- Important information and who we are
Email address: firstname.lastname@example.org
Postal address: 85 Great Portland Street, First Floor, London, W1W 7LT
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.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
- Third-party links
The website may include links to the websites belonging to third parties. We are not responsible for any content published by any such third parties, nor we are responsible for any malware contained on any such websites. Before filling in your personal details please ensure that you are doing so on our website to avoid unauthorised use of your personal data by any third party.
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 collect personal data when you place an order, call our Customer Care team, sign up for our marketing communications, browse our website. We also collect data regarding your shopping habits and the pages and the products that you have viewed from your use of our website.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- "Identity Data" includes first name, maiden name, last name, username or similar identifier, title, date of birth and gender.
- "Contact Data" includes past and present billing addresses, delivery address, email address, telephone numbers, company details, contact details of any representatives.
- "Financial Data" includes bank account details or any other payment account which you use to pay for the orders.
- "Transaction Data" includes details about payments for the orders that you make.
- "Technical Data" includes internet protocol (IP) address, 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, your interests and preferences.
- "Usage Data" includes data about how you came to the website; the date and time of your visit; products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction data (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.
- "Marketing and Communications Data" includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share "Aggregated Data" such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity.
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 provide to us personal information belonging to someone else
If you provide personal information about other people then you must:
- seek their prior consent; and/or
when providing information about other people, ensure that you have all relevant permissions and authority: (i) to make all necessary disclosures; (ii) to act on their behalf; and (iii) in relation to partners, members, shareholders or beneficial owners of borrowers, to allow us to make credit checks at credit reference agencies and otherwise for verification, in respect of those persons.
- If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data 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 goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- apply for our services;
- create an account on our site;
- subscribe to our service or publications;
- request marketing to be sent to you; or
- give us feedback or contact us.
- Automated technologies or interactions. As you interact with our site, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
- Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
- Technical Data from the following parties:
(a) analytics providers such as Google based outside the EU;
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services;
- Identity and Contact Data from data brokers or aggregators; and
- Identity and Contact Data from publicly available sources.
- How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- 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 obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third-party direct marketing communications to you via email, text message or post. You have the right to withdraw consent to marketing at any time by contacting us at email@example.com.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and 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 data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Type of data
Lawful basis for processing including basis of legitimate interest
to register you as a new website user
to take your orders
to enable delivery of our marketing communications if you choose to subscribe to receive such emails from us
to enable delivery of our marketing communications via post if you choose to subscribe to our mailing list
(a) performance of a contract with you
(b) necessary for our legitimate interests
to process and deliver orders
to detect and prevent fraud
to verify your identity and the other information you have provided to us, including your bank account information
to allow us to fulfil our contract with you including taking payment, completing any related anti-fraud checks if you choose to pay by credit/debit card, billing, shipping and delivery of the product and possible handling of the return
to train our staff
to give you access to services reserved for registered users
to provide you help and assistance via our Customer Care team
to provide product recommendations
(e) Marketing and Communications
(a) performance of a contract with you
(b) necessary for our legitimate interests
(c) necessary to comply with our legal and regulatory obligations
to manage our relationship with you which will include:
(b) asking you to leave a review or take a survey.
to carry out statistical analysis and market research and testing
to help us improve the website and our promotion of the website
to allow us to provide you with the services on the website, such as placing and holding items in your shopping bag
to collect the data (when you register on the website) necessary to ensure that we can recognise you on return visits and provide you with the services registration offers, or subscribing to emails about our products
to run the survey, competition or promotion
(d) Marketing and Communications
(a) necessary to comply with a legal obligation
(b) necessary for our legitimate interests (to keep our records updated and to study how customers use our services)
to administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
to personalise your visit to the website and ensure the content from our site is presented in the most effective manner for you and for your computer
to update the records we hold about you from time to time
(a) necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) necessary to comply with a legal obligation
to deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
to develop and improve our services, products and business, including analysing and improving our credit risk models, data collected and our customer service offering
to provide and administer the marketplace and our related services
(e) Marketing and Communications
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 site, services, marketing, customer relationships and experiences
necessary for our legitimate interests (to define types of customers for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
to make suggestions and recommendations to you about products that may be of interest to you
(f) Marketing and Communications
necessary for our legitimate interests (to develop our services and grow our business)
If you provide us with your credit card information, the information is encrypted using secure socket layer technology (SSL) and stored with a AES-256 encryption. Although no method of transmission over the Internet or electronic storage is 100% secure, we follow all PCI-DSS requirements and implement additional generally accepted industry standards.
