English Cut

1.0 Background
1.1 This privacy and cookie policy sets out how we use your personal data and what your rights are in respect of it.
1.2 We may change this privacy policy from time to time. If we make significant changes in the way we treat your personal information, or to the privacy policy, we will make that clear on our website, or by some other means such as email.
1.3 This page was last updated on 24 May 2018.

2.0 Our Details
We are your data controller for the purposes of the personal data we will collect.  Our details are as follows:
2.1 Our name, address and registered number: English Cut London Limited (“English Cut”), a limited company registered in England with the company registration number 10924194 and our registered address at Belmont House, Station Way, Crawley, West Sussex, United Kingdom, RH10 1JA.
If you wish to contact us in relation to this policy, or data protection policy and procedures generally, please contact us, details are provided at paragraph 14 below.

3.0 Personal data we collect about you
3.1 We collect personal data from you when you voluntarily submit information directly to us or via our website platform, correspond or meet with us, provide feedback or reviews on our products or platform, , purchase products from us platform, subscribe to our email lists or respond to surveys or promotions.
3.2 The categories of personal data we collect include the following:
(a) Contact details: Such as your name, your email address, your telephone number and addresses associated with your account.
(b) Profile information: Such as your contact details (as above) and other any information you share with us concerning our products.
(c) Comments and opinions: Such as, comments and opinions you share with us about our products, feedback or reviews on our products, or when you respond to our surveys, competitions and promotions.
(d) Messages to us: Messages you send to us such as email and written correspondence.
(e) Payment and transaction information: Records of the products you purchase from us and the payment method, and credit/ debit card details, you use for the transaction.
(g) Your preferences: Choices you make such as notification and messaging preferences.
(h) Information about products you are interested in: We collect information about the products that you express an interest in.
(i) Information about your location: Other than information you choose to provide to us, we do not collect information about your precise location. Your device’s IP address may help us determine an approximate location but this will be no more precise than the city, state or country you are using your device in.
(l) Information provided by other users: Sometimes, other customers/potential customers may provide your personal data to us if they think you would be interested in our products.
3.3 Where our legal basis for processing your personal data is:
(a) consent, you have the right to withdraw consent at any time (see the section titled “Withdrawing consent” below); or
(b) legitimate interests, you may have the right to object to our processing (see the section titled “Objecting to legitimate interests processing” below).

4.0 Where we obtain your personal data from
We obtain your personal data in the following ways:
4.1 directly from you, for instance where you sign up to our website, purchase something from us, communicate with us, or otherwise voluntarily provide personal data to us;
4.2 from your accounts on other website, where you give us permission to do so. For instance if you use Facebook to log into our website, we may obtain some information from Facebook;
4.3 automatically when you use our website. For instance:
(a) like most websites, we use cookies (which are smaller text files sent between your web browser and our services) to provide or improve certain functionality and to track which of our pages you visit (see our cookie policy for more information);
(b) our web server automatically collects certain information about your use of our website, for instance some key settings on your device, what type of device you are using, the operating system on your device, the website from which you came and your IP address; and
4.4 from commercial organisations for the purposes of fraud prevention, and in some cases for the purposes of assessing whether we can provide you credit.

5.0 Persons with whom we may share you data:
5.1 In general, access to your personal data will be restricted to those who have a need to access it in order to carry out their duties (for example our order processing and tailoring team).
5.2 However, we will also share your personal data with the following external third parties in some circumstances:
(a) fraud prevention agencies or other third parties that assist us in preventing fraud or other forms of risk;
(b) regulators such as the ICO, and government authorities such as HMRC or the police, if we are required to do so by law or if the regulator or authority requests it and we regard that request as reasonable;
(c) our insurers, legal advisers or other third parties who need access to it in the context of managing, investigating or defending claims or complaints;
(d) in connection with re-organisations, mergers and acquisitions of all or part of our business;
(e) organisations that process your data on our behalf who are not allowed to use your data for any other purpose, for instance our web hosts and the companies we use to pack and deliver your orders;
(f) Companies in the same group of companies as us: our subsidiaries (i.e. any organisation we own or control) or our ultimate holding company (i.e. any organisation that owns or controls us) and any subsidiaries it owns. These companies will only use your personal data in the same way as we can under this Privacy Policy; and
(g) where you have consented to do us doing so.
5.3 Where we share your personal data with our service providers, we have contracts with those service providers setting out how they must handle your personal data, including a requirement not to use your personal data other than in accordance with our instructions.

