OUR POLICIES

The organisation is controlled by a board of directors with offices based in Swansea, Leeds and Cheltenham. The main activity carried out by Ickle Bubba is the selling of baby and nursery products throughout the year.

Labour supplied to Ickle Bubba is in the implementation of its operations carried out in the locations mentioned above.

Ickle Bubba acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions in section 54(1) of the Modern Slavery Act 2015. We understand that this requires an ongoing review of both its internal practices in relation to its labour force and supply chains.

We do not enter business with any other organisation, in the United Kingdom or abroad, which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labour.

No labour provided to Ickle Bubba in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. we strictly adhere to the minimum standards required in relation to its responsibilities under relevant employment legislation in the United Kingdom.

We have a global network of suppliers from whom we source our production with a majority being based in China, Poland and the EU. Ickle bubba oversees quality control on a global basis by working with our suppliers to improve quality control measures currently in place to ensure a robust quality control programme.

During the reporting period covered by this statement, the COVID-19 pandemic had taken hold. For several months, the UK was placed into lockdown to stem the spread of COVID-19. This created several challenges for the Organisation, as it did for others across the nation.

Ickle Bubba welcomes the UK Government’s decision, as confirmed in April 2020, to allow for a delay of up to 6 months in the publication of modern slavery statements without the risk of facing penalty.

We understand that the COVID-19 pandemic did +not adjust the risk of modern slavery to a level above that which existed before the pandemic, which is as set out under ‘POTENTIAL EXPOSURE’ above.

During the pandemic, our employees still had access to the grievance procedure to raise any concerns that they may have had.

In line with emergency legislation passed by the Government, employees have been paid Statutory Sick Pay during periods of self-isolation where it has not been possible to agree a temporary period of homeworking.

Ickle Bubba’s modern slavery risks were subject to the same monitoring procedures during the pandemic as at all other times.

Ickle Bubba carries out due diligence processes in relation to ensuring slavery and/or human trafficking does not take place in our organisation or supply chains, including conducting a review of the controls of its suppliers.

We have not, to our knowledge, conducted any business with another organisation which has been found to have involved itself with modern slavery.

In accordance with section 54(4) of the Modern Slavery Act 2015,Ickle Bubba's taken the following steps to ensure that modern slavery is not taking place:

Ickle Bubba has set the following key performance indicators to measure its effectiveness in ensuring modern slavery is not taking place in the Organisation or its supply chains.

Implementing an on-boarding system and on-going auditing process

All new and current supplier are required to have and up to date social and ethical compliance audit on file prior to any purchase order being raised. Any attempt to raise a purchase order without and audit report on file is automatically blocked.

Our ethical and social compliance is fully implemented and on-going with suppliers submitting corrective action plans and SMETA reports for approval to our compliance officer.

Training our employees and encouraging our suppliers to conduct training.

All employee sat Ickle bubba have been issued with the social compliance policy that we send out to our suppliers on an annual basis. We encourage our suppliers to complete regular training within their own organisations.

We have a fire but firm approach to ensure that our key values, standards and expectations are met within a timely manner. If any member of our supply chain is unable or willing to address issues, we believe to be critical we reserve the right to terminate arrangement in accordance with contractual rights to do so.

Our Technical team here at Ickle Bubba are in regular contact with our supplier to guide and assist them through any improvements need as part of their corrective action plans. All Audits received are reviewed by trained members of the technical team to assess whether results meet the standards we expect.

This statement is made in pursuance of Section 54(1) of the Modern Slavery Act 2015 and will be reviewed for each financial year.

Date of approval: 25th Aug 2021

Signed:A Beasley

Print name:

Job Title: Product Director

Date:25th Aug 2021

To help us to get a complete view of our customer journey, we use integrations with Google Analytics - seamlessly connecting sales, marketing and advertising data. This will allow us to take action to engage with customers at the right moment and open up new ways to understand how customers engage with our brand and how marketing programs perform. Google Analytics involves automated decision making, including profiling.

We make use of the Google Demographics and Interest sections which provide us with information including overview reports and specific information on age, gender and interest categories based on behaviour patterns of our customers derived from their activity across all Google platforms. The significance of profiling is that your behaviours are being measured and eventually predicted by the models that they help to create and refine. In real terms the consequences are positive, helping us to ensure that you receive content that is relevant to you and, we hope, of interest.

The insights provided by Google Analytics and Google Demographics allow us to better understand who our users are and to understand the factors that influence whether a user will make a purchase or not.

The kind of aggregated information that Google provides to us includes:

• traffic source data or information about where website users originate whether it is organic traffic, paid search traffic, or display traffic.
• content data or information about your behaviour on our website including the URLs of pages that you look at, and how you interact with page content.

No personal information is passed to or from Google, it utilises information from your devices you use as an internet user and the cookies provided when you visit a website

Due to the nature of the Google Analytics service, the information we are provided by Google is also used by that company to inform its services to us and other business users

To read more about Google’s privacy policy, please click this link:  https://policies.google.com/privacy/update

Google data is derived from your use of our website. Note also that Google is located in the US and records will be held there however Google publicly promotes the fact that it subscribes to Privacy Shield in the US which provides data protection similar to Australian law.

Our marketing activity is solely, under legitimate interest directed towards promoting sales of our own goods, raising awareness of our brand and any offers we are promoting from time to time.

Marketing records include:

• your name
• gender
• your contact details
• your expectancy date
• details of previous transactions – purchases, returns, opt-in consents, payment methods, customer account number, promotion code number, entries into competitions
• browsing data, which includes pages & products you have viewed as well as products you have added to your basket
• IP address
• device ID

You should be aware that we have the functionality on our website to make video recordings of your sessions, showing us strike for strike how you used our website in real time.

