Last updated September 2023
We may also provide you with additional information about how we process your personal data, when we collect personal data and where we feel it would be helpful to provide relevant and timely information.
1. Our contact details
- Name: HiPP UK Ltd.
- Address: The Annexe, Hurst Grove, Sandford Lane, Hurst, Reading, Berkshire, RG10 OSQ
- Phone Number: 0800 2984477
- E-mail: email@example.com
- Website: www.hipp.co.uk
- Contact form: https://www.hipp.co.uk/hipp-organic-story/contact/customer-service/
2. The types of personal data we collect and how we collect it
The type of personal data we collect
The personal data we collect about you depends on the particular activities carried out through our website. To interact with certain services we offer, you will need to share some personal data in order for us to operate that service. In other circumstances, you will be able to choose if you want to share your personal data and let us use it. Where that is the case, we will tell you and give you the choice before you give the personal data to us. We will also tell you whether declining to share that personal data will have any effect on your use of our website or any services we offer.
We may collect the following personal data about you:
- Your title, first name and surname, gender, address and contact information (including email address and telephone number)
- Any delivery addresses you nominate for your order(s)
- Your billing address
- Your account details
- Your payment details
- Information you provide in your reviews of us or survey responses
- Your activities on, and use of, our website
- Your IP address
- Information from cookies, including information on the devices you may use to make a purchase
- Your contact history and purchase history
- Reasons for cancelling or returning your order
- Personal information you put on social media, including your social media handles
How we collect personal data
We receive data in two ways – either:
- Directly when you share information with us, such as when you register to use the HiPP BabyClub, contact us (including via email), send us feedback, or purchase products from the HiPP online shop; or
- Indirectly while you use our website, such as your browsing activity.
Under data protection law, we can only use your personal data if we have a proper reason for doing so. For example:
- Where you have given consent;
- To comply with legal and regulatory obligations;
- For the performance of a contract with you or to take steps at your request before entering into a contract; or
- For our legitimate interests or those of a third party.
A legitimate interest is where we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests. Where we use your personal data based on our legitimate interest, we will carry out an assessment to balance our interests against your own.
For further details of the personal data we collect and use in specific circumstances, and why, please see the service-specific sections of this policy:
- Log data
- Cookies and tracking technologies
- Contact form
- HiPP BabyClub
- HiPP Shop
- Healthcare professionals
- Product reviews
- Social media
- HiPP Buddies App
- HiPP Ambassador Programme
- User-generated content
HiPP may also convert your personal data into anonymous data and use it (normally on an aggregated statistical basis) for customer and market research and analysis, for example to improve our website and products, to analyse trends and to assess the success of advertising campaigns. Aggregated personal information does not personally identify you or any other use of the HiPP website.
Unless otherwise stated in individual cases, the legal basis for the processing of your data is that it is necessary for the performance of our contract with you or a pre-contractual measure.
We may use your personal data to send you updates about our products and services, including benefits, promotions, discounts, and competitions.
The legal basis for sending such updates is your consent. You have the right to opt out of receiving marketing communications at any time by:
- Using the ‘unsubscribe’ link in emails; or
- Sending an email to firstname.lastname@example.org.
4. Sharing your personal data
We may share your personal data with third parties where required by law, where it is necessary for fulfilment of a contract with you (e.g. to deliver our products), or where we have another legitimate interest in doing so. These organisations act as data processors and are strictly controlled in how they may/may not use your data and HiPP Organic remains responsible for the protection of your data.
Such selected third parties include:
- Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
- E-commerce partners, e-commerce payment processors, e-payment providers and e-commerce product fulfilment providers for the performance of any contract we enter into with them or you;
- IT providers, including those who host our website and provide us with email services;
- Data analytic companies to enable us to better understand how you use our site and shop and make our online presence more appealing when you visit;
- Networks that require the data to select and serve relevant targeted adverts to you and other target consumers – this may include personalising the advertising content you (and other target consumers) see on social media, based on the details given by you;
- If you enter a promotion or competition involving third parties, those third parties need to update you on whether you have won a prize or for other fulfilment needs. When you enter a promotion, you are subject to any official rules of that promotion which may contain additional information about the specific privacy practices associated with the promotion;
- If we are under a duty to disclose or share your personal data in order to comply with any legal obligation or enforce or apply our website terms and conditions of use and other agreements or to protect the rights, property or safety of HiPP Organic, our customers or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction; and
- In order to provide relevant customer care. Please note that the personal data processed relating to customer care is held in a separate database and is not used for marketing purposes.
