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This policy sets out when, how and why we may collect and use your personal information, as well as the type of personal information we may collect from you when using the www.sonality.co.uk website (the “Platform”).
This policy also sets out your rights and our obligations in respect of the controlling and processing of such information by us.
To the extent that we provide personal information to third party processors. Those processors are obliged to comply with this policy when processing personal information on our behalf. Any breach of this policy by that third party may result in disciplinary action being taken against them.
1. Who we are
We are Widcombe Kingsley Limited (“we/our/us”). We are a company registered in England and Wales with company number 10900248. Our registered office address is 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ. Our registered VAT number is 275 9955 35.
For the purpose of the Data Protection Act 1998 (“the Act”) and General Data Protection Regulation (Regulation (EU) 2016/679) (“the Regulation”) we are a data controller provided by you to us through our Platform.
We are registered as a data controller with the UK Information Commissioner’s Office with registration number 10900248.
2. Information we may collect and process
We may collect and process various types of personal information. This being at the time you register to use, and during your actual use, of our Platform. We will also collect personal information when corresponding with us by phone, email or otherwise.
The type of information collected, and the manner in which such information is used by us, will vary depending on how you use our Platform and whether or not you have consented for us to collect and/or process that information. Further details are set out below in paragraph 3 under the heading “How We Collect Personal Information”.
By using our Platform you are agreeing for us to collect and process the personal information provided as part of that process, for the purposes made clear to you at that time of collection.
The personal information we collect from you may be held on paper or on a computer or other media. This is subject to certain legal safeguards specified in the Act and the Regulation.
3. How we collect personal information
Personal information may be collected by us actively and passively. The specific types of personal information we may collect from you, and the manner in which such data may be collected, includes:
This is data we must collect from you in order to process and activate your registration to use our Platform. Registration Data includes, but is not limited to, your name, your email address, your password, your shipping and billing address(es), your postcode, and your telephone number. You may also choose to provide additional, non-necessary information to us at the time of completing the relevant registration form if you so wish – for example, your name on various social media platforms (such as Facebook, Instagram etc.).
Registration Data will be collected by us when completing and submitting the registration form through the Platform.
We may also use Registration Data for the purpose of providing you with information about similar products and services we provide as we consider ourselves to have a legitimate interest in doing so. You may choose to stop receiving this information at any time through clicking the “unsubscribe” link at the bottom of these marketing emails.
This data is passively collected by us in the course of you using and browsing the Platform (“Platform Data”).
Platform Data includes, but is not limited to, your device’s Internet Protocol (IP) address, your login information, web cookies, browser type and version, the pages of our Platform you visit, the amount of time spent on each page of our Platform, time zone settings, the time and date of your visit and the operating system or platform you use, information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our Platform (including date and time), any products you have viewed or searched for, page response times, download errors, length of visits to certain pages within the Platform, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page. Platform Data is collected by us when it is transmitted to us during or after your use of the Platform.
4. How we use your personal information
We may use the personal data we collect for several purposes.
Registration Data will be used for the purpose of creating your personal user account, granting a user account to you, and in order for you to gain full accessibility to the Platform.
We may also disclose Registration Data to a third party data processor for the purpose of that processor sending emails to you relating to your registration to use our Platform, your order or marketing emails, or other purposes including, but not limited to:
- the production of your order
- the delivery of your order
- coupons, discounts and other customer benefits
- customer reviews
We will also use Registration Data for the purpose of identifying you so that you can use the Platform and its full functionality and so that we can provide the services to you through the Platform.
We will use Platform Data for the purpose of understanding how our customers’ behave in order for us to develop or optimise:
a) how the Platform works for you;
- b) the information and services provided to you through our Platform; andc) the effectiveness of our online advertising and branding (to the extent that we use such advertising).
Where you have chosen (or where we have given you) a password which enables you to access certain parts of our Platform. Or use our Platform in a particular way, you are responsible for keeping this password confidential. We ask you not to share this password with anyone and to change it if you suspect someone has gained access to it.
Our Social Media Campaigns
We may use some elements of Registration Data (such as your name, or social media usernames you have provided to us at the time of registration) for the purpose of posting advertisements clothing and products you have designed on such social media platforms and “tagging” you in those advertisements.
We consider ourselves to have a legitimate interest in using your personal data in this way. You may ask for us to remove your social media name from any relevant post we have made as part of such a social media campaign.
We may also use such data in order for us to send newsletters and direct marketing to you if:
- you have consented to receiving such information; or
- if you have not consented, if we consider sending such information to you to be a legitimate interest of ours. (on the basis that the content contained within the direct marketing is relevant to you and that you may stop receiving such emails at any time).
You may prevent us using your data for this purpose at any time. Do this by following the unsubscribe procedure described in the marketing and newsletter emails you receive.
Storage of personal data
All personal information we collect and process is stored on our secure servers.
