- the types of personal information which we collect and how we collect it;
- the purposes for which we collect it;
- how we use and share your personal information;
- for how long we will hold personal information; and
- how we protect your privacy.
This policy (together with our terms and conditions and any other documents referred to) sets out the basis on which any personal information we collect from you, or that you provide to us including through your use of our site, will be processed and used by us.
Who we are?
This site is operated by Atterley.com Retail Limited. We are a limited company registered in Scotland under company number SC513447 and have our registered office at 2A Coates Crescent, Edinburgh EH3 7AL. . Our VAT number is 238686561. We are the data controller for the purposes of the Data Protection Act 1998 (the "Act"). References to 'we', 'us' and 'our' are to Atterley.com Retail Limited. The Chief Operating Officer of Atterley.com Retail Limited is the Data Protection Officer, responsible for overseeing data protection strategy and implementation to ensure compliance with the Data Protection Act 1998 and the General Data Protection Regulation 2016.
What Information Do We Collect About You?
You do not have to give us any personal information to make use of most of the site. However, to do any of the following things, you will need to provide us with personal information:
- fill in registration forms to register for an account
- place an order
- search for a product
- make use of our site and services
- sign up to receive emails and updates via post, for example, bulletins, newsletters, updates with information about us, new features, offers, services and products and/or promotional information (for more information see 'What are your rights?'' below)
- participate in social media functions which may be available on our site
- contact us by phone, email or otherwise
When you use the site, we or our third party providers may collect, process and store the following data about you:
- Information you give us. You may give us information as we have described above and the information you give us may include your name, delivery address, billing address, email address, phone number, date of birth, gender, product selections and financial and credit card or other payment information.
- Information we collect about you. With regard to each of your visits to our site we may automatically collect the following information:
- technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
- information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products you viewed or searched for; transactions you carried out and purchases you made; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.
- Information we receive from other sources. We work closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.
For What Purposes Do We Use Personal Information?
We use information held about you in the following ways:
- Information you give to us. We will use this information:
- to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us. When you place an order for products or services on our site, some of your personal details that you submit when placing an order must by necessity in order to deal with your request be forwarded to the relevant partner boutique along with your order as well as to our delivery partner in order to fulfill and keep you informed about your order (including by email and SMS notification updates);
- to process new and repeat orders;
- to verify your identity and details of your payment method or credit card account;
- to serve website content and advertisements to you;
- to provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about;
- to provide you with information about goods or services we feel may interest you. If you are an existing customer, we will only contact you by electronic means or post with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you. If you are a new customer, by purchasing a product on our site, we will assume that you are happy for us to contact you by electronic means or post with information about goods or services we feel may interest you and with mailings and offers. If you do not want us to use your data in this way, you may unsubscribe from receiving marketing communications from us at any time by following the link provided at the end of the marketing communication or by contacting us directly at firstname.lastname@example.org;
- to notify you about changes to our service or the functionality of our site;
- to answer any questions you may raise or respond to any comments you may send us;
- to ensure that content from our site is presented in the most effective manner for you and for your computer, such as personalising your visits to the site.
- Information we collect about you. We will use this information:
- to administer and improve our site and for internal operations, including troubleshooting, data analysis, such as your shopping habits, product and style preferences, research, statistical and survey purposes;
- to allow you to participate in interactive features of our service, when you choose to do so;
- as part of our efforts to keep our site safe and secure;
- to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
- to ensure that you are complying with our terms and to comply with our statutory and regulatory obligations;
- to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.
- Information we receive from other sources. We may combine this information with information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).
Disclouser Of Your Information
We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
We may share your information with selected third parties including:
- Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you, for example, fulfilling your order and arranging for a product to be sent to you.
- Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers, but we may provide them with aggregate information about our users (for example, we may inform them that 500 women aged under 35 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in EH1). We may make use of the personal data we have collected from you to enable us to comply with our advertisers' wishes by displaying their advertisement to that target audience.
- Third parties, service providers and agents we engage to help us in certain areas, including payment processors, identity verification service providers, such as credit reference agencies, analytics (such as size guide software providers who use anonymised data to develop their algorithms), and search engine providers that assist us in the improvement and optimisation of our site.
We may disclose your personal information to third parties:
- In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
- If Atterley.com Retail Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
- If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms and conditions and other agreements; or to protect the rights, property, or safety of Atterley.com Retail Limited, our customers or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
For How Long Do We Hold Personal Information?
We will not hold on to any personal information for any longer than is reasonably necessary for the purposes noted above. We will also retain your personal data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
What Procedures Do We Use To Protect Your Privacy?
The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA") or the country where you are located. Such processing may be required in order to fulfill your order, process your payment details or provide support services, for example, we may transfer personal data we have collected about you to a partner boutique located in another country to the one you are located in. It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers, such as our delivery partner. Such staff maybe engaged in, among other things, the fulfillment of your order, the processing of your payment details and the provision of support services. We will comply with the Act in respect of any such transfer. Please be aware that countries which are outside of EEA may not have the same level of data protection as the United Kingdom and by submitting your personal data, and using and/or shopping on the site, you agree to this transfer, storing or processing. Where this is the case we will take all steps reasonably necessary to ensure that your data is treated securely and the organisation receiving the data has provided adequate safeguards.
All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. Please bear in mind that if you voluntarily disclose your personal information online in a non-protected environment, such as a discussion board or chat area that information can be collected and used by others outside of our control.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
What Are Your Rights?
We may send you updates with news and information about us, new features, offers, services and products from time to time. You have the right to object to us processing your personal data for direct marketing purposes.
We will inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You may exercise your right to object online, by unsubscribing from receiving marketing communications by following the link provided at the end of the marketing communication. You can also exercise the right at any time in the following ways:
- emailing us at email@example.com or writing to us at Atterley.com Retail Limited, 2A Coates Crescent, Edinburgh EH3 7AL, marked for the attention of The Director, to let us know you would like to opt out of receiving any further emails from us;
- existing customers can also log in to their account to change their status;
- all emails communications will include information about how you can unsubscribe from receiving marketing communications.
We are registered in the UK with the Information Commissioners Office, which provides guidance and support on the processing of personal data. Under the legal framework, you have the right to lodge a complaint to a supervisory authority if you have any concerns.
Access To Information And Keeping Your Information Up To Date
The data protection framework gives you the right to access your personal data and supplementary information. Any access request is free of charge. (We may charge a ‘reasonable fee’ when a request is manifestly unfounded or excessive, particularly if it is repetitive.).
We may also charge a reasonable fee to comply with requests for further copies of the same information. Any fee will be based on the administrative cost of providing the information to you.
We want to make sure that your personal information is accurate and up to date. If, for any reason, you are concerned that personal information held by us is not correct, please visit our site and log in to change your personal information. If you have not registered or if you prefer, you can ask us to correct or remove information that you think is inaccurate at any time by emailing firstname.lastname@example.org or visiting the ‘Help’ section of the site.
You can contact us
Effective Date: December 2019