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Last updated: [June 3rd, 2020]

This privacy policy (“Privacy Policy”) applies to the processing of personal information in connection with the Decorté UK website at www.decortecosmetics.co.uk (the “Site”), and all of the products and  services that we offer, including from our stockists or stores (“Stores”) and the Site (“Services”). We respect the privacy of every person who visits our Site and our Stores or who uses our Services, and we are committed to ensuring a safe online experience.

    1. Purpose of this Privacy Policy

This Privacy Policy explains our approach to any personal information that we might collect from you or which we have obtained about you from a third party and the purposes for which we process your personal information. This Privacy Policy also sets out your rights in respect of our processing of your personal information. For more information

This Privacy Policy will inform you of the nature of the personal information about you that is processed by us and how you can request that we delete it, update it, transfer it and/or provide you with access to it.

This Privacy Policy is intended to assist you in making informed decisions when using the Site, visiting our Stores, and/or using our Services. Please take a moment to read and understand it. Please note that it should be read in conjunction with our Terms of Use, Terms of Purchase and Cookie Policy.

Please also note that this Privacy Policy only applies to the use of your personal information received by us, it does not apply to your personal information collected during your communications with third parties or your use of their products or services (for example where you follow links to third party websites over which we have no control or purchase goods or services from those third parties).

    2. About us

The Site, the Stores and our Services are operated by Kosé Corporation UK Branch, which is a branch of Kosé Corporation, (“we”, “us” or “our”). For more information

Kosé Corporation is the data controller responsible for your personal information and is a private limited company registered in Japan under company registration number 010001043552 with its registered office address located at 3-6-2 Nihonbashi, Chuo-Ku, Tokyo 1038251, Japan. The address and registered office of Kosé Corporation UK Branch is 4th Floor Regus, Rex House, 4-12 Regent Street, London SW1Y 4PE, with a UK establishment number of BR021338.

    3. How to contact us

If you have any questions about this Privacy Policy or want to exercise your rights set out in this Privacy Policy, please contact us by:

    4. How we collect and receive personal information

We collect and receive personal information using different methods:

  • Personal information you provide to us. For more information

You may give us your personal information directly. This will be the case when, for example, you purchase a product or service from our Site or Stores, contact us with enquiries, subscribe to receive our marketing communications or provide feedback to us.

  • Personal information we collect from you automatically. For more information

When you access and use our Site, we will automatically collect certain technical information about your equipment, browsing actions and patterns. We collect this personal information by using cookies and other similar technologies (see the “Our Use of Cookies and Similar Technologies” section below).

  • Personal information received from third parties. For more information

From time to time, we will receive personal information about you from third parties. Such third parties may include resellers of our products, analytics providers, event organisers that we partner with, social media platforms, payment providers, and third parties that provide services to us so that we can operate our Site, Stores and/or provide our Services. We may also receive personal information (which may include sensitive personal information relating to criminal convictions and offences) from the Disclosure and Barring Service in relation to our recruitment.

    5. Personal information we collect and how we use it

Our primary goal in collecting personal information from you is to: (i) provide our  Services to you; (ii) verify your identity (where applicable); (iii) help us improve our Site, our Stores and our Services and develop and market new products and services; (iv) carry out requests made by you on the Site or in Stores; (v) investigate or settle inquiries or disputes; (vi) comply with any applicable law, court order, other judicial process, or the requirements of a regulator; (vii) enforce our agreements with you; (viii) protect the rights, property or safety of us or third parties, including our other customers and users of the Site or Stores; (ix) carry out recruitment activities; and (x) use as otherwise required or permitted by law.

In particular, we use your personal information for the following purposes:

  • Fulfilment of our Services. For more information

We collect and maintain personal information that you voluntarily submit to us during your use of the Site, during your visit to our Stores and when you use our Services. If you click on one of the social media links on our Site, or otherwise interact with our social media accounts, such as on Facebook or Instagram, we may also receive information relating to such interaction and to your own social media accounts.

Purchases: We use your name, contact and payment details that you have provided so that we can fulfil the products or services that you have ordered from our Site or our Stores and to process any returns and/or refunds. Please note that any contractual terms applicable to the particular products or services that you have ordered will also apply.

Account registration and log in: If you register for a customer account with us, we will use your name and email address to process your registration. Once you are registered, we will process your email address and password to identify you when you log into secure areas of our Site. We will use your account information so that we can administer your account with us. 

