As at May 2020
1.4 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.
2. Who We Are
2.1 In accordance with Regulation (EU) 2016/679 (General Data Protection Regulation ‘GDPR’), here are our details as a 'data controller'. Our Website address is uk.bulkhomme.com. Our company name is RING LONDON ADVERTISING LIMITED and our registered address is 48 Warwick Street London W1B 5AW.
3. What we may collect
3.1 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).
3.2 We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity and contact data – first name, last name, username or similar identifier, email address, phone number and billing/invoicing address;
- Financial and transaction data – bank account data, payment card details, Services you have purchased from us and payment details;
- Profile data – username and similar identifier, password, reservations, interests, preferences, feedback and survey responses;
- Usage and technical data – information about how you use the Website and Services, ‘log files’ (such as your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions), ‘web beacons’, ‘tags’ and ‘pixels’ (information about how you browse the Website), operating system and platform and other technology on the devices you use to access the Website;
- Cookies data – please refer to the ‘Cookies’ section below for information about cookies and how we use them;
- Marketing and communications data – your preferences in receiving marketing from us. You may opt out of receiving any, or all, of these communications from us by contacting us.;
- Information we receive from Third Parties - we may receive information about you if you use any of the other websites we operate or through the Services we provide. In this case we will have informed you when we collected that data that it may be shared internally and combined with data collected on our Website. We are also working closely with third parties (including, for example, business partners, suppliers, sub-contractors, advertising networks, analytics providers, and search information providers) and may receive information about you from them. For example we use Shopify to power our online store – you can read more about how Shopify uses your personal data here: https://www.shopify.com/legal/privacy; and
3.4 We do not collect any sensitive 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.
3.5 Under GDPR we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following basis applies:
a) You have given consent to the processing of your personal data for one or more specific purposes;
b) processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;
c) processing is necessary for compliance with a legal obligation to which we are subject;
e) processing is necessary to protect the vital interests of you or of another natural person;
f) processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or
g) processing is necessary for the purposes of the legitimate interests pursued by us or by a third party such as our financial payments, except where such interests are overridden by the fundamental rights and freedoms of the data subject, in particular where the data subject is a child.
4. How we may collect and use your data
4.1 We (or third party data processors, agents and sub-contractors acting on our behalf) will collect, store and use your personal information through direct interactions such as filling in forms via our Website or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you present Website content, use any of our Services, create an account on our Website, subscribe to our publications, request marketing to be sent to you, enter a promotion or give us some feedback.
4.2 We may use the information in the following ways:
a) To present Website content effectively to you, to personalise your Website experience and to allow us to deliver the type of content and product offerings in which you are most interested;
b) To administer a contest, promotion, survey or other Website feature;
c) If you have opted-in to receive our newsletter/publication, we may send you periodic e-mails. If you would no longer like to receive promotional e-mail from us, please contact us on contact form. If you have not opted-in to receive e-mail newsletters, you will not receive these e-mails;
d) To communicate with you and to provide information, and services that you request, or (with your consent) which we think may interest you;
e) Carry out our contracts with you, including screening orders for potential risk of fraud where appropriate; and
f) Provide the relevant Services to you, including telling you our charges, fulfilling orders placed on our Website, processing your payment information, arranging shipping of products and providing you with order confirmations.
4.3 If you don't want us to use your personal data for any of the reasons set out in this section 4, you can let us know at any time by contacting us at email@example.com, and we will delete your data from our systems. However, you acknowledge this will limit our ability to provide the best possible products and services to you.
4.4 In some cases, the collection of personal data may be a statutory or contractual requirement, and we will be limited in the products and services we can provide you if you don't provide your personal data in these cases.
5. Automated Decision-Making and Profiling
5.1 Where we use personal data for the purposes of automated decision-making and those decisions have a legal (or similarly significant effect) on you, you have the right to challenge to such decisions under GDPR, requesting human intervention, expressing their own point of view, and obtaining an explanation of the decision from us.
5.2 The right described in this section does not apply if: (a) the decision is necessary for the entry into, or performance of, a contract between the you and us; (b) the decision is authorised by law; or c) you have given your explicit consent.
5.3 Where we use your personal data for profiling purposes, the following shall apply:
a) Clear information explaining the profiling will be provided, including its significance and the likely consequences;
b) Appropriate mathematical or statistical procedures will be used;
c) Technical and organisational measures necessary to minimise the risk of errors and to enable such errors to be easily corrected shall be implemented; and
d) All personal data processed for profiling purposes shall be secured in order to prevent discriminatory effects arising out of profiling.
6. Where we store your data and security
6.2 Where we use providers based in the US, we may 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.
6.3 Data security is of great importance to us, and to protect your data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through our Website. We have implemented security measures such as a firewall to protect any data and maintain a high level of security. Any payments made by you will be encrypted. By giving us your personal data, you agree to this arrangement. We will do what we reasonably can to keep your data secure. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
6.4 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.
6.5 Notwithstanding the security measures that we take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to us data via the internet and you take the risk that any sending of that data turns out to be not secure despite our efforts. If we give you a password upon registration on our Website, you must keep it confidential. Please don't share it.
6.6 We will keep personal data for as long as is necessary which is usually the life of our relationship and for a period after our relationship has ended. We may however be required to retain personal data for a longer period of time to ensure we comply with our legislative and regulatory requirements. We review our data retention obligations to ensure we are not retaining data for longer than we are legally obliged to.
7. Disclosing your information
7.1 We are allowed to disclose your information in the following cases:
7.1.1 If we want to sell our business, or our company, we can disclose it to the potential buyer;
7.1.2 We can disclose it to other businesses in our group;
7.1.3 We can disclose it if we have a legal obligation to do so, or in order to protect other people's property, safety or rights; or
7.1.4 We can exchange information with others to protect against fraud or credit risks.
7.2 We may contract with third parties to supply services to you on our behalf. These may include payment processing providers, search engine facilities, advertising and marketing suppliers. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, we will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under Data Protection Legislation.
8. Your rights
8.1 Under GDPR, European customers have the right (free of charge) to:
- request access to, deletion of or correction of, your personal data held by us;
- request that your personal data be transferred to another person (data portability);- be informed of what data processing is taking place;
- restrict processing;
- object to processing of your personal data; and
- complain to a supervisory authority.
8.2 You also have rights with respect to automated decision-making and profiling as set out in section 6 above.
8.3 You have the right to ask us not to process your personal data for marketing purposes. We will always 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.
9.2 For more information or questions about our privacy practices or if you would like to make a complaint, please contact us by email on firstname.lastname@example.org or click on the ‘Go To Advise Email’ on our Website.