We, or the third parties mentioned above, may also share your personal data with our professional advisors.
This may mean that your data will be transferred outside the UK to:
- Our/third-party companies that are located within the EU, in which the same standards of data protection will apply to your data; and
- Our/third-party companies that are located within the USA (see ‘Product reviews’, "Social media" and "User-generated content" for more details).
5. Data retention
We will retain your personal data only for as long as we need it for HiPP's legitimate interest in accordance with applicable law or to perform a service at your request or meet a legal requirement.
At the end of the retention period, we will take steps to delete your personal data or hold it in a form that no longer identifies you.
Further details on this are available on request.
6. Your right to withdraw consent
If you have provided us with consent to use your personal data, you have the right to withdraw that consent at any time.
You may withdraw consent by:
- Sending an email to email@example.com;
- In relation to cookie consent, changing the settings on the cookie banner via this link; or
- In relation to marketing, following the unsubscribe option offered in the communication.
Withdrawing consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn.
7. Your data protection rights
Under data protection law, your rights include:
- Your right of access - You have the right to ask us for copies of your personal data.
- Your right to rectification - You have the right to ask us to rectify personal data you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
- Your right to erasure - You have the right to ask us to erase your personal data in certain circumstances.
- Your right to restriction of processing - You have the right to ask us to restrict the processing of your personal data in certain circumstances.
- Your right to object to processing - You have the right to object to the processing of your personal data in certain circumstances.
- Your right to data portability - You have the right to ask that we transfer the personal data you gave us to another organisation, or to you, in certain circumstances.
To exercise these rights, please contact us.
You will not have to pay a fee to exercise the other above rights. However, we may refuse to comply with a request or charge a reasonable fee if a request for access is clearly unfounded or excessive.
8. Data security
We will endeavour to take all reasonable steps to protect your personal information. However, we cannot guarantee the security of any information you disclose online. You accept the inherent security risks of providing information and dealing online over the internet and you will not hold us responsible for any breach of security unless due to our negligence or willful default.
9. How to complain
If you have any concerns about our use of your personal data, you can make a complaint to us at HiPP UK Ltd., The Annexe, Hurst Grove, Sandford Lane, Hurst, Reading, Berkshire, RG10 OSQ.
You can also complain to the Information Commissioner’s Office (ICO) if you are unhappy with how we have used your data:
Information Commissioner’s Office
Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk
Examples of the personal data we collect
1. Data we receive through your use of our website
Some data is automatically generated when you visit our website.
1.1 Log data
When you visit our website, we collect automatically occurring data that your browser transmits to our server (“log data”). Every time you access a page on our website and every time a file is called up, data about this process is stored in a log file on our server. This log data includes:
- The previous page from which the new page or file was requested
- The address of the accessed file or page
- The date and time of the request, the success of the request and the server load at the time of the request
- The transmitted data volume
- The IP address assigned to you by your provider
- If you log in with a user account, the login information for the corresponding web service
- The device used (mobile, desktop etc.) and operating system; and
- The browser software used.
This log data is evaluated exclusively for the analysis of technical faults and possible attacks on our website. In addition, log data can be evaluated anonymously for statistical purposes.
We delete log data after 30 days in order to be able to investigate appropriately in the event of technical faults or possible attacks on our website and, if necessary, to be able to report to supervisory authorities and security bodies.
We process log data on the basis of our legitimate interests in:
- Maintaining, improving and protecting the security and functionality of the website;
- Preventing misuse and detecting criminal activity which may be harmful to you and/or us; and/or
- Statistical evaluation to help us understand our customer base.
1.2 Cookies and tracking technologies
Some of these cookies and technologies are essential, meaning they are mandatory to provide the core functionality of our digital offerings. We are not required to obtain your consent for these; we have a legitimate interest in being as efficient as we can to deliver the best service to you.
