Privacy Policy

Privacy 

SUMMARY – COLLECTION OF DATA

We may collect or obtain Personal Data about you, directly from you (e.g. where you contact us); in the course of our relationship with you (e.g. if you make a purchase); when you make your Personal Data public (e.g. if you make a public post about us on social media); when you visit our Sites; when you register to use any of our Sites / services; or when you interact with any third party content or advertising on a Site. We may also receive Personal Data about you from third parties (e.g. law enforcement authorities).

Collection of Personal Data

 We may collect Personal Data about you from the following sources:

• Data you provide – We may obtain your Personal Data when you provide it to us (e.g., where you contact us via email, telephone, by any other means when you provide us with your business card); 
• Relationship data – We may collect or obtain your Personal Data in the ordinary course of our relationship with you (e.g. if you make a purchase with us); 
• Data you make public – We may collect or obtain your Personal Data that you manifestly choose to make public, including via social media (e.g. we may collect information from your social media profile(s) if you make a public post about us);
• Site data – We may collect or obtain your Personal Data when you visit any of our Sites or use any features or resources available on or through a Site;
• Registration details – We may collect or obtain your Personal Data when you use or register to use any of our Sites or services; 
• Content and advertising information – If you choose to interact with any third party content or advertising on a Site, we may receive Personal Data about you from the relevant third party; 
• Third party information – We may collect or obtain your Personal Data from third parties who provide it to us (e.g. credit reference agencies; law enforcement authorities; etc.).

Creation of Personal Data 

We may also create Personal Data about you, such as records of your interactions with us, and details of your purchase history for internal administration purposes and analysis, including to better understand your needs and interests and to personalize and improve your experience.

CATEGORIES OF PERSONAL DATA WE MAY PROCESS 

Summary — Categories of Personal Data we may Process

We may Process your personal details (e.g. your name); demographic data (e.g. your age); your contact details (e.g.  your address); records of your consents; purchase details; payment details (e.g. your billing address); information about our Sites (e.g., the type of device you are using); information about your interactions with our content or advertising; and any views or opinions you provide to us.

We may Process the following categories of Personal Data about you:

• Personal details – given name(s); preferred name; and photograph;
• Demographic information – gender; date of birth/age; nationality; salutation; job title/industry; and language preferences;
• Contact details – correspondence address; telephone number; email address; and details of your public social media profile(s);
• Consent records – records of any consents you may have given, together with the date and time, means of consent and any related information (e.g., the subject matter of the consent);
• Purchase details – records of purchases and prices; 
• Payment details – invoice records; payment records; billing address; payment method; bank account number or credit card number; cardholder or accountholder name; card or account security details; card ‘valid from’ date; and card expiry date; BACS details; SWIFT details; IBAN details; payment amount; payment date; and records of cheques; 
• Data relating to our Sites – device type; operating system; browser type; browser settings; IP address; language settings; dates and times of connecting to a Site; location data, and other technical communications information (some of which may constitute Personal Data); username; password; security login details; usage data; aggregate statistical information;
• Employer details – where you interact with us in your capacity as an employee, the contact information of your employer (including name, address, telephone number and email address) to the extent relevant; 
• Content and advertising data – records of your interactions with our online advertising and content, records of advertising and content displayed on pages and any interaction you may have had with such content or advertising (including mouse hover, mouse clicks, any forms you complete (including incomplete forms not submitted) and any touchscreen interactions);
• Views and opinions – any views and opinions that you choose to send to us, or publicly post about us on social media platforms;

LAWFUL BASIS FOR PROCESSING PERSONAL DATA

Summary – Lawful basis for Processing Personal Data 

We may Process your Personal Data where – you have given your prior, express consent; the Processing is necessary for a contract between you and us; the Processing is required by applicable law; the Processing is necessary to protect the vital interests of any individual; or where we have a valid legitimate interest in the Processing.

