Thank you for visiting www.malonesouliers.com. At www.malonesouliers.com we are committed to protecting and respecting your privacy.
This policy (together with our terms and conditions and any other documents referred to on it) sets out what personal information we collect, how and when it is collected, how we look after it, how we use it and how we share it. Please read this policy carefully.
If you submit personal data to us it will be maintained in accordance with the provisions of the General Data Protection Regulation ((EU) 2016/679) (“GDPR”) and any national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK, until such time as the GDPR is no longer directly applicable to the UK, and then in accordance with the provisions of any successor legislation to the GDPR or the Data Protection Act 1998 (together, “the Data Protection Legislation”).
For the purpose of the Data Protection Legislation, the data controller is Worldwide Shoes LLP (Company no: OC379290) whose registered office is 16 Great Queen Street, London, WC2B 5DG.
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.
This version was last updated on ___ April 2018.
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.
When we refer to your “Data” in this policy we mean any information that we collect about you or any information that you provide to us. This includes information by which you are personally identifiable including without limitation your name, email address, home address, shipping and credit/debit card billing address(es), credit/debit card details, telephone number, other information that we may obtain as a result of authentication or identity checks, username and password, and our user or session ID that we allocate to you, and any information you submit to us when you use our services or otherwise provide via the Website at any time.
When do we collect or receive your Data?
We may collect and process personal information in several ways including when you:
- provide any information by filling in forms on our Website, including when you
- create your Malone Souliers/Worldwide Shoes account; and
- place an order on our Website;
- enter a competition, promotion, survey or other feature;
- make a complaint, report a problem, submit an enquiry or provide other feedback through the Website or otherwise; or
- correspond or communicate with us by phone, email or otherwise.
When you visit our Website we may automatically collect the following information:
- technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and
- information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our Website (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.
We may receive information about you if you use any of the other websites we operate or the other services or social media platforms we provide. In this case we will have informed you when we collected that data that it may be shared internally and combined with data collected on this Website or other social media platforms.
We are also working closely with third parties (including, for example, business partners, subcontractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.
The Legal Basis for Processing your Information
In accordance with GDPR, the main grounds that we rely upon in order to process your information are as follows:
- Necessary for entering into or performing a contract. In order to perform obligations which arise under any contract we have entered into with you, it will be necessary for us to process your information.
- Necessary for compliance with a legal obligation. We are subject to certain legal requirements which may require us to process your information. We may also be obliged by law to disclose your information to a regulatory body or law enforcement agency.
- Necessary for the purposes of legitimate interests. Either we or a third party will need to process your information for the purposes of our (or a third party’s) legitimate interests, provided that we have established that those interests are not overridden by your rights and freedoms (including your right to have your information protected).
- Consent. In some circumstances, we may ask for your consent to process your information in a particular way.
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 or services). 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.
How will we use your Data?
We use your Data in the following ways:
- to create your Malone Souliers/Worldwide Shoes account;
- to carry out our obligations arising from any contracts entered into between you and us;
- to provide you with the information, products and services that you request from us;
- to contact you if there is a problem with your order or the delivery of your items;
- to answer your queries and to inform you of new or changed services;
- to conduct analysis designed to improve the way in which we market the Website, any advertising and offers we serve to you and others and to deliver any relevant advertising or products to you;
- to provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about;
- to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you. If you are an existing customer, we will only contact you by electronic means (email or SMS) with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you. If you are a new customer, and where we permit selected third parties to use your Data, we (or they) will contact you by electronic means only if you have consented to this. If you do not want us to use your Data in this way, or to pass your details on to third parties for marketing purposes, please tick the relevant box situated on the form on which we collect your data;
- to improve our Website ensure that content from our Website is presented in the most effective manner for you and for your electronic device;
- to administer our Website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- to allow you to participate in interactive features of our service, when you choose to do so;
- as part of our efforts to keep our Website safe and secure;
- for general accounting and auditing purposes;
- to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you; and
- to make suggestions and recommendations to you and other users of our Website about goods or services that may interest you or them.
We may combine information received from other sources with Data we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).
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.
We may share your Data with:
- any member of our group, which means any subsidiaries, holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006;
- business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you; and
- analytics and search engine providers that assist us in the improvement and optimisation of our Website.
We may disclose your Data to third parties:
- in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
- if Worldwide Shoes LLPor substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets; or
- 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 the Website’s terms and conditions of supply and other agreements; or to protect the rights, property, or safety of Worldwide Shoes LLP, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
Where we store your Data
Our online store is hosted by Shopify Inc (http://www.shopify.co.uk/). They provide us with the online e-commerce platform that allows us to sell our products and services to you. Your Data is stored through Shopify’s data storage, databases and the general Shopify application. Shopify store your Data on a secure server behind a firewall.
All information you provide to us is stored on secure servers. Any payment transactions will be encrypted using SSL technology via Shopify Payments. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your Data, we cannot guarantee the security of your Data transmitted to our Website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
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.
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.
In some circumstances you can ask us to delete your data: see “Request erasure” below for further information.
In some circumstances we may 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.
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. 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.
If you wish to exercise any of the rights set out above, please contact us at email@example.com.
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.
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.
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.
Our Website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
In general, you can visit our Website without telling us who you are or providing us with any information. However, we may collect the IP (Internet Protocol) addresses of all visitors to our Website, and other related information such as page requests, browser type, operating system and average time spent on our Website. We use this information to monitor and improve our Website and your experience with it.
You can ask us to stop sending you communications at any time by contacting us.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of the provision by us to you of our services.