Privacy Policy
1. Introduction
The Privacy Policy sets out and explains in detail the type of personal data we may collect about you when you interact with us. It also explains how we will store and process that data, including how we keep it secure, as well as information about your legal rights relating to your personal data.
We appreciate that there is a lot of information within this policy, but it is important and necessary to ensure that you are fully informed about your rights and how we use your data.
We are committed to doing the right thing when it comes to how we collect, use and protect your personal data.
The data controller is Eleganze Limited (referred to in this policy as “we” or “us”). Eleganze Limited is a company registered in England and Wales that owns and trades under the brand names Klass and Anna Rose.
2. How
we use your data
In general
,
we (and trusted service providers acting on our behalf) use your personal data: – To provide you with products;- Whenever possible, personalize your browsing experience when you visit our website;- Manage your online account and/or klass reward card account you may have with us;- Verify your identity;- For the prevention of crime and fraud, detection and related purposes;- To contact you electronically about promotional offers and products (provided that you have consented to such communications being sent to you) that we believe are of interest to you.- To better understand your needs;- To help us provide better customer service when dealing with you;- Where we have a legal right or duty to use or disclose your information (for example, in connection with a legal dispute or in connection with an investigation by a public authority).
Klass VIP Card and Other Marketing
We use your
personal data for electronic marketing purposes (with your consent) and may sometimes send you emails about our latest offers or product ranges
.
We communicate to you in this way in the belief based on previous interactions with you as a customer or visitor of our website that we are sending you information about products or offers that are of interest to you.
You have the right to opt-out of receiving promotional communications at any time, before:
1. If you are a member of our loyalty program and hold a Klass VIP card when registering or re-registering at any time, your details on our website in www.klass.co.uk/register and select the opt-out option;
2. Using the “unsubscribe” link included in each marketing email we send you, you can also unsubscribe from any text message by sending a text message from your mobile phone to the “STOP” number displayed by any marketing text message we have sent you;
3. Contact us through any of the contact methods set out in this Policy.
If you have
a Klass VIP Card, we may collect data directly from you, as well as analyse your browsing and shopping history with us, both online and in-store, as well as your responses to marketing communications we have sent you.
This data,
together with other data you have provided to us, such as your date of birth and address, helps us to ensure that we contact you with relevant products and offers that are of interest to you. To better manage this and achieve a more accurate result, we use software and other technology that automates the processing of the data.
3. Sharing
data with third party Service Providers In order to make certain services
available to you, we may need to share your personal data with some of our service providers. These include payment processing companies so that we can process payments and refunds in respect of orders you place with us, IT companies that support our website and other business systems, operating companies such as delivery couriers and marketing service providers that help us manage our electronic communications with you and recommend products that might be of interest to you as you browse our website.
We ensure that
arrangements are in place with such third parties to ensure that we have your confirmation that appropriate security and data protection controls are in place and maintained when handling your personal data. Contractually, these third parties are only authorized to handle the data to provide the necessary service for us and for you and for no other purpose. If we stop using your services, any of your data in your possession will be deleted or anonymized.
Other
Third Parties Otherthan our service providers, we do not share your personal data with third parties except as set forth below. We never sell or license/rent our customers’ data to other organizations or individuals for marketing purposes.
We may share your data with:
Credit reference agencies where necessary for card transactions; Government departments, regulators, law enforcement agencies, courts/tribunals and insurers where we are required to do so: – Under a legal requirement;- To exercise our legal rights (e.g. in court cases);- For fraud and crime prevention, or the investigation or detection of a crime or to prosecute an offender;- For your protection, the protection of customers or our employees.
4. How long do we keep your data?
We will not retain your data for longer than is necessary for the purposes set out in this Policy. While different retention periods apply for different types of data, as a general rule, we will not normally retain any personal data beyond 6 years after your last interaction with us.
5. What kind of personal data do we collect?
– If you have
an online account with us: your name, gender, date of birth, billing/delivery address, orders and receipts, email and phone number.- Details of your purchases and returns with us, either in-store if you are a member of our loyalty program and have used your Klass reward card or online.- Details of your interactions with us thought our customer service, in-store or online. For example, we collect notes of our conversations with you, details of complaints or comments you make, details of purchases, items viewed online or added to your basket, coupon redemptions, web pages you visit and how and when you open or click on emails we may send you. You can learn more about how we use cookies.- Payment card informationWhile we collect your card details in order to process the payment necessary to complete your purchase, this is done through an encrypted connection that is displayed by the padlock or security symbol in the address bar as recognized by your browser as secure and we do not store your card information in our systems. We transmit your data via encrypted connection to our payment provider’s secure and fully compliant environment, which is responsible for protecting all sensitive data using industry-leading technology to protect your card against digital breaches in order to keep your card data completely secure at all times. – Your comments and reviews about our products and services.
6. How we protect
your data
We are committed to keeping your personal data safe and secure.