In Processing your Personal Data in connection with the purposes set out in this Policy, we may rely on one or more of the following legal bases, depending on the circumstances:

• Consent – We may Process your Personal Data where we have obtained your prior, express consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary — it is not used for Processing that is necessary or obligatory in any way);

• Contractual necessity – We may Process your Personal Data where the Processing is necessary in connection with any contract that you may enter into with us;

• Compliance with applicable law – We may Process your Personal Data where the Processing is required by applicable law;

• Vital interests -We may Process your Personal Data where the Processing is necessary to protect the vital interests of any individual; 

• Legitimate interests – We may Process your Personal Data where we have a legitimate interest in carrying out the Processing for the purpose of managing, operating or promoting our business, and that legitimate interest is not overridden by your interests, fundamental rights, or freedoms.

SENSITIVE PERSONAL DATA

Summary — Sensitive Personal Data

We do not seek to collect or otherwise Process your Sensitive Personal Data. Where we need to Process your Sensitive Personal Data for a legitimate purpose, we do so in accordance with applicable law.

We do not seek to collect or otherwise Process your Sensitive Personal Data in the ordinary course of our business. Where it becomes necessary to process your Sensitive Personal Data for any reason, we rely on one of the following legal bases:

• Compliance with applicable law – We may Process your Sensitive Personal Data where the Processing is required or permitted by applicable law (e.g., to comply with our diversity reporting obligations);
• Detection and prevention of crime – We may Process your Sensitive Personal Data where the Processing is necessary for the detection or prevention of crime (including the prevention of fraud);

• Establishment, exercise or defence of legal rights – We may Process your Sensitive Personal Data where the Processing is necessary for the establishment, exercise or defence of legal rights; 

• Consent – We may Process your Sensitive Personal Data where we have, in accordance with applicable law, obtained your prior, express consent prior to Processing your Sensitive Personal Data (this legal basis is only used in relation to Processing that is entirely voluntary — it is not used for Processing that is necessary or obligatory in any way); 

PURPOSE FOR WHICH WE MAY PROCESS YOUR PERSONAL DATA

Summary — Purposes for which we may Process your Personal Data

We may Process your Personal Data for the following purposes – providing services to you; operating our Sites; communicating with you; managing our IT systems; financial management; conducting surveys; ensuring the security of our premises and systems; conducting investigations where necessary; compliance with applicable law; and improving our Sites and services.

The purposes for which we may Process Personal Data, subject to applicable law, include:

• Provision of services to you – providing our Sites and services to you; communicating with you in relation to those services, and providing you with promotional items at your request or in connection with those services or similar services; 

• Our Sites – operating and managing our Sites; providing content to you; displaying advertising and other information to you; communicating and interacting with you via our Sites; identifying issues with our Sites and planning improvements to or creating new Sites and notifying you of changes to any of our Sites or our services; 

• Communications – communicating with you via any means (including via email, telephone, text message, social media, post or in person) news items and other information in which you may be interested, subject to ensuring that such communications are provided to you in compliance with applicable law; maintaining and updating your contact information where appropriate; and obtaining your prior opt-in consent where required; 

• Communications and IT operations – management of our communications systems; operation of IT security systems; and IT security audits;

• Financial management – sales; finance; corporate audit; and vendor management; 

• Surveys – engaging with you for the purposes of obtaining your views on our services;
• Security – physical security of our premises (including records of visits to our premises; and CCTV recordings); and electronic security (including login records and access details); 
• Investigations – detecting, investigating and preventing breaches of policy, and criminal offences, in accordance with applicable law;
• Legal proceedings – establishing, exercising and defending legal rights;
• Legal compliance – compliance with our legal and regulatory obligations under applicable law;
• Improving our Sites and services – identifying issues with our Sites or our services; planning improvements to our Sites or services; and creating new Sites or services; 

DISCLOSURE OF PERSONAL DATA TO THIRD PARTIES 

Summary — Disclosure of Personal Data to third parties

We may disclose your Personal Data to – legal and regulatory authorities; our external advisors; our Processors; any party as necessary in connection with legal proceedings; any party as necessary for investigating, detecting or preventing criminal offences; any purchaser of our business; and any third party providers of advertising, plugins or content used on our Sites. 

