Privacy Policy

This Privacy Notice is issued on behalf of Miniml Refills. Therefore, when we mention “we”, “us” or “our” in this Privacy Policy, we are referring to Miniml Refills which is responsible for processing your information. We value the trust you place in us when you provide us with your personal information. We take your privacy seriously and are committed to protecting it.

We have a privacy team which is responsible for overseeing questions in relation to this Privacy Notice. If you have any questions about this Privacy Notice, please contact the privacy team using the details set out below.

This Privacy Notice will inform you as to how we look after your personal information when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

This Privacy Policy explains:

  • What information may be collected and the means of collection
  • Your information may be collected in several ways, for example, when you provide information to us (such as your name, date of birth, mailing address, and email address) or when you use or interact with our website or services. General information about your use of our website or services may be collected (such as IP addresses) through the use of automated technology like cookies and beacons.

  • How we use information
  • We may use information for various purposes, including providing you with information about our products, promotions and other special offers, personalising your website experience, and conducting research and analysis on our website, products, marketing efforts and sales.

  • When we share personal information
  • We do not sell or rent your personal information to third parties. We may share your personal information with (1) third parties with your consent, (2) our partners, advertisers or other third parties primarily for business and operational purposes, (3) third parties providing services on our behalf, and (4) other third parties to comply with legal obligations.

  • How we keep information secure
  • We use industry-accepted security measures to help protect your personal information from unauthorised access, alteration, loss, or misuse.

  • More on cookies, beacons, and how to stop the automated collection of information
  • Automated technology (e.g. cookies and beacons) is used to collect general non-personal information and, in some cases, IP addresses.

  • More on on-line advertising in unrelated websites (third party ad serving or targeted advertising) and how to stop its delivery
  • We use information collected through automated technology (e.g. cookies and beacons) to engage in third party ad serving/targeted advertising.

  • How we will inform you of changes to this Privacy Notice
  • We may change this Privacy Policy at any time. If we make material changes, we will seek to provide you with reasonable notice of the changes to the extent they are material. Changes will be effective immediately upon the posting of the revised Privacy Notice on our corresponding website.

  • How you can communicate with us about this Privacy Policy or your personal information
  • This Privacy Policy contains contact information if you have any questions or concerns about this Privacy Policy or your personal information.

    This website may contain links to the websites of other companies. These websites may collect data independently of MINIML. Please be aware that we do not control and are not responsible for the content, privacy policies, or practices of the websites of other companies. You should review the privacy notices of these websites before deciding whether to submit information to them.

    PLEASE NOTE THAT OUR WEBSITE IS NOT INTENDED FOR CHILDREN UNDER THE AGE OF 13. IF YOU ARE UNDER THE AGE OF 13, PLEASE DO NOT PROVIDE INFORMATION OF ANY KIND. WE DO NOT COLLECT PERSONAL INFORMATION FROM ANY PERSON WE ACTUALLY KNOW IS AN INDIVIDUAL UNDER THE AGE OF 13.

    PLEASE READ THIS PRIVACY NOTICE CAREFULLY BECAUSE, BY USING OUR WEBSITES, YOU ARE ACKNOWLEDGING YOU UNDERSTAND AND AGREE TO THE TERMS OF THIS PRIVACY NOTICE.

    Section 1

    What information may be collected and the means of collection

    Your information may be collected by us in several ways, including when you provide information to us, when information is collected automatically, or when information is shared with us by a third party.

  • The information you provide to us through our website or the websites of one of our promotional or advertising partners
  • We collect information, including personal information, such as your name, date of birth, mailing address, and email address, when you provide it through registration to receive emails, request information, submit comments, submit product reviews or participate in a promotion (e.g., contest or sweepstakes) or survey.

    MINIML’s website offers shopping or other commercial services, you will use an order form to request information, products and services. The order form may ask you to provide financial information like account or credit card numbers. MINIML does not collect or store financial information which is, instead, processed by our third party payment processing providers. Please do not send us any financial information outside the secured browsing session.

    Providing personal information to us is purely optional. However, if you refuse to provide details that are essential (e.g. as may be identified in a registration form), it would be impossible to use some of the features and functions of the website and/or to benefit from our services or promotions (for instance, by not being able to participate in a sweepstake or contest).

  • Information collected automatically when you visit our website or the website of one of our promotional or advertising partners
  • We, as well as any third party advertisers and/or service providers, may place cookies, beacons or other tracking technologies in your browser to automatically collect general non-personal information when you visit one of our websites (further information on cookies, beacons, and how to stop automated collection is set out below in this Privacy Notice). Your IP address, which in some instances may be considered personal information, may also be collected through the use of automated technology. Please see more regarding the collection of IP addresses and the ability to associate browsing habits with your individual personal computer in this section below.