For non-mandatory tracking, we use consent management (our “cookie banner”), to offer you the opportunity to decide which cookies and tracking technologies you consent to. You can update your preferences or withdraw your consent at any time via the cookie banner.
2. Individual services
2.1 Contact form
Where you use our website contact form, we collect your first name and last name as well as your e-mail address so that we can contact you to answer your questions. If you give us your address or telephone number, we will be happy to write to you or call you back to answer your question.
Data you provide via the contact form will only be used to answer your request - it will not be used for sales or for any other advertising purpose.
We process contact form data to:
- Perform our contract with you or to take steps before entering into a contact; and/or
- Based on our legitimate interest to answer enquiries from our customers efficiently.
The contact form includes the option to consent to us saving your data, in which case we will store your information for as long as is necessary to answer your enquiry. You can withdraw your consent at any time.
2.2 HiPP BabyClub
You can join the HiPP BabyClub on our website to receive benefits such as product samples, competitions and discounts. You can see an up-to-date overview of all the HiPP BabyClub benefits here.
Legal basis of processing for HiPP BabyClub
Registering for the HiPP BabyClub
When you register for the HiPP BabyClub for the first time, you’ll be asked to create a profile for yourself and your baby. We collect:
- Your first and last name;
- Your email address;
- Your postal address; and
- A password of your choice.
We also ask for details about your little one to personalise emails and packaging to make the information provided relevant to you and to send you product samples based on their age. This includes your child’s:
- First and last name; and
- Date of birth.
You may also provide additional profile information, such as a profile photo. Please see “Registration” in our Terms & Conditions for more information.
Please make sure that the data in your profile, especially your email and postal address, is correct. If you need to update your information at any time, you can do this by logging into your BabyClub account and going to "My profile".
As a BabyClub member, you have the opportunity to take part in competitions. Where you participate, please note our instructions for use and the terms and conditions, which you can find on the respective competition page.
Prizes may be provided by our selected partner companies. With your consent, we may share your personal data with those partners, in order to redeem or send the prize. This may include information which is saved in your BabyClub profile, e.g. your name, your e-mail address or postal address.
As a BabyClub member, you have the opportunity to take part in product testing. Where you choose to participate, we collect personal data which usually includes your name, email and postal address and, in individual cases, a telephone number. This data is only used to carry out and process the results of the product test.
BabyClub newsletter and emails
As a BabyClub member, you will receive a monthly newsletter by e-mail, with information and tips for you and your baby. You will also receive emails containing information about new BabyClub partners and products. You can unsubscribe from HiPP BabyClub emails at any time. The easiest way to do this is via the link in the email or via your profile if you are registered in the HiPP BabyClub – simply sign in to your BabyClub account, go to 'my profile' and select 'my communication settings', then untick the options you wish to unsubscribe from. Remember to save any changes you make.
We are always striving to improve our BabyClub emails. This includes evaluating the data of our sends. For example, how many emails were sent in total, how many of them were opened and how often the links embedded in the emails were clicked on in total. As part of this evaluation, we can also see email data about an individual recipient’s behaviour, such as who opened an email and clicked on a link.
If you would like to unsubscribe from the HiPP BabyClub, please contact our customer service or click “unsubscribe” on the relevant email communication(s).
2.3 HiPP Shop
In the HiPP Shop, you can easily order our products and have them delivered to your home. You can place an order via your customer account, but you can also order goods without opening a customer account. If you have any questions about the Shop and your customer account, please read our FAQs or contact us.
The legal basis for use of your personal data in connection with our Shop and orders you place is for us to perform our contract with you or to take steps before entering into a contract.
To process your order, we require your contact details, including:
- First name and last name;
- Email address;
- Telephone number;
- Nominated delivery address; and
- Billing address.
You will also have the option to provide your baby’s name.
We will use your e-mail address to send you an order confirmation and verify your identity when creating an account.
In the customer account, you can choose whether to save your personal data for future order processes. You can update your details at any time by changing your account settings or contacting us. You can delete your customer account at any time by following the steps in our FAQs.
