Looking after the personal information you share with us is very important, and we want you to be confident that your personal data is kept safely and securely and to understand how we use it to offer you a better and more personalised shopping experience.
Data Protection says that we are allowed to use and share your personal data only where we have a proper reason to do so. The law says we must have one or more of these reasons and these are:
· Contract - your personal information is processed in order to fulfil a contractual arrangement e.g. in order to send you your Directory catalogue.
· Consent – where you agree to us using your information in this way e.g. for storing your payment card details.
· Legitimate Interests - this means the interests of Next in managing our business to allow us to provide you with the best products and service in the most secure and appropriate way e.g. to transfer your data to certain Third Party’s such as delivery partners.
· Legal Obligation – where there is statutory or other legal requirement to share the information e.g. when we have to share your information for law enforcement purposes.
Here is a list of the ways that we may use your personal information, and which of the reasons described above we rely on to do so. Where we list legitimate interests as a reason, we also describe below what we believe these legitimate interests are.
|What We Use Your Personal Information For||Our Reasons (Legal Basis)||Our Explanation Of VMD eyewear’s Legitimate Interests|
|Set up your VMD Eyewear or Dirty Dog account||• Legitimate interest||Process efficiency in dealing with such activity.|
|Storing payment cards||• Consent||N/A|
|Process your orders||• Fulfilling a contract||N/A|
|Notify you of your order status.||• Legitimate interests||Process efficiency in dealing with such activity, and to make improvements to our services.|
|Manage your account/ provide customer services to you. This may include: transfers to Third Countries who undertake customer services/communications activities call recording data verification customer complaints/queries||• Legal obligation/ Legitimate interests (depending on nature of services)||Keeping our records up to date, handling our customer contact efficiently and effectively, working out which of our products and services may interest you and telling you about them.|
|To detect, investigate and report financial crime (e.g. Fraud)||• Legal Obligation / legitimate interests||Developing and improving how we deal with financial crime. Complying with any legal obligation placed on us by regulators such as the FCA. Complying with any regulations that apply to us. Process efficiency in dealing with such activity, and to make service and process improvements.|
|Undertake website personalisation and administration.||• Legitimate interests||Developing products, services, applications and designs that attract and retain customers. Improving customer interaction with our sites. Defining types of customers for new products or services|
|Marketing communications to inform you of special offers, promotions, new lines and Sales. Provide you with online advertising.||• Legitimate interests||Developing products, services, applications and designs that attract and retain customers. Improving customer interaction with our sites.|
|Notifying you about enhancements to our services, such as changes to the website and new services that may be of interest to you.||• Legitimate interests||Developing products, services, applications and designs that attract and retain customers. Improving customer interaction with our sites.|
|Contact you to undertake customer satisfaction surveys, invite you to provide product reviews or for market research.||• Legitimate interests||Developing products, services, applications and designs that attract and retain customers. Improving customer interaction with our sites.|
|Maintaining network and data security||• Legitimate interests||To maintain the security of our network this in turns helps us to maintain the safety and confidentiality of your information.|
|Logistics planning, demand forecasting, management information and research||• Legitimate interests||We use information about shopping habits, products bought and volumes, to help us to respond to demand, ensure the right products get to the right areas and to help us plan our ranges.|
"your data" means any information about you which is personally identifiable, including, without limitation, your name, address, telephone number, email address, Registration Name, Password, where applicable, and other information from which you can be identified and which you may disclose to us or otherwise via the site at any time. This information is known as "personal information" because it is capable of identifying you as a living individual. Personal information is afforded certain protections under data privacy and other laws and you can be assured that your personal information will be handled at all times by us in compliance with such laws. We may also collect information from you at the site that does not personally identify you, thought it may be unique or consist of or contain information that you consider personal. For example, we may automatically collect the following information: clickstream information such as the address of the web site that you came from before visiting our site, which pages you visit on the site, what country you are browsing from and what default language your internet browser is set to, which browser you used to view the site and any search terms you have entered on our site. This information is anonymous meaning we cannot identify you personally.
We collect your data when:
2.1 you create an online account;
2.2 you place an order;
2.3 you make a complaint or enquiry or provide other feedback to us;
2.4 you place a comment on the site;
2.5 you submit an entry to a competition or prize draw; or
2.6 you disclose your data to us through the site at any other point.
3.1 We use your data to:
3.1.1 process the registration of your online account and maintain your online account;
3.1.2 process and complete orders you place via the site;
3.1.3 process and deal with any complaints or enquiries made by you;
3.1.4 monitor, develop and improve the site and your experience;
3.1.5 make comments available on the site;
3.1.6 where (and only where) consented to by you, to send you and keep you updated with information by email/post/telephone about existing and new services and special offers from us.
3.1.7 where (and only where) consented to by you, to send you information by email/post/telephone about products or services of selected third parties; and
3.1.8 where you are a prize winner, to publish or otherwise make available a list of prize winners.