6.0 Transfers outside of the EEA
6.1 In certain limited circumstances, we may export personal data outside of the European Economic Area for processing, and we may use third party service providers who do the same.
6.2 We only do that if there is a good reason to do it and where either:
(a) there are adequate safeguards in place (such as the appropriate contractual arrangements with suppliers, or adequacy decisions, depending on the destination country); or
(b) we are otherwise permitted by data protection law (for instance, where you consent or such transfer is necessary to provide our service to you).
6.3 For example, where an English Cut user places an order for delivery outside of the EEA, we will transfer personal data out of the EEA as it is necessary for the performance of a contract concluded for the benefit of you.

7.0 How long we keep your information
We will retain your information for as long as we believe it is necessary to fulfil our business purposes or to comply with applicable law, audit requirements, regulatory requests or orders from competent courts.

8.0 Links to third party sites or content
Our website and emails may, from time to time, contain links to and from third party platforms of our partner networks, advertisers, partner merchants, news publications, retailers and affiliates. If you follow a link to any of these platforms, please note that these platforms have their own privacy policies and that we do not accept any responsibility or liability for their policies. Please check the individual policies before you submit any information to those platforms

9.0 Withdrawing consent
9.1 Where we process your personal data on the basis of consent for marketing purposes, you can withdraw your consent in one of the following ways:
(a) by following the unsubscribe link which we include in all electronic marketing; or
(b) by contacting our customer services team using the details on our “contact us” page.

10.0 Objecting to our legitimate interests processing
10.1 Where we process your personal data on the basis of our legitimate interests for direct marketing purposes, you always have the right to object to that processing. To object to direct marketing either follow the instructions for withdrawing marketing consent in the section above or contact us using the details at the top of this notice.
10.2 You have the right to object to other processing on the basis of our legitimate interests, but we might not have to cease processing where you do so if either:
(a) we are able to demonstrate compelling legitimate grounds for the processing which override your interests; or
(b) where that legitimate interest is the establishment, exercise or defence of legal claims.
To object to legitimate interests processing, please contact us using the details at the top of this notice.

11.0 Your rights (with effect from 25 May 2018)
The law gives you certain rights in respect of the personal data that we hold, which you should be aware of:
11.1 You have the right to obtain your personal data from us except in limited circumstances. Where we provide it, the first copy will be free of charge, but we reserve the right to charge a small fee for additional requests;
11.2 You have the right to require us to rectify any inaccurate personal data we hold concerning you;
11.3 Taking into account the purposes of the processing, you may also have the right to have incomplete personal data completed, by means of providing a supplementary statement or otherwise;
11.4 You have the right to require us to erase your personal data on certain limited grounds (including where they are no longer necessary for the purpose for which they were collected or where we rely on consent, which you withdraw, and there is no other legal ground for the processing);
11.5 Where we process personal data either on the basis of consent or contractual necessity, you provided the personal data to us, and we process that personal data by automated means, you have the right to require us to give you your data in a commonly used electronic format;
11.6 You have the right to object to our processing of personal data which we process on the grounds of our legitimate interests, as detailed in the paragraph titled “objecting to our legitimate interest processing” above;
11.7 You have the right to require us to restrict the processing of your personal data on certain grounds, including where:
(a) you contest the accuracy of the personal data and want us to restrict processing of your personal data while we verify its accuracy;
(b) the processing is unlawful, but you request a restriction of the processing rather than erasure;
(c) we (as controller) no longer need the data for the purposes of the processing, but you have told us you require us to retain that personal data for you to establish, exercise or defend legal claims; or
(d) you have objected to us processing your personal data on grounds of legitimate interests and want us to restrict processing of your personal data while we consider your objection.
11.8 If you would like to exercise any of these rights, please contact us using the details set out at the top of this notice.

12.0 If we can’t remedy an issue you have
Should you have any complaints or issue with our treatment of your personal data, you may lodge a complaint with the Information Commissioner’s Office (ico.org.uk).

13.0 Cookies
13.1 Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. By continuing to browse the site, you are agreeing to our use of cookies.
13.2 A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.
13.3 We use the following cookies:
(a) Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
(b) Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
(c) Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
(d) Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
13.4 Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.
13.5 You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.
13.6 You can find out more about cookies by visiting the ICO’s website: https://ico.org.uk/for-organisations/guide-to-pecr/cookies-and-similar-technologies/.

14.0 Contacting us
Questions, comments and requests regarding this Privacy and Cookie Policy are welcome and should be addressed to info@englishcut.com or English Cut London Limited, Belmont House, Station Way, Crawley, West Sussex, United Kingdom, RH10 1JA.