We also collect your payment data as part of the ordering process. This information will be shared with our fulfilment partner, Promotional Handling Limited, for the purposes of completing your order but they will not contact you regarding any other services. Promotional Handling Limited can be contacted on 0800 012 9079 or at firstname.lastname@example.org.
Where you use a discount in our Shop, such as voucher codes, we collect statistical data that provides us with information about the effectiveness of certain campaigns. For example, we evaluate how many voucher codes were issued and how many of these voucher codes were actually redeemed. This does not result in any personal data – no reference is made to specific persons.
2.4 Healthcare professionals
This section applies to users of using our dedicated UK healthcare professionals’ site.
We only collect personal data from you, as a healthcare professional, for the purposes of answering your queries submitted via our contact us page. To submit an enquiry, you must provide your first name, last name and email address. Optionally, you may also provide your postal address and/or phone number.
In addition, you are given the option to consent to us saving your data, in which case we will store your information for as long as is necessary to answer your enquiry. You can withdraw your consent at any time.
2.5 Product reviews
We may ask you to rate and review products you have purchased from us. On our website, you can also view product reviews from other customers and vote whether other customer’s reviews are helpful or not.
If you submit a product review, we (i) verify the authenticity of your review as described below and (ii) may use the information you provide in the review to advertise our products online thereafter.
We may use your review in online advertising for our products, for example on the HiPP website and social media accounts and also in our sales partners’ online media for the product reviewed. The following data is displayed in each case:
- Your review (stars, title, text);
- Any images you have taken of the product;
- The date of your review;
- Where the review originally appeared;
- The nickname you provided, if any; and
- How many of your own reviews and how many votes of other users’ reviews you have already submitted.
Your email address will not be displayed.
We use Bazaarvoice Inc. (10901 Stonelake Blvd., Austin, Texas 78759, USA) as a service provider for the collection, management and evaluation of product reviews, as part of order processing. Bazaarvoice also processes your data in the USA. There is currently no decision by the EU Commission that the USA generally offers an adequate level of data protection. However, the EU Commission has published Standard Contractual Clauses as a means of ensuring adequate protection when transferring data to non-European countries. When transferring data to Bazaarvoice, we rely on these Standard Contractual Clauses. We will provide you with a copy of these Standard Contractual Clauses upon request.
To ensure that reviews we publish originate from genuine consumers of the relevant product, we and Bazaarvoice process your e-mail address, the IP address of your end device and various other information about your end device, i.e. a so-called “fingerprint" of your end device. This data is processed in accordance with the Bazaarvoice Authenticity Policy.
The data processing in relation to reviews is based on our legitimate interest in collecting and displaying legally compliant product reviews on our website. You can object to this data processing at any time.
2.6 Social media
We also offer extensive support and the opportunity to stay in touch with us via our social media pages:
Where you contact us via one of these social media channels, we will forward the enquiry to the relevant HiPP department. The data will only be used to respond to your message and will not be passed on to third parties.
- Meta (Facebook and Instagram): https://www.facebook.com/policy.php
- Twitter: https://twitter.com/en/privacy
- Google: https://policies.google.com/privacy
We have no influence on the type, scope and processing of this data. This also applies to images and videos uploaded to social media.
The following platform providers are US companies:
- Facebook Inc. (1601 S. California Ave, Palo Alto, CA 94304, USA)
- Google LLC (1600 Amphitheater Parkway, Mountain View, CA 94043, USA)
- X Corp. (1355 Market Street, Suite 900, San Francisco, CA 94103, USA)
2.7 HiPP Buddies App
In the HiPP Buddies App, children and parents get to engage with our HiPPiS animals in various learning games and three exciting stories. The app is set up in an intuitive and user-friendly way and offers adventure stories that parents can read out loud as well as eight different learning games. These games are a fun and playful way to train kids’ cognitive skills. Whether it’s learning numbers or colours, guessing animal sounds or solving puzzles – the games are fully suitable for toddlers and children with five levels, each increasing in difficulty. All information about the HiPP Buddies App can be found here.
The legal basis for the data processing involved herein is Art. 6(1)(b) GDPR (contract performance and pre-contractual measures).