Beauty treatments: We use your name and contact details provided in our Stores, through our Site, over the phone or via the Harrods Beauty Concierge team to book beauty treatment services. Please note that any contractual terms applicable to the particular service will also apply. We may also use the information provided in customer consent forms to ensure the safety and suitability of the supply of our beauty treatment services. Such information may include special categories of personal information (such as information about your health including any allergies, skin conditions, previous treatments or any relevant medical conditions).

What is our legal basis?

It is necessary for us to use your personal information to perform our obligations in accordance with any contract that we may have with you or it is in our legitimate interest or a third party’s legitimate interest to use personal information in such a way to ensure that we provide the Services you have requested in the most effective and efficient way that we can.

We will only process special (or sensitive) categories of personal information (for example information relating to your health) with your explicit consent.

  • Customer services and enquiries. For more information

We maintain a record of personal information that you may provide to us from time to time in order to provide a bespoke customer experience appropriate to the luxury products and services that you receive from us. For example, we may keep a record of your birthday or information relating to your personal preferences. Our enquiry services are accessible by email or our office telephone (when open). We can also answer any enquiries at our Stores or via any of our social media pages on Instagram, Facebook, YouTube or Twitter. When making an enquiry, the enquirer’s name and contact information (email address, postal address, telephone number) may be requested, together with details of other personal information that is relevant to the enquiry. This information is used in order to enable us to manage and respond to your enquiries and requests.

 

What is our legal basis?

It is in our legitimate interest to use your personal information in such a way to ensure that we provide the very best customer service we can to you.

  • Your feedback about our Services. For more information

From time to time, we may invite you to provide feedback about our Services via focus groups. We will collect your name and contact details (email address, postal address, telephone number) and any other personal information you choose to volunteer in your feedback.

We use this information to help us improve the quality of customer service provided by our staff. We also use your feedback to monitor the quality of our products and services and to assist with the selection of future product and service lines. If you inform us of any safety concerns with our cosmetic products, we will have to keep a record of your concerns and may have to report this to our relevant regulatory body. 

 

What is our legal basis?

It is in our legitimate interest to use the personal information provided by you in your feedback for the purposes described above.

We will only process special (or sensitive) categories of personal information (for example, personal information relating to your health) where we are able to do so under applicable legislation or with your explicit consent.

  • Customer insight and analysis. For more information

We analyse your contact details with other personal information that we observe about you from your interactions with our Site (such as the products or services you have purchased or viewed) or with our email communications to you.

Where you have given your consent (where lawfully required), we use cookies, log files and other technologies to collect personal information from the computer hardware and software you use to access the Site, or from your mobile device. This includes the following:

  • an IP address to monitor Site traffic and volume;
  • a session ID to track usage statistics on our Site; and
  • information regarding your personal or professional interests, demographics, buying habits, experiences with our Services and contact preferences.

Our web pages and emails contain cookies, web beacons or pixel tags (“Tags”). Tags allow us to track receipt of an email to you, count users who have visited a web page or opened an email and collect other types of aggregate information. Once you click on an email that contains a Tag, your contact information may subsequently be cross-referenced to the source email and the relevant Tag.

In some of our email messages, we use a “click-through URL” linked to certain websites administered by us or on our behalf. We may track click-through data to assist in determining interest in particular topics and measure the effectiveness of these communications.

Please see our Cookie Policy for further information.

This information is used to create insights about our visitors’ browsing habits on our Site. Where we have your consent to do so, we will also use your location data for customer insight and analysis purposes. 

By using this information, we are able to measure the effectiveness of our content and how visitors use our Site and our Services. This allows us to learn what pages of our Site are most attractive to our visitors, which parts of our Site are the most interesting and what kind of features and functionalities our visitors and clients like to see.

We use this information to help us with the selection of future product and service lines and website design and to remember your preferences.

We also use this information for marketing purposes (see the “Marketing Communications” section below for further details).

 

What is our legal basis?

Where your personal information is completely anonymised, we do not require a legal basis to use it as the information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymised personal information may be subject to other laws where your consent is required. Please see our Cookie Policy for further details.

Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information in such a way to ensure that we provide the very best services to you and our other customers.

We will only use your location data for insight and analysis purposes where we have your consent to do so.

  • Marketing communications.

