A very warm welcome to The Linen Works (London) Ltd privacy notice.
The Linen Works is highly committed to your privacy and protecting your personal data. This privacy notice explains the types of personal data that we may collect from you when you interact with us. This privacy notice will also inform you as to how we look after your personal data and keep it safe and will tell you about your privacy rights and how the law protects you.
We appreciate that there is a lot of information here, but we want you to feel fully informed and be transparent about your personal data rights, reassuring you that we work extremely hard to ensure the applicable protection of your data both now and in the future.
PURPOSE OF THIS PRIVACY NOTICE
This privacy notice aims to provide you with an outline of how The Linen Works collects and processes any personal data that you provide to us, including any data you may provide through this website when you sign up to receive our email newsletter or mailout, purchase a product, take part in a competition or sign up for special event and offer updates.
The Linen Works is the controller and responsible for your personal data (collectively referred to as “company”, “we”, “us” or “our” in this privacy notice).
If you have any questions about this privacy notice including any requests to exercise, please contact us via email with reference ‘Data Privacy’ to: firstname.lastname@example.org
OUR CONTACT DETAILS
Our full contact details are set out below:
The Linen Works (London) Ltd
Riverside Business Centre
Telephone: 020 3744 1020
Company Registration Number: 07321876
VAT Registration Number: 997771146
The Linen Works® is a Registered Trade Mark of The Linen Works (London) Ltd
If you consider The Linen Works to process your personal data in an incorrect way, you have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, be grateful and would appreciate the chance to deal with your concerns before you approach the ICO, so please kindly contact us in the first instance.
CHANGES TO OUR PRIVACY NOTICE
YOUR DUTY TO INFORM US OF YOUR DATA CHANGES
It is important that the personal data we hold about you is accurate and current. We kindly ask that you please keep us informed if your personal data changes during your relationship with us and we can ensure all data we hold for you is correct and reflects your personal preferences.
Our website may include links to third-party websites, plug-ins for our website platform Shopify and applications. We currently link to Feefo, Facebook, Twitter, Google, Instagram and Pinterest throughout our website. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
WHAT TYPE OF DATA MAY 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 which we have gathered together as follows:
- Identity Data includes first name, maiden name, last name or surname, username or similar identifier, marital status, title, date of birth and gender
- Contact Data includes billing address, delivery address, email address and telephone numbers
- Financial Data includes bank account and payment card details
- Transaction Data includes details about payments to and from you and other details of products you have purchased from us
- Technical Data includes 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. This helps us to provide you with the best possible customer shopping experience with us
- Profile Data includes your username and encrypted password, purchases or orders made by you, your interests, preferences, feedback and survey responses. This can also include demographic information, such as your postcode, preferences and other interests
- Marketing and Communications Data includes your preferences in receiving marketing from us both in digital and printed forms as well as your communication preferences
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
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 RELEVANT 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.
If a password is used in the creation of an account, we are not able to see the password used. We do not store your password in plain text, instead these are encrypted on the Shopify server. We can process a request through our website platform to reset your password if you have forgotten it which will send an email notification to the email registered on the account.
HOW DO WE COLLECT YOUR PERSONAL DATA?
We use different methods to collect data from and about you including through the likes of:
You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- Make an online purchase of our products
- Purchase a product by telephone
- Create an account on our website
- Request a brochure, printed marketing collateral or swatch pack from us
- Sign up to subscribe for our email newsletters
- Engage with us across social media platforms
- Contact us by any means with feedback such as queries, complaints, etc
- Enter a competition, promotion, giveaway or prize draw with us
- Participate in any surveys we may send you
- Comment on or review our products and services
- Apply for a trade account with us through our website, over the phone and in-store
- Interact with us on a business to business project or becoming a stockist basis
From time to time, we may also receive personal data about you from various third parties or publicly available sources with whom we may partner with in the future.
- Technical Data from analytics providers or search information providers such as Google based outside the EEA
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services based inside or outside the EEA. For example, we may deliver products to a customer outside the EEA
- Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EEA
HOW MIGHT WE USE YOUR PERSONAL DATA?
