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2019 EventsPrivacy Policy
1. Introduction
1.1 We
are committed to safeguarding the privacy of our website visitors and service
users.
1.2 This
policy applies where we are acting as a data controller with respect to the
personal data of our website visitors and service users; in other words, where
we determine the purposes and means of the processing of that personal data.
1.3 We
use cookies on our website. Insofar as those cookies are not strictly necessary
for the provision of our website and services, we will ask you to consent to
our use of cookies when you first visit our website.
1.4 Our
website incorporates privacy controls which affect how we will process your
personal data. By using the privacy controls situated in your account, you can
specify whether you would like to receive direct marketing communications and
limit the publication of your information.
1.5 In
this policy, "we", "us" and "our" refer to Silver
by Victoria and/or Jewelzonline. For more information about us, see Section
13.
2. Credit
2.1 This
document was created using a template from SEQ Legal (https://seqlegal.com).
3. How we use your personal data
3.1 In
this Section 3 we have set out:
(a) the
general categories of personal data that we may process;
(b) in
the case of personal data that we did not obtain directly from you, the source
and specific categories of that data;
(c) the
purposes for which we may process personal data; and
(d) the
legal bases of the processing.
3.2 We
may process data about your use of our website and services ("usage
data"). The usage data may include your IP address, geographical
location, browser type and version, operating system, referral source, length
of visit, page views and website navigation paths, as well as information about
the timing, frequency and pattern of your service use. The source of the usage
data is Zen Cart. This usage data may be
processed for the purposes of analysing the use of the website and services.
The legal basis for this processing is consent.
3.3 We
may process your account data ("account data"). The account
data may include your name and email address. The source of the account data is
you. The account data may be processed for the purposes of operating our
website, providing our services, ensuring the security of our website and
services, maintaining back-ups of our databases and communicating with you. The
legal basis for this processing is consent or the performance of a contract
between you and us and/or taking steps, at your request, to enter into such a
contract.
3.4 We
may process your information included in your personal profile on our website
("profile data"). The profile data may include your name,
address, telephone number, email address, date of birth and business name if
applicable. The profile data may be processed for the purposes of enabling and
monitoring your use of our website and services. The legal basis for this
processing is consent or the performance of a contract between you and us
and/or taking steps, at you request, to enter into such a contract.
3.5 We
may process your personal data that are provided in the course of the use of
our services ("service data"). The service data may include your
name, address, telephone number, email address, date of birth and business name
if applicable. The source of the service data is you. The service data may be
processed for the purposes of operating our website, providing our services,
ensuring the security of our website and services, maintaining back-ups of our
databases and communicating with you. The legal basis for this processing is
our legitimate interests, namely the proper administration of our website and
business or the performance of a contract between you and us and/or taking
steps, at your request, to enter into such a contract.
3.6 We
may process information that you post for publication on our website or through
our services ("publication data"). The publication data may be
processed for the purposes of enabling such publication and administering our
website and services. The legal basis for this processing is our legitimate
interests, namely the proper administration of our website and business or the
performance of a contract between you and us and/or taking steps, at your
request, to enter into such a contract.
3.7 We
may process information contained in any enquiry you submit to us regarding
goods and/or services ("enquiry data"). The enquiry data may
be processed for the purposes of offering, marketing and selling relevant goods
and/or services to you. The legal basis for this processing is your legitimate
request for service information and communication and our proper legitimate
interests in the proper administration of running our website and business.
3.8 We
may process information relating to transactions, including purchases of goods
and services, that you enter into with us and/or through our website ("transaction
data"). The transaction data may include your contact details, and the
transaction details. The transaction
data may be processed for the purpose of supplying the purchased goods and
services and keeping proper records of those transactions. The legal basis for
this processing is the performance of a contract between you and us and/or
taking steps, at your request, to enter into such a contract and our legitimate
interests, namely the proper administration of our website and business.
3.9 We
may process information that you provide to us for the purpose of subscribing
to our email notifications and/or newsletters ("notification data").
The notification data may be processed for the purposes of sending you the
relevant notifications and/or newsletters. The legal basis for this processing
is consent or the performance of a contract between you and us and/or taking
steps, at your request, to enter into such a contract.
3.10 We
may process information contained in or relating to any communication that you
send to us ("correspondence data"). The correspondence data
may include the communication content and metadata associated with the
communication. Our website will generate the metadata associated with
communications made using the website contact forms. The correspondence data
may be processed for the purposes of communicating with you and record-keeping.
The legal basis for this processing is our legitimate interests, namely the
proper administration of our website and business and communications with users.
3.11 We
may process any of your personal data identified in this policy where necessary
for the establishment, exercise or defence of legal claims, whether in court
proceedings or in an administrative or out-of-court procedure. The legal basis
for this processing is our legitimate interests, namely the protection and
assertion of our legal rights, your legal rights and the legal rights of
others.
