PRIVACY POLICY

Introduction

Welcome to our privacy policy.

Dr Dilly Limited respects your privacy and is committed to protecting your personal data. This privacy policy 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 policy is provided in a layered format so you can click through to the specific areas set out below.

  1. IMPORTANT INFORMATION AND WHO WE ARE
  2. TYPES OF PERSONAL DATA WE COLLECT ABOUT YOU
  3. HOW IS YOUR PERSONAL DATA COLLECTED?
  4. HOW WE USE YOUR PERSONAL DATA
  5. DISCLOSURES OF YOUR PERSONAL DATA
  6. INTERNATIONAL TRANSFERS
  7. DATA SECURITY
  8. DATA RETENTION
  9. YOUR LEGAL RIGHTS
  10. CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES
  11. THIRD PARTY LINKS

1. IMPORTANT INFORMATION AND WHO WE ARE

1.1 Purpose of this Privacy policy

  1. This privacy policy gives you information about how Dr Dilly Limited collects and uses your personal data through your use of this website, including any data you may provide when you register with us, sign up to our newsletter, purchase a product or take part in a competition or interact with our website.
  2. This website is not intended for children and we do not knowingly collect data relating to children.
  3. It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

1.2 Controller

  1. DR DILLY LIMITED is the controller and responsible for your personal data (collectively referred to as (Company), (we), (us) or (our) in this privacy policy).
  2. If you have any questions about this privacy policy or our privacy practices, please contact support@drdilly.com.

1.3 You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator 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.

2. THE TYPES OF PERSONAL DATA WE COLLECT ABOUT YOU

2.1. Personal data means any information about an individual from which that person can be identified.

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

  • Identity Data includes first name, last name, any previous names, marital status, title, date of birth and gender.
  • Contact Data includes billing address, delivery address, email address and telephone numbers.
  • Financial Data includes bank account and payment card details.
  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
  • 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, device ID and other technology on the devices you use to access this website.
  • Profile Data includes your password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
  • Usage Data includes information about how you interact with and 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.

2.3. We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.

3. HOW IS YOUR PERSONAL DATA COLLECTED?

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

  1. Your interactions with us. You may give us your personal data by filling in online forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
    1. apply for our products or services
    2. create an account on our website
    3. subscribe to our service or publications
    4. enter a competition, promotion or survey; or
    5. give us feedback, or when you contact us via email or via our enquiry form
  2. 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.
  3. Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
    1. Technical Data is collected from the following parties:
      (A) analytics providers;
      (B) advertising networks; and
      (C) search information providers.
    2. Contact, Financial and Transaction Data is collected from providers of technical, payment and delivery services.

4. HOW WE USE YOUR PERSONAL DATA

Legal basis

4.1. The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

  1. Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
  2. Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
  3. Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
  4. Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

4.2. We have set out below, in a table format, a description of all the ways we plan to use the various categories of your personal data, and which of the legal bases we rely

Purpose/Use Type of data Legal basis
To register you as a new
customer
(a) Identity
(b) Contact
Performance of a contract with you

To process and deliver your
order including:

(a) Manage payments, fees and
charges

(b) Collect and recover money
owed to us

(a) Identity
(b) Contact
(c) Financial
(d) Transaction

(e) Marketing and
Communications

(a) Performance of a contract with you
(b) Necessary for our legitimate
interests (to recover debts due to us)

(c) To learn more about which products
are popular so our offering can be
enhanced.

To manage our relationship
with you which will include:
(a) Notifying you about changes
to our terms or privacy policy
(b) Dealing with your requests,
complaints and queries
(c) Asking you to leave a review
or take a survey.

(a) Identity
(b) Contact
(c) Profile
(d) Marketing and
Communications

(a) Performance of a contract with you
(b) Necessary to comply with a legal
obligation
(c) Necessary for our legitimate
interests (to keep our records updated
and to study how customers use our
products
(d) Consent

To enable you to partake in a
prize draw, competition or
complete a survey

(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and
Communications

(a) Performance of a contract with you
(b) Necessary for our legitimate
interests (to study how customers use
our products/services, to develop
them and grow our business)

To administer and protect our
business and this website
(including troubleshooting,
data analysis, testing, system
maintenance, support,
reporting and hosting of data)

(a) Identity
(b) Contact
(c) Technica

(a) Necessary for our legitimate
interests (for running our business,
provision of administration and IT
services, network security, to prevent
fraud and in the context of a business
reorganisation or group restructuring
exercise)
(b) Necessary to comply with a legal
obligation