    In cases when you are on the website of one of our promotional or advertising partners, our cookies or beacons are placed on your computer via MINIML content that you may be viewing (e.g. a product promotion or advertisement).

    Information collected by cookies or beacons may be used by us or our promotional or advertising partners to deliver targeted advertising to you. The practice of displaying advertisements on the websites of unrelated companies is called third party ad serving or targeted advertising (further information on online advertising in unrelated websites (third party ad serving or targeted advertising) and how to stop its delivery is set out below in this Privacy Policy).

    The type of information that may be collected automatically includes:

    • internet browser type;
    • computer type;
    • IP address. Please note that an IP address is a number that is assigned to your computer by your Internet Service Provider (ISP) so you can access the internet. Some ISPs assign a new IP address every time you access the internet while other ISPs assign you the same number every time you access the internet. In instances when you are assigned the same IP address, it is possible for information about your browsing habits to be associated with your individual personal computer;
    • operating system;
    • webpages visited;
    • links clicked; and
    • date and time of visits

    We will use this information as is necessary to pursue our legitimate interests in helping us provide a better website experience by diagnosing problems with our servers, evaluating site navigation and better understanding the demographics of our site visitors so we can provide more relevant content, functionality and offers.

  • Information shared with us by a third party
  • We may receive information about you from social networking sites if you or other users (e.g., your “friends”) give us access to your profiles, comments, or “connections”, if you “like” us, or if you choose to participate in a MINIML sponsored page or program residing in a social networking site (e.g., MINIML’s Facebook page). The type of information that we may receive includes lists of your friends, comments you have shared, groups and location.

    Our websites may also have “plugins” and other website features from third parties, such as the Facebook “Like” button and Facebook Conversations and other features which allow for login or other website functionality or interactions with social networking sites. These “plugins” and features, including their operation and use, and the information you provide to those third parties as part of their use, are governed by the privacy policy and practices of the third party providing them. Please be aware that we do not control and are not responsible for the privacy policies or practices of such parties. You should review the privacy notices and applicable terms before deciding whether to use the third party “plugins” or features.

    Section 2

    How we use information

    We may use your information to pursue the following legitimate interests:

  • respond to your questions and requests,
  • provide you with information about our company or companies, products, services, promotions and other special offers, including through the delivery of targeted advertising,
  • personalise your website experience through tailored content, advertisements and offers, communicate with you about your account and other matters, and in our discretion, changes to any MINIML policy that may affect you,
  • conduct research and analysis related to, and manage and improve, our websites, products, services, advertising, promotions and sales, including, for example, to make our websites easier to use with better content by understanding how people use our websites, products and services,
  • process transactions,
  • administer programs and promotions for which you sign up, including sweepstakes and contests,
  • implement other activities disclosed at the time you provide your information,
  • implement social networking features you have activated, and/or
  • combine all the information we collect or receive about you for any of the foregoing purposes.
  • We may also use the information you give to us as is necessary to carry out our obligations arising from a contract (or potential contract) between you and us (i.e. in order to process a product order).

  • Marketing communications
  • If you would like to be kept up to date with news and receive information about our products, promotions and details of other events and activities, please let us know by subscribing on our website or writing to us. We will not send communications to you without your consent and you have the right to ask us not to use your contact details for marketing. You can opt out of these marketing communications or change your preferences at any time. If you would like to change or stop receiving communications from us, please contact our privacy team (and contact details are provided above).

    Section 3

    When we share personal information

    We will not sell or rent your personal information to third parties. Periodically, we may share your personal information with our business partners and service providers, such as in the circumstances below. We may also share aggregated and/or anonymous information with our business partners for their own business purposes.

  • MINIML’s business partners
  • We may share your personal information with our partners, advertisers or other third parties primarily for business and operational purposes, including joint promotional activities with such other third parties.

  • Third parties providing services on our behalf
  • We may share your personal information with third party companies that help us carry out your requests, make various features, services and materials available through our websites, respond to your enquiries and for the other purposes described in the section above on “How we use information”. The third party companies to which we may provide this information may include potential or actual advertisers, providers of advertising services (including website tracking services), commercial partners, sponsors, licensees, researchers and other similar parties. We may also use your personal information to develop general audience segments for delivering targeted advertising on social media platforms and third party sites.