Our security measures
include:
– data encryption –
only sharing data with organizations that we are satisfied adhere similarly to the commitment to keep your personal data safe and secure – security controls that protect all data we have in our systems from external attacks and unauthorized access – training of our employees
However, although we take appropriate technical and organizational measures to safeguard your personal data, please note that we cannot guarantee the security of personal data you transfer to us over the Internet.
The personal data 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 companies operating outside the EEA that work for us or for one of our service providers. We will implement appropriate protection to ensure that your personal data remains adequately protected and is treated in accordance with this policy.
The legal basis for us to process
customer personal data
General
We collect and use customers’ personal data
because: – it is necessary in pursuit of our legitimate interest (as set out below); – the customer has consented to the processing of his personal data by providing his e-mail address while subscribing to the newsletter to receive direct marketing communications from us;-To perform our contractual obligations in respect of a contract for the sale of goods to a customer; or – To comply with our legal obligations.
Customers have the right to withdraw consent at any time. Where consent is the sole legal basis for processing, we will stop processing data after consent is withdrawn.
Our legitimate interests The normal legal basis for processing customer data is that it is necessary for our
legitimate interests
, including: – Selling and supplying goods and services to our customers;- Protecting customers,
employees and others and maintaining their safety, health and well-being;- Promoting, marketing and advertising our products;- Sending electronic dial-up communications to existing customers who have opted in Receive such communications by providing us with your contact details;- Send other promotional communications that are relevant and personalised to individual customers (including the management of the Klass rewards card scheme)- Improve existing products, ranges and promotions;- Understand the behaviours, preferences, interests and needs of our customers;- Comply with legal and regulatory obligations;- Prevent, investigate and detect crime, fraud and prosecute offenders, as well as assist with law enforcement agencies;- manage customer contacts, enquiries, reviews, complaints or disputes;- protect Eleganze Limited, its employees and customers, by taking appropriate legal action against third parties who have committed or appear to have committed criminal acts or are in breach or we suspect that they are in breach of legal obligations owed to us;- manage legal claims or regulatory compliance actions taken against or for us; – To comply with our duties to customers, employees, shareholders and other interested parties.
7. Yourrights You have the following rights: – The right to request: – Access to the personal data we hold about you at any time, free of charge in most cases;- The correction of your personal data when it is incorrect, outdated or incomplete;- That we stop using your personal data for direct dialing (either through specific channels or all channels).- That we stop any processing based on the consent to your personal data after you withdraw that consent- The deletion of the data we hold about you, in specific circumstances; For example, when you withdraw your consent or object, and we have no overriding legitimate interest, or once the purpose for which we hold the data has come to an end (such as the end of a return period),
you
can contact us to request the exercise of these rights at any time by writing to the data access request, Eleganze Limited, Unit B Royle Pennine Trading Estate, Lynroyle Way, Rochdale Lancs OL11 3EX, or by email to info@klass.co.uk. To request that your information be amended, update your online account, re-register your reward card online, or contact our customer service team. If we decide not to act on your request, we will explain the reasons for our rejection.
Your
right to withdraw consent As long as you have given us your consent to use your personal data,
you have the right to change your mind at any time and withdraw consent
.
When we rely on our
legitimate interest
Where we process your personal data on the basis of a legitimate interest, you can ask us to stop doing so for reasons relating to your individual situation. We must do so unless we believe we have a legitimate compelling reason to continue processing your personal data.
Direct marketing
You have the right to stop the use of your personal data for direct marketing activities through all selected channels or channels. We must always comply with your request.
To
protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Policy. If you have authorized a third party to submit a request on your behalf, we will ask them to prove that they have their permission to act.
How to stop the use of personal data for direct marketing.
There are several ways to stop our direct marketing communications:
Click on the “unsubscribe” link in any email marketing communication we send you. We will then stop any further marketing email.- If by subsequently registering your reward card or creating an online account you indicate that you do not consent to emails and/or text messages being sent to you from us.- Send your request by email to info@klass.co.uk including sufficient information for us to identify your email address or if your request only relates to text messages, your mobile phone number. An email request with a header that says “unsubscribe” is acceptable.- Please write to us with your request to Customer services, Eleganze Limited, Unit B, Royle Pennine Trading Estate, Lynroyle Way, Rochdae Lancs OL11 3EX Please
note that you may continue to receive communications from us for a short period after you make your request for this to stop while our systems are fully up to date.
7. Do you have any questions or need to contact us about this Privacy Policy?
We trust that this policy has been helpful in setting out how we handle your personal data and your rights to control it.
If you have
any questions that have not been addressed in this Policy, please contact us and we will be happy to assist you:
–
By email to datapolicy@klass.co.uk– Or write to us at Data Policy, Eleganze Limited, Unit B, Royle Pennine Trading Estate, Lynroyle Way, Rochdale Lancs OL11 3EX
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This Policy was last updated on 17/05/2018
