third party cookies together to inform, optimize, and display ads based on your past visits to the Service. You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences or by visting NAI’s online resources at http://www.networkadvertising.org/choices. We do not engage with remarketing features on Google Analytics for activity through our iOS application. 
  8.4 To learn about interest-based advertising and how you may be able to opt-out of some of this advertising and to limit some third party advertising cookies, you may wish to visit:
  (a) Your Online Choices (http://www.youronlinechoices.com/ )
  (b) Network Advertising Initiative (http://www.networkadvertising.org/) 
  (c) Digital Advertising Alliance (http://www.aboutads.info/consumers)
Please note that opting-out of receiving interest-based advertising through the NAI’s and DAA’s or Your Online Choices online resources will only opt-out a user from receiving interest-based ads on that specific browser or device, but the user may still receive interest-based ads on his or her other devices. You must perform the opt-out on each browser or device you use. 8.5 Some of these opt-outs may not be effective unless your browser is set to accept cookies. If you delete cookies, change your browser settings, switch browsers or computers, or use another operating system, you will need to opt-out again.


9. Tracking Technologies used in our emails
9.1 Our emails may contain tracking technologies that provide us with information about your interactions with our emails, including identifying if and when you have opened an email that we have sent you, how many times you have read it and whether you have clicked on any links in that email. This helps us measure the effectiveness of our marketing email campaigns, make the emails we send to you more relevant to your interests and to understand if you have opened and read any important administrative emails we might send you.
9.2 Most popular email clients will allow you to block these technologies by disabling certain external images in emails. You can do this through the settings on your email client – these generally give you the option of choosing whether emails will display "remote images", "remote content" or "images" by default.
9.3 Some browsers also give you the option of downloading and installing extensions that block tracking technologies.
 10. LINKS TO THIRD PARTY SITES
Our Service may, from time to time, contain links to and from third party websites, including those of other users, our partner networks, advertisers, partner merchants, news publications, retailers 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 their policies. Please check the individual policies before you submit any information to those websites.


 11. OUR POLICY TOWARDS CHILDREN
11.1 Our Service is not directed at persons under 16 and we do not knowingly collect personal information from children under 16. If you become aware that your child has provided us with personal information, without your consent, then please contact us using the details below so that we can take steps to remove such information and terminate any account your child has created with us.


 12. CHANGES TO THIS POLICY
We may update this privacy policy from time to time and so you should review this page periodically. When we change this privacy policy in a material way, we will update the "last modified" date at the end of this privacy policy. Changes to this privacy policy are effective when they are posted on this page.


 13. NOTICE TO YOU
If we need to provide you with information about something, whether for legal, marketing or other business related purposes, we will select what we believe is the best way to get in contact with you. We will usually do this through email or by placing a notice on our Service. The fact that we may send notices to you will not stop you from being able to opt out of certain types of contact as described in this privacy policy.
 
14. CONTACTING US
14.1 Please contact privacy@butternutbox.com if you have any questions, comments and requests regarding this Privacy Policy.
14.2 This privacy policy was last modified on the 3rd of March 2020.
 

ANNEX 1 – PERSONAL INFORMATION WE COLLECT

 

1. Contact information such as your name, phone number, address and e-mail address.

 
HOW WE USE IT
We use this information to operate, maintain and provide to you the features and functionality of the Service. The processing is necessary for the performance of a contract and to take steps prior to entering into a contract.
We use this information to facilitate the shipment of dog food ordered through the Service. The processing is necessary for the performance of a contract and to take steps prior to entering into a contract.
We use this information to communicate with you, including sending service-related communications (such as statements, order confirmations and updates). The processing is necessary for the performance of a contract and to take steps prior to entering into a contract.
We use this information to deal with enquiries and complaints made by or about you relating to the Service. The processing is necessary for our legitimate interests, namely administering the Service, and for communicating with you effectively to respond to your queries or complaints. We use this information to send you unsolicited marketing emails relating to our products in accordance with your preferences. The processing is necessary for our legitimate interests, namely sending you marketing communications in relation to our products. 
We use this information to send you unsolicited marketing post and to make marketing calls to you. The processing is necessary for our legitimate interests, namely direct marketing and to inform our direct marketing.
We use this information to deliver to you named address gifts, promotional materials or personal greetings cards. 


RECIPIENTS
 

2. Information about your dog.

 
HOW WE USE IT
We use this information to provide you with features of the Service, including tailoring the dog food we recommend for your dog. The processing is necessary for the performance of a contract and to take steps prior to entering into a contract.
We use this information to send you unsolicited marketing communications in accordance with your preferences. The processing is necessary for our legitimate interests, namely sending you marketing communications in relation to our products.
We use this information to deliver to you named address gifts, promotional materials or personal greetings cards. 


