Last updated August 2019
1. Why do we need your personal data?
Charlotte Wikke Limited, hereafter identified as www.charlottes.shopping, uses information from our interactions with you to help achieve its goal of providing the highest quality products and services. www.charlottes.shopping respects the privacy rights of our online visitors and recognises the importance of protecting the information collected about them. To this end, we have established procedures that ensure your personal data is processed in a responsible manner.
DEFINITIONS: The definition of personal data means any information relating to an identified or identifiable natural person. An identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. The term ‘processing,’ in this context mean any operation or set of operations performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
2. Who controls the data?
www.charlottes.shopping determines the purposes and means of the processing of your personal data. Carrying with it legal responsibilities, a data controller is legally responsible for the storing and use of personal information on computer or in manual files.
Charlotte Wikke Limited
20 Prior Place
Oxfordshire OX12 7FP
www.charlottes.shopping does not employ a Data Protection Officer. If you have any questions or concerns regarding privacy or if you have any enquires regarding the personal data you have given us, please contact www.charlottes.shopping at any time. For details on how to contact us, please see “Contact Information” or send an email directly to our Privacy Responsible: firstname.lastname@example.org
3. What personal data is collected?
All our activities are based on stringent ethical principles and legal requirements, and we are committed to protecting the privacy of all visitors to our website. For this reason, the way in which we collect and store information, including personal data, is dependent on how our website and related services are used. We do not collect any sensitive data about you. 3.1 Data collected through your interaction with us Various technologies may be used on our websites in order to improve them, make them more user-friendly, efficient and secure. Such technologies may lead to personal data being collected automatically by us or by third parties on our behalf. Examples of such technologies include cookies and web analytics. Our website may, from time to time, contain links to and from the websites of our partner networks and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies for which we do not accept any liability. Please check these policies before you submit any personal data to their websites.
3.1.1 Click-stream data When you visit our website, data is sent from your browser to our server. This data makes it possible for us to optimise our services and improve your experience on our website. The data is automatically collected and stored by us or by third parties on our behalf. We may collect information about your computer for system administration purposes as well as to report aggregate information for internal marketing analysis reasons. This is data about our users’ browsing actions and patterns and may include the following:
• Visitor’s IP address
• Date and time of the visit
• Referral URL (the site from which the visitor has been referred)
• Pages visited and user journey on our website
• Information about the browser used (type, version, operating system, etc.)
3.2 Data provided by you In addition to the data collected by automated means (see 3.1), we also process data which you have provided to us. This includes but is not limited to:
• Personal data that identifies you as an individual—namely, your contact information, title, including your first and last name(s), billing address(es), post code, telephone number, email address.
• Information provided by you at the time of registration for a www.charlottes.shopping account.
• Information provided when you create a Wish List,
• Information you provide when you enter a competition or promotion sponsored by www.charlottes.shopping
• Information you provide to us via third parties such as Facebook, Instagram and Pinterest
• Information that you upload to or share through our site by using our services such our Blog or by submitting reviews.
• If you have created an online account with us: the preferences and interests stored in this profile (please see below for further information regarding these profiles).
• If you contact us, we may keep a record of your correspondence.,
• If you contact us to report a problem with our site or for technical and/or customer support, we may keep a record of your correspondence or conversation.
4. How is the collected data processed?
When you have registered for a www.charlottes.shopping account, we may process your personal data in the following ways:
• Ensure that content from our site is presented on your computer in the most efficient manner.
• For purposes relating to your order; e.g. to notify you on the status of your order or delivery; to fulfill your requests, such as responding to a question regarding our products; to help you locate a store near you; to fulfill your order; to process your payment card and/or to provide you with customer service.
• Verification of your identity and to respond to any query you may raise with us; to process your request and provide you with the best service possible.
• To carry out our obligations arising from any contracts entered into between you and us.
• To allow you to participate in the interactive features of our service(s) when you choose to do so.
• To notify you about changes to our services, terms, conditions and policies, and/or other administrative information.
• To provide you with the benefits and services of being a www.charlottes.shopping account holder.
• To administer and maintain our records.
