We want to keep you informed, so this Privacy Notice explains in detail what personal data we may collect about you when you interact with us. It also explains what we do with it, how we use it and how we store it.
When you are using www.cwclothes.co.uk, Fashion Empire Limited is the data controller.
Why do we collect your personal data?
We may state the obvious, but in order to be able to offer you different services, we will need to collect your personal data and we may share it with third parties. All these reasons are regulated by law:
- Contractual obligations. We collect and use your data to deliver an on-line order placed through our Website and we pass it on to our courier.
- Direct marketing and legitimate interest. We collect and use your data (including your e-mail address and purchase history, for instance) to send you relevant information about our offers, discounts, new Products etc. We can also use the data we have about you and collate it with other people’s data; this will allow us to obtain statistics that help us improve the quality of our services, Products etc.
- Legal compliance. Sometimes, we can pass on details of people involved in fraud or other criminal activity affecting us.
When do we collect your personal data?
Here is a list of possible scenarios when we will need to collect your personal data:
- you visit any of our Websites and create an account with us to buy Products and services.
- you make an online purchase and check out as a guest.
- you engage with us on social media.
- you contact us by any means with queries, complaints etc.
- you enter prize draws or competitions.
- you choose to complete a survey of ours.
- you comment on or review our Products and services.
What personal data do we collect?
- Your name, gender, date of birth, billing/delivery address, orders and receipts, e-mail, telephone number and an encrypted record of your login password (for your protection). We need them all when you open an account with us.
- Details of your interaction with us: emails, comments, Product reviews or complaints that you have made using our message system, wish lists, Products that you have viewed or added to your basket without purchasing, your voucher history, pages you have viewed etc.
- Your social media username, if you interact with us through those channels, to help us respond to your comments, questions or feedback.
- Payment card information.
Please remember that we will only ask for this data to be able to fulfil a contractual obligation or to tailor our services to your best interest. We will never disclose these information to anybody else unless you have given us direct and positive consent.
Of course, it’s always your choice whether you share such details with us; keep in mind, though, that if you opt out from us using some of your personal data, you may miss the full experience of our services or we may not be able to provide some of the services you have required.
How we use IP addresses and cookies?
- Cookies are text files with that contain bits of information — such as username and password — that are used to identify your device as you use an electronic network. Data stored in cookies is created by the server upon your connection to the network. This data is labelled with an ID unique to you and your device.
- An IP address is a unique string of numbers that identifies a device on the internet or a local network. IP is shorthand for "Internet Protocol," which is the set of rules governing the format of data sent using the internet or local network.
This allows us to estimate our audience size and usage pattern, to store information about some preferences, and so allow us to customise the Website according to your individual interests, speed up your searches and recognise you when you return to the Website. Therefore, this is chiefly statistical data about our users' browsing actions and patterns, and does not identify any individual.
How do we use your data?
The data privacy law allows us to collect relevant information about you and your purchase behaviours as part of our legitimate interest. That means we will do our best to understand you, as an individual and to provide you with tailored promotions, Products, services and rewards that will most likely interest you.
Here’s how we’ll use your personal data and why:
- To process any orders that you make by using our Website. If we don’t collect your personal data during checkout, we won’t be able to process your order and comply with our legal obligations.
Please note that we may keep your details for a reasonable period afterwards in order to fulfil any contractual obligations such as refunds, guarantees etc. and to comply with current tax legislation.
- To respond to your queries, refund requests and complaints. Handling the information you sent enables us to respond. We may also keep a record of these to inform any future communication with us and to demonstrate how we communicated with you throughout. We do this on the basis of our contractual obligations to you, our legal obligations and our legitimate interests.
- To protect our business and your account from fraud and other illegal activities. This includes using your personal data to maintain, update and safeguard your account. We’ll also monitor your browsing activity with us to quickly identify and resolve any problems and protect the integrity of our Website. We’ll do all of this as part of our legitimate interest.
For example, by checking your password when you login and using automated monitoring of IP addresses to identify possible fraudulent log-ins from unexpected locations.
- To process payments and to prevent fraudulent transactions. We do this on the basis of our legitimate business interests. This also helps to protect our customers from fraud.
- We will use your personal data, preferences and details of your transactions to keep you informed by email, web, text or telephone about relevant Products and services including tailored special offers, discounts, promotions, events, competitions and so on. We’ll do this on the basis of our legitimate business interest.
Of course, you are free to opt out of hearing from us by any of these channels at any time.