5. Your rights and our obligations
We will generally process personal data on the basis of having specific consent to do so for that specific purpose. If we require your consent, we will explicitly ask for such consent at the time of collecting your personal data.
However, we may also process your personal information if we are able to do so without explicit consent under the Act and/or Regulation. For example, we may be able to legally control and process your personal information without your consent if it is necessary in order for us to provide the service you have asked to, or if we have a legitimate interest in doing so, or if doing so is in the public interest.
We may also process your personal information without your consent if we have a legitimate interest in doing so. For example, by sending direct marketing emails to you, for some internal administrative purposes, or for the purpose of ensuring electronic information security.
If we are controlling and processing your personal information on the sole basis of having your consent to do so, we must gain separate consents from you in respect of each distinct processing operation.
Where we are processing your personal information on the basis of you having given us your consent to do so, you do have the right to withdraw that consent at any time, but this will not affect the lawfulness of processing prior to the withdrawal of such consent.
You can exercise your right to withdraw consent to processing at any time by contacting us via firstname.lastname@example.org.
Rectification and Erasure
You benefit from the right to rectify inaccurate personal information we hold which relates to you. (also known as the “right to rectification”). This means that, taking into account the subject of the processing, you shall have the right to have incomplete personal information completed. You can exercise your right to rectification by contacting us via email@example.com.
You also benefit from the right to erasure (also known as the ‘right to be forgotten’). This means that you have the right to request us to erase personal information we hold about you. Also that we should erase such data without undue delay. Provided that you are able to demonstrate one of the following to us:
(a) that our processing of the personal information is no longer necessary in relation to the purpose for which it was collected;
(b) that you withdraw your consent to the processing. Resulting in that there is no other legal ground for us to continue to process the data;
(c) that you object to the processing under regulation 21 of the Regulation and there are no overriding legitimate grounds for processing;
(d) that the personal information must be erased in order to comply with a national legal obligation; or
(e) the personal information in question belongs to a child under the age of 16 and no consent is given or authorised by the holder of parental responsibility over the child.
You also have the right to receive the personal information concerning you in a structured, commonly used and machine-readable format. You have the right to transmit such data to other data controllers without hindrance from us where we are processing that data on the basis of having your consent to do so. Or where it is necessary for the performance of a contract, and the processing is carried out by automated means.
Subject Access Requests:
You as a data subject are entitled to make a formal request for information we hold about you. We must provide you with a copy of this information. The reasons it is being processed and whether it will be given to any other organisations or people provided that you make this request in writing.
6. Sharing and transferring personal information
We use industry-standard encryption for transmission of data to our systems. Although we cannot guarantee the absolute safety of transmission of data via the internet, we adhere to the highest standards to give your data the strongest protection possible.
Sharing of Personal information:
We may share personal information we hold with any member of our group. This means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
We may also disclose personal information we hold to third parties, with your consent, or on the basis of us an otherwise lawful reason for doing so under the Act and/or Regulation.:
(a) in order to facilitate, provide and improve the products and services we provide to you through our Platform;
(b) in order to analyse the manner in which our services are used by services and product users;
(c) in the event that we sell or buy any business or assets. In which case we may disclose personal information we hold to the prospective seller or buyer of such business or assets;
(d) if we or substantially all of our assets are acquired by a third party. In which case personal information we hold will be one of the transferred assets; and
(e) if we are under a duty to disclose or share your personal information in order to comply with any legal obligation. Or in order to enforce or apply any contract with the data subject or other agreements; or to protect our rights, property, or safety of our employees, customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
Transfers outside the EEA:
We may transfer any personal information we hold to a country outside the European Economic Area (EEA). This is provided that one of the following conditions applies:
(a) the country to which the personal information is transferred ensures an adequate level of protection. This is for the data subjects’ rights and freedoms;
(b) you have given your consent;
(c) the transfer is necessary for one of the reasons set out in the Act and/or Regulation. Including the protection of your vital interests;
(d) the transfer is legally required on important public interest grounds. Orr for the establishment, exercise or defence of legal claims; or
(e) the transfer is authorised by the relevant data protection authority. This includes where we have adduced adequate safeguards with respect to the protection of the data subjects’ privacy. As well as their fundamental rights and freedoms, and the exercise of their rights.
Personal information we hold may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. That staff may be engaged in, among other things, the provision of support services.
7. Changes to this policy
We reserve the right to change this policy at any time. Where appropriate, we will notify you, as a data subject, of those changes by email.
8. Concerns or complaints
If you have any concerns or complaints relating to this policy, its subject matter, or the manner in which we collect, control and/or process your personal information, please do let us know by sending an email to firstname.lastname@example.org.
You also have the right to lodge a complaint with a supervisory authority if you consider that the processing of your personal information has infringed the Regulation. In the UK, the relevant supervisory authority is the Information Commissioner’s Office.