Privacy Policy
Last updated: July 2021.
Purpose Of This Privacy Policy
This policy is to explain what data we collect about you (or that you have provided to us), how we use it and how you can control what we do with this information.
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. This privacy policy, as well as our Cookie policy, is incorporated into and made a part of our Terms and Conditions of Sale. By visiting www.charliemackesystore.com you agree that you have read, understand and are bound by the conditions set forthwith herein.
https://charliemackesystore.com/ is a website operated by True Colors Limited t/a freuds Bazaar of 1 Stephen Street, London W1T 1AL (“we”, “our”, “us”). We are committed to protecting and respecting your privacy in accordance with the applicable data protection legislation.
For the purpose of the Data Protection Act 2018 (the Act), we are the data controller of the personal data we collect and process about you. If you have any questions relating to this Privacy Policy, please contact us as contact@charliemackesystore.com.
Our commitment to you
We take the protection of your personal data seriously and will process your personal data fairly, lawfully and transparently. This privacy notice describes the personal data we are collecting about you and how it is used.
We will only collect and use your personal data for the following purposes, to:
· fulfil your order(s)
· fulfil orders made on your behalf
· communicate with you
· keep you up to date with the latest offers and trends
· give you a better shopping experience
· help us to make our marketing more relevant to you and your interests
· improve our services
· meet our legal responsibilities.
The personal data we collect
Personal data or personal information means any information about an individual from which that person can be identified. It does not include anonymised data, where the identity has been removed.
Our website is designed for a general audience and we will not knowingly collect any data from children or sell products to children. If you are under the age of 18, you are not permitted to use or submit your data to the website.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
· Identity Data includes information such as: first name, last name, title, date of birth, occupation, personal description, and gender.
· Contact Data includes information such as: email address, billing address, delivery address, location, country, and telephone number.
· Financial Data includes information such as: payment card details and bank account.
· Transaction Data includes information such as: details of your purchases and the fulfilment of your orders (such as basket number, order number/reference, subtotal, title, currency, discounts, shipping (including tracking information, order status), number of items, product number, single item price, category, tax etc.); payments to and from you and details of other products and services you have obtained from us, information relating to returns, correspondence or communications with you in respect of your orders, and details of any rewards and bonuses awarded.
· Technical Data includes information such as: details of the device(s) you use to access our services, your internet protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform.
· Profile Data includes information such as: purchases or orders made by you, your interests, preferences, feedback, and survey responses.
· Usage Data includes information such as: how and when you use our website, products and services.
· Marketing and Communications Data includes information such as: your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with products you have ordered from us). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
How we collect your data
We may collect personal data about you in the following ways:
· Direct interactions. You may give us your Identity, Contact, Financial, Transaction, Profile, and Marketing and Communications data (as described above) by filling in forms, entering information online or by corresponding with us by post, phone, email, telephone or otherwise.
· Automated technologies or interactions. As you interact with our website, we may automatically collect the following types of data (all as described above): Technical Data about your equipment, Usage Data about your browsing actions, and Contact Data where tasks carried out via our website remain uncompleted, such as incomplete orders or abandoned baskets. We collect this data by using cookies, server logs and other similar technologies. Please see our Cookie Policy for further details.
· Third parties. We may receive personal data about you from various third parties, including:
o Identity and Contact data from another individual when they purchase a product for you or on your behalf;
o Technical Data from third parties, including analytics providers such as Google.
o Technical Data from affiliate networks through whom you have accessed our website;
o Identity and Contact Data from social media platforms when you log in to our website using such social media platforms;
o Identity and Contact data from third parties, including organisations (including law enforcement agencies), associations and groups, who share data for the purposes of fraud prevention and detection and credit risk reduction;
o Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
How we use your data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
· Where we need to perform the contract we are about to enter into or have entered into with you.
· 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.
· Where we need to comply with a legal obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Uses made of your personal data
Your personal data is used to support a range of different activities. These are listed in the table below together with the types of data used and the legal bases we rely on when processing them, including where appropriate, our legitimate interests. Please be aware that we may process your personal data using more than one lawful basis, depending on the specific activity involved. Please contact us 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 including basis of legitimate interest
To register you as a new customer
Identity
Contact
Performance of a contract with you
To process and deliver your order including:
recording your order details; keeping you informed about the order status; process payments and refunds, collect money owed to us; and automated decision making to assist fraud prevention and detection
Identity
Contact
Financial
Transaction
Performance of a contract with you.
Necessary for our legitimate interests (to recover debts due to us.
