Date of last update: 22 May 2018
For the purpose of the General Data Protection Regulation 2016/679 (the “GDPR”) the data controller is Clive Christian Perfume Limited (company number 03538453) of Yalding House, 4th Floor, 152-156 Great Portland Street, London, W1W 6AJ
Under the 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:
- you have given consent to the processing of your personal data for one or more specific purposes;
- 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;
- processing is necessary for compliance with a legal obligation to which we are subject;
- processing is necessary to protect the vital interests of you or of another natural person;
- 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
- processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data.
COLLECTION OF YOUR PERSONAL INFORMATION
We may collect and process the following data about you:
- Information you give us:
You may give us information about you by filling in forms on our site www.clivechristian.com (“Our Site”) or by corresponding with us by phone, e-mail,or otherwise. This includes information you provide when you register to use our site, search for a product, place an order on our site, enter a competition, promotion or survey and when you report a problem with our site. The information you give us may include your name, address, e-mail address and phone number, financial and credit card information and personal description/title.
1.2 Information we collect about you:
With regard to each of your visits to our site we may automatically collect the following information:
- Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, 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 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), and methods used to browse away from the page and any phone number used to call our customer service number.
1.3 Retail Partners / Dealerships
1.4 Information we collect automatically:
When you visit our site, view or click on our online advertisements (including our advertisements on third party websites), visit our social media pages, we also collect certain information about your usage or device by automated means by using technologies such as cookies, web server logs.
The data collected could be some or all of: Name, Host, rawhost, urldomain, path, issecure, ishttponly, issession, expires, isnew, sessionid, timestamp, browserid.
2.USE OF YOUR PERSONAL INFORMATION
2.1 How we use the information:
The information above that you may provide us with may be used to provide the following services:
- Send you promotional materials or other communications after you provide your consent by positively opting in to receive such materials and communications
- Process your payment when chosen to purchase our products on www.clivechristian.com
- Provide services to you and operational features on our site
- Create and manage your online account
- Chat with you or respond to your enquiries via our customer service email address
- Communicate special events, sweepstakes, surveys and offers through our positively opted in newsletter/email marketing
- Personalised adverts displayed to you on our site and elsewhere to your interests and online history with us
- Automated Decision-Making and Profiling
In the event that 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.
- The right described above does not apply in the following circumstances:
- The decision is necessary for the entry into, or performance of, a contract between the You and Us;
- The decision is authorised by law; or
- You have given you explicit consent.
Where We use your personal data for profiling purposes, the following shall apply:
- Clear information explaining the profiling will be provided, including its significance and the likely consequences;
- Appropriate mathematical or statistical procedures will be used;
- Technical and organisational measures necessary to minimise the risk of errors and to enable such errors to be easily corrected shall be implemented; and
- All personal data processed for profiling purposes shall be secured in order to prevent discriminatory effects arising out of profiling.
- We currently make the following automated decisions:When you visit this site or our online advertisements, or use one of our social networking or mobile applications, we collect certain information by automated means, using technologies such as cookies, web server logs and web beacons. Information may include (i) technical information, such as the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone settings, language settings, domain, operating system, platform or other system settings, and (ii) information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site, products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information, and methods used to browse away from the page and any phone number used to call our customer service number.
- We currently profile your personal data for the following purposes:We may use the information collected through automated means on this site to deliver personalised content for market research, data analytics and system administration purposes, such as to determine whether you’ve visited us before or are new to the site, and for compliance with our legal obligations, policies and procedures, including compliance with relevant industry standards and the enforcement of our Terms and Conditions. We may also use the information in other ways for which specific notice is provided at the time of collection.
3.SHARING OF YOUR PERSONAL INFORMATION
3.1 We do not sell or rent personal data, or otherwise disclose personal information we collect about you, except to the following:
- Any of the brands owned by any member of our group – including Clive Christian Perfume and Clive Christian Interiors
- Third party service providers who perform services on our behalf based on our instructions. We do not authorise these services providers to use or disclose the information except as necessary to perform services on our behalf or comply with legal requirements. Examples of these service providers include entities that process credit card payments, fulfil orders, provide web hosting and marketing activities, provide data cleansing and analytics services
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 the law. We currently contract with Mailchimp as a third party.