We carry out the following marketing activities using your personal information:

    • Email marketing. For more information

We use your name, email address and on occasion your date of birth to send you marketing communications by email. Such communications will include information about the products, services, offers and promotions we offer from time to time.

Our email marketing will include personalised and non-personalised email marketing. Personalised marketing is marketing which has been specifically tailored to you. For example, our personalised email marketing will feature our products, services, offers and/or promotions that we think are most likely to appeal to you based on our understanding of your interests. Non-personalised marketing is marketing about our products, services, offers and promotions generally and is not tailored to any particular individual. 

Where we are sending you personalised email marketing, we will also use information that we observe about you from your interactions with our Site, with our email communications to you and/or with our products and services in order to decide what sort of personalised marketing communications to send you. Please see the “

Customer Insight and Analysis
” section above for more details about the personal information collected and how it is collected.

 

What is our legal basis?

Where your personal information is completely anonymised, we do not require a legal basis to use it as the personal information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymised personal information may be subject to other laws where your consent is required. Please see our Cookie Policy for further details.

Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information for marketing purposes.

We will only send you marketing communications by email where you have consented to receive such communications, or where we have a lawful right to do so.

    • Online and social media remarketing. For more information

We use information that we observe about you from your interactions with our Site, with our Stores, with our email communications to you and/or with our Services to provide you with personalised advertising on social media channels operated by Facebook (including Instagram) and/or Google where you are a registered user of such services. Please see the “

Customer Insight and Analysis
” section above for more details about the personal information collected and how it is collected. We do this using Facebook Custom Audiences and/or Google Customer Match. Please note that such activity is also subject to the privacy choices you have elected to make on such services.

 

What is our legal basis?

Where your personal information is completely anonymised, we do not require a legal basis to use it as the personal information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymised personal information may be subject to other laws where your consent is required. Please see our Cookie Policy for further details.

Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information for marketing purposes.

We will only engage in social media remarketing where you have consented to us using your email address and sharing your email address in an encrypted format with Facebook and/or Google respectively for marketing purposes.

    • Social media insight. For more information

Where you are a registered user of Facebook or of a Google service, we will use your email address in an encrypted format to enable Facebook and Google to find other registered users of their services who share similar interests to you based on:

  • information that we observe about you from your interactions with our Site, our Stores, with our email communications to you and/or with our Services (see the “Customer Insight and Analysis<” section above for more details of the information collected and how it is collected); and
  • the information Facebook and/or Google hold about you.

We do this using Facebook Lookalike Audiences and/or Google Similar Audience respectively. Please note that such activity is subject to the privacy choices you have elected to make on such services.

 

What is our legal basis?

Where your personal information is completely anonymised, we do not require a legal basis to use it as the personal information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymised personal information may be subject to other laws where your consent is required. Please see our Cookie Policy for further details.

Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information for marketing purposes.

  • Publicising Decorté. For more information

In order to raise our brand profile, we or our PR agency: (i) organise beauty events for both journalists and our customers or prospective customers to attend; (ii) may contact influencers, journalists or any other beauty industry experts who we think would be interested in using our products in order to send samples of our products; or (iii) may contact you if we see that you have posted about our brand, and we wish to use your content. In such circumstances, we will process your name, email address, postal address and social media handle (if applicable), as well as any other personal information volunteered by you.

 

What is our legal basis?

It is in our legitimate interest to use your personal information in order to publicise our products and services, including any new products and services that we may offer from time to time.

  • Prize draws, prize competitions and other promotions. For more information

From time to time, we may run prize draws, prize competitions and other promotions in our Stores and/or on our social media accounts. For the purposes of administering such promotions, we may process your name, contact details (email address, postal address, telephone number), social media handle (if relevant) and any other personal information volunteered by you in your promotion entry.

 

What is our legal basis?

It is necessary for us to use your personal information to perform our obligations in accordance with any contract that we may have with you (e.g. the terms and conditions applicable to the promotion) or it is in our legitimate interest to use your personal information to enable you to participate in any prize draws, prize competitions and other promotions.

  • Recruitment. For more information

We use your personal information for recruitment purposes, in particular, to assess your suitability for any position for which you may apply for with us, whether such application has been received by email or by hard copy and whether submitted directly by you or by a third party recruitment agency on your behalf. We also use your personal information to communicate with you about the recruitment process, to keep records about our recruitment process and to comply with our legal and regulatory obligations in relation to recruitment.