- To send you communications required by law or which are necessary to inform you about our changes to the services we provide you. For example, updates to this Privacy Notice, Product recall notices and legally required information relating to your orders. These service messages will not include any promotional content and do not require prior consent when sent by email or text message. If we do not use your personal data for these purposes, we would be unable to comply with our legal obligations.
- To display the most interesting content to you on our Website or app, we’ll use data we hold about your favourite brands or Products and so on. We do so on the basis of your consent for our Website to place cookies or similar technology on your device.
- To administer any of our prize draws or competitions which you enter, based on your consent given at the time of entering.
- To develop, test and improve the systems, services and Products we provide to you. We’ll do this on the basis of our legitimate business interests.
- To comply with our contractual or legal obligations to share data with law enforcement.
- To send you survey and feedback requests to help improve our services. These messages will not include any promotional content and do not require prior consent when sent by email or text message. We have a legitimate interest to do so as this helps make our Products or services more relevant to you.
Of course, you are free to opt out of receiving these requests.
To summarise all the above, within the legal boundaries and our legitimate business interest, we can send you information about our great Products, offers, services and other exciting stuff. Just remember, if you ever feel that you don’t want to keep in contact with us, you will have the option to stop receiving messages by opting out. It is your legal right.
How we protect your data?
We know how much data security matters to all our customers. With this in mind, we will treat your data with the utmost care and take all appropriate steps to protect it.
We secure access to all transactional areas of our Website and app using ‘https’ technology.
Access to your personal data is password-protected and sensitive data (such as payment card information) is secured and encrypted to ensure it is protected.
We regularly monitor our system for possible vulnerabilities and attacks and we carry out penetration testing to identify ways to further strengthen security.
Whenever we collect or process your personal data, we’ll only keep it for as long as is necessary for the purpose for which it was collected. It is your right to be forgotten, that is why you can delete your account if you no longer wish us to keep your personal data.
At the end of the relevant retention period your data will either be deleted completely or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning.
Who do we share with?
We sometimes share your personal data with trusted third parties.
For example, delivery couriers or for fraud management, to handle complaints, to help us personalise our offers to you and so on.
Here’s the policy we apply to those organisations to keep your data safe and protect your privacy:
We provide only the information they need to perform their specific services.
They may only use your data for the exact purposes we specify in our contract with them.
We work closely with them to ensure that your privacy is respected and protected at all times.
If we stop using their services, any of your data held by them will either be deleted or rendered anonymous.
Examples of the kind of third parties we work with are:
IT companies who support our Website and other business systems.
Operational companies such as delivery couriers.
Direct marketing companies who help us manage our electronic communications with you.
Search engines, social media and online marketing companies to show you Products that might interest you while you are browsing the internet.
Data insight companies to ensure your details are up to date and accurate.
Sharing your data with third parties for their own purposes
For fraud management, we may share information about fraudulent or potentially fraudulent activity in our premises or systems. This may include sharing data about individuals with law enforcement bodies.
We may also be required to disclose your personal data to the police or other enforcement, regulatory or Government body, in your country of origin or elsewhere, upon a valid request to do so. These requests are assessed on a case-by-case basis and take the privacy of our customers into consideration.
We may, potentially, expand, reduce or sell our business and this may involve the transfer of divisions or the whole business to new owners. If this happens, your personal data will, where relevant, be transferred to the new owner or controlling party, under the terms of this Privacy Notice.
Manage the way we use your personal data
There are several ways you can manage the communication with us:
- To stop any direct marketing, click the ‘unsubscribe’ link in any email communication that we send you. We will then stop any further emails to you regarding offers, discounts, news etc. You will only receive updates related to an order or a back-order you have placed with us.
- If you have an account with us, log into your online account, and navigate to the relevant page.
- Ask us to delete your personal data and your account (the right to be forgotten).
YOUR LEGAL RIGHTS
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, for example, of our clients) 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 (or our clients) to use or where we used the information to perform a contract with you (or between you and our client if you are a customer of client).
- 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 services to you or provide information about our clients’ Products and services to you.
No fee usually required
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.
What we may need from you:
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.
Time limit to respond
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.
Queries & Questions
Any adjustments we may make to our Privacy Notice in the future will be recorded on this page and, where appropriate, informed to you by e-mail.
Any questions, comments and requests regarding any part of this Privacy Notice is welcomed and should be headed to our Customer Service Team via the Contact Us link.