Who we disclose your personal information to as part of our services?
We may retain the services of external suppliers to help meet our business needs and may share your data with these suppliers. These suppliers have been selected after a rigorous evaluation process and chosen for their security, reliability and competence. They will process your data only under our instructions. We may disclose your personal data:
- to companies in our group and our affiliates; and
- to our suppliers, sub-contractors and third-party data processors (including payment processors, marketing and data analytics service providers, collection agents, tracing agents, professional advisers and persons who provide us with the following services from time to time: marketing; technology; marketplace support; and back-up and business continuity);
- with any third party you have asked us to share your personal data with, including social media sites if you have asked us to connect with your social media account;
- to a third party if it acquires all or part of our business or assets in connection with the acquisition, or to a successor in interest in the unlikely event of our insolvency, winding up or liquidation;
- if we are required to do so by applicable law and regulation or by any governmental, tax, regulatory body or law enforcement agency;
- if you are represented by an agent, to your agent; and
- to any other person with your prior consent to do so.
Any such third parties who process your personal data on our behalf are only permitted to process your personal data in accordance with our instructions and we take steps to ensure that the transfer and any on-going processing by those third parties is carried out securely and in accordance with applicable data protection laws.
If you opt-in to receive marketing information from us, we will send you messages by email and text to keep you informed of new arrivals, special offers, sales and promotions.
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 services and offers may be relevant for you.
You may opt out from receiving our marketing communication at any time by contacting our Customer Care team at firstname.lastname@example.org. Once you opt out, we will cease sending you marketing communications, however our system may take some time to adjust and you may still receive marketing emails before our system is fully updated.
Stopping marketing messages will not stop service communications, such as order updates.
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 services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase, warranty registration, product/service experience or other transactions.
Change of purpose
We will only use your personal data 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 data 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 data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
- Disclosures of your personal data
We may share your information with selected third parties including:
- business partners, suppliers and sub-contractors for the performance of any contract we enter into with you;
- advertisers and advertising networks that require the data to select and serve relevant adverts to you and others; or
- analytics and search engine providers that assist us in the improvement and optimisation of our site.
We may disclose your personal information to third parties:
- In the event that we sell or buy any business or assets, in which case we may disclose your personal information to the prospective seller or buyer of such business or assets.
- If all or substantially all of our assets are acquired by a third party, in which case personal information held by it about its customers will be one of the transferred assets.
- 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 our terms set out herein.
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 data for?
We will not keep your personal information for longer than is necessary, for the purposes for which it was collected and is processed and for the purposes of satisfying our legal, accounting or regulatory reporting requirements. We may retain personal information for longer than this in certain circumstances, for example in the event of an ongoing dispute. We may retain your personal information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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 unauthorised 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, regulatory, tax, accounting or other requirements.
In some circumstances you can ask us to delete your data by contacting our Customer Service Team at firstname.lastname@example.org.
In some circumstances we will anonymise 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.
- Where we store your personal information
A cookie is a small file which asks permission to be placed on your computer's hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.
Overall, cookies help us provide you with a better site, 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.
All Cookies used by and on the website are used in accordance with the Data Protection Legislation. We may use some or all of the following types of Cookies:
- Strictly Necessary Cookies
- Analytics Cookies
- Functionality Cookies
- Targeting Cookies
- Third Party Cookies
- Persistent Cookies
- Session Cookies
Any of the above types of Cookie may be a session Cookie. Session Cookies are temporary and only remain on your computer or device from the point at which you visit the website until you close your browser. Session Cookies are deleted when you close your browser.
We may use the following Cookies:
_ session id, unique token, sessional
allows Shopify to store information about your session (referrer, landing page, etc.)