We may process any personal information about you that you volunteer when you apply for a job with us. We may also process your personal information obtained from any third parties we work with in relation to our recruitment activities, including without limitation, recruitment agencies, background check providers, credit reference agencies, your referees and the Disclosure and Barring Service (if applicable).

The personal information we process may include your name and contact information (e.g. email address, postal address, telephone number), personal information concerning your education, qualifications and employment history and any other personal information which appears in your curriculum vitae and covering letter, which you volunteer in an application form or during an interview or which is contained in any reference we receive about you. Such information may also include special categories of personal information (such as information about your health, any medical conditions and your health and sickness records) and information relating to criminal convictions and offences if that information is relevant to the role you are applying for.

We also use your personal information for the purposes of reviewing our equal opportunity profile in accordance with applicable legislation. We do not discriminate on the grounds of gender, race, ethnic origin, age, religion, sexual orientation, disability or any other basis covered by local legislation. All employment-related decisions are made entirely on merit.

 

What is our legal basis?

Where we use your personal information in connection with recruitment, it will be in connection with us taking steps at your request to enter into a contract we may have with you or it is in our legitimate interest to use personal information in such a way to ensure that we can make appropriate and informed recruitment decisions.

We will only process special (or sensitive) categories of personal information or personal information relating to criminal convictions or offences where we are able to do so under applicable legislation or with your explicit consent.

  • Receipt of services from suppliers. For more information

If we have engaged you or the organisation you represent to provide us with products or services (for example, if you or the organisation you represent provide us with services such as IT support, financial advice, social media marketing), we may collect and process your personal information in order to manage our relationship with you or the organisation you represent, to receive products and services from you or the organisation you represent and, where relevant, to provide products and services to our customers.

The personal information we collect from you may include your name, job title, contact information (including email address, telephone number and postal address), social media handle (where relevant), bank account or other payment details and any other personal information you volunteer which is relevant to our relationship with you or the organisation you represent.

 

What is our legal basis?

It is necessary for us to use your personal information to perform our obligations in accordance with any contract that we may have with you or it is in our legitimate interest to use personal information in such a way to ensure that we have an effective working relationship and are able to provide our products and services to our customers in an effective way.

  • Business administration and legal compliance. For more information

We use your personal information for the following business administration and legal compliance purposes:

  • to comply with our legal obligations;
  • to enforce our legal rights;
  • to protect the rights of third parties; and
  • in connection with a business transition such as a merger, acquisition by another company, or sale of all or a portion of our assets.

 

What is our legal basis?

Where we use your personal information in connection with a business transition, to enforce our legal rights or to protect the rights of third parties, it is in our legitimate interest to do so. For all other purposes described in this section, it is our legal obligation to use your personal information to comply with any legal obligations imposed upon us such as a court order.

We will only process special (or sensitive) categories of personal information or personal information relating to criminal convictions or offences where we are able to do so under applicable legislation or with your explicit consent.

  • Any other purposes for which we wish to use your personal information that are not listed above, or any other changes we propose to make to the existing purposes, will be notified to you using your contact details.
    6. What if you fail to provide your personal information?

Where we are required by law to collect your personal information, or we need to collect your personal information under the terms of a contract we have with you, and you fail to provide that personal information when we request it, we may not be able to perform the contract we have or are trying to enter into with you. This may apply where you do not provide the personal information we require in connection with an application for employment with us. In this case, we may have to cancel your job application or the provision of the relevant products or services to you, in which case we will notify you.

    7. How do we obtain your consent?

Where our use of your personal information requires your consent, you can provide such consent:

  • at the time we collect your personal information following the instructions provided; or
  • by informing us by email, post or phone using the contact details set out in this Privacy Policy.

Our Site uses certain cookies, web beacons, pixel tags, log files and other technologies of which you should be aware. Please see our Cookie Policy to find out more about the cookies and other similar technologies we use, the purposes for which we use them and how to manage, block or delete them.

    9. Third party links and services

Our Site contains links to third party websites and services. Please remember that when you use a link to go from our Site to another website or you request a service from a third party, this Privacy Policy no longer applies. For more information

Your browsing and interaction on any other websites, or your dealings with any other third party service provider, is subject to that website’s or third party service provider’s own rules and policies.