To manage our relationship with you, including:
providing you with any information, products and services that you request from us; notifying you about changes to our services, terms and conditions or privacy notice; asking you to leave a review or take a survey
Identity
Contact
Profile
Marketing and Communications
Performance of a contract with you
Necessary to comply with a legal obligation
Necessary for our legitimate interests (to keep our records updated and to study how customers use our products and services)
To enable you to take part in a competition, event, survey
Identity
Contact
Profile
Usage
Marketing and Communications
Performance of a contract with you
Necessary for our legitimate interests (to study how customers use our products and services, to develop them and grow our business)
To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, data analysis, reporting and hosting of data)
Identity
Contact
Technical
Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, and to detect and prevent fraud)
Necessary to comply with a legal obligation
To deliver relevant website content, online advertisements and information for you; and measure the effectiveness of the advertising provided
Identity
Contact
Profile
Usage
Marketing and Communications Technical
Necessary for our legitimate interests (to study how customers use our products and services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products, services, marketing, customer relationships and experiences
Technical
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 recommend products, services and offers that may be of interest to you
Identity
Contact
Technical
Usage
Profile
Marketing and Communications
Necessary for our legitimate interests (to develop our products and services and grow our business) or Consent.
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Marketing and Promotional Offers
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This us how we decide which products, services and offers may be relevant for you. You will receive marketing communications from us if you have requested information from us or purchased goods from us and you have not opted out of receiving that marketing.
Third-party marketing opt-in
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Cookies
Our website uses cookies to distinguish you from other users of our website and to keep track of your visits. They help us to enhance your shopping experience, provide our services and to make improvements to our website.
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our website may become inaccessible or not function properly.
For detailed information on the cookies, please refer to our Cookie Policy.
How we share your data
We may share information that we collect about you with other our affiliates, suppliers, sub-contractors and you can be assured that we will only share your personal data that is needed for these parties to be able to provide the right service or support us in doing so.
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.
We may disclose and share your personal data with the following parties:
· Other companies within our group of companies – including for fraud prevention purposes or for the provision of other products and services.
· Customer service providers – our partners who work with us to administer your account and provide you with any help you may need.
· Delivery companies – our couriers, parcel firms and mail firms who deliver your goods or services and manage any returns on our behalf.
· Distributors and manufacturers of goods – our partners who fulfil orders and deliver products to you and manage any returns on our behalf.
· Product service providers – our partners who provide retail or financial products and services including credit facilities, insurance or extended warranties.
· Research service providers – our partners who work with us to provide research and data analysis services.
· Marketing service providers – our partners who work with us to send you information about products, services and special offers that we or they believe are of interest to you.
· Data pool facilitators – we may share and pool information (on an anonymous basis or otherwise) with other third party retailers or financial service providers. This may help up to improve our products and quality of service to all customers.
· Debt collectors, tracing agencies, debt purchasers or organisations providing debt support – our partners who help us to recover debts, who purchase debts or who offer debt advice and support.
· Regulators and other governmental agencies or law enforcement agencies.
· Organisations who may be interested in purchasing our business or organisations who we may be interested in purchasing - we may sell parts of our business or acquire other businesses and your personal data may be shared with such third parties as part of this process.
Your data and countries outside of the UK
The personal data we collect from you may be transferred to, and stored at, destinations outside the UK. It may also be processed by staff operating outside the UK who work for us or for one of our affiliates, suppliers or sub-contractors. Such parties may be engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy notice.
We will be only transfer your personal data to third parties that adhere to appropriate data security standards and controls. Whenever we transfer personal data outside the UK, we will ensure a similar degree of protection is afforded to it by ensuring appropriate safeguards, as required by law, are in place to protect your personal data and complies with applicable law which may including having standard contractual clauses in place with the third party. For further details, see https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/international-transfers-after-uk-exit/.
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, suppliers, 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.
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.
How long we keep your data for
We will keep your personal data for no longer than is necessary for the purpose(s) it was provided for and to meet our legal obligations. Further details of the periods for which we retain data are available on request.
Your Rights
You have several rights under the data privacy legislation. This includes, under certain circumstances, the right to:
• Request access to your personal data. This is known as a Subject Access Request. You have the right to obtain a copy of the personal data we hold about you and certain information relating to our processing of your personal data.
• Request correction of your personal data. You are entitled to have your personal data corrected if it is inaccurate or incomplete. In certain circumstances we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to request us to delete your personal data where there is no good reason for us continuing to process it. 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.
• Request restriction of processing of your personal data. You have a right to ask us to suspend the processing of your personal data in certain scenarios, for example if you want us to establish the accuracy of the data, or you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. Where processing is restricted, we are allowed to retain sufficient information about you to ensure that the restriction is respected in future.
• Request the transfer of your personal data. You have the right to request a transfer of your personal data to another company. 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.
• Object to processing of your personal data. You have the right to object to the processing of your personal data where we believe we have a legitimate interest in processing it (as explained above). You also have the right to object to our processing of your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your data which override your rights and freedoms.
• Withdraw your consent to process your personal data. You have the right to withdraw previously given consent at any time where we are relying on consent to process your personal 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.
If you wish to exercise any of the rights set out above, please contact us.
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.
Changes to this privacy notice
From time to time we may change this privacy notice. If there are any significant changes we will post updates on our website, applications or let you know by email.
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.
How to contact us
We welcome feedback and are happy to answer any questions you may have about your data.