1. IMPORTANT INFORMATION AND WHO WE ARE
We collect, use and are responsible for the personal data we collect about you. When we do so we are subject to the UK General Data Protection Regulation ( UK GDPR ). We are also subject to the EU General Data Protection Regulation ( EU GDPR ) in relation to the goods and services we offer to individuals and any of our business activities in the European Economic Area ( EEA ).
This website is not intended for children and we do not expect to collect the personal data of anyone under 13 years of age. If you are aware that any personal data of anyone under 13 years of age has been shared with us, please let us know so that we can delete that data.
Who we are
This website is provided by Collagerie Ltd a company registered in England and Wales under company registration number 11165708 with our registered office at Lynton House, 7-12 Tavistock Square, London, United Kingdom WC1H 9BQ (referred to herein as “ Collagerie“, “ we“, “ us“ or “ our“). We are the controller and responsible for your personal data.
Email address: HELLO@COLLAGERIE.COM Postal address: Lynton House, 7-12 Tavistock Square, London EC1H 9BQ, United Kingdom
You have the right to make a complaint at any time to the Information Commissioner's Office ( UK ICO ), the UK supervisory authority for data protection issues, and a relevant data protection supervisory authority in the EEA state of your habitual residence or place of work.
The UK ICO may be contacted at https://ico.org.uk/make-a-complaint/ or by telephone: 0303 123 1113. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to this policy
Your duty to inform us of changes
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.
2. THE DATA WE COLLECT ABOUT YOU
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 depending on the particular activities carried out through our website. We may collect and use the following types of personal data about you:
Identity data including first name, last name, username or similar identifier, marital status, title, date of birth and gender ( Identity Data );
Contact data including billing address, delivery address, email address and telephone numbers ( Contact Data );
Technical data including internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website, time and date of your visit to our website, the time you spent on each page and how you found our website ( Technical Data );
Profile data including your username and password, purchases or orders made by you, your interests, preferences, feedback and survey response ( Profile Data );
Usage data including information about how you use our website, products and services ( Usage Data );
Payment data including payment card details and other billing information ( Payment Data );
Marketing and communications data including your preferences in receiving marketing from us and our third parties and your communication preferences ( Marketing and Communications 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). Nor do we collect any information about criminal convictions and offences.
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 goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
3. 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 identity and contact information by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- Create an account on our website;
- Subscribe to our publications;
- Request marketing to be sent to you;
- Purchase products or services via our website;
- Enter a competition, promotion or survey; or
- Give us feedback or contact us.
We will receive personal data about you from various third parties and public sources such as analytics providers based outside the EU, advertising networks and search information providers.
4. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Under data protection law, we can only use your personal data if we have a proper reason, such as:
- where you give consent;
- to comply with our legal and regulatory obligations;
- for the performance of a contract with you or to take steps at your request before entering into a contract; or
- for our legitimate interests or those of a third party.
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interest against your own. You can obtain details of this assessment by contacting us.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before 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.
Purposes for which we will use your personal data
We have set out below a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
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 if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Purpose/Activity: (a) To register you as a new customer. (b) To manage your account with us. (c) To check your identity and help us prevent and detect fraud against you or us. Type of data: Identity and Contact data. Lawful bases for processing including: Performance of a contract with you, or our legitimate interest or those of a third party, in order to be as efficient as we can so we can deliver the best service.
Purpose/Activity: (a) To process and deliver your order including to manage payments, fees and charges; (b) collect and recover money owed to us. Type of data: Identity, Contact, Financial, Transaction, Marketing and Communications data. Lawful bases for processing including: (a) Performance of a contract with you and (b) Necessary for our legitimate interests (to recover debts due to us).
Purpose/Activity: To enable you to partake in a prize draw, competition or complete a survey. Type of data: Identity, Contact, Profile, Usage and Marketing and Communications data. Lawful bases for processing including: (a) Performance of a contract with you; (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business).
Purpose/Activity: To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data). Type of data: Identity, Contact and Technical data. Lawful bases for processing including: (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise); and (b) Necessary to comply with a legal obligation.
Purpose/Activity: To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you. Type of data: Identity, Contact, Profile, Usage, Marketing and communications and Technical data. Lawful bases for processing including: Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy).
Purpose/Activity: To use data analytics to improve our website, products/services, marketing, customer relationships and experiences. Type of data: Technical and Usage data. Lawful bases for processing including: Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy).
Purpose/Activity: To make suggestions and recommendations to you about goods or services that may be of interest to you. Type of data: Identity, Contact, Technical, Usage, Profile and Marketing and Communications data. Lawful bases for processing including: Necessary for our legitimate interests (to develop our products/services and grow our business).
Purpose/Activity: internal updating and enhancing customer records and keeping in touch with our customers about orders and new products. Type of data: Identity, Contact, Technical Usage, Profile. Lawful bases for processing including: to perform our contract with you, to comply with legal and regulatory obligations, or for our legitimate interests or those of a third party.
