Privacy Policy

Effective date: June 18, 2020

Introduction

This policy applies to your use of our website, https://thesolewomens.co.uk (the “Website”) and our mobile application (the “App”) (together referred to as the “Sites”).

The Sole Women’s respects your privacy and is committed to protecting your personal data. This purpose of this privacy policy is to inform you about how we look after your personal data when you visit our Sites, and tell you about your privacy rights and how the law protects you.

1. Important information and who we are

Purpose of this privacy policy

This privacy policy aims to give you information on how The Sole Women’s collects and processes your personal data through your use of our Sites, including any personal data you may provide to our Sites when you register for an account, set reminders, or sign up to receive communications from us.

Our Sites are not intended for children (under the age of 13) and we do not knowingly collect personal data relating to children. If you are a parent or guardian and you are aware that your child has provided us with personal data, please contact us. If we become aware that we have collected personal data from children without verification of parental consent, where required, we may take steps to remove that information from our servers.

It is important that you read this privacy policy together with any other privacy policy 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 policy supplements other notices and privacy policies and is not intended to override them.

Controller

The Sole Supplier Ltd is the controller and responsible for your personal data (collectively referred to as “The Sole Supplier”, “The Sole Women’s”, “we“, “us” or “our” in this privacy policy).

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact our data privacy manager in the following ways:

Full name of legal entity: The Sole Supplier Ltd

Email address: [email protected]

Postal address: 70 CKR House, East Hill, Dartford, DA11RZ, Telephone number: 020 3743 1482

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).

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. We will notify you of any changes by posting the new privacy policy on this page. You are advised to review this privacy policy periodically for any changes. This version was last updated in December 2019.

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.

Third-party links

Our Sites include links to third-party websites/apps, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share personal data about you. We do not control these third-party websites/apps and are not responsible for their privacy statements. When you leave our Sites, we encourage you to read the privacy policy of every website/app you visit.

2. The data we collect about you

Personal data 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 as follows:

  • Identity Data includes your first name and last name.
  • Contact Data includes email address, telephone number, Whatsapp account and social media account.
  • Transaction Data includes details about products you have purchased from our third party retailers when you click through to the third party website or app from our Sites.
  • Profile Data includes your username and password, profile picture, shoe size, your interests, preferences, feedback and survey responses.
  • Usage Data includes technical information about your device and information about how you access and use our Sites and services, which may include information such as your computer’s Internet Protocol address (IP address), browser type, browser version, the pages of our website/app that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website/app feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

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 personal 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 services). In this case, we may have to cancel 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 data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

  • create an account on our Sites;
  • request reminders to be sent to you;
  • request marketing communications to be sent to you;
  • enter a raffle, competition, promotion or survey; or
  • give us feedback or contact us.

Automated technologies or interactions As you interact with our Sites, we will automatically collect Usage Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy https://thesolewomens.co.uk/cookie-policy/ for further details.

Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:

  • Usage Data from analytics providers such as Google Analytics.

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 have your consent.
  • 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 obligation.

Purposes for which we will use your personal data

We have set out below, in a table format, 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 below.

To register you with a profile on our Sites

Type of data: Identity Data, Contact Data, Profile Data

Lawful basis for processing including basis of legitimate interest: Performance of a contract with you

To deliver our service to you including providing you with updates about the latest trainers and offers from the third party retailers featured on our Sites

Type of data: Identity Data, Contact Data, Transaction Data, Profile Data, Usage Data

Lawful basis for processing including basis of legitimate interest: Consent. Performance of a contract with you. Necessary for our legitimate interests (to provide our service to you in an effective and efficient manner)

Providing customer support to you

Type of data: Identity Data, Contact Data, Transaction Data, Profile Data, Usage Data

Lawful basis for processing including basis of legitimate interest: Performance of a contract with you. Necessary for our legitimate interests (in order to effectively run our business)

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

Type of data: Identity Data, Contact Data, Profile Data, Marketing and Communications Data

Lawful basis for processing including basis of legitimate interest: Performance of a contract with you. Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To enable you to partake in a raffle, competition or complete a survey

Type of data: Identity Data, Contact Data, Profile Data, Usage Data, Marketing and Communications Data

Lawful basis for processing including basis of legitimate interest: Performance of a contract with you. Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

To administer and protect our business and our website and app (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

Type of data: Identity Data, Contact Data, Transaction Data, Profile Data, Usage Data

Lawful basis for processing including basis of legitimate interest: Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise). Compliance with legal obligation

To deliver a personalised feed content and relevant advertisements to you and measure or understand the effectiveness of the advertising we serve to you

Type of data: Identity Data, Contact Data, Transaction Data, Profile Data, Usage Data, Marketing and Communications Data

Lawful basis for processing including basis of legitimate interest: Consent. Necessary for our legitimate interests (to study how customers use our services, to develop them, to grow our business and to inform our marketing strategy)

To use data analytics to improve our website, app, services, marketing, customer relationships and experiences

Type of data: Transaction Data, Profile Data, Usage Data

Lawful basis for processing including basis of legitimate interest: Consent. Necessary for our legitimate interests (to define types of customers for our services, to keep our website and app updated and relevant, to develop our business and to inform our marketing strategy)

To form a view on what we think you may want or need, or what may be of interest to you and to make suggestions and recommendations to you about goods that may be of interest to you

Type of data: Identity Data, Contact Data, Transaction Data, Profile Data, Usage Data, Marketing and Communications Data

Marketing

The purpose of our Sites is to provide you with information about the products, offers and services available on our Sites. That includes information about products, offers and services provided by third party retailers available on our Sites. By signing up to our Sites you are signing up to receive those marketing communications by email. You can also sign up to receive marketing communications via other means (such as Whatsapp, or social media direct message including Facebook Messenger) by providing your contact details relating to those means, where prompted.

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You can opt out of receiving marketing communications at any time by emailing us at [email protected]

Cookies

Our website uses cookies for the purposes set out in the table above. You will be asked to consent to certain types of cookies when you first visit our site. You can set your browser to refuse all or some browser cookies, or to alert you when websites and apps set or access cookies. If you disable or refuse cookies, please note that some parts of our Sites may become inaccessible or not function properly. For more information about the cookies we use, please see https://thesolewomens.co.uk/cookie-policy/

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 share your personal data with the following third party processors for the purposes set out in section 4 above:

  • Service providers who provide IT and system administration services.
  • Analytics and search engine providers who assist us in the improvement and optimisation of our Sites.
  • Marketing service providers.
  • Customer survey providers in order to receive feedback and improve our services.

We may also share your personal data with third parties in the following circumstances:

  • Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy. HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.
  • If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect the rights, property, or safety of our customers, our regulator, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and prevention of money laundering and credit risk reduction.

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 reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

In some circumstances you can ask us to delete your data: see ‘Your legal rights’ below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9. Your legal rights

We aim to take reasonable steps to allow you to correct, amend, delete, or limit the use of your personal data without having to exercise your legal rights. You can update our personal data yourself within your account settings section. If you are unable to do so, then please contact us to make the required changes.

Under certain circumstances, you have rights under data protection laws in relation to your personal data. 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. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which overrides your rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes.

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:

  • If you want us to establish the data’s accuracy.
  • Where our use of the data is unlawful but you do not want us to erase it.
  • 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.
  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

– 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 Request the transfer of your personal data to you or to a third party – 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.

If you wish to exercise any of the rights set out above, please contact us using the contact details above.

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 could 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 could 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.