3.12 We
may process any of your personal data identified in this policy where necessary
for the purposes of obtaining or maintaining insurance coverage, managing
risks, or obtaining professional advice. The legal basis for this processing is
our legitimate interests, namely the proper protection of our business against
risks.
3.13 In
addition to the specific purposes for which we may process your personal data
set out in this Section 3, we may also process any of your personal data where
such processing is necessary for compliance with a legal obligation to which we
are subject, or in order to protect your vital interests or the vital interests
of another natural person.
3.14 Please
do not supply any other person's personal data to us, unless we prompt you to
do so.
4. Providing your personal data to others
4.1 We
may disclose your personal data to any member of our group of companies insofar
as reasonably necessary for the purposes, and on the legal bases, set out in
this policy.
4.2 We
may disclose your personal data to our insurers and/or professional advisers
insofar as reasonably necessary for the purposes of obtaining or maintaining
insurance coverage, managing risks, obtaining professional advice, or the
establishment, exercise or defence of legal claims, whether in court
proceedings or in an administrative or out-of-court procedure.
4.3 We
may disclose personal data to our suppliers or subcontractors insofar as
reasonably necessary for the proper administration of our website and business.
4.4 Financial
transactions relating to our website and services are handled by our payment
services providers, PayPal, Etsy and Stripe (Folksy). We will share
transaction data with our payment services providers only to the extent
necessary for the purposes of processing your payments, refunding such payments
and dealing with complaints and queries relating to such payments and refunds.
You can find information about the payment services providers' privacy policies
and practices at:
Folksy - https://folksy.uservoice.com/knowledgebase/articles/54066-4-privacy-policy
Etsy – https://www.etsy.com/uk/legal/privacy/?ref=ftr
PayPal -
https://folksy.uservoice.com/knowledgebase/articles/54066-4-privacy-policy
4.5 We
may disclose your enquiry data to one or more of those selected third party
suppliers of goods and services identified on our website for the purpose of
enabling them to contact you so that they can offer, market and sell to you
relevant goods and/or services. Each such third party will act as a data
controller in relation to the enquiry data that we supply to it; and upon
contacting you, each such third party will supply to you a copy of its own
privacy policy, which will govern that third party's use of your personal data.
4.6 In
addition to the specific disclosures of personal data set out in this Section
4, we may disclose your personal data where such disclosure is necessary for
compliance with a legal obligation to which we are subject, or in order to
protect your vital interests or the vital interests of another natural person.
We may also disclose your personal data where such disclosure is necessary for
the establishment, exercise or defence of legal claims, whether in court
proceedings or in an administrative or out-of-court procedure.
5. International transfers of your personal data
5.1 In
this Section 5, we provide information about the circumstances in which your
personal data may be transferred to countries outside the European Economic
Area (EEA).
5.2 We
have in the United Kingdom. The European Commission has made an "adequacy
decision" with respect to the data protection laws of each of these
countries. Transfers to will be
protected by appropriate safeguards, namely the use of standard data protection
clauses adopted or approved by the European
Commission, a copy of which can be obtained from:
5.3 The hosting facilities for our website are
situated in the United Kingdom. The European Commission has made an
"adequacy decision" with respect to the data protection laws of the
United Kingdom. Transfers to will be protected by appropriate safeguards,
namely the use of standard data protection clauses adopted or approved by the
European Commission, a copy of which you can obtain from:
5.4 Our Email service provider is situated in
United Kingdom. The European Commission has made an "adequacy
decision" with respect to the data protection laws of the United Kingdom.
Transfers to each of these countries will be protected by appropriate
safeguards, namely the use of standard data protection clauses adopted or
approved by the European Commission, a copy of which can be
obtained from:
5.5 You
acknowledge that personal data that you submit for publication through our
website or services may be available, via the internet, around the world. We
cannot prevent the use (or misuse) of such personal data by others.
6. Retaining and deleting personal data
6.1 This
Section 6 sets out our data retention policies and procedure, which are
designed to help ensure that we comply with our legal obligations in relation
to the retention and deletion of personal data.
6.2 Personal
data that we process for any purpose or purposes shall not be kept for longer
than is necessary for that purpose or those purposes.
6.3 We
will retain your personal data as follows:
(a) Personal
data will be retained for a minimum period of one year and for a maximum period
of seven years following the consent/purchase
date.
6.4 In
some cases it is not possible for us to specify in advance the periods for
which your personal data will be retained. In such cases, we will determine the
period of retention based on the following criteria:
(a) the
period of retention of your name, address, telephone number, email address,
date of birth and business name if applicable. Will be determined based on what
is reasonably necessary for the proper administration of our website and
business needs.
