PROTECTING YOUR PRIVACY
Caramel Clothing Ltd
1. Introduction
This Privacy Notice explains in detail 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 know that there’s a lot of information here, but we want you to be fully informed about your rights, and how Caramel Clothing Ltd uses your data. We hope the following sections will answer any questions you have but if not, please do get in touch with us.
It’s likely that we’ll need to update this Privacy Notice from time to time. We’ll notify you of any significant changes, but you’re welcome to come back and check it whenever you wish.
2. Explaining the legal bases we rely on
The law on data protection sets out a number of different reasons for which a company may collect and process your personal data, including:
Consent
In specific situations, we can collect and process your data with your consent. For example, when you tick a box to receive email newsletters.
Contractual obligations
In certain circumstances, we need your personal data to comply with our contractual obligations. For example, if you order an item from us our website, we’ll collect your address details to deliver your purchase, and pass them to our courier.
Legal compliance
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 Caramel to law enforcement .
Legitimate interest
In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests.
For example, we will use your purchase history to send you or make available personalised offers. We also combine the shopping history of many customers to identify trends and ensure we can keep up with demand, or develop new products/services.
3. When do we collect your personal data?
• When you visit our website and use your account to buy products and services, on the phone or in our shop.
• When you make an online purchase and check out as a guest (in which case we just collect transaction-based data).
• When you create an account with us.
• When you engage with us on social media.
• When you contact us by any means with queries, complaints etc.
• When you ask one of our staff to phone or email you information about a product or service.
• When you enter prize draws or competitions.
• When you comment on or review our products and services.
• Any individual may access personal data related to them, including opinions. So if your comment or review includes information about the member of staff who provided that service, it may be passed on to them if requested.
• When you fill in any forms. For example, if an accident happens in store.
• When you visit our shop which has a CCTV system operated for the security of both customers and staff. This system may record your image during your visit.
4. What sort of personal data do we collect?
• If you have a web account with us: your name, gender, date of birth, billing/delivery address, orders and receipts, email and telephone number. For your security, we’ll also keep an encrypted record of your login password.
• Details of your orders with us in store or online. For example, we collect details of purchases you make, items viewed or added to your basket, wish list choices, pages you visit on our website and how and when you contact us.
• Details of your visits to our website and from which site you came from to ours.
• Information gathered by the use of cookies in your web browser. For example, you might tell us your clothing size, which we’ll use to guide our suggested items. We’ll only ask for and use your personal data collected for recommending items of interest and to tailor your shopping experience with us. Of course, it’s always your choice whether you share such details with us.
• Payment card information.
• Your comments and product reviews.
• Your image may be recorded on CCTV when you visit our shop.
• 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 terms you entered. See Cookies
• Your social media username, if you interact with us through those channels, to help us respond to your comments, questions or feedback.
5. How and why do we use your personal data?
We use this information to offer you promotions, products 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 service. Of course, if you wish to change how we use your data, you’ll find details in the ‘What are my rights?’ section below.
If you choose not to share your personal data with us we might not be able to deliver your goods or let you know when they are dispatched. For example, if you’ve asked us to let you know when an item comes back into stock, we can’t do that if you’ve withdrawn your general consent to hear from us.
Here’s how we’ll use your personal data and why:
• To process any orders that you make by using our website or in store.
If we don’t collect your personal data during checkout, we won’t be able to process your order and comply with our legal obligations. For example, your details may need to be passed to a third party to supply or deliver the product or service that you ordered, and we may keep your details for a reasonable period afterwards in order to fulfil any contractual obligations such as refunds.
• To respond to your queries, refund requests and complaints. Handling the information you sent enables us to respond. 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 service based on your experience.
• To protect our business and your account from fraud and other illegal activities. This includes using your personal data to maintain, update and safeguard your account. We’ll also monitor your browsing activity with us to quickly identify and resolve any problems and protect the integrity of our websites. We’ll do all of this as part of our legitimate interest. For example, by checking your password when you login and using automated monitoring of IP addresses to identify possible fraudulent log-ins from unexpected locations.
• To protect our customers, premises, assets and staff from crime, we operate CCTV systems in our store which records images for security. We do this on the basis of our legitimate business interests.
• To process payments and to prevent fraudulent transactions. We do this on the basis of our legitimate business interests. This also helps to protect our customers from fraud.
• If we discover any criminal activity or alleged criminal activity through our use of CCTV, fraud monitoring and suspicious transaction monitoring, we will process this data for the purposes of preventing or detecting unlawful acts. Our aim is to protect the individuals we interact with from criminal activities.