  • Legal proceedings and other special circumstances
  • We may share your personal information with third parties to comply with a legal obligation such as at the request of governmental authorities conducting an investigation, to verify or enforce our websites’ terms of use or other applicable policies or to protect the rights, property, safety or security of visitors to our websites, the public or third parties.

    Section 4

    How we keep information secure

    We take information security seriously and use industry-accepted security measures to help protect your personal information from unauthorised access, alteration, loss, or misuse. For example, we store personal information on computer systems with limited access and these systems are located in controlled facilities.

    Section 5

    More on cookies, beacons, and how to stop the automated collection of information

    MINIML uses automated technology to collect general non-personal information. Automated collection of information occurs mainly through the use of two technologies: cookies and web beacons.

  • More on “Cookies”
  • What is a cookie — A cookie is a small file that a website you are visiting places in your computer through your internet browser. Cookies have the ability to identify your computer and store information like web pages visited, advertisements viewed, frequency, and type of browser used.

    Cookies are usually managed through your internet browser.

    How are cookies used — Cookies are normally used to help with security (e.g. to time you out of a secured browsing session after a certain period of inactivity), site navigation (e.g. to remember your preferences so that you don’t need to re-enter information like language preference), and improve your browsing experience (e.g. deliver content, advertisements, or offers that are consistent with your browsing habits).

    Cookies can remain in your computer for the duration of a browsing session or for a predetermined period of time. Cookies that remain in your computer for the duration of a browsing session are called “session” cookies (e.g. the contents of an online “shopping basket” will disappear at the end of your browsing session). Cookies that remain in your computer for a predetermined period of time are called “persistent” cookies (e.g. selecting English in a website that offers content in multiple languages so that the content is displayed in English when you return to the website even weeks or months later).

    Accepting, disabling or deleting cookies – You may be able to set your browser to notify you before you receive a cookie, giving you the change to decide whether to accept it, or to block cookies altogether. To do so, please refer to your browser’s help menu.

    Most browsers also allow you to erase cookies already stored. Please be aware that deleting cookies will likely have a negative effect on the performance of the websites you visit and, consequently, you may not be able to see content or use applications offered through the websites.

    To delete cookies that have been installed in your computer, please refer to your browser’s help menu. Below are links to some of the most popular internet browsers where you can find additional information on managing cookies:

    • Internet Explorer
    • Firefox
    • Chrome
    • Safari
    • Opera

    In addition, some of our websites may contain an icon (such as an “AdChoices” icon), typically on the footer of the page, or another button that enables users to learn more about the companies that use cookies on our websites and their choices with respect to such cookies.

    You can also learn more about cookies at:

    http://allaboutcookies.org/ and http://www.onguardonline.gov/
  • More on web “beacons”
  • What is a web beacon — Web beacons are small pieces of computer code placed in transparent graphic images displayed in websites you may be viewing or emails you may receive. Web beacons are not noticeable since they are usually placed within a very small portion of an image being observed. Web beacons are also known as pixel tags, clear GIFs, and web bugs.

    How are web beacons used — Web beacons are normally used to monitor website traffic. Web beacons can also be used with cookies to gain an understanding of how website users navigate and process the content contained in websites. For example, a company owning a network of websites may use web beacons to count and recognise users travelling through its multiple websites. Being able to recognise users allows the website owner to personalise users’ visits and make them more user-friendly.

    How to delete web beacons — To delete web beacons, you will need to delete cookies from your browser (see the section above on “how to delete cookies”).

    You can learn more about web beacons at:

    http://www.allaboutcookies.org/faqs/beacons.html

    Section 6

    More on online advertising in unrelated websites (third party ad serving or targeted advertising) and how to stop its delivery

    We and our promotional and advertising partners use information collected by cookies or beacons to engage in third party ad serving/targeted advertising.

    What is third party ad serving/targeted advertising — Third party ad serving is the most common practice of delivering advertisements in the websites of unrelated companies.

    How does third party ad serving/targeted advertising work — Third party ad serving utilises technology such as cookies and web beacons to assemble usage information from websites you’ve visited. This information is utilised to try to understand your potential interests and match them with potential suppliers of related product and services. If one of these potential suppliers has contracted with a website that you are visiting to deliver its corresponding advertisement, your internet browser will assemble appropriate ad information and deliver it to you while you are browsing on the unrelated website.

    How to limit third party ad serving – Your jurisdiction may have adopted laws or an industry self-regulatory framework that enables you to limit or stop third party advertising. An increasing number of advertisers have embedded an icon (such as an “AdChoices” icon) in or near their ads to indicate compliance with applicable self-regulatory frameworks. By selecting this icon, you may be redirected to a website that should allow you to limit or stop the delivery of advertisements to your computer. However, you should know that such icons (including the “AdChoices” icon) can only help you limit advertisements from companies that have signed-up to use the applicable icon to manage third party ad serving.