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we have entered or are due to enter with you. Performance contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. Legitimate interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law)
- Where we need to comply with a legal or regulatory obligation. This means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to
- Where you consent. Consent means that the data subject’s clear and unambiguous consent; this must be requested in an intelligible and easily accessible form, using clear and plain language and where it is required in writing, it is clearly distinguishable from any other matters which may also be referred to
Where you give your consent to any of our processing, you have the right to withdraw consent at any time by contacting us at email@example.com using reference ‘Data’
PURPOSES FOR WHICH WE MIGHT USE YOUR PERSONAL DATA
We have set out below a description example of all the ways we may to use your personal data. 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.
- To register you as a new customer, obtaining identity and contact data to complete this
- To process any orders that you make on our website. If we did not collect your personal data during checkout, we would not be able to process and deliver your order and comply with legal obligations. For example, your details may need to be passed to a third party to supply or deliver the product or service that you ordered, and we may keep your details for a reasonable period afterwards in order to fulfil any contractual obligations such as refunds, guarantees and so on
- To respond to your queries, refund requests and complaints. Handling the information that you send enables us to respond accordingly. 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 in providing you with the best service and understanding how we can improve our service based on your experience.
- To protect our customers, premises, assets and staff from crime. We do this on the basis of our legitimate business interests
- 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.
- If we discover any criminal activity or alleged criminal activity through fraud monitoring and suspicious transaction monitoring, we will process this data for the purposes of preventing or detecting unlawful acts. We aim to protect the individuals we interact with from criminal activities
- To send you relevant communications by email or post in relation to updates, products and services. We'll do this on the basis of our legitimate business interest. You are free to opt out of hearing from us by email or post at any time
- To administer any of our prize draws, giveaways or competitions which you enter
- To listen to recorded telephone conversations for internal staff training purposes
- To develop, test and improve the systems, services and products ((including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) we provide to you. We'll do this on the basis of our legitimate business interests and to comply with legal obligation
- 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
- To build a picture of who you are and your interests, and to inform our business decisions, we'll combine data captured by The Linen Works, third parties and data from publicly. We'll do this on the basis of our legitimate business interest.
- To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you. Necessary for our legitimate interests (to study how customers use our products, to develop them, to grow our business and to inform our marketing strategy)
- To use data analytics to improve our website, products, customer services marketing, customer relationships and experiences. Necessary for our legitimate interests (to define types of customers for our products, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
WHO MIGHT WE SHARE YOUR DATA WITH?
We may have to share your personal data with the parties set out below and service providers acting as processors for the purposes outlined in ‘Purposes for which we might use your personal data’. This typically includes the likes of:
- Help us with our IT, our website systems (including hosting) and our business systems administration services
- Operational companies, such as delivery couriers who help us with our order fulfilment such as delivery partners and courier companies. Please note that we supply our products directly to customers in the jurisdictions listed on our website (the list of which is updated from time to time), some of which are outside the EEA. Where your order is required to be delivered to you outside of the EEA, we will share your data with third parties in order to deliver your product to you
- Direct marketing companies, who help us manage our electronic communications to you and any companies that might carry out data analysis and survey/research work on our behalf, with consent and privacy protection
- Professional advisers (acting as processors where access to personal data is necessary) including lawyers, bankers, auditors and insurers based in the jurisdictions in which we operate who provide consultancy, banking, legal, insurance and accounting services. We take advice in relation to supplying our products to consumers and other corporate customers in all countries in which we operate
- HM Revenue & Customs, regulators and other authorities (acting as processors or controllers in their own right) based in the United Kingdom who require reporting of processing activities in certain circumstances.
- Data insight companies to ensure your details are up to date and accurate
- We may also share certain limited information with companies who assist us with other services, for example, in analysing our customer data in order to better understand, profile and monitor customer patterns so we can consistently improve our products and services and understand what may be of interest to you and other customers. They will only be allowed to use your information in the way in which we instruct them and as permitted by the Data Protection Act or the GDPR. To opt out of having your data used in this way, please email firstname.lastname@example.org
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
- 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
WHERE YOUR PERSONAL DATA MAY BE PROCESSED
If we are sending your order internationally, sometimes we need to share your personal data with third parties outside the European Economic Area (EEA) such as name, email address and contact phone number for courier information purposes to ensure your parcel is delivered safely to you. The EEA consists of all EU Member States as well as Norway, Iceland and Liechtenstein.
Whenever we transfer your personal data out of 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 by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
- 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 European Commission: Model contracts for the transfer of personal data to third countries.
- 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 the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established a basic preference centre where you can view and make certain decisions about your personal data use.
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.
