PRIVACY POLICY

1. This privacy policy aims to give you information on how Fiona Campbell Design collects and processes your personal data, this includes any data you may provide through our website when you sign up to our newsletter, request a design consultation or when we take your details over the phone, by email or in person via our showroom in order to take your enquiry or answer any questions you have about our services and products. It is important you read this privacy policy together with any other privacy policy or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.

2. Controller – The data controller is Fiona Campbell Design (collectively referred to as ‘we’, ‘us’ or ‘our’ in this privacy policy.)

3. Changes to our Privacy Policy – This version of our privacy policy was updated on 25/05/2018. 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.

If you need to update your information at any time or have any questions about this privacy policy, please contact us at info@fionacampbelldesign.co.uk

4. Collection of personal data – We may collect and process your data when:

• You order a sample or swatch from us.
• You make an enquiry over the phone.
• You sign up for our newsletter.
• You make an enquiry through our website.
• You visit our showroom.
• You’ve given a third party permission to share information they hold about you
• We collect data from publicly-available sources when you have given consent to share information or where the information is made public as a matter of law.
• When you apply for a trade account with us .
• When you interact with our website, we may automatically collect technical data about your equipment, browsing actions, patterns and the website that referred you, where relevant. We collect this data by using cookies, server logs and other similar technologies. Technical data is collected from the following parties: analytics and search information providers, such as Google. Please see our cookie policy for more details.

5. Personal data we may collect from 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 as detailed below:

• Identity data including first name, surname and title.

• Contact data including billing address, delivery address, email address and telephone numbers. We will also collect your social media username if you interact with us through those channels.

• Financial data including bank account and payment card details.

• Transaction data including details about payments from you and other details of products and services you have paid for through us.

• Technical data including internet protocol (IP) address, browser type and version, time zone and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website.

• Profile data including order history, your preferences, feedback and survey responses.

• Usage data including information about how you use our website. This includes information gathered by the use of cookies in your web browser. Learn more about how we use cookies by reading our cookie policy.

• Marketing and Communications data which includes your preferences in receiving marketing from us and 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 it 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 web page. 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 policy.

• 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.

• Where we need to collect personal data by law, or under 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 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.

6. How your personal data will be used –
We cannot use your personal data without a lawful basis for doing so.
The legitimate bases are as follows:

• Contract. This 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.

• Legitimate interest. This 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, 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 interest. 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). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

• Legal or regulatory obligation. This entails processing your personal data where it is necessary or compliance with a legal or regulatory obligation that we are subject to.

• Consent. We will process your data for the purposes of marketing communications only if we have your consent to do so. This can be given online, over the phone, by email or in person.

• Vital interest. Where the processing of data is necessary in order to protect someone’s life.

7. Sharing your data – We may have to share your personal data with certain parties in certain circumstances as set out below:

• IT companies who support our website and other business systems and software
• Operational companies, such as couriers, contractors and subcontractors.
• Manufacturers of bespoke products, such as upholsterers, seamstresses, furniture makers.
• 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 policy.
• For fraud management, we may share information about fraudulent or potentially fraudulent activity in our premises or our 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 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 the data for the exact purpose we specify in our contract with them
• Work closely with them at all times to ensure that privacy is respected and protected

We will never share your data with third parties for their own purposes.

8. International transfers –
We will only transfer your data outside of the EEA in compliance with data protection laws and provided appropriate or suitable safeguards are in place to protect your data, these being either standard contractual clauses, binding corporate rules or in the case of transfers to the US, a Privacy Shield Certification.

9. Protecting your data –
The security of your personal data is very important to us and we are committed to treating it with the utmost care, taking 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 unauthorized 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. Access to your personal data is password-protected and sensitive data is secured.

We regularly monitor our system for possible vulnerabilities and attacks and have procedures in place to address breaches of security.

10. Holding on to your data –
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 consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized 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 anonymized, so that it can be used in a non-identifiable way for statistical analysis and business planning.

If you have given consent to receive marketing communications from us, your data will be retained for that purpose only. You can unsubscribe or update your preferences at any time by using the link included at the bottom of every email.

11. Your rights over your personal data –
Under certain circumstances, you have rights under data protection laws in relation to your personal data, as detailed below:

• Request access. 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. This enables you to have any incomplete or inaccurate data we hold about you corrected. We may need to verify the accuracy of the new data you provide to us.

• Request erasure. This enables you to ask us to delete or remove personal data where there is no legitimate 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. You have the right to object to us processing your data for direct marketing purposes. You also have the right to object where there is something about your particular situation that you feel impacts on your fundamental rights and freedoms. 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. 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. Where you have requested the transfer of your data to you or a third party, we will provide you, or the chosen third party, 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, you can withdraw your consent at any time. 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. We will advise you if this is the case at the time you withdraw your consent.

• In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must do so unless we believe we have a legitimate overriding reason to continue processing your personal data.

• You have the right to stop the use of your personal data for direct marketing activity through all channels or selected channels. We must always comply with your request.

If you wish to exercise any of the rights set out above, please contact us:

By email – info@fionacampbelldesign.co.uk

By phone – 020 7731 3681