    If and to the extent an advertisement does not include the applicable icons, you should visit the website where you are receiving the third party ad (espn.com in the example above) or the actual advertiser’s website to view its privacy policy, which may provide information on how to stop receiving third-party advertisements.

    You can learn more about third party ad serving and how to limit related advertisements at:

    http://www.aboutads.info/

    Please note that MINIML has no control over this advertising network or the companies that belong to the network.

    What is Do Not Track – Do Not Track is a privacy preference that you can set in your web browser that is intended to allow you to control the tracking of your online activities across websites.

    How we respond to Do Not Track Signals – MINIML does currently honour Do Not Track settings that are enabled from your web browser.

    Transfer of personal information outside the EEA

    We may transfer your personal information outside the European Economic Area (“EEA”). We try to limit this where possible but it may be necessary where, for example, one of our suppliers has a data centre outside the EEA. Whenever we transfer your personal information outside of the EEA, we will take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this Privacy Notice and that the appropriate legal safeguards are in place prior to the transfer, for example particularly ensuring that any contracts between us and the recipient of the information have EU-approved standard data protection clauses, or are recognised as having adequate protection for the transfer of personal data.

    Section 9

    How we will inform you of changes to this Privacy Notice

    Please note that we reserve the right to change this Privacy Notice, at any time. To the extent that we make material changes, we will seek to provide you with reasonable notice of the changes. Changes will be effective immediately upon the posting of the revised Privacy Notice on our corresponding website. Please check back from time to time.

    Section 10

    How you can communicate with us about this Privacy Notice or your personal information

    If you have any questions or concerns about this Privacy Notice or your personal information, please let us know by addressing your query to the privacy team on the below email and mail addresses and your request will be handled by our customer service centre in Leeds:

    By email: hello@minimlrefills.co.uk

    By mail: Unit 3, Parkwood Business Park, Parkwood Street, Keighley, West Yorkshire, BD21 4WD, United Kingdom

    Your rights

    Under the General Data Protection Regulation, you have the following rights:

    Right to correction. You have the right to have inaccurate personal information about you rectified.

    The right to erasure. You have the right to request that we delete your personal information where: (a) the personal information are no longer necessary in relation to the purposes for which they were collected or processed; (b) you withdraw your consent to processing for which we previously obtained your consent; (c) you object to the processing and, as a result, we agree to cease that processing (please see below about the right to object for more details); (d) the personal information has been unlawfully processed; and (e) we are required to erase the personal information in order to comply with the law.

    Right to restriction. You have the right to obtain from us the restriction of processing where: (a) you contest the accuracy of the personal information we hold about you; (b) the personal information has been unlawfully processed; (c) we no longer need the personal information but they are required in limited circumstances; and (d) you object to the processing and, as a result, we agree to cease that processing (please see below about the right to object for more details).

    Right to request a transfer. In certain circumstances, you have the right to receive personal information from us in a structured, commonly used and machine-readable format and the right to transmit it to a third party organisation.

    Right to object. You have the right to raise an objection to any of our processing where we rely on our legitimate interests to process your personal information. Please tell us if you object to any type of processing that we do and we will work with you to address any concerns you may have.

    Right to object to marketing. If you do not want us to process your personal data for direct marketing, please tell us and we will ensure that we no longer do this.

    Right to complain to the ICO. Whilst we would always prefer it if you approached us first about any complaints or queries you may have, you always have the right to lodge a complaint with the Information Commissioner’s Office.

    Right to request access. You have the right to access the personal information we hold about you.

    How long we keep your personal information

    We will not keep any personal information about you for any longer than is necessary for the purposes for which the personal information is processed. We may retain your personal information for a longer period than usual in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect of our relationship with you.

    To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal, regulatory or other requirements.

    We follow an internal personal information retention policy which determines how long we keep specific types of personal information for. For further information about the criteria we use to determine what periods we keep specific information, please contact our privacy team on the contact details provided above.

    In some circumstances you can ask us to delete your information: please see your legal rights above for further information. In some circumstances, we will anonymise your personal information (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

    Klarna In order to offer you Klarna’s payment methods, we might in the checkout pass your personal data in the form of contact and order details to Klarna, in order for Klarna to assess whether you qualify for their payment methods and to tailor those payment methods for you. Your personal data transferred is processed in line with Klarna’s own privacy notice.