George Rye & Sons Ltd, also known as GRS Footwear or Lunar Shoes ("we", "us" or "our") are committed to protecting and respecting your privacy.
This policy explains the way we use your personal data and sets out specifically:
1. What personal data we use and how we collect it.
2. How and why we use your personal data.
3. Our legal basis for using your personal data.
4. Obligations on you to provide us with personal data.
5. When your personal data will be shared.
6. Where we use your personal data.
7. How long we store your personal data for.
8. Your rights in relation to our use of your personal data.
9. Changes to this policy.
10. How to make a complaint.
11. How to contact us contact.
Please read this policy carefully to understand our practices regarding your personal data and how we will treat it.
We will use the following personal data about you:
· Information you give us. You will give us information about you by [filling in forms on our site or by corresponding with us by phone, e-mail or otherwise.] This includes information you provide when you [register to use our site, subscribe to our service, search for a product, place an order on our site, participate in discussion boards or other social media functions on our site, enter a competition, promotion or survey and when you report a problem with our site]. The information you give us will include, but is not limited to, [your name, address, e-mail address and phone number, financial and credit card information, personal description and photograph].
· Information we collect about you. With regard to each of your visits to our site we will collect the following information:
· technical information, including the [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 [when and how you accessed our site (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].
· Information we receive from other sources. We will receive information about you if you use any of the other websites we operate, the other services we provide and/or any of our social media pages. We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and will receive information about you from them.
2. How and why we use your personal data
We use personal data held about you in the following ways and for the following purposes:
· Contractual and sales purposes
- we need to use your personal data for administrative purposes, in respect of our relationship with you as a customer or supplier;
- we need to use your personal data to enable us to carry out our obligations arising from any contracts entered into between you and us; and
- we need to use your personal data to notify you about changes to our service.
· Marketing purposes
- we need to use your personal data for direct marketing purposes, so that we can communicate to you information about goods and services, that we or selected third parties offer, that are similar to those you have already purchased or enquired about or which we feel may interest you;
- we need to use your personal data so that we can measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
· Website purposes
- we need to use your personal data to personalise your experience of our site as a user, so that the content from our site is presented in the most effective manner for you and for your computer and so that you can participate in interactive features of our site when you choose to do so;
- we need to use your personal data to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes; and
- we need to use your personal data to facilitate our efforts to keep our site safe and secure.
3. Our legal basis for using your personal data
So that we can process your personal data for the purposes set out above, we rely on the following legal bases:
The legal basis we rely on to use your personal data is that it is necessary for the purpose of our legitimate interests. Our legitimate interest for using your personal data is so that we are able to:
· fulfil our obligations to you as a customer or supplier;
· provide you with information about goods and services that we, or selected third parties, feel may interest you;
· provide you with a personalised and functional experience both online and offline; and
· operate our administration services effectively.
Our legitimate interest is therefore our commercial interest. However, our legitimate interest is also in your interest as our use of your personal data allows us to provide a more effective and efficient service to our customers and suppliers. We use your personal data in a way that has a minimal impact on your rights and only in ways that you would reasonably expect considering the nature of our goods and services.
We also use your personal data where it is necessary for the performance of a contract between us and you as a customer or supplier. This is a separate legal basis which applies when you buy something from us or where we buy something from you.
We may in some circumstances ask for your consent to use your personal data. If we do so, we will make it clear that we are asking for your consent, as this is the legal basis we intend to rely on for using your personal data in that instance.
We will ensure that you know why we are asking for your consent and how we will use your personal data so that you can make an informed decision as to whether to consent to us processing your personal data.
We will only ask for your consent where absolutely necessary. If you do not provide us with your consent when we request it, we will not use your personal data for the purpose to which the requested consent relates, and we will not rely on any other legal basis to do so.
For example, if we ask for your consent so that we can communicate marketing materials to you, and you do not provide us with your consent, or if you later withdraw your consent, we will not rely on our legitimate interest to use your personal data in this way.
When we ask for your consent, we will do so by:
· asking you to tick a tick-box on our website or a form in one of our retail stores;
· verbally over the telephone;
When you provide us with your consent, we will keep a record of this.
However, should you wish to withdraw your consent, you have the right to do this at any time and you should do this by [accessing the preferences section of your online account or by contacting our customer services department on 01670 716878
You must be over the age of 16 to provide us with your consent. If you are 16 or under, your parental guardian must authorise your consent first and complete our online and offline forms do show this where necessary.
4. Obligations on you to provide us with your personal data
There is no statutory obligation on you to provide us with your personal data. However, you may be required to provide your personal data when entering into a contract with us. Without this personal data, we may not be able to carry out our obligations arising from any contracts entered into between you and us
5. When your personal data will be shared
We may share your personal data with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries. These are companies that are legally connected to us, because of the way in which they are owned.
We may share your personal data with selected third parties including:
· business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
· advertisers and advertising networks that require the personal data to select and serve relevant adverts to you and others;
· analytics and search engine providers that assist us in the improvement and optimisation of our site; and
· credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you.
We may disclose your personal data to third parties:
· in the event that we sell or buy any business or assets, in which case we may provide your personal data to the prospective seller or buyer of such business or assets;
· if George Rye & Sons Limited or substantially all of its property are bought by a third party, in which case personal data held by it about its customers will be one of the transferred property; and
· if we are under a duty to provide or share your personal data in order to comply with any legal obligation, to protect our rights, property, or safety, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
6. Where we use your personal data
The personal data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (EEA). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers.
Such staff may be engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services.
7. How long we will store your personal data
We will continue to store your personal data in circumstances where the criteria set out below is satisfied. We will review this annually to help ensure that your personal data is not stored for longer than necessary.
Your personal data will be held with us for as long as you are actively purchasing with us as your contact details will be used in order to ensure we can fulfil your order and communicate order updates to you.