WEB SITE PRIVACY NOTICE
This privacy notice explains the types of personal data we may collect about you when you interact with us. It also explains how we’ll store and handle that data, and keep it safe.
We appreciate that there is a lot of information to take in but we want you to be fully informed about your rights, and how we use your data.
We hope the following sections will answer any questions you have but if not please get in touch with us.
2. Explaining the legal bases we rely on
The law on data protection sets out a number of different reasons for which a business may collect and process your personal data and we rely on the following:
Consent: In specific situations, we collect and process your data with your consent, for example when you tick a box to receive email newsletters.
When collecting your personal data, we’ll always make it clear to which data is necessary in connection with a particular service.
We need your personal data to comply with our contractual obligations, [for example if you order an item from us for home delivery, we’ll collect your address details to delivery your purchase, and pass them to our courier.]
If the law requires us to, we may need to collect and process your data, for example we can pass on details of people involved in fraud or other criminal activity affecting our legal obligations.
We require your data to pursue our legitimate business interests in ways, which you might reasonably expect as part of running our business and which does not materially impact your rights, freedom or interests.
3. When do we collect your personal data?
• When you visit our website;
• When you engage with us on social media; e.g. Instagram
• When you contact us by any means with queries, orders etc;
• When you ask us to email you information about a product or service;
• When you comment on or review our products and service via social media;
• When you fill in forms to register on our website;
• When you’ve given a third party permission to share with us the information they hold about you, e.g. trade references.
4. What sort of personal data do we collect?
• Details of your interactions with us online for example the web pages you visit and how and when you contact us.
• Details of your visits to our websites and which site you came from to ours.
• Your comments on Instagram;
• To deliver the best possible web experience, we collect technical information about your internet connection and browser as well as the country and telephone code where your computer is located, the web pages viewed during your visit, and any search items you entered;
• Your social media username, if your interest with us is through those channels, to help us respond to your comments, questions or feedback.
5. How and why do we use your personal data?
We want to give you a good experience as one of our customers and hence we use the personal data you register with us to offer you products, prices and services that are most likely to interest you. The data privacy law allows this as part of our legitimate interest in understanding our customers and providing the highest levels of services.
You can change how we use your data and you will find details in the “What are my rights”? Section below.
Please remember that if you choose not to share your personal data with us, or do not register with us, we might not be able to provide some services or information that you’ve asked for.
We will use your personal data to:
• To respond to your enquiries. We may also keep a record of these to inform any future communication with us and to demonstrate how we communicated with you throughout. We do this on the basis of our contractual obligations to you, our legal obligations and our legitimate interests in providing you with the best service and understanding how we can improve our services based on your experience;
• If we discover any criminal activity or alleged criminal activity through our fraud monitoring we will process this data for the purposes of preventing or detecting unlawful acts. Our aim is to protect the individuals with interact with from criminal activities;
• We will use your personal data and preferences to keep you informed about relevant products and services including special offers, promotions, sales, events, and so on. You can opt out of hearing from us at any time.
• To send you communications required by law or which are necessary to inform you about our changes to the services we provide you. For example, updates to this Privacy Notice. These services messages will not include any promotional content and do not require prior consent when sent by email or text message. If we do not use your personal data for these purposes, we would not be able to comply with our legal obligations;
• To develop, test and improve the systems, services and products we provide to you. We’ll do this on the basis of our legitimate business interests. For example, we’ll record your browser’s Session ID to help us understand more when you leave us online feedback about any problems you’re having;
6. How we protect your personal data
We know that data security matters to all our customers. With this in mind we will treat your data with great care and take all appropriate steps to protect it.
We secure access to our website and apps using ”https’ technology.
Access to your personal data is password-protected.
We regularly monitor our system for possible vulnerabilities and attacks.
We have confirmed the staff in our web site hosting company have received GDPR training in regards to any personal data which they may be able to see as part of the process of updating the web site.
7. How long will we keep your personal data?
Whenever we collect or process your personal data, we will only keep it for as long as is necessary and for at least one year.
At the end of that year, your data will be deleted completely unless you renew your consent to us keeping it
8. Who do we share your personal data with?
We share your personal data with trusted third parties. We provide only the information they need to perform their specific services.
Examples of the kind of third parties we work with are:
• IT companies who support our website and other business systems;
• Operational companies such as delivery couriers and the postal service;
Sharing your data with third parties for their own purposes:
We will only do this in very specific circumstances, for example:
• For fraud management, we may share information about fraudulent or potentially fraudulent activity in our system. This may include sharing data about individuals with law enforcement bodies.
We may also be required to disclose your personal data to the police or other enforcement, regulatory or Government body, in your country of origin or elsewhere, upon a valid request to do so. These requests are assessed on a case-by-base basis and take the privacy of our customers into consideration.
• We may, from time to time, expand, reduce or sell our business and this may involve the transfer of parts or the whole of the business to new owners. If this happens, your personal data will, where relevant by transferred to the new owner or controlling party, under the terms of this Privacy Notice.
• For further information please contact our Data Protection Controller.
9. Where your personal data may be processed
We do not process your personal data with any third parties outside the EEA
10. What are your rights over your personal data?
In summary, you have the right to request:
• Access to the personal data we hold about you, free of charge in most cases;
• The correction of your personal data when incorrect, out of date or incomplete. For example, when you withdraw consent, or object and we have no legitimate overriding interest, or once the purpose for which we hold the data has come to an end;
• That we stop using your personal data for direct marketing (either through specific, or all channels);
• That we stop any consent-based processing of your personal data after you withdraw that consent;
You have a right to request a copy of any information about you that we hold at any time, and also to have that information corrected if it is inaccurate.
To ask for your information to be amended, contact – Bindy McCallum at [email protected]
Your right to withdraw consent
Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent.
Where we rely on our legitimate interest
In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.
Checking your identity
To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Notice. If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.
11. Contacting the Regulator
If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have to us regarding the use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
You can contact them on 0303 123 1113 or go online to www.ico.org.uk/concerns
If you are based outside the UK you have the right to lodge your complaint with the relevant data protection regulator in your country of residence.
12. If you live outside the UK
FOR ALL NON-UK CUSTOMERS
By using our services or providing your personal data to us, you expressly consent to the processing of your personal data on our behalf. You still have the right to ask us not to process your data in certain ways, and if you do so, we will respect your wishes.
In the ordinary course of business, we will transfer your personal data from your country of residence to ourselves and to third parties located in the UK.
By dealing with us, you are giving your consent to this overseas use, transfer and disclosure of your personal data outside your country of residence for our legitimate business purposes.
This may occur because our information technology storage facilities and servers which hold your personal data are located in the UK.
We’ll ensure that reasonable steps are taken to prevent third parties outside your country of residence using your personal data in any way that’s not set out in this Privacy Notice. We’ll also make sure we adequately protect the confidentiality and privacy of your personal data.
13. Any questions?
We hope this Privacy Notice has been helpful in setting out the way we handle your personal data and your rights to control it.
If you have any questions that haven’t been covered, please contact us follows
• Emails us at: [email protected]
• Write to us at: Marcus McCallum F.G.A. Rooms 27-31, New House, 67-68 Hatton Garden, London EC1N 8JY
This notice will be updated as necessary