Our Commitment To Privacy
Last Updated and Effective as of: June 19, 2018
Your privacy is important to us. To explain how we respect your privacy, we provide this notice explaining our online information practices and the choices you can make about the way your information is collected and used.
This Web site is intended for use by the residents of the United Kingdom, Ireland or Australia. If you are located outside of the United Kingdom, Ireland or Australia, one of our sister sites may be more appropriate for your region:
IMPORTANT INFORMATION AND WHO WE ARE
Full name of legal entity: THE DESSY GROUP
Name of privacy manager: Lori Lakovic
Email address: email@example.com
Postal address: 8 West 38th Street NY NY 10018
Telephone number: 646.638.9617
You have the right to make a complaint at any time to your local Supervisory Authority. We would, however, appreciate the chance to deal with your concerns before you approach your Supervisory Authority so please contact us in the first instance.
Additionally, 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.
THE DATA WE COLLECT ABOUT YOU
Categories of data we collect
Personal data, or personal information, 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 follows:
- Identity Data includes name, username or similar identifier.
- Contact Data includes mailing address, email address and telephone numbers.
- Financial Data includes payment card details.
- Transaction Data includes details about payments to and from you and purchase details.
- Technical Data includes internet protocol (IP) address, browser type, location data, your login data.
- Profile Data includes your username and password, purchases made by you, your interests, and preferences.
- Usage Data includes information about how you use our web site and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us.
We may also collect aggregate demographic information collected from our users (such as the number of users in a particular state) in a manner which does not identify any one individual. Certain aggregated data does not constitute personal data.
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).
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 our services). In this case, we will not be able to provide services to you.
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 personal data by registering or contacting us. This includes personal data you provide when you:
- create an account on our Web site;
- make a purchase;
- contact us;
- request newsletters or marketing to be sent to you; or
- give us feedback.
Third parties or publicly available sources. We may receive your name and email from Facebook if you sign up for an account on our web site through Facebook.
Automated technologies or interactions. As you interact with our web site, we may automatically collect Technical Data about your equipment, browsing actions and patterns. Some of the ways in which we or our web site may collect are further described below:
- Cross Device Matching: We use your data to facilitate cross device association. We or our third party vendors analyze device activity data using a mathematical tool known as a “probabilistic algorithm” to determine if you have interacted with content across multiple devices and to match such devices. In connection with this analysis, we may rely on data (including demographic, geographic and interest-based data) from third parties such as data vendors, pursuant to their own privacy policies or we may use the data we collect in conjunction with such third party data. Based on this data, we may then display targeted advertisements across devices that we believe are associated and may provide other services to our advertisers such as tools, analyses, data and insights to see how their web site or mobile applications are used and to further enable the display of targeted advertisements to you, including across your devices. Our advertisers may also provide us with deterministic data about you that may be used to supplement our probabilistic data. Based on this data, we may then display targeted advertisements across devices that we believe are associated and may provide other services to our advertisers such as tools, analyses, data and insights to see how their web site or mobile applications are used and to further enable cross-device targeting and analysis. For further instructions on restricting our use of certain cross-device data, please see the “Opt-Out Process” section below
- Interest-Based Advertising: We may ourselves, or with third party vendors, use your data in connection with our own or vendor information to deliver targeted advertising to you when you visit other web sites or our Service. Cookies, clickstream data, and other similar technologies described below may be used in this process. For example, if you are searching for information on a particular product, we or our vendor may cause an advertisement to appear on other web sites you view with information on that product. This form of advertising is sometimes called “behavioral advertising”. As a result, we and our vendor know your interests and can deliver ads that may specifically be of interest to you. We believe that such advertising is helpful because you will see advertisements that are relevant to your interests. However, if you would like to opt out of these interest-based advertisements, please follow the opt-out process described below under the section “Opt-Out Process”.
- Clickstream Data: As you use the Internet, a trail of electronic information is left at each website you visit. This information, which is sometimes referred to as “clickstream data,” can be collected and stored by a website’s server. Clickstream data can tell us the type of device and browsing software you use and the address of the website from which you linked to the Service. We may collect and use clickstream data to anonymously determine how much time visitors spend on websites, how visitors navigate throughout websites and how we may tailor our Service to better meet consumer needs. This information will be used to improve our Service and our services. Any collection or use of clickstream data will be anonymous, and will not intentionally contain any personal information.
HOW WE USE YOUR PERSONAL DATA
Our use of 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:
- We will use personal data to complete any orders you have placed.
