CONTENTS ____________________________________________________________ CLAUSE 1. Important information and who we are 2. The data we collect about you 3. How is your personal data collected? 4. How we use your personal data 5. Disclosures of your personal data 6. International transfers 7. Data security 8. Data retention 9. Your legal rights 10. Glossary
Welcome to the My Perfect Pattern’s privacy notice.
My Perfect Patterns respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
1. Important information and who we are
Purpose of this privacy notice
This privacy notice aims to give you information on how My Perfect Patterns collects and processes your personal data through your use of this website, including any data you may provide through this website when you purchase a product.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice 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 notice supplements the other notices and is not intended to override them.
Adele Burnett is the controller and responsible for your personal data (collectively referred to as ["COMPANY"], "we", "us" or "our" in this privacy notice).
Our full details are: My Perfect Patterns Email address: [email protected] Postal address: 48c South Snowdon Wharf, Porthmadog, LL49 9NE, UK
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.
Changes to the privacy notice and your duty to inform us of changes
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.
We may update this Privacy Notice from time to time. This version was updated on 18 July 2018. Please contact us for historic versions.
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
2. The data we collect about you
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 includes first name, last name, username or similar identifier, marital status, title and date of birth. • Contact Data includes billing address, delivery address, email address and telephone numbers. • Transaction Data includes details of products you have purchased from us.
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.
If you fail to provide personal data
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). 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.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
• Direct interactions. You may give us your Identity and Contact Data by filling in an order or by corresponding with us by phone, email or otherwise. This includes personal data you provide when you: • apply for our products or services; • create an account on our website; • give us some feedback.
4. How we use your personal data
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.
We do not rely on consent as a legal basis for processing your personal data.
Purposes for which we will use your personal data
We have set out below, in bullet points, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Purpose/activity: To register you as a new customer
Type of data: (a) Identity. (b) Contact
Lawful basis for processing including basis of legitimate interest: Performance of a contract with you.
Purpose/activity: To process and deliver your order including: (a) delivering products to you; (b) Dealing with any returns.
Type of data: (a) Identity; (b) Contact (c); Transaction
Lawful basis for processing including basis of legitimate interest: (a) Performance of a contract with you;(b) Necessary for our legitimate interests (to recover products being returned to us)
Type of data: (a) Identity; (b) Contact
Lawful basis for processing including basis of legitimate interest: (a) Performance of a contract with you; (b) Necessary to comply with a legal obligation; (c) Necessary for our legitimate interests (to keep our records updated)
We will not use your personal data for marketing purposes.
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.
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 choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.
If you have any questions about cookies please get in touch.
Data aggregation, analytics and profile creation
We may analyse your browsing behaviour to draw inferences and create profiles about your personal preferences and behaviours. We may then use such information for the purposes described below;
Behavioural advertising and cross platform targeting (a) Served by us We may use your information (including profile data) to serve you with advertising, which is relevant to you, on our websites and the websites of third parties.
(c) Served by third parties on third party websites We may provide your personal information (including profile data) to third parties who may then use it in combination with personal information that they have collected from you to serve you with relevant advertising on third party websites.
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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
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.
5. Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above:
We require all third parties to respect the security of your personal data and to treat it in accordance with the law.
We use Royal Mail to send parcels. Details and links to their Privacy Statements can be found here: https://www.royalmail.com/gdpr If this link is no longer active, please contact us at [email protected] and we will send an updated link.
6. International transfers
We do not transfer your personal data outside the European Economic Area (EEA).
7. Data security
We have put in place appropriate security measures to prevent your personal data 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.
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.
8. Data retention
How long will you use my personal data for?
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. We will therefore only retain your personal data for 6 months after the date of your order in order to allow us to deal with any issues that arise, such as returns. Our website provider will continue to store details of your transactions for up to 6 years for legal reasons.
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.
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data including: • the right to Request access to your personal data; • the right to Request correction of your personal data; • the right to Request erasure of your personal data; • the right to Object to processing of your personal data; • the right to Request restriction of processing your personal data; • the right to Request transfer of your personal data; and • the right to Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us. 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.
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.
YOUR LEGAL RIGHTS
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.