PRIVACY POLICY
This Privacy Policy explains in detail the types of personal data we may collect about you when you interact with us.
It also explains how we store and handle that data, and keep it safe.
There’s a lot of information here but we want you make sure you’re fully informed about your rights and how Isabel Haines uses your data.
We hope the following notice will answer any questions you have but, if not, please email us on info@isabelhaines.com
1. PURPOSE OF THIS PRIVACY POLICY
1.1 This privacy policy aims to give you information on how Isabel Haines collects and processes your personal data through your use of our website including any data you may provide through our website when you purchase a product or service, order a brochure, a sample, sign up for our newsletter or when we take your details (collect your personal data) over the phone, by email or at a fair or event in order to take your order or answer any questions you have about our products. It is important that you read this privacy policy together with any other privacy policy or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements the other notices and is not intended to override them.
2. CONTROLLER
2.1 The data controller is Isabel Haines, "we", "us" or "our" in this privacy policy).
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy including any requests to exercise, please contact the data privacy manager using the details set out below:
GDPR Controller
Isabel Haines
26 Hansler Grove
East Molesey
Surrey KT8 9JN
Email: info@isabelhaines.com
Tel: 07733113440
VAT Number: 267 070501
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.
3. CHANGES TO OUR PRIVACY POLICY
3.1 This version was last updated on 24/05/2018. You can access archived versions by contacting us.
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.
4. WHEN DO WE COLLECT PERSONAL DATA FROM YOU
4.1 We may collect and process the following data about you:
When you purchase or enquiry about a product at a fair or charity event
When you make a purchase or enquiry by email or by phone
When you make an online purchase
When you sign up for our email newsletter
When you engage with us on social media
When you contact us by any means with queries, complaints, etc
When you enter prize draws or competitions
When you comment on or review our products and services
When you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions, patterns and the website that referred you to isabelhaines.com. We collect this personal data by using cookies, server logs and other similar technologies. Technical Data is collected from the following parties: analytics and search information providers (such as Google) and advertising networks (such as AdRoll). Please see our cookie policy for further details.
When you've given a third party permission to share with us information they hold about you
We collect data from publicly-available sources when you have given consent to share information or where the information is made public as a matter of law
5. PERSONAL DATA WE MAY COLLECT FROM YOU
5.1 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).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
Identity Data including first name, last name, title.
Contact Data including billing address, delivery address, email address, telephone numbers. We will also collect your social media username, if you interact with us through those channels.
Financial Data including bank account and payment card details
Transaction Data including details about payments to and from you and other details of products you have purchased from us
To deliver the best possible web experience, we collect Technical Data including internet protocol (IP) address, 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 our website.
Profile Data including purchases or orders made by you, your interests, preferences, feedback and survey responses.
Usage Data including information about how you use our website. This includes information gathered by the use of cookies in your web browser.
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 may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
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.
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.
6. HOW AND WHY WE USE YOUR PERSONAL DATA
6.1 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 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.
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
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.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
6.2 Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message.
Remember, if you choose not to share personal data with us, or refuse certain contact permissions, we might not be able to provide some services you asked for.
Examples of how we use information held about you include:
To process any orders that you make on our website or at an event. If we don't collect your personal data during checkout, we won't be able to process and deliver your order and comply with legal obligations. For example, your details may need to be passed to a third party to supply or deliver the product or service that you ordered, and we may keep your details for a reasonable period afterwards in order to fulfil any contractual obligations such as refunds, guarantees and so on.
To respond to your queries, refund requests and complaints. Handling the information you send enables us to respond. We may also keep a record of these to inform any future communication with us and to demonstrate how we communicated with you throughout. We do this on the basis of our contractual obligations to you, our legal obligations and our legitimate interests in providing you with the best service and understanding how we can improve our service based on your experience.
To send you relevant communications by email or post in relation to updates, products and services. We'll do this on the basis of our legitimate business interest. You are free to opt out of hearing from us by email or post at any time.