_shopify_visit, no data held
used by our website provider’s internal stats tracker to record the number of visits
_shopify_uniq, no data held
counts the number of visits to a store by a single customer
stores information about the contents of your cart.
if the shop has a password, this is used to determine if the current visitor has access
Google Analytics Tag
reviews performance and audience browse and shopping behaviours
display the right message to the right people on Facebook paid advertising
displays the right message to the right people on Twitter paid advertising
displays video footage related content hosted in our YouTube channel
- Where we store your personal information
If you choose a direct payment gateway to complete your purchase, then Shopify stores your credit card data. It is encrypted through the Payment Card Industry Data Security Standard (PCI-DSS).
Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access and will ensure that any third party receiving your personal data adopts such appropriate measures necessary to safeguard your personal data.
Whenever we transfer your personal information out of the EEA, we ensure a similar degree of protection is afforded to it. 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.
- Overseas transfers
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 data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
- Some of our suppliers and some group companies may be based in non-EU countries. Where this is the case, the transfer of your personal data to these countries is carried out in compliance with the guarantees provided by law.
- The USA is not a country in respect of which there is a European Commission decision of adequacy. To transfer personal data from the EU to the US we use different tools which are available, such as contractual clauses, binding corporate rules and the Privacy Shield. Where we use providers based in the US, we may also transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield. The US Department of Commerce is responsible for managing and administering the Privacy Shield and ensuring that companies live up to their commitments.
The Privacy Shield allows your personal data to be transferred from the EU to a company in the United States, provided that the company there processes your personal data according to a strong set or data protection rules and safeguards. The protection given to your data applies regardless of whether you are an EU citizen or not.
- Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
- Your legal rights
Under certain circumstances, you have rights under the relevant data protection laws in relation to your personal information.
- right to rectification
If your personal information is incorrect or incomplete any way, you may notify a person dealing with your matter and where inaccurate or incomplete, we will correct it without delay.
- right of access
You have a right to:
- request a confirmation from us that we are processing your personal information;
- access your personal information held by us and request a copy (unless providing a copy adversely affects the rights and freedoms of others);
- obtain certain information about how we process your personal information, categories of personal information processed, recipients or categories of recipients who receive personal information from us; and
- request how long we store your personal information for and the criteria we use to determine retention periods.
- right to be informed
You have a right to be informed:
- how your personal information is being processed;
- how long it will be stored for;
- the legal basis for processing;
- recipients (or categories of recipients) of your personal information; and
- whether personal information must be provided under statute or for another reason and the consequences of not providing the personal information to ensure the fair and transparent processing of your personal information.
- right to restrict processing under certain circumstances
You have a right to restrict processing under certain circumstances:
- if you contest the accuracy of your personal information, we may restrict its processing, until we can verify its accuracy;
- if the processing is unlawful;
- If we no longer need to process your personal information, unless we still need your personal information for the establishment, exercise, or defence of legal claims; and
- if you object to processing that relies on public interest or our (or third party’s) legitimate interest as the lawful processing ground.
- right to data portability
- You have a right to receive from us a copy of your personal information in commonly used and machine-readable format and store it for further use on a private devise.
- You have a right to transmit personal information to another third party; or have your personal information transmitted directly from one third party to another where technically possible.
- right not to be subject of automated processing
You have a right not to be subject to automated decision-making, including profiling, which has legal or other significant effects on you. This does not apply when the automated decision is necessary for entering into or performing a contract with you; or it is authorised by EU or member state law applicable to us if the law requires suitable measures to safeguard your rights and freedoms and legitimate interests; or based on your explicit consent.
- the right to object to processing
You may object to direct marketing, including profiling related to direct marketing. We will stop processing your personal information once notified by you, except if we can demonstrate a compelling legitimate ground for processing the personal information that overrides your request; or processing is necessary to exercise or defend legal claims.
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
You will not have to pay a fee to access your personal data (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 could 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 data (or to exercise any of your other rights). This is a security measure to ensure that personal data 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 could 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.
"Comply with a legal obligation" means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
"Legitimate Interest" means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us at email@example.com.
"Performance of Contract" means processing your data 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.
"External third parties" means:
- service providers acting as processors based in the United Kingdom who provide reals estate services;
- Shopify Inc (to learn more about Shopify Inc please follow this link); and
- professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.