- Other third parties, but only with your explicit consent e.g. social media platforms
In addition, we may disclose information about you if we are required to do so by law or legal process, to law enforcement authorities or other government officials, or when we believe disclosure is necessary to appropriate to prevent physical harm or financial loss
We share your personal data within the Clive Christian Holdings Group, company based in the USA Clive Christian Perfume LLP, 584 Broadway, Suite 1100, New York, NY, 10012. This will involve transferring your data outside the European Economic Area (EEA).]
We ensure your personal data is protected by requiring all our group companies to follow the same rules when processing your personal data. These rules are called “binding corporate rules”. For further details, see European Commission: Binding corporate rules.
Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data 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:
- Data is only sent when fully encrypted.
- 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. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
- 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. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
- 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. For further details, see European Commission: EU-US Privacy Shield.
Please contact us on the details provided in clause 14 below if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
- INFORMATION STORAGE PERIOD
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. As a general rule we hold data for 6 years. If you would like more information on our retention periods please let us know.
- PROTECTION OF YOUR PERSONAL INFORMATION
We endeavor to have in place the appropriate technical and organisational measures to protect personal data you provide against accidental or unlawful destruction or accidental loss, alternation, unauthorised disclosure or access or use.
- SOCIAL MEDIA AND USER GENERATED CONTENT
Some of our sites allow users to submit their own content. Please note that any content submitted to one of our social platforms can be viewed by the public, and you should be cautious about providing certain personal information e.g. financial information, address details or health issues via these platforms. We are not responsible for any actions taken by other individuals if you post personal information on one of our social media platforms.
To remove or delete our apps from your social networking account, follow the instructions from the social network:
Facebook: Link provided by the FACEBOOK HELP CENTER.
You have the right to ask us not to process your personal data for marketing purposes. 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. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at firstname.lastname@example.org to remove your data from our records.
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.
- THIRD PARTY WEBSITE AND LINKS
Cookies are small text files that websites send to your computer or other Internet-connected device to uniquely identify your browser or to store information or settings in your browser. Your browser may tell you how to be notified when you receive certain types of cookies and how to restrict or disable certain cookies. Please note, however, that without cookies you may not be able to use all of the features of our website.
In conjunction with obtaining information through cookies, our web servers may log details such as your operating system type, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone in which your device is located. The web server logs also may record information such as the address of the web page that linked you to our site and the IP address of the device you use to connect to the Internet.
THIS WEBSITE WILL:
- Remember what is in your shopping basket
- Store custom user preferences and personalisation data
- Allow you to share pages with social networks like Facebook
THIS WEBSITE WILL NOT:
- Send information to other websites so that advertising is more relevant to you
Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit WWW.ABOUTCOOKIES.ORG or WWW.ALLABOUTCOOKIES.ORG.
12.Third Party Web Analytics
You may deactivate the ability of these analytics services to analyze browsing activities on this site:
To disable Google Analytics, please download the browser add-on for the deactivation of Google Analytics provided by Google at: http://tools.google.com/dlpage/gaoptout?hl=en
We may implement certain Google Analytics Advertising Features (including Remarketing with Google Analytics; Google Display Network Impression Reporting or Google Ad settings or by visiting http://tools.google.com/dlpage/gaoptout/
- CONTACT US
If you would like us to update the information we have about you or your preferences, including opt out of emailing, mailing, withdraw the consent and/or object to any processing of your data or if you have any questions about the protection of your personal information please contact us by email at email@example.com or send a letter to the following address:
Clive Christian Perfume Limited Yalding House
4th Floor, 152-156 Great Portland Street
No failure to exercise and no delay on our part in exercising any of our rights, remedies, powers or privileges under these Terms & Conditions (of which this Privacy & Cookies Policy forms part) and no course of dealing between us shall be construed or operate as a waiver, nor shall any single or partial exercise of any right, remedy, power or privilege preclude any other or further exercise thereof or the exercise of any other right, remedy, power or privilege on our part.
- LAW, JURISDICTION AND LANGUAGE
This website, any content contained herein, and any contracts entered into as a result of usage of this website are governed by English law. The parties to any such contract agree to submit to the exclusive jurisdiction of the courts of England and Wales. All contracts are concluded in English.