3.2 To opt-out of receiving any information pursuant to paragraphs 3.1.7 or 3.1.8, you can:
i. amend your preferences accordingly in your online account;
ii. use the facility contained in any such communication; or
iii. email us at email@example.com stating your name and desire to be removed from the list. Your request to be removed from our email list may take up to five (5) business days to become effective. Please note that you may receive emails that were already in process even though we have removed you from our list. Even if you are removed from our list, please know that if you place an order on our site we will send you an email confirmation.
3.3 your data will be held by us for so long as is necessary for the purposes for which it was collected, for the settlement of any potential disputes which may be raised or otherwise in accordance with legal requirements.
3.4 Please be aware that when you choose to post a comment review to the site, this and any personal data that you choose to include in it may be made available on the site and therefore be accessible to any visitor to the site. Please therefore think carefully about the content of your comment and only make available what you are happy for others to read.
4.1 We may pass on your data to other parties as follows:
4.1.1 to our employees, agents and sub-contractors to administer your online account and orders and other parts of the services;
4.1.2 to third parties in the circumstances set out in Clause 3.1.8;
4.1.3 some general statistical information about the site user base, sales patterns, traffic volumes and related matters may be passed on to reputable third parties and cookies (see 6 below) and other web analytics may be collected and processed by a third on our behalf but these details will not include information personally identifying you;
4.1.4 we may disclose your data to the police, regulatory bodies or legal advisers in connection with any alleged criminal offence or where required by law;
4.2 we do not actually pass your data to third persons other than in the circumstances set out in 4.1 above. Any administration or correspondence under paragraph 4.1 (save in the case of 4.1.2) is conducted by us on behalf of third parties and they do not have any access to your data unless you yourself choose to contact them or give your consent to such third persons directly.
5.1 We endeavour to take all reasonable steps to protect your data. All the data collected by us is stored on a secure server. The secure server software encrypts all personally identifiable information you input when you place an order before it is sent to us.
7.1 Where you are a registered online account holder, you may access and update your data contained in your online account. You must make sure that you update your data as soon as possible with any and all relevant changes. 7.2 If you would like to receive a copy of your data held by us, please email firstname.lastname@example.org
Your data may be held or accessed by VMD Eyewear entities or its affiliates globally in the course of providing the site and services to you. We also use third party providers in order to fulfil the purposes set out in paragraph 3 above who may be located in other cities globally. In terms of any such transfers, we ensure that your data is transferred with relevant and appropriate contractual and other safeguards in place to ensure that it is kept secure and handled in accordance with relevant privacy laws. When you access or use this site, you consent to this transfer of your data on these terms. Please also note that if you choose to post a comment on the site then this and any personal data you choose to include in it may potentially be available to site users worldwide.
Please be aware that the site may link to other web sites that may be accessed by you through our site. We are not responsible for the data policies, content or security of these linked web sites and encourage you to review the policies on these other sites.
If we collect your personal information, the length of time we retain it is determined by a number of factors including the purpose for which we use that information and our obligations under other laws.
We may need your personal information to establish, bring or defend legal claims. For this purpose, we will always retain your personal information for 7 years after the date it is no longer needed by us for any of the purposes listed under How we use your information above. The only exceptions to this are where:
the law requires us to hold your personal information for a longer period, or delete it sooner;
you exercise your right to have the information erased (where it applies) and we do not need to hold it in connection with any of the reasons permitted or required under the law;
we bring or defend a legal claim or other proceedings during the period we retain your personal information, in which case we will retain your personal information until those proceedings have concluded and no further appeals are possible; or
in limited cases, existing or future law or a court or regulator requires us to keep your personal information for a longer or shorter period.
You are entitled to request the following, these are called Data Subject Rights and there is more information on these on the Information Commissioners website www.ico.org.uk
Right of access –to request access to your personal information and information about how we process it
Right to rectification –to have your personal information corrected if it is inaccurate and to have incomplete personal information completed
Right to erasure (also known as the Right to be Forgotten) – to have your personal information erased.
Right to restriction of processing – to restrict processing of your personal information
Right to data portability - to electronically move, copy or transfer your personal information in a standard form
Right to object - to object to processing of your personal information
Rights with regards to automated individual decision making, including profiling –rights relating to automated decision making, including profiling
If you have any general questions about your rights or want to exercise your rights please contact email@example.com
You have the right to lodge a complaint with a data protection regulator, in particular in a country you work or live or where your legal rights have been infringed. Where your personal information has or is being used in a way that you believe does not comply with data and privacy regulations, we encourage you to contact us before making any complaint and we will seek to resolve any issues or concerns you may have.
For UK residents the contact details for the Information Commissioner’s Office (ICO), the data protection regulator in the UK, are available on the ICO website www.ico.org.uk
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