With your consent, we use Google Analytics (including Google Analytics for Firebase) to improve our app, an analytics service of Google Ireland Limited (Gordon House, Barrow St., Dublin 4, D04 E5W5, Ireland) and Google LLC (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA), collectively “Google”. Google Analytics uses “cookies”, which are text files placed on your smartphone to help the website analyse how users use the app.
As a rule, the information generated by Google Analytics about your use of the app is transmitted to a Google server in the United States and stored there for up to 14 months. Within the app, IP anonymisation has been activated so that the IP address of Google users within Member States of the European Union or in other Contracting States to the Agreement on the European Economic Area is shortened and made anonymous. Only in exceptional cases is the full IP address transmitted to a Google server in the USA and shortened there.
There is currently no decision by the EU Commission as to whether the USA offers a broadly adequate level of data protection. However, the EU Commission has published standard contractual clauses as a means of ensuring adequate protection when data is transferred to non-EU countries. For data transfers to the USA, Google relies on these standard contractual clauses and additional measures designed to protect your data. We can provide you with a copy of these standard contractual clauses upon request. Further information on data protection at Google can be found at https://policies.google.com/privacy?hl=en. You can find more information specifically on data collection by Google Analytics for Firebase here: https://support.google.com/firebase/answer/6318039?hl=en.
On our behalf, Google will use the information collected to evaluate your use of the app, compile reports on activities and provide us with other related services. The IP address transmitted by your smartphone as part of Google Analytics is not combined with other data from Google.
The legal basis for processing your data in connection with Google Analytics is Art. 6(1)(a) GDPR in conjunction with your consent. You can revoke your consent at any time with effect for the future by going to the menu item “Settings”. The withdrawal of consent does not affect the lawfulness of the data processing carried out from the time you gave consent until you withdrew it.
If you allow notifications to your smartphone through the HiPP Buddies App, we use the service Firebase Cloud Messaging, also from Google, for these notifications. With Firebase Cloud Messaging, your IP address and the messages sent to your smartphone will also be transmitted to Google servers in the USA, where they are only temporarily stored for the purpose of sending the message.
As already mentioned above, there is currently no decision of the EU Commission as to whether the USA generally offers an adequate level of data protection. However, the EU Commission has published standard contractual clauses as a means of ensuring adequate protection when data is transferred to non-EU countries. For data transfers to the USA, Google relies on these standard contractual clauses and additional measures designed to protect your data. We can provide you with a copy of these standard contractual clauses upon request. Further information on data protection at Google can be found at https://policies.google.com/privacy?hl=en. More information specifically on data collection by Google Firebase can be found at https://firebase.google.com/support/privacy?hl=en.
The legal basis for the processing of data associated with notifications to your smartphone is Art. 6(1)(b) GDPR (contract performance and pre-contractual measures). You can terminate this data processing at any time by deactivating the notifications from our HiPP Buddies App in your smartphone operating system.
2.8 HiPP Ambassador Programme
To unsubscribe from our Brand Ambassador Programme emails, click on the link at the bottom of one of the emails you've received from us. Please note: If you unsubscribe from the Brand Ambassador Programme emails, you'll stop receiving all email communications from HiPP Organic. If you're a BabyClub member and wish to remain subscribed to our BabyClub emails, please email us at email@example.com.
If you've signed up for our Brand Ambassador Programme and no longer wish to receive marketing communications via post or Instagram, please email us at firstname.lastname@example.org.
Please note: In some of the postal packages, there will be material and/or products from some of our third-party BabyClub Partners. Your personal data will not be shared with these brands.
2.9 User-generated content
We may reach out to social media users to seek their permission to feature our favourite content on our website, social channels and promotional materials.
We use Bazaarvoice, Inc. to collect, manage and evaluate user-generated content.
If you choose to allow us to use your words, pictures, images, video, post, survey answers, data, information or any other content you have put together (‘Content’) by replying to us and confirming you have read Bazaarvoice, Inc.’s Terms and Conditions, you agree to these Terms and Conditions, as well as the Instagram, Facebook, Twitter, Pinterest or other social channel terms and conditions of use (as applicable) and you certify that you are least 18 years of age.