• To store any Wish List you may create and to allow you to share your Wish List with others.
• To allow you to send emails to others through our “send to a friend” functionality.
• To allow you to participate in sweepstakes, contests and similar promotions as well as to administer such activities. Some of these activities have additional rules which could contain additional information about how we use and disclose your personal information.
• Customise your content on our websites to provide you with personalised offers.
• Prevent and/or detect any misuse or fraud. • With your permission, we may contact you directly through the details provided by you (e.g. postal services, email, text message, telephone or any other electronic means) for marketing, advertising and market research purposes. For example, this includes information related to www.charlottes.shopping products, e-commerce activities, special offers and promotions.
In order to be able to contact you with information that is of special interest to you, your overall interaction with www.charlottes.shopping (such as, but not limited to, your shopping behaviour on our online store; your use of any loyalty programmes we may decide to launch; your ratings and reviews of products; your contact history with our customer service; your newsletter clicks/opening results; your surfing behaviour (web tracking); the types of newsletter you are subscribed to; your participation in promotions or events) will be jointly analysed and used. We may use your personal data for marketing, advertising and market research purposes. In paragraph 7 you will find information on your rights, e.g. how to withdraw your consent or amend your personal details. 4.1 When you visit www.charlottes.shopping’s website your personal data may be processed in the following ways:
• Content and product browsing analytics
• Traffic source analytics
• Internal search analytics
• Purchase analytics
• Device analytics
5. Legal basis When you purchase an item in our online store, create an account with us, or enter into any other form of agreement with us, we will process your conventional personal data for that particular purpose. We may also process your conventional personal data if you e.g. have a query or similar that precedes your decision to enter into an agreement with us. The legal basis for which we may process your personal data is stated in Article 6 1, b) of the EU Personal Data Regulation (EU) 2016/679 (GDPR), as the processing of your information is necessary for us to fulfill our agreement with you or for us to handle your inquiries and such like, ahead of concluding an agreement. We may also process your ordinary personal data on the basis of the rules in the GDPR Article 6 1, f) unless our interests are outweighed by your privacy rights and statutory freedom. We have a legitimate interest in processing your personal data (name and email address) for both marketing and analytical purposes. Our legitimate interest is based on your preferences so that we can better customise our offerings to you—and ultimately offer products and services that better meet your needs and wishes. Additionally, we have a legitimate interest in processing your personal data for analytical purposes.
6. Disclosure of personal data Treating your data with the utmost care and confidentiality is extremely important to us. If required by law, your data may be disclosed to third parties. We employ service providers and data processors to process data on our behalf. These services include authentication, hosting and maintenance services, analysis services, e-mail messaging services, delivery services, handling of payment transactions, address and e-mail checks. These third parties are our data processors and may only process personal data to the extent necessary in order to deliver their services. Our data processors are contractually obliged to treat such information in the strictest confidence. They are prohibited from using the data in any other way than required. Necessary steps are taken to ensure that our data processors, including service providers and other processors working on behalf of www.charlottes.shopping, uphold and protect the confidentiality of your data. Some of our data processors are situated outside the EU/EAA. Consequently, we will share your personal data with countries outside the EU/EEA. However, we will only provide this information on the basis of the recipient fulfilling the applicable requirements, including:
• The country in question is considered a safe third country.
• The supplier in question shall accede to the European Commission’s Model Contracts for the transfer of personal data to third countries.
• The supplier in question is certified according to Art. 40 of GDPR; or
• The supplier in question has a set of approved Binding Corporate Rules.