We do not monitor, control or endorse the privacy practices of any third parties.

We encourage you to become familiar with the privacy practices of every website you visit or third party service provider that you deal with and to contact them if you have any questions about their respective privacy notices and practices.

This Privacy Policy applies solely to personal information collected by us through our Site and/or the supply of our products and services and does not apply to these third party websites and third party service providers.

    10. Sharing personal information

We will only share personal information with others when we are legally permitted to do so. When we share personal information with others, we put contractual arrangements and security mechanisms in place to protect the personal information and to comply with our data protection, confidentiality and security standards. For more information

When processing your personal information we may need to share it with third parties as follows:

Other organisations within our group of companies: We may share personal information with other organisations within our group of companies where necessary for administrative purposes or where those organisations assist us in the provision of our Services. 

Third-party organisations that provide applications/functionality, data processing or IT services: We use third parties to support us in providing our Site, our Stores, our Services and to help provide, run and manage our internal IT systems. Such third parties may include, for example, providers of information technology, cloud-based software as a service, identity management, website hosting and management, data analysis, data back-up, security and storage services. The servers powering and facilitating that cloud infrastructure are located in secure data centres around the world, and personal information may be stored in any one of them. We also share your personal information with third-party service providers to assist us with insight analytics. These providers are described in our Cookie Policy.

Payment providers: We may share personal information with third parties who assist us with the processing of payments and refunds.

Delivery and courier companies: We use third-party delivery companies and couriers to help deliver Services that our customers order from our Site.

Third-party email marketing and CRM specialists: We share personal information with specialist suppliers who assist us in managing our marketing database and sending out our email marketing communications.

Event organisers and PR agencies: We may share personal information with other organisations with whom we are co-hosting an event or with our PR agency.

Stockists: We may share personal information, in limited circumstances, with department stores and online retailers who sell our products and services.

Recruitment agencies and related organisations: We may share your personal information with external recruiters, third party providers that undertake background checks on our behalf and other entities within our group of companies.

Auditors, lawyers, accountants and other professional advisers: We share personal information with professional services firms who advise and assist us in relation to the lawful and effective management of our organisation and in relation to any disputes we become involved in.

Law enforcement or other government and regulatory agencies: We may share personal information with law enforcement or other government and regulatory agencies or other third parties as required by, and in accordance with, applicable law or regulation.

Other third parties: Occasionally, we may receive requests from third parties with authority to obtain disclosure of personal information, such as to check that we are complying with applicable law and regulation, to investigate an alleged crime, to establish, exercise or defend legal rights.  We will only fulfil requests for personal information where we are permitted to do so in accordance with applicable law or regulation.

This list is non-exhaustive and there may be circumstances where we need to share personal information with other third parties in order to provide our products and services and carry out our regulatory duties as effectively as we can.

    11. Transfers outside the eea

Where necessary in order to deliver our Services, we will transfer personal information to countries outside the European Economic Area. Please note that Kosé Corporation is the data controller responsible for your personal information and is a private limited company registered in Japan, therefore some personal information will be transferred to Japan. Japan has been deemed to provide an adequate level of protection and has been granted an adequacy decision by the European Commission. 

Other non-EEA countries do not have the same data protection laws as the United Kingdom and the EEA. However, when transferring your personal information outside the EEA, we will comply with our legal and regulatory obligations in relation to the personal information including having a lawful basis for transferring personal information and putting appropriate safeguards in place to ensure an adequate level of protection for the personal information. We will take reasonable steps to ensure the security of your personal information in accordance with applicable data protection laws. For more information

When transferring your personal information outside the United Kingdom and/or the EEA, we will ensure that at least one of the following safeguards is implemented:

Adequacy decisions: We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en

Model clauses: Where we use certain service providers, 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 https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.

EU-U.S. Privacy Shield: Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/eu-us-privacy-shield_en.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

    12. Personal information of children under 18

Our Site, our Stores and the Services that we offer are not targeted at those under 18. If you are under 18, we ask that you obtain your parent’s or guardian’s consent before submitting personal information to us or requesting any Services from us.

If you are a parent or guardian of a child under 18, please ensure that you supervise your child’s use of our Site and our Services and ensure they obtain your consent before submitting any personal information to us or requesting any Services from us.