RECIPIENTS
 

3. Correspondence, comments and opinions

When you contact us directly, e.g.by email, phone or when you complete an online form, we will record your comments and opinions.


HOW WE USE IT
We use this information to address your questions, issues and concerns. The processing is necessary for our legitimate interests, namely communicating with users and responding to queries, complaints and concerns.
We use this information to develop new products and features available through our Service or otherwise improve our Service. The processing is necessary for our legitimate interests, namely developing and improving our Service.
 We use this information to determine products and services that may be of interest to you. The processing is necessary for our legitimate interests, namely marketing. 
We use this information to send you solicited marketing communications and other information in response to your enquiries. The processing is necessary for the performance of a contract and to take steps prior to entering into a contract. We use this information to send you unsolicited marketing communications in accordance with your marketing preferences. We will process your personal information for this purpose to the extent that you have given us consent to do so.


RECIPIENTS

4. Transaction Information

Such as items purchased, date and time of your transaction.


HOW WE USE IT
We use this information to facilitate transactions. The processing is necessary for the performance of a contract.
We use this information to provide customer support. The processing is necessary for our legitimate interests, namely administering the Service and providing customer support. 
We use this information to detect and prevent fraud. The processing is necessary for our legitimate interests, namely the detection and prevention of fraud. 
We use this information to inform our advertising and marketing. The processing is necessary for our legitimate interests, namely marketing.


RECIPIENTS

5. Payment Information

Such as your credit card or bank account details.


HOW WE USE IT
We use this information to facilitate transactions. The processing is necessary for the performance of a contract.
We use this information to detect and prevent fraud. The processing is necessary for our legitimate interests, namely the detection and prevention of fraud. 


RECIPIENTS
 

6. Preferences

Preferences set for notifications, marketing communications, how our website is displayed and how you use the Service.


HOW WE USE IT
We use this information to provide notifications, send marketing communications and display our Service in accordance with your choices. The processing is necessary for our legitimate interest, namely ensuring the user receives the correct marketing and other communications.


RECIPIENTS
 

7. Location Information

Other than information you choose to provide to us, we do not collect information about your precise location. Your device’s IP address may help us determine an approximate location.


HOW WE USE IT
We use information you provide to us about your location to inform and plan our marketing strategy. The processing is necessary for our legitimate interest, namely informing our direct marketing strategy.
 

8. All personal information set out above

 
HOW WE USE IT
We will use all the personal information we collect to operate, maintain and provide to you the features and functionality of the Service, to communicate with you, to monitor and improve our Service and business, to deliver to your named address gifts, promotional materials or personal greetings cards, and to help us develop new products and services. The processing is necessary for our legitimate interests, namely to administer and improve the Service.
 

ANNEX 2 – PERSONAL INFORMATION COLLECTED AUTOMATICALLY

 

1. Information about how you access and use the Service.

For example, the website from which you came and the website to which you are going when you leave our website, how frequently you access the Service, the time you access our Service and how long you use it for, the approximate location that you access the Service from, whether you access the Service from multiple devices, and other actions you take on the Service.


HOW WE USE IT
We use information about how you use and connect to our Service to present our Service to you on your device. The processing is necessary for our legitimate interests, namely to tailor our Service to the user.
We use this information to determine products and services that may be of interest to you for marketing purposes. The processing is necessary for our legitimate interests, namely to inform our direct marketing. We use this information to monitor and improve our Service and business, resolve issues and to inform the development of new products and services. The processing is necessary for our legitimate interests, namely to monitor and resolve issues with our Service and to improve our Service generally.


RECIPIENTS
 

2. Log files and information about your device.

We also collect information about the computer, tablet, smartphone or other electronic device you use to connect to our Service. This information can include details about the type of device, unique device identifying numbers, operating systems, browsers and applications connected to our Service through the device, and your IP address.
 
HOW WE USE IT
We use information about how you use and connect to our Service to present our Service to you on your device. The processing is necessary for our legitimate interests, namely to tailor our Service to the user. We use this information to determine products and services that may be of interest to you for marketing purposes. The processing is necessary for our legitimate interests, namely to inform our direct marketing. We use this information to monitor and improve our Service and business, resolve issues and to inform the development of new products and services. The processing is necessary for our legitimate interests, namely to monitor and resolve issues with our Service and to improve our Service generally


RECIPIENTS