To administer any of our prize draws or competitions which you enter
To develop, test and improve the systems, services and products we provide to you. We'll do this on the basis of our legitimate business interests.
To comply with our contractual or legal obligations to share data with law enforcement.
To send you survey and feedback requests to help improve our services. These messages will not include any promotional content and do not require prior consent when sent by email or text message. We have a legitimate interest to do so as this helps make our products or services more relevant to you.
To build a picture of who you are and your interests, and to inform our business decisions, we'll combine data captured by Isabel Haines, third parties and data from publicly-available lists as we have described in the section 'Personal Data we collect from you?' We'll do this on the basis of our legitimate business interest.
7. WHO DO WE SHARE YOUR DATA WITH?
7.1 We may have to share your personal data with the parties set out below for the purposes outlined in item 6.
Examples of the kind of third parties we work with are:
IT companies who support our website and other business systems
Operational companies such as delivery couriers
Manufacturers of custom order or personalised products
Google, Facebook, Pinterest and AdRoll to show you products that might interest you while you're browsing the internet. We'll also use your data to identify other internet users who share similar interests. This is based on your acceptance of cookies on our website. For more information about the cookies we use, please see the cookie policy.
For fraud management, we may share information about fraudulent or potentially fraudulent activity on our premises, at events or systems. This may include sharing data about individuals with law enforcement bodies.
We may also be required to disclose your personal data to the police or other enforcement, regulatory or Government body, in your country of origin or elsewhere, upon a valid request to do so. These requests are assessed on a case-by-case basis and take the privacy of our customers into consideration.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
In order to protect your privacy we will:
Only provide the information necessary to perform their specific services
Only use their data for the exact purpose we specify in our contract with them
Work closely with them to ensure their privacy is respected and protected at all times
7.2 Cookies
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.
We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.
Overall, cookies help us provide you with a better website, 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.
You can set your browser to accept or refuse cookies. Most web browsers automatically accept cookies, but you can disable or refuse cookies. If you disable or refuse cookies, this may prevent you from taking full advantage of the website as some parts may be inaccessible or not function properly.
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 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.
7.3 Links to other websites
Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.
8. HOW WE PROTECT YOUR DATA
8.1 The security of your personal data is very important to us and we are committed to ensuring your information is secure, taking all appropriate physical, electronic and managerial procedures to safeguard and protect it.
We have put in place appropriate security measures to prevent your personal data in digital or written format from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. 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. Access to your personal data is password-protected, and sensitive data (such as payment card information) is secured to ensure it is protected.
We secure access to all transactional areas of our websites and apps using 'https' technology.
We regularly monitor our system for possible vulnerabilities and attacks, and we carry out penetration testing to identify ways to further strengthen security.
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.
9. HOW LONG WILL YOU KEEP MY DATA FOR?
9.1 We will only retain your personal data 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 data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. For example, if your order included a product guarantee, the associated personal data will be kept until the end of the guarantee period.
At the end of that retention period, your data will either be deleted completely or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning.
10. WHAT ARE YOUR RIGHTS OVER YOUR PERSONAL DATA?
11.1 Under certain circumstances, you have rights under data protection laws in relation to your personal data.
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 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 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: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) 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. We will provide to you, or a third party you have chosen, your personal data 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 data. 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 products or services to you. We will advise you if this is the case at the time you withdraw your consent.
In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.
You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We must always comply with your request.
If you wish to exercise any of the rights set out above, please contact us at Isabel Haines, Privacy Rights, 26 Hansler Grove, East Molesey KT8 9JN or by email info@isabelhaines.com
To ask for your information to be amended please email us on info@isabelhaines.com.
To opt out of postal marketing email us on info@isabelhaines.com
To opt out from email marketing please click on the unsubscribe link featured at the bottom of each marketing email we send.
If we choose not to action your request we will explain to you the reasons for our refusal.
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 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 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 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.