    13. How long we keep your personal information

Regarding personal information we have processed in connection with the use of our Site, our Stores and/or the supply of our Services to any person or organisation, we will retain personal information relevant to the use of our Site, our Stores and/or the supply of our Services from the date of the use and/or supply in compliance with our obligations under the EU General Data Protection Regulation (or similar legislation around the world). We may then destroy such files without further notice or liability.

Regarding any other personal information we have processed, we will retain relevant personal information from the date of our last interaction with the relevant person or organisation in compliance with our obligations under the EU General Data Protection Regulation (or similar legislation around the world). We may then destroy such files without further notice or liability.

If any personal information is only useful for a short period (e.g. for a specific marketing campaign), we may delete it at the end of that period.

If you have opted out of receiving marketing communications from us, we will need to retain certain personal information indefinitely, so we know not to send you further marketing communications in the future.

    14. Confidentiality and security of your personal information

We are committed to keeping the personal information you provide to us secure and we will take reasonable precautions to protect your personal information from loss, misuse or alteration. For more information .

We have implemented information security policies, rules and technical measures to protect the personal information that we have under our control from:

  • unauthorised access;
  • improper use or disclosure;
  • unauthorised modification; and
  • unlawful destruction or accidental loss.

All our employees and data processors (i.e. those who process your personal information on our behalf, for the purposes listed above) who have access to and are associated with the processing of personal information are obliged to respect the confidentiality of the personal information of all users of our Site, our Stores and our Services.

    15. How to access your information and your other rights

You have the following rights in relation to the personal information we hold about you:

  • Your right of access. For more information

If you ask us, we will confirm whether we are processing your personal information and, if so, provide you with a copy of that personal information (along with certain other details). If you require additional copies, we may charge a reasonable fee for producing those additional copies.

  • Your right to rectification. For more information c

If the personal information we hold about you is inaccurate or incomplete, you are entitled to have it rectified. If we have shared your personal information with others, we’ll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we will also tell you who we’ve shared your personal information with so that you can contact them directly.

  • Your right to erasure. For more information

You can ask us to delete or remove your personal information in some circumstances, such as where we no longer need it or where you withdraw your consent (where applicable). If we have shared your personal information with others, we will let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we will also tell you who we have shared your personal information with so that you can contact them directly.

  • Your right to restrict processing. For more information

You can ask us to block or suppress the processing of your personal information in certain circumstances, such as where you contest the accuracy of that personal information or you object to us processing it. It won’t stop us from storing your personal information, though. We will tell you before we lift any restriction. If we have shared your personal information with others, we will let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we will also tell you who we have shared your personal information with so that you can contact them directly.

  • Your right to data portability. For more information

You have the right, in certain circumstances, to obtain personal information you have provided to us (in a structured, commonly used and machine-readable format) and to reuse it elsewhere or to ask us to transfer it to a third party of your choice.

  • Your right to object. For more information

You can ask us to stop processing your personal information, and we will do so, if we are:

  • relying on our own or someone else’s legitimate interest to process your personal information, except if we can demonstrate compelling legal grounds for the processing; or
  • processing your personal information for the purposes of direct marketing.
  • Your rights in relation to automated decision-making and profiling. For more information

You have the right not to be subject to a decision when it is based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for the entering into, or the performance of, a contract between you and us.

  • Your right to withdraw consent. For more information

If we rely on your consent (or explicit consent) as our legal basis for processing your personal information, you have the right to withdraw that consent at any time. You can exercise your right of withdrawal by contacting us using our contact details in the “

How to Contact Us
” section above or by using any other opt-out mechanism we may provide, such as an unsubscribe link in an email.   

  • Your right to lodge a complaint with the supervisory authority. For more information

If you have a concern about any aspect of our privacy practices, including the way we have handled your personal information, you can report it to the Information Commissioner’s Office (ICO). You can find details about how to report a concern on the ICO website at https://ico.org.uk/concerns/ or by calling their helpline on 0303 123 1113.

    16. Changes to this Privacy Policy

We may make changes to this Privacy Policy from time to time. For more information

To ensure that you are always aware of how we use your personal information we will update this Privacy Policy from time to time to reflect any changes to our use of your personal information. We may also make changes as required to comply with changes in applicable law or regulatory requirements. We will notify you by email, if we have your email address, of any significant changes. However, we encourage you to review this Privacy Policy periodically to be informed of how we use your personal information.