Sourcerie Privacy Notice

Last effective update: 15/07/2025

1. Important information and who we are

About us

We are Sourcerie Ltd, a limited company registered in England and Wales under company number 13350633. For the purpose of data protection laws, we are the controller, and are responsible for your personal data (collectively referred to as “Sourcerie”, “we”, “us” or “our” in this privacy notice).

Sourcerie respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data 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 notice forms part of our terms of business, but is not intended to override them. This policy may be amended or updated from time to time and revised versions will be shown on our website. It is your responsibility to check for the most recent version of this notice.

Purpose of this privacy notice

This privacy notice aims to give you information on how Sourcerie collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our community or to receive news from us.

For the avoidance of doubt, this website is not intended for children under the age of 18 years old. We do not knowingly collect data relating to such individuals.

Contact details

If you have any questions about this privacy notice or our privacy practices, please contact us by email at: help@sourcerie.co.

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

Third-party links

2. Who does this privacy policy apply to?

This privacy policy will apply to you if you are one of the following:

• A representative of one of our customers – if you engage with us on behalf of the customer

• A Sourcerie vendor – if you engage with us as a vendor or on behalf of a vendor

• A website user – if you use or visit our website (even before signing up to any of our services)

• A Sourcerie Community member – if you sign up to the Sourcerie Community to participate in feedback projects for our customers

3. The data we collect about you

Personal data, or personal information, refers to any information about an individual from which that person can be identified (personal data). It does not include data where the identity has been removed to the extent that it cannot be reconstructed to identify an individual (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you that we have grouped together as follows:

• Identity Data includes first name, last name, username or similar identifier, title, date of birth and gender.
• Contact Data includes email address and telephone numbers.
• Delivery Data includes delivery address.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
• General Profile Data includes your username and password where you log into our website to receive services from us.
• Community Profile Data includes where you sign up to the Sourcerie Community, your interests, preferences, feedback and survey responses.
• Self-Reported Health and Lifestyle Data includes, where you sign up to the Sourcerie Community or participate in feedback projects, information you choose to provide about your health, lifestyle and use of health and lifestyle-related products or services.
• Feedback Data includes other feedback data and survey responses when participating in feedback projects.
• Usage Data includes information about how you use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data (such as statistical or demographic data) for any purpose. Aggregated Data could be derived from your personal data, but is not considered personal data in law, as this data will not directly or indirectly reveal your identity.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, we cannot send you a product sample as part of a feedback project where you fail to provide your delivery address). In this case, we may have to cancel or suspend our services.

4. How is your personal data collected?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity, Contact, Delivery, Community Profile, Self-Reported Health and Lifestyle Data by filling in forms or by corresponding with us. This includes personal data you provide when you:
  • create an account on our website;
  • update your account on our website;
  • use our services;
  • request marketing to be sent to you;
  • enter a competition, promotion or survey; or
  • give us feedback or contact us.
• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our Cookie Policy for further details.
• Third parties or publicly available sources. We may receive personal data about you from various third parties, such as other users of our website/services or advertising networks, and public sources.

5. What do we use your personal data for (including the lawful bases we rely on)?

Lawful bases

We only process your data (which may include providing it to a third party) where we have identified a valid lawful basis to do so. The valid lawful basis we rely on are as follows:

• Contractual Obligation – Where processing is necessary to comply with our obligations arising out of a contract, for example, providing you or someone you represent with services or completing a feedback project.
• Legitimate Interest – Where we use legitimate interests, we will record our decision on making this decision. We rely on legitimate interest where processing of the data we hold on you does not, in our opinion, affect your rights or freedoms and is proportionate to our interests e.g. obtaining your feedback on our service.
• Legal Obligation – Where we need to comply with a legal obligation.
• Consent – We require your consent to process your Self-Reported Health and Lifestyle Data, and where we do not rely on a contractual obligation, a legitimate interest or a legal obligation to process your data (see above). You have the right to withdraw consent at any time by contacting us. However, please note that if you do so, some of the aspects of the Service you receive from us may be impacted (for example, we can‘t complete a feedback project which includes questions on health and lifestyle without your consent).

