PRIVACY POLICY

 


1.1 At Fashion for Change we are committed to protecting the privacy of your personal data collected as part of your use of http://fashionforchange.boutique (the “website”) and our associated software services.  This Privacy Policy forms part of the Terms and Conditions for use of and access to the website

Personal data is defined in Article 4(1) of the General Data Protection Regulations 2018 (EU) 2016/679 (“GDPR”):

(1) 'personal data' means any information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person".

1.2. We will always comply with the GDPR when dealing with your personal data.  Further details on the GDPR can be found at the website for the Information Commissioner (http://www.ico.gov.uk)

1.2.1. For the purposes of the GDPR, we will be the “data controller” of all personal data held in respect of the website.

1.3. As a condition of you accessing the website, you agree that we may collect, use and store your personal data, as described in this Privacy Policy and elsewhere on the website.

1.4. We have implemented generally accepted standards of technology and operational security in order to protect personal data from loss, misuse, or unauthorised alteration or destruction.  However, please note that transmission of information via the internet can never be completely secure and we cannot guarantee the security of your personal data before it is received at the Website.  All such transmission is at your risk.

1.5. We may use your personal data in order to provide you with the best possible customer service as set out in this Privacy Policy, and (with your permission) to keep you updated about our other services and products. 

1.6. We will never sell your personal data or make it available to any third parties without your prior consent except:

1.6.1. where required to do so by law or in the event that we sell any part of our business or assets (in which case we may disclose your personal data to the  prospective buyer), or

1.7. We reserve the right to amend this Privacy Policy from time to time without prior notice.  You are advised to check the Website regularly for any amendments (but note that amendments will not be made retrospectively).


2. What information do we collect and why?

2.1 We may process data about your use of our website and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system]. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interest in monitoring and improving our website and services.

2.2. We may process your account data ("account data") which may include your name and email address. The source of the account data is you or your employer. The account data may be processed for the purposes of providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is consent OR our legitimate interests, namely the proper administration of our website and business OR the performance of a contract between you and us and/or taking steps at your request, to enter into such a contract.

2.3. We may process your personal data that are provided in the course of the use of our services ("service data"). The service data may include your name, email address, mailing address and telephone number. The source of the service data is you. The service data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

2.4. We may process information that you post for publication on our website or through our services ("publication data"). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is consent OR our legitimate interests, namely the proper administration of our website and business.

2.5. We may process information contained in any enquiry you submit to us regarding goods and/or services ("enquiry data"). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is consent.

2.6. We do not collect or hold credit or debit card details; these are collected and processed securely by our third party payment processing agent in compliance with PCI data security standards.

2.7. We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters ("notification data"). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent.

2.8. We may process information contained in or relating to any communication that you send to us ("correspondence data"). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.

2.9. We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

2.10. We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

2.11. Our server logs requests for website content.  By analysing this information, we can identify which parts of the Website are popular and which are not, helping us to improve the Website. The Website uses these log files to compile non-personal statistical information about matters such as length of stay on the Website, type of pages visited and other general information.  This information is entirely anonymous and cannot identify you personally: we want to know how people in general are using the Website, not what you in particular are doing on the Website.

2.12. In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

2.13. Please do not supply any other person's personal data to us, unless we prompt you to do so.


3. Providing your personal data to others

3.1. We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

3.2. Financial transactions relating to our website and services are handled by our payment services providers, PayPal. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers' privacy policies and practices at www.paypal.com.

3.3. We may disclose your enquiry data to one or more of those selected third party suppliers of goods and services identified on our website for the purpose of enabling them to contact you so that they can offer, market and sell to you relevant goods and/or services. Each such third party will act as a data controller in relation to the enquiry data that we supply to it; and upon contacting you, each such third party will supply to you a copy of its own privacy policy, which will govern that third party's use of your personal data.

3.4. In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.


4. Retaining and deleting personal data

4.1. This Section 4 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

4.2. Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

4.3. We will retain your personal data as follows:

(a) Personal data will be retained for a minimum period of 3 months following the date you first accessed the website, submitted an enquiry form or contacted us, and for a maximum period of 12 months following.