• With your consent, we will use your personal data, preferences and details of your transactions to keep you informed by email about relevant products and services including tailored special offers, discounts, promotions, events, competitions and so on. Of course, you are free to opt out of hearing from us by any of these channels at any time. You are free to opt out of hearing from us by post 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, product recall notices, and legally required information relating to your orders. These service messages will not include any promotional content and do not require prior consent when sent by email. If we do not use your personal data for these purposes, we would be unable to comply with our legal obligations.
• To display the most interesting content to you on our website we’ll use data we hold about your favourite brands or products and so on. We do so on the basis of your consent for our website to place cookies or similar technology on your device. For example, we might display a list of items you’ve recently looked at, or offer you recommendations based on your purchase history.
• To administer any of our prize draws or competitions which you enter, based on your consent given at the time of entering.
• To comply with our contractual or legal obligations to share data with law enforcement. For example, when a court order is submitted to share data with law enforcement agencies or a court of law
6. How we protect your personal data
We know how much data security matters to all our customers. With this in mind we will treat your data with the utmost care and take all appropriate steps to protect it.
We secure access to all transactional areas of our website using ‘https’ technology.
Access to your personal data is password-protected, and sensitive data (such as payment card information) is secured by SSL encryption.
7. How long will we keep your personal data?
Whenever we collect or process your personal data, we’ll only keep it for as long as is necessary for the purpose for which it was collected. At the end of that retention period, your data will either be deleted completely or anonymised.
Some examples of customer data retention periods:
Orders When you place an order, we’ll keep the personal data you give us for two years so we can comply with our legal and contractual obligations.
8. Who do we share your personal data with?
We only share your data with our couriers to allow your purchase to be delivered.
Your personal data is processed by our web developer Visualsoft who send it to our EPOS (Till software) provider Intelligent Retail.
Your payment details are processed using SSL encryption technology by Barclaycard.
Your data is also processed by social media companies if you interact with us in that way. These are: Facebook, Twitter, Instagram, Pintrest and YouTube Via the use of cookies search engines such as Google may tailor their results based on your search history including use of our website.
Here’s the policy we apply to our couriers to keep your data safe and protect your privacy:
• We provide only the information they need to perform their specific services.
• They may only use your data for the exact purposes we specify in our contract with them.
• We work closely with them to ensure that your privacy is respected and protected at all times.
• If we stop using their services, any of your data held by them will either be deleted or rendered anonymous.
If Caramel Clothing Ltd is taken over or sold to a third party your personal data will be part of the company assets sold with the business.
9. Where your personal data may be processed
Sometimes we will need to share your personal data with third parties and suppliers outside the European Economic Area (EEA), such as Australia or the USA.
International orders outside the EEA
If you are based outside the UK and place an order with us, we will transfer the personal data that we collect from you to delivery couriers delivering your order.
The EEA includes all EU Member countries as well as Iceland, Liechtenstein and Norway.
We may transfer personal data that we collect from you to third-party data processors in countries that are outside the EEA.
Any transfer of your personal data will follow applicable laws and we will treat the information under the guiding principles of this Privacy Notice.
10. What are your rights over your personal data?
An overview of your different rights 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 channels, or all channels).
• That we stop any consent-based processing of your personal data after you withdraw that consent.
You have the right to request a copy of any information about you that Caramel Clothing Ltd holds at any time, and also to have that information corrected if it is inaccurate.
To ask for your information, please contact Data Protection Officer, Caramel Clothing Ltd, 17-18 The Strand, Exmouth, Devon EX8 1AF, or email enquiries@caramelclothing.co.uk
To ask for your information to be amended, please email enquiries@caramelclothing.co.uk
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.
Direct marketing
You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We must always comply with your request.
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. How can you stop the use of your personal data for direct marketing?
Here are the ways you can stop direct marketing communications from us:
• Click the ‘unsubscribe’ link in any email communication that we send you. We will then stop any further emails.
• Unfollow us on any of our social media channels
Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated.
12. 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 made 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 by calling 0303 123 1113. Or go online to www.ico.org.uk/concerns (opens in a new window; please note we can't be responsible for the content of external websites)
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.
13. 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 by us or on our behalf. Of course, 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.
Sometimes we’ll need to transfer your personal data between countries to enable us to supply the goods or services you’ve requested. In the ordinary course of business, we may 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 ordinary business purposes. This may occur because our information technology storage facilities and servers are located outside your country of residence and could include storage of your personal data on servers 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.
14. 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 our Data Protection Officer who will be pleased to help you:
• Email us enquiries@caramelclothing.co.uk
• Write to us Caramel Clothing Ltd, 17-18 The Strand, Exmouth, Devon EX8 1AF