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data, where more than one ground has been set out in the table below.

Marketing and Opting Out

We may contact you from time to time via email about our services, promotions, rewards, and events offered by us, provide news and information that we think will be of interest to you, invite you to provide feedback on our services. We will send these communications to you if you have opted-in and have not unsubscribed or opted out from receiving them, which you can do at any time.

We use your Contact Data to send you these communications.

We will never use data about your health (for example, your Self-Reported Health and Lifestyle Data) for marketing purposes.

Where you have consented, we may share your personal data with our customers for marketing purposes.

Cookies

We may collect information using ‘cookies’. Cookies are small data files stored on the hard drive of your computer or mobile device by a website. We may use both ‘session cookies’ (which expire once you close your web browser) and ‘persistent cookies&rsuo; (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience on our website.

Cookies we use

We may use both ‘first party cookies’, which are created and accessed only by us, and ‘third party cookies’, which may be created and accessed by our partners or service providers. The types of cookies used by our website and what they are used for is outlined below:

Essential Cookies (first party):

These cookies are essential to provide you with services available through our site and to enable you to use some of its features. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.

Analytics and Performance Cookies (first and third party):

These cookies are used to collect information about traffic to our website and how users use our website. The information gathered may include the number of visitors, the websites that referred them to our website, the pages they visited on our website, what time of day they visited our website, whether they have visited our website before, and other similar information. We use this information to help operate our website more efficiently, to gather broad demographic information, monitor the level of activity on our website and to improve it.

How to disable cookies and consequences of doing so

You can decide which cookies we can store, or remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser. Many browsers are set to accept cookies until you change your settings. If you do not accept our website&rsuo;s cookies, you may experience some inconvenience in your use of the website. For example, we may not be able to recognise your computer or mobile device and you may need to log in every time you visit our website. Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org and youronlinechoices.eu.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason that is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us using the details set out above.

If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

6. Disclosures of your personal data

We will keep your information within the organisation except where disclosure is required or permitted by law, or when we use third party service providers (data processors) to supply and support our services to you. Where we use third party processors, we have contracts in place with them. This means that they cannot do anything with your personal data unless we have instructed them to do so. They will not share your personal data with any organisation apart from us. They will hold it securely and retain it for the period we instruct.

Please see below the list which sets out the categories of recipients of personal data:

• Suppliers and service providers, including hosting and other technology and communication providers, analytics providers, CRM, system administration services, security consultants, support and customer service vendors, e-commerce and payment processors
• Our customers, who receive the results of feedback projects and personal data about participants as described above, as well as product delivery details for fulfilment by them where samples are provided as part of a feedback project
• Where you have consented to marketing cookies or for us to use your contact details for marketing purposes: advertising partners such as social media partners.
• HM Revenue and customers, regulators and other authorities who require reporting of processing activities in certain circumstances
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
• Auditors and professional advisers including lawyers, bankers, auditors and insurers.

7. International Transfers

Your data is stored by us and our processors in the UK, or the EEA, or in another country in accordance with the adequacy decisions granted by the UK government or European Commission, or where the transfer has been completed via an appropriate transfer mechanism, such as standard contractual clauses.

8. Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

9. Data Retention

We will only retain your personal data for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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

For example, we keep information we use to provide you with our Sourcerie Community services (including Identity and Contact Data) for as long as you are a member of our Community and for a period of 6 years after you end your membership or close your account (as applicable). This is necessary for us to be able to resolve any legal disputes that may arise.

10. Your data protection rights

You have rights under data protection laws in relation to your personal data (though please note that your rights may be limited under certain circumstances). For example, you may have the right to:

Request access to your personal data (commonly known as a ‘data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons, which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

• If you want us to establish the data’s accuracy.
• Where our use of the data is unlawful, but you do not want us to erase it.
• Where you need us to hold the data even if we no longer require it, as you need it to establish, exercise or defend legal claims.
• You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use, or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us using the details provided at the start of the policy.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.