(b) Service data will be retained for a minimum period of 3 month following the termination date of the relevant contractual agreement and for a maximum period of 12 months.

4.4. In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:

(a) the period of retention of personal data will be determined based on the terms of the contractual agreement or consent.

4.5. Notwithstanding the other provisions of this Section 4, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.


5. Your rights

5.1. In this Section 5, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

5.2. Your principal rights under data protection law are:

(a)   the right to access;

(b)   the right to rectification;

(c)    the right to erasure;

(d)   the right to restrict processing;

(e)   the right to object to processing;

(f)    the right to data portability;

(g)   the right to complain to a supervisory authority; and

(h)   the right to withdraw consent.

5.3. Under the terms of the GDPR you have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. You can access your personal data by visiting http:fashionforchange.boutique/account when logged into our website.

5.4. You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed you can simply update the details within your account or contact.

5.5. In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.

5.6. In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

5.7. You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

5.8. You have the right to object to our processing of your personal data for direct marketing purposes, including profiling for direct marketing purposes. If you make such an objection, we will cease to process your personal data for this purpose.

5.9. You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

5.10. To the extent that the legal basis for our processing of your personal data is:

(a) consent; or

(b) that the processing is necessary for the performance of a contract to which you are party; or in order to take steps at your request prior to entering into a contract, and such processing is carried out by automated means, then you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

5.11. If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.

5.12. To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

5.13. You may exercise any of your rights in relation to your personal data by written notice to us via email to contact@fashionforchange.boutique, or by mail to Data Protection Officer, Fashion for Change Limited, The Studio, Seagrims, Pitchcombe, Gloucestershire. GL6 6LY. in addition to the other methods specified in this Section 5.


6. About cookies

6.1. Like most websites, the Website uses cookies.  These are small files that are sent to your computer, phone or other internet enabled device when you log into this Website.  Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.  You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website. Please note that a cookie only tracks the computer, phone or other internet enabled device that is logging on to the Website: it does not necessarily identify who is using that device. 

6.2. Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

6.3. Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.


7. Cookies that we use

7.1. We use cookies for the following purposes:

(a) Authentication - we use cookies to identify you when you visit our website and as you navigate our website;

(b) Status - we use cookies to help us to determine if you are logged into your online account.


8. Cookies used by our service providers

8.1. Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

8.2. We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google's privacy policy is available at: https://www.google.com/policies/privacy/. The relevant cookies are: gat.gtag, ga, gtag.js, gid, analytics.js, and ga.js cookies.


9. Managing cookies

9.1. Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

(a)   https://support.google.com/chrome/answer/95647?hl=en (Chrome);

(b)   https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);

(c)    https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);

(d)   https://support.apple.com/kb/PH21411 (Safari); and

9.2. Blocking all cookies will have a negative impact upon the usability of many websites.

9.3. If you block cookies, you will not be able to use all the features on our website.


10. Links to other websites

The Website may from time to time contain links to other unrelated websites (including those of our advertisers). This privacy statement does not apply to these websites nor are we responsible for the content and practices of these websites.  In particular, please note that such other sites may also use cookies, and that we have no control over this.


11. Changes to this privacy policy

Fashion for Change has the discretion to update this privacy policy at any time. When we do, we will post a notification on the main page of our Site, revise the updated date at the bottom of this page. We encourage Users to frequently check this page for any changes to stay informed about how we are helping to protect the personal information we collect. You acknowledge and agree that it is your responsibility to review this privacy policy periodically and become aware of modifications.


12. Acceptance


By using this Website, you signify your acceptance of this policy. If you do not agree to this policy, please do not use our Website. Your continued use of the Website following the posting of changes to this policy will be deemed your acceptance of those changes.


13. Contact Information

If you have any questions about the privacy of data we hold, to “opt-out” of receiving marketing communications from us or to request a copy of information we hold about you, please email us at contact@fashionforchange.boutique or write to us at:

Data Protection Officer

Fashion for Change Limited
The Studio, Seagrims Pitchcombe,
Gloucestershire. 
GL6 6LY.

This document was last updated on 20 May 2018.

 

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