In addition, we may disclose your Personal Data to:

• legal and regulatory authorities, upon request, or for the purposes of reporting any actual or suspected breach of applicable law or regulation;

• outside professional advisors (such as accountants, auditors, or lawyers), subject to binding contractual obligations of confidentiality;

• third party Processors (such as payment services providers; data centres; etc.), subject to the requirements noted below in this Section;

• any relevant party, law enforcement agency or court, to the extent necessary for the establishment, exercise or defence of legal rights;

• any relevant party for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties, including safeguarding against and the prevention of threats to public security;

• any relevant third party acquirer(s), in the event that we sell or transfer all or any relevant portion of our business or assets (including in the event of a reorganization, dissolution or liquidation); 

• any relevant third party provider where our Sites use third party advertising, plugins or content. If you choose to interact with any such advertising, plugins or content, your Personal Data may be shared with the relevant third party provider. We recommend that you review that third party’s privacy policy before interacting with its advertising, plugins or content;

If we engage a third-party Processor to Process your Personal Data, the Processor will be subject to binding contractual obligations to: (i) only Process the Personal Data in accordance with our prior written instructions; and (ii) use measures to protect the confidentiality and security of the Personal Data; together with any additional requirements under applicable law.

INTERNATIONAL TRANSFER OF PERSONAL DATA 

Summary — International transfer of Personal Data

We may transfer your Personal Data to recipients in other countries. Where we transfer Personal Data from the EEA to a recipient outside the EEA that is not in an Adequate Jurisdiction, we do so on the basis of Standard Contractual Clauses.

In order to process your payment and administer the Services, we may need to transfer limited classes of your Personal Data to third parties in connection with the purposes set out in this Policy. For this reason, we may transfer your Personal Data to other countries that may have different laws and data protection compliance requirements to those that apply in the country in which you are located.

Where we transfer your Personal Data from the EEA to recipients located outside the EEA who are not in Adequate Jurisdictions, we do so on the basis of Standard Contractual Clauses. 

Please note that when you transfer any Personal Data directly to a person or entity established outside the EEA, we are not responsible for that transfer of your Personal Data. We will nevertheless Process your Personal Data, from the point at which we receive the data, in accordance with the provisions of this Privacy Policy.

DATA SECURITY 

Summary — Data security

We implement appropriate technical and organisational security measures to protect your Personal Data. Please ensure that any Personal Data that you send to us is sent securely.

We have implemented appropriate technical and organisational security measures designed to protect your Personal Data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access, and other unlawful or unauthorised forms of Processing, in accordance with applicable law.

Because the internet is an open system, the transmission of information via the internet is not completely secure. Although we will implement all reasonable measures to protect your personal data, we cannot guarantee the security of your data transmitted to us using the internet — any such transmission is at your own risk and you are responsible for ensuring that any Personal Data that you send to us is sent securely.

DATA ACCURACY

Summary — Data accuracy

We take every reasonable step to ensure that your Personal Data is kept accurate and up-to-date and is erased or rectified if we become aware of inaccuracies. 

We take every reasonable step to ensure that:

• your Personal Data that we Process is accurate and, where necessary, kept up to date;

• any of your Personal Data that we Process that you inform us is inaccurate (having regard to the purposes for which it is Processed) is erased or rectified;

DATA MINIMISATION 

Summary — Data minimisation

We take every reasonable step to limit the volume of your Personal Data that we Process to what is necessary.

We take every reasonable step to ensure that your Personal Data that we Process is limited to the Personal Data reasonably necessary in connection with the purposes set out in this Policy or as required to provide you services or access to our Sites.

DATA RETENTION

Summary — Data retention

We take every reasonable step to ensure that your Personal Data is only retained for as long as it is needed. We take every reasonable step to ensure that your Personal Data is only Processed for A minimum period necessary for the purposes set out in this Policy

The criteria for determining the duration for which we will keep your Personal Data are as follows: we will retain copies of your Personal Data in a form that permits identification only for as long as is necessary in connection with the purposes set out in this Policy, unless applicable law requires a longer retention period. In particular, we may retain your Personal Data for the duration of any period necessary to establish, exercise or defend any legal rights.