This does not include any record of your payment card data, or any personal data that can identify you personally

Some of the data we hold is derived from your activity on our website, this includes:

• source data
• key words
• clicks on adverts
• search history

We share your information with our core service providers and third-party platforms as required for our business to function; for example, picking, packaging and processing orders, fulfilling deliveries, customer support, fraud detection, credit risk reduction checks, IT systems support, and internal audits. This sole purpose of this is to serve our customer better, more effectively and more efficiently.

Your information may be processed by a third party in order to maintain the functionality of our Site and database.

We also use services offered by Google, Facebook/ Instagram social media platforms as well as Affiliate marketing partners to better tailor our marketing communications and for targeted advertising – we do this using the cookies derived from your visit to our website, and is anonymous data.

We receive insights from Facebook about the effectiveness of our advertising campaigns which you experience on our Site and social channels, which helps to better target our advertising.

You can read further information on Facebook’s privacy policy by clicking this link: https://www.facebook.com/full_data_use_policy

Competitions: From time to time we run competitions through our website, with no purchase necessary for you to enter. We collaborate with like-minded companies to create a prize we feel would be beneficial to you – each of these competitions will have unique terms and conditions relating to that competition, and we will ask your consent if you wish your information to be shared with this third party, when you can choose to opt-in or opt out as requested.

All of our marketing activity, including Google services is undertaken in our legitimate business interests in promoting and selling our products.

You can opt-in or opt-out of marketing activity at any time you wish:

• Click the “unsubscribe” link in any marketing e-mail communication that we send you
• Alternatively use our “Contact us” page to request this here
• You can manage your preferences and consent of our cookies through our page, or through the settings on your device.

Every external company we work with has a contract with us which clearly sets out our expectations and requirements in handling personal information and obligates them to meet these standards and those contained in the GDPR.

We do not seek to collect sensitive personal information (i.e. information relating to race or ethnic origin, political opinions, religious or other beliefs, trade union membership, physical or mental health, sexual orientation or criminal records) - We ask that you do not provide such information to us.

We also process the purchase of retail products through our website so that you can view and buy our products online. The sale process requires information from customers which is used to fulfil the contract of sale, taking payment and arranging delivery of the goods to the correct address, handling returns, compliments and complaints.

To process a sales order, we collect information directly from you, including:

• your name
• delivery address
• billing address where different from delivery address
• your e-mail address
• telephone number
• payment card details (which are held in encrypted form at all times)
• details of the size, colour and type of product you have selected.

We have no need to share this information with any third parties but we do pass your name and address details to our selected couriers so that they can deliver the parcel.

Ickle Bubba pay all VAT and excise Duty on all orders.

If we are legally obliged to share any of your data with a 3rd party then we are obliged to comply with that request – such as but not exclusive to:

With any public authority or law enforcement agency (if they ask for it).

To comply with law or regulations, or for possible legal proceedings.

If you give us personal information that's wrong or we find out (or think) you're responsible for fraud. In these circumstances we might share your information with third parties such as law enforcement agencies, credit reference agencies and other affected third parties.

If one of our partners who are processing information for us are compelled to do so by law.

If there's an emergency and we think you or other people are at risk.

When you place an order through any marketplace (eg. Amazon or Ebay, but not exclusive to) for any of our products, we are sent your order securely from these marketplaces so we can process your order – this includes all data as above, with the exception of your payment details, as this is processed through Amazon or eBay.

Details of Amazon privacy policy can be found here: www.amazon.co.uk/gp/help/customer/display.html/ref=footer_privacy?ie=UTF8&nodeId=201909010

Details of eBay privacy policy can be found here:  https://pages.ebay.co.uk/help/policies/privacy-policy.html

In addition to placing an order on the Ickle Bubba website, we will also collect selected and only relevant information when:

• you create an account on our website
• subscribe to our e-mail marketing list
• fill in forms, such as to leave feedback, contact our customer services team, enter a competition, respond to a survey or enter details for your warranty

Your information may be processed by our staff to the extent necessary to fulfil your order. By submitting your personal information to us, you agree to the transfer of your personal information, its storage and processing.

We will keep the data which we collect from you on a secure server. Any information you give us relating to credit card details is handled by a PCI DSS compliant third party and encrypted using secure server technology. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access

Where you have set up a password to access certain parts of this website, you are responsible for keeping this password confidential. We ask that you do not share a password with anyone, and we do not have access to this password.

Klarna - In order to be able to offer you Klarna’s payment options, certain aspects of your personal information will be passed over, such as contact and order details, in order for Klarna to assess whether you qualify for their payment options and to tailor the payment options for you. Further details on Klarna’s privacy policy can be found here

http://cdn.klarna.com/1.0/shared/content/legal/terms/Klarna/en_gb/privacy

You have the right to ask for a copy of the personal data we hold that relates to you. If you think that information about you which we hold is incorrect or misleading you have the right to have the information corrected provided you can demonstrate that it is incorrect. You can also request the erasure of personal data relating to you in certain circumstances, where we do not require it to meet a legal obligation. You can also request or restriction of processing so that your records are maintained beyond our usual retention period. You have the right to object to processing on the grounds that it causes you damage or distress and the right to take away a copy of your personal data in electronic format in certain circumstances.

If you are unhappy about the way we use your personal data or the way in which we respond to your request to exercise your data protection rights, you can contact our Data Protection Officer at Ickle Bubba Ltdbut you also have the right to lodge a complaint with a supervisory authority, the Information Commissioner at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.

If you have any questions about this policy and the practices of this website, please contact our Data Protection Officer at privacy@icklebubba.com

Please note that if the ownership or control of all or part of our Products or their assets changes, we may transfer your information to the new owner.