CLARETTE LONDON (”We”) are committed to protecting and respecting your privacy.
This policy and any other documents referred to on it sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting www.clarettelondon.com or any of our social media channels you are accepting and consenting to the practices described in this policy.
For the purpose of the General Data Protection Regulations (the GDPR), the data controller is CLARETTE LONDON of 44 BLANDFORD STREET, LONDON W1U 7HS who can be contacted using the following contact details email@example.com
The identity of the Data Protection Officer (the DPO) is Rudolph Galand of CLARETTE LONDON. 44 BLANDFORD STREET, LONDON W1U 7HS Your point of contact for any issues relating to this policy or to your personal data is Rudolph Galand of CLARETTE LONDON. 44 BLANDFORD STREET, LONDON W1U 7HS . The email address you should use to contact them is firstname.lastname@example.org
INFORMATION WE COLLECT FROM YOU
We will collect and process the following data about you:
- Information you give us. This is information about you that you give us by filling in forms on our site www.clarettelondon.com (our site) or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use our site, subscribe to our WiFi, place a booking on our site and when you report a problem with our site. The information you give us may include your name, address, e-mail address, date of birth and phone number, financial and credit card information, personal description and photograph.
- Information we collect about you. With regard to each of your visits to our site we will automaticallycollect the following information:
- technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
- information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), products and pages you viewed or searched for’ page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page and any phone number used to call our customer service number.
- Information we receive from other sources. This is information we receive about you if you use any of the other websites we operate or the other services we provide. In this case we will have informed you when we collected that data if we intend to share those data internally and combine it with data collected on this site. We will also have told you for what purpose we will share and combine your data. We are working closely with third parties (including, for example, business partners, sub-2 contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies). We will notify you when we receive information about you from them and the purposes for which we intend to use that information.
We primarily use information from cookies for the following purposes:
- Traffic monitoring, e.g., the IP address from which you access the site, the type of browser and operating system used to access the site, the date and time of your access to the site, the pages you visit, and the Internet address of the website from which you accessed the site.
- To register you in programs and to recognize your website preferences.
- To recognize repeat visitors for statistical / analytical purposes.
- Anonymous tracking of interaction with online advertising, e.g., to monitor the number of times that a banner ad is displayed and the number of times it is clicked.
- To compile and report to third parties (such as advertisers) aggregate statistics about our users in terms of numbers, traffic patterns and related site information.
- We may also use clear gifs (also known as web bugs or web beacons), which are tiny graphics embedded in web pages and email messages that we use, in connection with cookies, to collect nonpersonal information from users to analyze site usage, manage content on the site, track visits to other related sites, and track the performance of online advertising.
- We may also connect the information that we collect through cookies and clear gifs with other personal information that you provide to us in order to:
- customize or personalize your experience of the site; for example, so that we can greet you on the site by name;
- conduct transactions, such as credit card sales;
- monitor your use of our website(s) in order to make our communications to you as relevant as possible and for other marketing and advertising research purposes.
USES MADE OF THE INFORMATION
We use information held about you in the following ways:
- Information you give to us. We will use this information:
- to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
- to provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about;
- to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you. If you are an existing customer, we will only contact you by electronic means (e-mail or SMS) with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you. If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have specifically consented to this;
- to notify you about changes to our service;
- to ensure that content from our site is presented in the most effective manner for you and for your computer.
- Information we collect about you. The legitimate interests that we will rely upon to process this information are:
- to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
- to allow you to participate in interactive features of our service, when you choose to do so;
- as part of our efforts to keep our site safe and secure;
- to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
- to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them via email.
- Information we receive from other sources. We will combine this information with information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).
If we are not able to process your personal data whether because you do not consent, you withdraw or limit consent, or for any other reason then we will not be able to achieve the purposes listed above.
DISCLOSURE OF YOUR INFORMATION
You agree that we have the right to share your personal information with:
- Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006
- Selected third parties including:
- business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
- advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers, but we will provide them with aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in SW1). We may make use of the personal data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience;
- analytics and search engine providers that assist us in the improvement and optimisation of our site;
- credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you
We will disclose your personal information to third parties:
- In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets
- If CLARETTE LONDON or substantially all of its assets are acquired by a third party, in which case personal data 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 data in order to comply with any legal obligation, or to protect the rights, property, or safety of CLARETTE LONDON our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
WHERE WE STORE YOUR PERSONAL DATA
All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology. 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. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
AUTOMATED DECISION MAKING
We do use automated decision making including profiling. For example; you may receive different marketing messages from us based on your interaction with automated email marketing campaigns.
RETENTION OF DATA
Your data is retained and cleansed in accordance with our Data Retention and Cleansing Policy which can be obtained by contacting our Data Protection Officer via email@example.com
We will only process your data for marketing purposes where you have either given express consent to us to do so or where there is a legitimate interest for us to do so. The legitimate interests that we will rely on are as listed above under “Uses made of the Information – Information that we collect about you”.
In any event, we will only rely on legitimate interest as a grounds for processing your data where we have completed a Legitimate Interest Assessment and where such assessment supports the use of such data processing. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes.
At any time, even if you have previously consented, you have the right to ask us not to process your personal data for marketing purposes and/or not to disclose it to third parties for marketing purposes. You can do this by contacting us using the following email address: firstname.lastname@example.org. You can also use this email address to notify us of any preferences you have in relation to the processing of your data for example as to the frequency of communications that you receive from us or the manner or the subject matter of such communications
The GDPR also gives you the following rights:
- 1. to access information held about you;
- 2. to request the deletion or correction of information held about you;
- 3. to object to or restrict the processing of information about you;
- 4. to request that information about you be transferred to another person;
- 5. to complain to the relevant supervisory authority.
You can exercise rights 1 – 4 by contacting us using the following contact details email@example.com
In the UK this is the Information Commissioner’s Office (ICO) https://ico.org.uk/ whose contact details are as follows:
Information Commissioner’s Office
THIRD PARTY SITES
Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
If you have any complaints in relation to how our business has processed your data or in relation to the exercise of your rights as detailed above you can in the first instance raise your concerns by contacting us as follows: CLARETTE LONDON. 44 BLANDFORD STREET, LONDON W1U 7HS
You may also contact the Information Commissioner’s Office in relation to any such complaints https://ico.org.uk/
Information Commissioner’s Office