YOUR LEGAL RIGHTS

Summary — Your legal rights

Under applicable law, you may have a number of rights, including the right not to provide your Personal Data to us; the right of access to your Personal Data; the right to request rectification of inaccuracies; the right to request the erasure, or restriction of Processing, of your Personal Data; the right to object to the Processing of your Personal Data; the right to have your Personal Data transferred to another Controller; the right to withdraw consent; and the right to lodge complaints with Data Protection Authorities. We may require proof of your identity before we can give effect to these rights.

Subject to applicable law, you may have a number of rights regarding the Processing of your Relevant Personal Data, including:

• the right not to provide your Personal Data to us (however, please note that we may be unable to provide you with the full benefit of our Sites or our services, if you do not provide us with your Personal Data — e.g., we may not be able to process your orders without the necessary details);

• the right to request access to, or copies of, your Relevant Personal Data, together with information regarding the nature, Processing and disclosure of the Relevant Personal Data;

• the right to request rectification of any inaccuracies in your Relevant Personal Data;

• the right to request, on legitimate grounds, erasure of your Relevant Personal Data; or  restriction of Processing of your Relevant Personal Data;

• the right to object, on legitimate grounds, to the Processing of your Relevant Personal Data by us or on our behalf;

• the right to have certain Relevant Personal Data transferred to another Controller, in a structured, commonly used and machine-readable format, to the extent applicable;

• where we Process your Relevant Personal Data on the basis of your consent, the right to withdraw that consent (noting that such withdrawal does not affect the lawfulness of any Processing performed prior to the date on which we receive notice of such withdrawal, and does not prevent the Processing of your Personal Data in reliance upon any other available legal basis);

• the right to lodge complaints with a Data Protection Authority regarding the Processing of your Relevant Personal Data by us or on our behalf;

This does not affect your statutory rights.

To exercise one or more of these rights, or to ask a question about these rights or any other provision of this Policy, or about our Processing of your Personal Data, please use the contact details provided below. Please note that:

• we may require proof of your identity before we can give effect to these rights; 

• where your request requires the establishment of additional facts (e.g., a determination of whether any Processing is non-compliant with applicable law) we will investigate your request reasonably promptly, before deciding what action to take.

COOKIES AND SIMILAR TECHNOLOGIES 

Summary — Cookies and similar technologies

We may Process your Personal Data by placing or reading Cookies and similar technologies. 

Cookie Policy – When you visit a Site we may place Cookies onto your device, or read Cookies already on your device, subject always to obtaining your consent, where required, in accordance with applicable law. We use Cookies to record information about your device, your browser and, in some cases, your preferences and browsing habits. We may Process your Personal Data through Cookies and similar technologies.

TERMS OF SERVICE 

Summary — Terms of Service

The Terms of Service available on our Sites will govern all use of our Services and Sites.

All use of our Sites or our Services is subject to the Terms of Service published on our Sites. 

We recommend that you review our Terms of Service regularly, in order to review any changes we might make from time to time.

DIRECT MARKETING 

• Summary — Direct marketing

We may Process your Personal Data to contact you with information regarding services that may be of interest to you. You may unsubscribe for free at any time.

We may Process your Personal Data to contact you via email, telephone, direct mail or other communication formats to provide you with information regarding services that may be of interest to you. If we provide services to you, we may send information to you regarding our services, upcoming promotions and other information that may be of interest to you, using the contact details that you have provided to us and always in compliance with applicable law.

You may unsubscribe from our promotional email list at any time by following the unsubscribe instructions included in every promotional email we send. We will not send you promotional emails from a list you have selected to be unsubscribed from, but we may continue to contact you to the extent necessary for the purposes of any services you have requested or from additional lists you have signed up under.

CONTACT DETAILS 

Summary — Contact details

You may contact us at the addresses set out below or by 

emailing: dkl@dinakashaplondon.com  

If you wish to be taken off our contact list for direct marketing, or if you have any comments, questions or concerns about any of the information in this Policy, or any other issues relating to the Processing of Personal Data carried out by us, or on our behalf, please contact:

Dina Kashap – dkl@dinakashaplondon.com.