To deliver relevant website
content and online
advertisements to you and
measure or understand the
effectiveness of the advertising
we serve to you

(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and
Communications
(f) Technical

(a) Necessary for our legitimate
interests (to study how customers use
our products/services, to develop
them, to grow our business and to
inform our marketing strategy)
(b) Consent

To use data analytics to
improve our website,
products/services, customer
relationships and experiences
and to measure the
effectiveness of our
communications and marketing

(a) Technical
(b) Usage

Necessary for our legitimate interests
(to define types of customers for our
products and services, to keep our
website updated and relevant, to
develop our business and to inform our
marketing strategy)

To send you relevant marketing
communications and make
personalised suggestions and
recommendations to you about
goods or services that may be of interest to you based on your
Profile Data

(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile

(f) Marketing and
Communications

(a) Consent, having obtained your prior
consent to receiving direct marketing
communications.
(b) Necessary for our legitimate
interests (to develop our products/services and grow our
business).

To carry out market research
through your voluntary
participation in surveys


Necessary for our legitimate interests
(to study how customers use our
products/services and to help us
improve and develop our products and
services).

 

Direct marketing

4.3. During the process on our website when your personal data is collected, you will be asked to indicate your preferences for receiving direct marketing communications from us via email, SMS, telephone or post.

4.4. You will receive marketing communications from us if you have requested information from us, signed up for offers or purchased goods or services from us and you have not opted out of receiving that marketing. 

4.5. We may also analyse your Identity, Contact, Technical, Usage and Profile Data to form a view which products, services and offers may be of interest to you so that we can then send you relevant marketing communications.

Third-party marketing 

4.6. We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out of marketing 

4.7. You can ask to stop sending you marketing communications at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links within any marketing communication sent to you or by contacting us at support@drdilly.com.

4.8. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

4.9. If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes, for example (but not limited to) relating to order confirmations for a product, updates to our Terms and Conditions, or checking that your contact details are correct.

Cookies 

4.10. When you visit the Site, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Site,

we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site. We refer to this automatically collected information as “Device Information”. We collect Device Information using the following technologies:

- “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.

 - “Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps. - “Web beacons”, “tags”, and “pixels” are electronic files used to record information about how you browse the Site."

5. DISCLOSURES OF YOUR PERSONAL DATA 

5.1. We may share your personal data where necessary with the parties set out below for the purposes set out in the table Purposes for which we will use your personal data above.

(a) Third party Payment Providers; 

(b) Third party partners such as comment sharing facilitators;

(c) Advertising partners;

(d) 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.

5.2. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

5.3. We are happy to disclose to you on request the identity of the third parties with whom we work. If a third party such as a comment sharing facilitator or an organiser of a promotion asks you to register then that party is a separate data controller solely responsible for handling your personal data.

6. INTERNATIONAL TRANSFERS

6.1. We do not transfer your personal data outside the UK. 

7. DATA SECURITY

7.1. 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.

7.2. 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.

8. DATA RETENTION

8.1. How long will you use my personal data for?

(a) We will only retain your personal data for as long as reasonably necessary to fulfil 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.

(b) 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.

(c) By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for at least six years after they cease being customers for tax purposes].

(d) In some circumstances you can ask us to delete your data: see [paragraph 9] below for further information.

(e) In some circumstances we will anonymise your personal data (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.

9. YOUR LEGAL RIGHTS

9.1. You have a number of rights under data protection laws in relation to your personal data. You have the right to:

(a) 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. 

(b) 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.

(c) Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove 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.

(d) Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.

(e) You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes (see OPTING OUT OF MARKETING in paragraph 4 for details of how to object to receiving direct marketing communications).

(f) 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.

(g) Withdraw consent at any time where we are relying on consent to process your personal data (see the table in section 4 for details of when we rely on your consent as the legal basis for using your 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.

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

(a) If you want us to establish the data's accuracy;

(b) Where our use of the data is unlawful but you do not want us to erase it;

(c) 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; or

(d) You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

9.3. If you wish to exercise any of the rights set out above, please contact us at support@drdilly.com.

No fee usually required

9.4. 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 

9.5. 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

9.6. 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.

10. CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

10.1. We keep our privacy policy under regular review. This version was last updated on 20th June 2025.

10.2. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address.

11. THIRD-PARTY LINKS

11.1. This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.