7. Your rights If you provide us with personal data on our websites or other channels, this is done on an entirely voluntary basis. If you choose not to provide the requested information, various customer benefits may not be available to you. In certain cases, only those who have submitted to us the required personal data are able to order products, use certain services and in other ways avail themselves of the activities and offers available on our website. We provide numerous options, depending on the exact circumstances, in order to help you retain control over your data. These options may include displaying and editing your data online. It may also be possible to unsubscribe from services or delete user accounts or to receive information about the data held. You can access and amend your personal data at any time by logging on to your account on www.charlotte wikke.co.uk and entering your account profile details. Click on ”My Account” to gain access to your personal details. If any of the information that you have provided us with has changed, e.g. if you change your email address or other contact details, or if you wish to cancel your registration with us, please let us know by editing your details on the “My Profile” or ”My Account” pages or by sending an email outlining the changes to: email@example.com In general, you have the following rights:
7.1 The right to request access to your personal data You are entitled to gain access to some of the personal data you provide to www.charlottes.shopping. By writing to us at firstname.lastname@example.org you may request details of the information about you that we hold and process, including the purposes for which it is used. You can also access your personal details by logging on to your www.charlottes.shopping account on www.charlottes.shopping and entering your account profile details. Click on” My Account” to gain access to your personal details.
7.2 The right to amend and/or delete your personal data You have the right to request correction, appendage, deletion or blockage of your stored personal data. To do so, send your request to: email@example.com. Without undue delay of receipt of your request, we will comply to the required extent. If, for any reason, we cannot comply with your request, we will contact you.
7.3 The right to restrict the processing of your personal data In special circumstances, you have the right to restrict the processing of your personal data. To request restriction, kindly contact us at: firstname.lastname@example.org
7.4 The right to data portability You have the right to receive your personal data (concerning you only) in a structured, commonly used and machine-readable format (“data portability”), and have the right to transit this data to another data controller. To request data portability, kindly contact us at: email@example.com
7.6 The right to withdraw your consent at any time You are at any time entitled to withdraw your consent to our processing of your personal data. The withdrawal of consent shall, however, not affect the lawfulness of processing based on consent before its withdrawal. Contact us at firstname.lastname@example.org to withdraw your consent. If you wish to withdraw your consent to receiving promotional information and offers in general, including by postal services, email, text message, telephone or any other electronic means, you may do so at any time in writing to www.charlottes.shopping, Data Protection, or by sending an email to email@example.com. Should we have misgivings regarding your identity, we may ask you to provide identification.
7.7 Conditions and/or limitations on your rights There may be conditions to or limitations on your aforementioned rights. We are therefore unable to guarantee your right to data portability, as it is dependent on the specific circumstances of the processing activity.
8. Retention of your personal data www.charlottes.shopping will not retain your personal data for longer than necessary for the purposes for which it is processed within the following processing activities:
How do we define an inactive account holders
An inactive account holder is someone who have not engaged with us by: logging into our website, made a purchase either on a www.charlottes.shopping owned website, opened and clicked an email for a time period of up to 5 years from the last engagement. When will Personal data be erased? Personal data will be erased, if the account has been inactive for up to five years. What Personal data will be kept after the 5 year inactive period? No Personal data will be kept unless required by local mandatory law. How do we erase Personal data? Our IT department will on a quarterly basis manually erase Personal data. Personal data will be erased in all IT systems.
9. The security of information and data integrity We take the appropriate technical and organisational measures to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised use, disclosure or access, in particular where processing involves the transmission of data over a network, and against all other unlawful forms of processing and misuse
9.2 Social Networks Our website provides you with social plug-ins from various social networks. If you choose to interact with a social network, your activity on our website will also be made available to social networks such as Facebook and Twitter. If you have logged in to one of these social network sites during your visit to one of our websites, the social network site may add this information to your profile. If you are interacting with one of the social plug-ins, this information will be transferred to the social network site. If you do not want this data transfer, please log out of your social network site before entering one of our websites or (mobile) applications. We cannot prevent this data collection and social plug-in information transfer. Please read carefully the privacy policies of your social networks for detailed information about their collection and transfer of personal data, your rights, and how you can achieve satisfactory privacy settings. Additionally, to improve your user and brand experience, your data may be passed to a third party (e.g. Facebook) for processing in accordance with data protection and privacy regulations.
Google +: http://www.google.com/intl/en/policies/privacy/
10 Consequences of non-disclosure of personal data It is not possible to create a www.charlottes.shopping account or to make a purchase on the www.charlottes.shopping website if you are unable to provide us with the required information.
12. Complaints should be submitted directly to the UK data protection supervisory authority