You 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 ICO so please contact us in the first instance.
PERSONAL INFORMATION WE COLLECT
You can browse this website without being asked to provide any personal information, but we do collect technical data through cookies (see below) and Google Analytics (see below).
We obviously require a certain amount of information from you directly to allow us to fulfil your order, answer your queries and offer you the best possible shopping experience.
We only ever ask you to provide the minimum required to allow us to do that – name, address (including delivery address, if different), email and telephone number. If you make a purchase from us, we record details of any transactions you have made, including the products (or services) you have bought from us. [If you have an account with us we collect your username and password.]
We ask you for payment card details in order to process payment for your order, but we do not store these. (In addition, we are certified as being PCI-DSS compliant, so the transaction is as safe as we can reasonably make it.)
Apart from that, we also use Google Analytics to help us understand how our customers use the Site -- you can read more about how Google uses your Personal Information here: https://www.google.com/intl/en/policies/privacy/. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.
We may receive data about you from third parties such as technical data from analytics providers like Google (based outside the EU), and contact and financial information from payment providers (based in the EU).
Data collected in the UK is held in accordance with the Data Protection Act 2018. All reasonable precautions are taken to prevent unauthorised access to this information. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. This safeguard may require you to provide additional forms of identity should you wish to obtain information about your account details.
Cookies are data files that are placed on your device or computer and often include an anonymous unique identifier. Your Internet browser has the in-built facility for storing small files- "cookies" - that hold information which allows a website to recognise your account. Our website takes advantage of this facility to enhance your experience. You have the ability to prevent your computer from accepting cookies but, if you do, certain functionality on the website may be impaired.
HOW DO WE USE YOUR PERSONAL INFORMATION?
We use the personal information we collect:
- to perform our contract with you and fulfil any orders placed through the site;
- where it is necessary for our legitimate business interests (or those of a third party) and your interests and fundamental rights do not override those interests including to enhance your future experience and marketing from us (see below); and
- where we need to comply with the law.
Principally, that means:
- Processing your order
- Keeping you up-to-date with Spirit & Grace
- Improving your experience as a customer
We use the information that we collect to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimise our site (for example, by generating analytics about how our customers browse and interact with the site, and to assess the success of our marketing and advertising campaigns).
We may from time to time provide aggregated information of a general nature to third parties, for example, the number of individuals visiting our website or completing a registration form, but we will not use any information that could identify those individuals.
If you are an existing customer we may send you tailored marketing materials including information on new products, offers and promotions or news regarding Spirit & Grace; however you do have the opportunity to remove yourself from any mailing list at any time. We do not disclose information collected on this website to any third party for marketing purposes without your knowledge and consent.
When you place an order through the Site, we will maintain your Order Information for our records for six years after you cease being a customer or holding an account with us unless you ask us to delete this information (see YOUR LEGAL RIGHTS below).
DISCLOSING YOUR PERSONAL DATA
We may share your personal data with the following parties for the purposes we describe:
- Service providers acting as processors based [in the UK] who provide IT and system administration services.
- Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in [the UK].
- HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the UK who require reporting of processing activities in certain circumstances.
- Payment providers (such as PayPal, Klarna, based inside the EU) to approve and process payments.
In order to be able to offer you Klarna’s payment options, we will pass to Klarna certain aspects of your personal information, such as contact and order details, in order for Klarna to assess whether you qualify for their payment options and to tailor the payment options for you.
YOUR LEGAL RIGHTS
You have the right to:
- Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data 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 data 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 data to comply with local law. Note, however, that we may not 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 data 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 data 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 data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data's accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.
CHANGES TO THIS POLICY
We may review this policy from time to time and any changes will be notified to you by posting an updated version on this Site and/or by contacting you by email or via your account. Any changes will take effect 3 days after we post the modified terms on our website or after the date we notify by email or via your account. We recommend you regularly check for changes and review our policy when you visit this Site. If you do not agree with any aspect of the updated policy, you must promptly notify us and cease using this Site.
For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e-mail at firstname.lastname@example.org