Last Modified: 25 May 2018
- Important information and who we are
- The data we collect about you
- How is your personal data collected?
- How we use your personal data
- Disclosures of your personal data
- International transfers
- Data security
- Data retention
- Your legal rights
Important information and who we are
Please note that this Site is not intended for children under 16 years of age. No one under age 16 may provide any information to or on this Site. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on this Site or on or through any of its features, use any of the interactive or public comment features of this Site or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us using our “Contact Us” form at https://www.whowhatwear.co.uk/contact-us and/or https://www.byrdie.co.uk/contact-us.
Clique Brands Uk Limited is the controller and responsible for your personal information.
- Our full details are:
- Clique Brands Uk Limited
- Attn: data protection team
- Email address: firstname.lastname@example.org
- Postal address: 48-49 Russell Square. London, WC1B 4JP
You also have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the regulator so please contact us at email@example.com in the first instance.
This version was first published on 25
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.
This Site may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share information about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Site, we encourage you to read the privacy notice of every website you visit.
Please note that we also do not control third parties' collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. If you are based in the United States you can opt out of receiving targeted ads from members of the Network Advertising Initiative ("NAI") on the NAI's website at http://optout.networkadvertising.org. If you are based in the European Union you may visit the website of the European Interactive Digital Advertising Alliance (“EIDAA”) at https://www.edaa.eu as well as of the European Advertising Standards Alliance (“EASA”) at http://www.easa-alliance.org.
The information we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal information about you which we have grouped together follows:
- Identity Data includes first name, last name, social media profile information, title, date of birth, and gender.
- Contact Data includes billing address, delivery address, email address, and telephone numbers.
- Transaction Data includes details about payments to and from you and other details of services you have purchased from us.
- Technical Data includes internet protocol (IP) address, your mobile device’s unique ID number, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this Website.
- Profile Data includes your username and password, purchases or orders made by you, your location, interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our Site, and services, such as the buttons, controls, products and ads you click on, pages of our Site that you visit, the time spent on those pages, and the dates and times of your visits.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
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 information
Where we need to collect personal information by law, or under the terms of a contract we have with you and you fail to provide that information 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 our services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.
How is your personal information collected?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity and Contact by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- contact us through our “Contact Us” or “Join Our Community” online forms;
- subscribe to our e-newsletter; or
- request marketing to be sent to you.
- Third parties or publicly available sources. We may receive personal information about you from various third parties [and public sources] as set out below:
- Technical Data from the following parties:
- analytics providers such as Google based outside the EU]; and
- advertising and affiliate networks such as Google based inside and outside the EU.
How we use your personal information
We will only use your personal information 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 or regulatory obligation.
Please check the table below to find out more about the types of lawful basis that we will rely on to process your personal data.
Generally we do not rely on consent as a legal basis for processing your personal information other than in relation to 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 at firstname.lastname@example.org.
Purposes for which we will use your personal information
We have set out below, in a table format, a description of all the ways we plan to use your personal information, and, for those of you who reside in the European Union, which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal information for more than one lawful ground depending on the specific purpose for which we are using your information. Please contact us at email@example.com if you need details about the specific legal ground we are relying on to process your personal information 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 administer and protect our business and this Site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||
||Necessary for our legitimate interests (to study how customers use our services, to develop them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve our website, services, marketing, customer relationships and experiences||
||Necessary for our legitimate interests (to define types of customers for our services, to keep our Site updated and relevant, to develop our business and to inform our marketing strategy)|
|To make suggestions and recommendations to you about services that may be of interest to you||
||Necessary for our legitimate interests (to develop our services and grow our business)|
|To review and process your application for a position with one of our companies||
||Necessary for our legitimate interests (to ensure that job candidates’ credentials meet the requirements for a particular position).|
We strive to provide you with choices regarding certain personal information uses, particularly around marketing and advertising. We have established the following personal information control mechanisms:
Promotional offers from us
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 is 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 if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal information with any company outside our company for marketing purposes, including service providers who perform marketing services on our behalf, such as conducting surveys, sending communications to you on our behalf, or serving advertisements to you.
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 at firstname.lastname@example.org.
Change of purpose
We will only use your personal information 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 at email@example.com.
If we need to use your personal information 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 information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law. In particular, we may be required to disclose personal information in response to lawful requests by public authorities, including for purposes of meeting national security or law enforcement requirements. We may also disclose personal information in the good faith belief that such action is necessary in order to conform to the edicts of the law or to comply with a legal process.
Disclosures of your personal information
We may have to share your personal information with the parties set out below for the purposes set out in the table in paragraph 4 above.
- Third Parties as set out in the Glossary.
We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.
We share your personal information within our company. This will involve, if you are based in the European Union, transferring your data outside the European Economic Area (EEA).
Many of our external third parties are also based outside the European Economic Area (EEA) so their processing of your personal information will involve a transfer of data outside the EEA.
If you are based in the European Union, whenever we transfer your personal information out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal information to countries that have been deemed to provide an adequate level of protection for personal information by the European Commission. For further details, see https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en
- Where we transfer your personal information to our corporate affiliates in the United States or use certain service providers based outside the EEA, we may use specific contracts approved by the European Commission which give personal information the same protection it has in Europe. For further details, see https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en
- Where we use providers based in the US, we may transfer information to them if they are part of the Privacy Shield which requires them to provide similar protection to personal information shared between the Europe and the US. For further details, see https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/eu-us-privacy-shield_en
- Please contact us at firstname.lastname@example.org if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information 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 will you use my personal information for?
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
Details of retention periods for different aspects of your personal information are available in our retention policy which you can request from us by contacting us at email@example.com
In some circumstances you can ask us to delete your information: see [Request erasure] below for further information.
In some circumstances we may anonymize your personal information (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal information. Please look at clause 10 below to find out more about these rights:
- Request access to your personal information.
- Request correction of your personal information.
- Request erasure of your personal information
- Object to processing of your personal information.
- Request restriction of processing your personal information.
- Request transfer of your personal information.
- Right to withdraw consent.
No fee usually required
You will not have to pay a fee to access your personal information (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 may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Performance of Contract means processing your information where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal information where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
- Service providers acting as processors based in the UK and the U.S., who provide IT and system administration services.
- Social networking sites acting as processors based in the United States to which you have linked your account. Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK and the U.S. who provide [consultancy, banking, legal, insurance and accounting services].
- Regulators and other government authorities acting as processors or joint controllers based in the UK and the U.S., who require reporting of processing activities in certain circumstances.
YOUR LEGAL RIGHTS
You have the right to:
- Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected, though we may need to verify the accuracy of the new information you provide to us.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal information to comply with local law. 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.
- Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal information. This enables you to ask us to suspend the processing of your personal information in the following scenarios: (a) if you want us to establish the information's accuracy; (b) where our use of the information is unlawful but you do not want us to erase it; (c) where you need us to hold the information even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your information but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal information to you or to a third party. We will provide to you, or a third party you have chosen, your personal information in a structured, commonly used, machine-readable format. 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.
- Withdraw consent at any time where we are relying on consent to process your personal information. 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 services to you. We will advise you if this is the case at the time you withdraw your consent.