Privacy Policy

Last Updated: 10th June 2024

Firefly Friends is aware of its obligations under the General Data Protection Regulation (GDPR) and is committed to processing your data securely and transparently. This privacy notice sets out, in line with GDPR, the types of data that we hold. It also sets out how we use that information, how long we keep it for and other relevant information about your data.

1. Scope

This notice applies to individuals including (but not limited to) customers, suppliers, business contacts, client, and any other individuals we have a direct or indirect relationship with. We have a separate Privacy Notice for our employees, contractors, and agency workers.

2. Data Controller Details

The Company is a data controller, meaning that it determines the processes to be used when using your personal data. Our contact details are as follows:

Firefly Friends Ltd
19c Ballinderry Road
Lisburn
BT28 2SA
E: hello@fireflyfriends.com
Tel: 028 9267 8879
Company Number: NI626626
VAT Number: GB 202106872

If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.
It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at hello@fireflyfriends.com

3. How we use your personal data

We will only use your personal data when legally permitted. The most common uses of your personal data are:
1. Where we need to perform the contract between us.
2. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
3. Where we need to comply with a legal or regulatory obligation.
Generally, we do not rely on consent as a legal ground for processing your personal data, other than in relation to sending marketing communications to you via email. You have the right to withdraw consent to marketing at any time by emailing us at hello@fireflyfriends.com

4. Purposes for Processing your Personal Data

Set out below is a description of the ways we intend to use your personal data and the legal grounds on which we will process such data. We have also explained what our legitimate interests are where relevant.
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 email us at hello@fireflyfriends.com 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.

Purpose/Activity

Type of Data

Lawful Basis for Processing

To register you as a new customer.

(a) Identity

(b) Contact

Performance of a contract with you.

To process and deliver your quote or 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 owed to us.

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy.

(b) 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/services.

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 our site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).

(a) Identity

(b) Contact

(c) Technical

(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 content and advertisements to you and measure and understand the effectiveness of our advertising.

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

(g) Photo

(h) Video

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.

Where the photos / video is of Children for purposed of case studies / case histories. Consent will be gained from the parent.

To use data and data analytics to improve our website, to develop products/service, to improve products/services, marketing, customer relationships and experiences.

(a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Photo

(f) Video

(g) Bio and Health data

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

Where the photos / video are of Children for purposed of case studies / case histories, consent will be gained from the parent.

Where the bio/health data of Children is collected for the purposes of product / service development and improvement, consent will be gained from the parent.

To make suggestions and recommendations to you about products or services that may be of interest to you.

(a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

Necessary for our legitimate interests to develop our products/services and grow our business.

5. Marketing Communications

You will receive marketing communications from us if you have:
1. Requested information from us or purchased goods or services from us; or
2. If you provided us with your details and ticked the box at the point of entry of your details for us to send you marketing communications.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes. You can ask us or third parties to stop sending you marketing messages at any time by emailing us at hello@fireflyfriends.com at any time.

Where you opt out of receiving our marketing communications, 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.

6. Cookies

To collect certain data described above, we use cookie technology on our website.

Cookies are small pieces of information that websites send to a visitor’s computer and are saved to your device to allow that website to store your interactions and recognise you when you visit. This allows us to provide you with a tailored experience when using the Firefly Friends website. Cookies are either session-based (they only last until you close your internet browser) or persistent (they remain on your computer for a specific amount of time or until you delete them). For example, Firefly Friends uses persistent cookies to remember when you return to our website or to track your activities when using our website. We may associate personal data with a cookie in those instances.

During your visit to the Firefly website, you may notice some cookies that are not related to us. These may include Facebook, Google, and YouTube. This Privacy Policy does not apply to these features. Your interactions with these features are governed by the privacy policy and other policies of the companies providing them. You can opt out these third-party cookies by changing your cookie preferences.
For more information, please see our Cookie Policy.

7. Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table above:
• Service providers who provide IT and system administration services.
• Professional advisers including lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities based in the United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances.
• Third parties to whom we sell, transfer, or merge parts of our business or our assets.

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

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 such data. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

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 necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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 requirements.

By law we must keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes. You can request our data retention table from hello@fireflyfriends.com

In some circumstances you can ask us to delete your data: see below for further information.

In some circumstances we may 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.

10. Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:


• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.

You can see more about these rights at: https: //ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

If you wish to exercise any of the rights set out above, please email us at hello@fireflyfriends.com.

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 may refuse to comply with your request in these circumstances.

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.

We try to respond to all legitimate requests within one month.

Occasionally it may take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.

11. Changes to our Policy

We may change this Policy from time to time. If we do, we will post the revised version here and change the “Effective Date” listed at the top of this Statement before such changes take effect. If we make changes to this Policy that impacts the purposes of processing your personal data, we will also inform you by email.

12. Further Information and Complaints

You may request further information about the way we manage your Personal Data or lodge a complaint by contacting us using the details above.

We will deal with any complain by investigating it and providing a response to you within a reasonable time, provided that we have all necessary information and have completed, and investigation required. In some cases, we may need to ask you to put your complaint in writing so that we are sure that we understand it and may also need to ask you for further information or to verify your identity. In cases where further information, assessment or investigation is required, we will seek to agree an alternative timeframe with you.

If you are dissatisfied with the outcome, please contact us. Alternatively, you may contact our Data Protection Officer at data.privacy@sunrisemedical.eu or take your compliant to the Information Commissioner’s Office via their website at https://ico.org.uk/your-data-matters/raising-concerns/ or write to them at:


Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF