1. WHAT WE COLLECT
We may collect the following information: a) Name, b) Contact information including email address and telephone number, c) Demographic information such as postcode, preferences and interests, d) Other information relevant to customer surveys and/or offers or competitions, e) recipient names, addresses and related occasions where you have either sent a subscription box to such recipient or saved such details in your account, f) IP address g) information connected with reviews you leave on our website h) your marketing communication preferences i) details of the device with which you transacted with us j) your purchase history with us k) your browsing history on our website.
To the extent permitted by applicable law, we may receive additional information about you, such as demographic data or fraud detection information, from third party service providers and/or partners, and combine it with information we have about you in order to improve the service and marketing that you receive from Club Rozalie.
2. WHAT WE DO WITH THE INFORMATION WE GATHER
We require this information to understand your needs and provide you with a better service, and in particular for the following reasons:
Where the information is necessary for the adequate performance of the contract between you and us for us to provide our services;
For customer service and resolution purposes; and
Internal record keeping.
We may use the information to improve our products and services.
We may periodically send promotional emails about new products, special offers or other information which we think you may find interesting using the email address which you have provided and we may personalise such content based on what we believe may be of interest to you.
From time to time, we may also use your information to contact you for market research purposes. We may contact you by email, phone or mail.
We may use the information to customise the website according to your interests
We may use the information to send you relevant, personalised communications by post in relation to updates, offers, services and products. We’ll do this on the basis of our legitimate business interest. You are free to opt out of hearing from us at any time by emailing us at email@example.com
We may use the information for the purposes of fraud detection and prevention and enhancing safety on our website and app.
We have a legitimate interest in obtaining and using the information as set out above in being able to provide and improve the service and marketing that you receive from Club Rozalie. You can opt-out of receiving marketing communications from us by following the unsubscribe instructions included in our marketing communications or by contacting us by phone, post or email.
3. WHO WE SHARE YOUR INFORMATION WITH
In order to provide our services, we may need to provide your information to our trusted third party partners, for example:
Our supply and fulfilment partners in order to ensure we can process and complete your order;
Our marketing partners in order to offer you services and products that may be of interest to you;
Our technology partners to ensure we can provide a safe and secure site and improve the performance and relevance of our site to you;
Our customer service platform providers so you can interact with our customer service team;
Our professional services partners in order to comply with our legal obligations;
We will cooperate with all third parties to enforce their intellectual property or other rights. We will also cooperate with law enforcement requests from within or outside your country of residence;
Where you have consented to such, our competition and brand partners
From time to time, we may need to transfer your data to trusted third party partners in countries outside of the EU in order to complete the activities listed above. In such an event, we will ensure that those third party partners comply with all relevant data protection legislation in force in the EU from time to time.
We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.
A cookie is a small file which asks permission to be placed on your computer's hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.
We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.
Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us. You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website. The ICO provide an extensive explanation of the ways that you can block cookies, please visit https://ico.org.uk/for-the-public/online/cookies/ for more information on how to block cookies.
Specific cookies that may be used on our site include:
Facebook ads, Facebook Connect, Google Adwords, Google Analytics, Google Tag Manager, Mention Me, Pinterest, Hotjar, reviews.co.uk, Snapchat, Twitter.
Please note that if you wish to share a product on a third-party website (such as Facebook, Twitter etc) you may be sent cookies from these websites. We do not control the setting of these cookies, so we suggest you check the third-party websites for more information about their cookies and how to manage them.
5. LINKS TO OTHER WEBSITES
Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.
6. CONTROLLING YOUR PERSONAL INFORMATION
You may exercise any of the rights described in this section by sending an email to firstname.lastname@example.org. Please note that we will ask you to verify your identity before taking further action on your request. 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.
Managing Your Information
You may access and update some of your information through your Account settings.
Rectification of Inaccurate or Incomplete Information
You have the right to ask us to correct inaccurate or incomplete personal information concerning you.
Data Access and Portability
You have the right to request copies of your personal information held by us. You may also be entitled to request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider (where technically feasible).
Data Retention and Erasure
We generally retain your personal information for a period of six years after your last active use of our website or app (in line with our legal obligation to keep order information for this duration for tax, legal reporting and auditing obligations). If you no longer want us to keep your information, you can request that we erase your personal information and close your Club Rozalie Account. Please note that if you request the erasure of your personal information:
- We may retain some of your personal information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety. For example, if we suspend a Club Rozalie Account for fraud or safety reasons, we may retain certain information from that Account to prevent that user from opening a new Club Rozalie Account in the future.
- We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, we may keep some of your information for tax, legal reporting and auditing obligations.
- Additionally, some copies of your information (e.g. log records) may remain in our database, but are disassociated from personal identifiers.
Withdrawing Consent and Restriction of Processing
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you. Where you have provided your consent to the processing of your personal information by Club Rozalie you may withdraw your consent at any time by sending a communication to Club Rozalie specifying which consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal. Additionally, you have the right to limit the ways in which we use your personal information, in particular where (i) you contest the accuracy of your personal information; (ii) the processing is unlawful and you oppose the erasure of your personal information; (iii) we no longer need your personal information for the purposes of the processing, but you require the information for the establishment, exercise or defence of legal claims; or (iv) you have objected to the processing pursuant to paragraph 7.7 and pending the verification whether the legitimate grounds of Club Rozalie override your own.
Objection to Processing and Profiling
You are entitled to require Club Rozalie not to process your personal information for certain specific purposes (including profiling) where such processing is based on legitimate interest. If you object to such processing Club Rozalie will no longer process your personal information for these purposes unless we can demonstrate compelling legitimate grounds for such processing or such processing is required for the establishment, exercise or defence of legal claims.
7. Data Security
The security of your data is very important to us. With this in mind we will take all appropriate steps to protect your data and will treat it with the utmost care and attention. We use ‘https’ technology to secure access to all areas of our website. Access to your personal data is password-protected, and sensitive data such as payment card information is held securely by our 3rd party payment providers, and tokenized to ensure it is protected. We ensure that our systems are regularly monitored for possible vulnerabilities and attacks.
You have the right to lodge complaints about the data processing activities carried out by Club Rozalie before the Information Commissioner's Office. Please read: https://ico.org.uk/your-data-matters/raising-concerns/ for details of how to do this. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by writing to or emailing us at email@example.com or by clicking the link on our marketing communications to change your communication preferences.
We will not sell, distribute or lease your personal information to third parties unless we have your permission, are required by law to do so or it is required for the provision of our services as detailed above. We may use your personal information to send you promotional information about third parties which we think you may find interesting if you tell us that you wish this to happen.