Purpose/Activity: To enforce our legal rights or defend or undertake to defend legal proceedings. Type of data: Identity, Contact, Profile. Lawful basis for processing including: to comply with our legal and regulatory obligations, for our legitimate interests or those of a third party, including, to protect our business, interests and rights or those of others.
Purpose/Activity: To protect the security of our systems and data. Type of data: Identity, Contact, Profile, Payment Data. We may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interest or those of a third party, and to protect systems and data and to prevent and detect criminal activity that could damaging to you and/or us.
Purpose/Activity: Statistical analysis to help us manage our business, for example, in relation to our financial performance, customer base, product range or other efficiency measures. Type of data: Identity, Contact, Profile, Usage Data, Technical Data and Aggregate Data. Lawful bases for process include: for our legitimate interests or those of a third party, in order to be as efficient as we can so we can deliver the best service to you at the best price.
Purpose/Activity: external audits and quality checks. Type of data: Identity, Contact, Profile, Usage Data, Technical Data, Usage, Marketing and Communications Data, Payment Data and Aggregate Data. Lawful bases for process include: for our legitimate interests or a those of a third party, such as to maintain our accreditations so we can demonstrate we operate at the highest standards.
Purpose/Activity: we may need to share your personal data with members of our group and third parties in connection with a significant corporate transaction. Type of data: Identity, Contact, Profile, Usage Data, Technical Data, Usage, Marketing and Communications Data, Payment Data and Aggregate Data. Lawful bases for process include: to comply with our legal and regulatory obligations. Lawful bases for processing: for our legitimate interests or those of a third party, such as to protect, realise or grow the value in our business and assets.
We may use your personal data to send you updates about our products and/or services, including exclusive offers, promotions or new products and/or services. We may have a legitimate interest in using your personal data for marketing purposes. This means we do not usually need your consent to send you marketing information. However, we strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. If you would like to change your options in relation to our use of your personal data for marketing and advertising, please let us know at: HELLO@COLLAGERIE.COM.
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile 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 (we call this marketing).
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
Opting out You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
5. DISCLOSURES OF YOUR PERSONAL DATA
We may share your personal data with:
- External third parties we use to help deliver our products and/or services to you, such as payment service providers, IT providers, delivery companies, and system administration services, professional advisers (including lawyers, accountants, auditors and insurers); and
- Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets;
- Third parties we use to help us run our business, for example marketing agencies or website hosts and website analytics providers.
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.
The European Economic Area ( EEA ), UK and other countries outside the EEA and the UK have differing data protection laws, some of which may provide lower levels of protection of privacy. It is sometimes necessary for us and many of our external third party partners to share your personal data to countries outside the UK and EEA.
Whenever we transfer your personal data out of the UK or the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data of personal data further to Article 45 of the UK GDPR and Article 45 of the EU GDPR
- there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you, or
- a specific exception applies under relevant data protection law.
Where we transfer your personal data outside the UK we do so on the basis that an adequacy regulation or (where such is not available) legally-approved standard data protection clauses recognised or issues further to Article 46(2) of the UK GDPR. In the event we cannot or choose not to continue to rely on either of those mechanisms at any time we will not transfer your personal data outside the UK unless we can do so on the basis of an alternative mechanism or exception provided by UK data protection law.
6. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
7. DATA RETENTION
How long will you use my personal data for? We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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 unauthorised 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, regulatory, tax, accounting or other requirements.
In some circumstances you can ask us to delete your data. Please refer to the section on “Your Legal Rights“ below for further information. In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
8. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You generally have the following rights:
Access: 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 use: 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.
Restriction to use: 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:
- If you want us to establish the data's accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- 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.
You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Data portability: 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.
Consent: 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.
Correction: You have the right to require us to correct any mistakes in the personal data we hold about you.
Erasure: This is the right to require us to delete your personal data in certain circumstances.
Automated decision making: the right not to be subjected to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you.
If you wish to exercise any of the rights set out above, please contact us at HELLO@COLLAGERIE.COM
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 could 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 could 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.
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With your permission, we use Google Analytics, Facebook Pixel, Microsoft Clarity and Klaviyo to collect data about how you use Collagerie. This information helps us to improve our service, for example, by ensuring that users are finding what they are looking for easily.
Neither Google, Facebook, Microsoft or Klaviyo are allowed to use or share our analytics data with anyone.
Google Analytics stores anonymised information about:
- how you got to Collagerie
- the pages you visit on Collagerie and how long you spend on them
- any errors you see while using Collagerie
Facebook stores anonymised information to:
- determine how people use our website
- prevent the creation of fake accounts and spam accounts (used to gather email addresses for sending spam);
- lower the risk of account theft;
- protect users’ content against theft; and
- prevent denial of service attacks that could prevent some users from accessing Facebook.
Microsoft Clarity stores anonymised information about:
- how you got to Collagerie
- the pages you visit on Collagerie and how long you spend on them
- any errors you see while using Collagerie
Klaviyo stores information about:
- whether you got to Collagerie from one of our emails
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