You will receive marketing communications from us if you have requested information from us or purchased goods from us, or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
When you sign-up to receive our email updates, we may collect optional information such as your name, postcode, and product interests. We use this personal information to tailor our email messages and to enhance our product and service offerings.
If you do not want to receive offers and promotions by email, you can easily unsubscribe by clicking on the link on the bottom of your email. Please remember it can take up to 21 days to fully remove you from our email mailing list so you may receive one or two more.
If you do not want to receive offers and promotions by post, please let us know at email@example.com. Our brochures are printed in advance so please bear in mind that it can take up to eight weeks for the process to be complete and please be warned that you may receive one further brochure as a result of this.
We do not sell, rent or otherwise disclose your personal information to third parties for their marketing purposes. We will get your express opt-in consent before we share your personal data with any company outside The Linen Works for marketing purposes.
If you do not wish to receive marketing communications from us, you can unsubscribe at any time via the link in an e-mail you received, or by logging into your account on our website and checking or unchecking relevant boxes to adjust your marketing preferences or by contacting us at firstname.lastname@example.org at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us because of a product purchase, warranty registration, product experience or other transactions.
OUR COOKIES POLICY
We use various analytics tools to log when users visit specific pages or take specific actions on our website; this allows us to provide targeted advertising through the likes of Google and third-party vendors to display The Linen Works products that you may be interested in based on your past browsing history on our website.
You can visit our site without telling us who you are or providing us with any personal information. However, we collect the I.P. (Internet protocol) addresses of all our website visitors and other related information such as page requests, browser type, operating system and average time spent on our website. We use this information to improve our website.
If you would like further instructions on how you can opt out of receiving targeted advertising, please follow this link to the EDAA opt-out site at www.youronlinechoices.com/uk/
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the:
- External third-parties as set out below the section ’Who Might We Share Your Data With’
- you can find above
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
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.
In order to protect your privacy, we will:
- Only provide the information necessary to perform their specific services
- Only use their data for the exact purpose we specify in our contract with them
- Work closely with them to ensure their privacy is respected and protected at all times
The security of your personal data is extremely important to us here at The Linen Works and we are committed to treating it with the utmost care, promising to take all appropriate steps to protect it. 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. Access to your personal data is password-protected and confidentiality and database access controls are reviewed periodically and updated as required to further protect our personal data.
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 regularly monitor our system for possible vulnerabilities and attacks, and we carry out penetration testing to identify ways to further strengthen security.
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.
We know that security is a major concern to many of our customers. Our system is secure and credit card information entered on our site will not be accessed by any unauthorised person or company. Once your order has been transferred to our order processing system all credit card details are removed from the website. We do not store any payment detail data on our website. This does mean you have to give your card details every time you place an order with us, but this minor inconvenience ensures that it is totally safe to shop with us.
PCI Compliant Shopping Cart & Hosting
The Payment Card Industry Data Security Standard (PCI DSS) is an information security standard for organizations that handle credit card and debit card information. Defined by the Payment Card Industry Security Standards Council, the standard was created to increase controls around credit card data to reduce credit card fraud via its exposure.
Shopify, our online store platform in which we operate from, is certified Level 1 PCI DSS compliant and meets all six categories of PCI standards. From annual on-site assessments validating compliance to continuous risk management, Shopify work really hard to ensure our shopping cart software and ecommerce hosting is secure.
These categories include:
- Maintaining a secure network
- Maintaining a vulnerability management programme
- Regularly monitoring and testing networks
- Protecting Cardholder Data
- Implementing strong access control measures
- Maintaining an information security policy
We work hard to prevent any fraudulent activities across our website. Shopify's built-in fraud analysis uses machine learning algorithms to help bring suspicious orders to our attention, allowing us to investigate a suspicious order in several ways.
The risk of fraud from using your card on our website is extremely low. Nevertheless, if your card is used fraudulently as a direct result of having been used to buy from our site, we will work closely with your bank and credit card company to provide any information they require to resolve the issue to make sure you do not lose out as a result.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we will consider many factors including 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 requirements. At the end of that 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.
YOUR LEGAL RIGHTS OVER YOUR PERSONAL DATA
Under certain circumstances, you have rights under data protection laws in relation to your personal data. 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) 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 to use or where we used the information to perform a contract with you.
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.
If you wish to exercise any of the rights set out above, you can contact us at email@example.com
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 RESPONDWe 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.