- We will use personal data to provide you with the specific services that you have requested.
- We will use your personal data to respond to questions that you send to us.
- We will use your personal data to send you emails from time to time, such as newsletters and notices about our promotions, to the extent you have opted in to receive such communications.
Below are the types of lawful basis that we will rely on to process your personal data:
- Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us at firstname.lastname@example.org.
- Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
- Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
- Consent means you have given your consent for certain processing activities.
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to your request to make a reservation through our web site, or sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us at email@example.com.
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 at firstname.lastname@example.org if you need details about the specific legal ground.
Disclosures of your personal data
We may have to share your personal data with the parties set out below:
- We may permit our vendors and subcontractors to access your personal information, but they are only permitted to do so in connection with performing services for us. They are not authorized by us to use the information for their own benefit. For instance, we may share your personal information with a credit card processing company or shipping provider to process orders that you have placed
- We may disclose personal information as required by law or legal process.
- We may disclose personal information to investigate suspected fraud, harassment or other violations of any law, rule or regulation, or the terms or policies for the Web site.
- We may transfer your personal information in connection with the sale or merger of The Dessy Group or the division responsible for the services with which your personal information is associated.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
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 at email@example.com.
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 strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising:
Promotional offers from us: We may use your personal data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you. You will receive marketing communications from us if you have requested information from us or used our services and, in each case, you have not opted out of receiving that marketing.
Third-party marketing: We will get your express opt-in consent before we share your personal data with any company outside our company for marketing purposes.
To see how you can opt out of marketing communications, please see the Opt-Out Process section below.
THIRD-PARTY LINKS AND SOCIAL NETWORKING SERVICES
The Web site may integrate with social networking services. You understand that we do not control such services and are not liable for the manner in which they operate. While we may provide you with the ability to use such services in connection with our Web site, we are doing so merely as an accommodation and, like you, are relying upon those third party services to operate properly and fairly.
You should be aware that personal data which you voluntarily include and transmit online in a publicly assessable blog, chat room, social media platform or otherwise online may be viewed and used by others without any restrictions. We are unable to control such uses of your personal data, and by using such services you assume the risk that the personal data provided by you may be viewed and used by third parties for any number of purposes.
The security of your personal data is very important to us. We attempt to provide for the secure transmission of your information from your computer to our servers by utilizing encryption software. However, due to the inherent open nature of the Internet, we cannot guarantee that communications between you and The Dessy Group or information stored on the Web site or our servers, will be free from unauthorized access by third parties such as hackers and your use of the Web site demonstrates your assumption of this risk. We have put in place reasonable physical, electronic, and managerial procedures to safeguard the information we collect. Only those employees who need access to your information in order to perform their duties are authorized to have access to your personal data.
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 resolve disputes, and to enforce our agreements. 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 unauthorized 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, even if we delete some or all of your personal data, we may continue to retain and use anonymous or aggregated data previously collected.
If you would like your data deleted, please email firstname.lastname@example.org to request deletion.
PROTECTION FOR CHILDREN
We do not knowingly collect personal information from children. When we become aware that personal information (or other information that is protected under applicable law) from a child under 13 (or such other age as may be restricted under local law) has been collected, we will use all reasonable efforts to delete such information from our database.
Opting out of messages from us
All unsubscribe or opt-out requests should be sent to us at email@example.com and we will process your request within a reasonable time after receipt.
Opting out of cookies
If you want to stop or restrict the placement of cookies or flush any cookies that may already be on your computer or device, please refer to and adjust your web browser preferences. Further information on cookies is available at www.allaboutcookies.org. By deleting our cookies or disabling future cookies you may not be able to access certain areas or features of our Web site or some of its functionality may be affected. Cookies and similar items are not used by us to automatically retrieve personal information from your device without your knowledge.
Opting out of interest based advertising
YOUR LEGAL RIGHTS
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.
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.
To exercise your rights, please contact us at firstname.lastname@example.org.
CROSS BORDER TRANSFERS
Our Web site is maintained in the United States of America. If you are visiting from the regions with laws governing data collection and use that may differ from those in the United States, please note that you may be transferring your information to the United States and in other countries around the world. You understand that data stored in the United States may be subject to lawful requests by the courts or law enforcement authorities in the United States. If we transfer your personal data to a processor outside the European Economic Area, such transfer will be in compliance with the requirements of the GDPR. We may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
Dessy Group UK Limited
C/O PKF Littlejohn LLP
2nd Floor, 1 Westferry Circus
London, E14 4HD UK