6.5 Notwithstanding
the other provisions of this Section 6, we may retain your personal data where
such retention is necessary for compliance with a legal obligation to which we
are subject, or in order to protect your vital interests or the vital interests
of another natural person.
7. Amendments
7.1 We
may update this policy from time to time by publishing a new version on our
website.
7.2 You
should check this page occasionally to ensure you are happy with any changes to
this policy.
7.3 We
may notify you of changes to this policy by email.
8. Your rights
8.1 In
this Section 8, we have summarised the rights that you have under data
protection law. Some of the rights are complex, and not all of the details have
been included in our summaries. Accordingly, you should read the relevant laws
and guidance from the regulatory authorities for a full explanation of these
rights.
8.2 Your
principal rights under data protection law are:
(a) the
right to access;
(b) the
right to rectification;
(c) the
right to erasure;
(d) the
right to restrict processing;
(e) the
right to object to processing;
(f) the
right to data portability;
(g) the
right to complain to a supervisory authority; and
(h) the
right to withdraw consent.
8.3 You
have the right to confirmation as to whether or not we process your personal
data and, where we do, access to the personal data, together with certain
additional information. That additional information includes details of the
purposes of the processing, the categories of personal data concerned and the
recipients of the personal data. Providing the rights and freedoms of others
are not affected, we will supply to you a copy of your personal data. The first
copy will be provided free of charge, but additional copies may be subject to a
reasonable fee. You can access
your personal data by visiting the “Your
Account” when logged into our website.
8.4 You
have the right to have any inaccurate personal data about you rectified and,
taking into account the purposes of the processing, to have any incomplete
personal data about you completed.
8.5 In
some circumstances you have the right to the erasure of your personal data
without undue delay. Those circumstances include: the personal data are no
longer necessary in relation to the purposes for which they were collected or
otherwise processed; you withdraw consent to consent-based processing; you
object to the processing under certain rules of applicable data protection law;
the processing is for direct marketing purposes; and the personal data have
been unlawfully processed. However, there are exclusions of the right to
erasure. The general exclusions include where processing is necessary: for exercising
the right of freedom of expression and information; for compliance with a legal
obligation; or for the establishment, exercise or defence of legal claims.
8.6 In
some circumstances you have the right to restrict the processing of your
personal data. Those circumstances are: you contest the accuracy of the
personal data; processing is unlawful, but you oppose erasure; we no longer
need the personal data for the purposes of our processing, but you require
personal data for the establishment, exercise or defence of legal claims; and
you have objected to processing, pending the verification of that objection.
Where processing has been restricted on this basis, we may continue to store
your personal data. However, we will only otherwise process it: with your
consent; for the establishment, exercise or defence of legal claims; for the
protection of the rights of another natural or legal person; or for reasons of
important public interest.
8.7 You
have the right to object to our processing of your personal data on grounds
relating to your situation, but only to the extent that the legal basis for the
processing is that the processing is necessary for: the performance of a task
carried out in the public interest or in the exercise of any official authority
vested in us; or the purposes of the legitimate interests pursued by us or by a
third party. If you make such an objection, we will cease to process the
personal information unless we can demonstrate compelling legitimate grounds
for the processing which override your interests, rights and freedoms, or the
processing is for the establishment, exercise or defence of legal claims.
8.8 You
have the right to object to our processing of your personal data for direct
marketing purposes (including profiling for direct marketing purposes). If you
make such an objection, we will cease to process your personal data for this
purpose.
8.9 You
have the right to object to our processing of your personal data for scientific
or historical research purposes or statistical purposes on grounds relating to
your situation, unless the processing is necessary for the performance of a
task carried out for reasons of public interest.
8.10 To
the extent that the legal basis for our processing of your personal data is:
(a) consent;
or
(b) that
the processing is necessary for the performance of a contract to which you are
party or in order to take steps at your request prior to entering into a
contract,
and
such processing is carried out by automated means, you have the right to
receive your personal data from us in a structured, commonly used and
machine-readable format. However, this right does not apply where it would
adversely affect the rights and freedoms of others.
8.11 If
you consider that our processing of your personal information infringes data
protection laws, you have a legal right to lodge a complaint with a supervisory
authority responsible for data protection. You may do so in the EU member state
of your habitual residence, your place of work or the place of the alleged infringement.
8.12 To
the extent that the legal basis for our processing of your personal information
is consent, you have the right to withdraw that consent at any time. Withdrawal
will not affect the lawfulness of processing before the withdrawal.
8.13 You
may exercise any of your rights in relation to your personal data by written
notice to us, in addition to the other methods specified in this Section 8.
9. About cookies
9.1 A
cookie is a file containing an identifier (a string of letters and numbers) that
is sent by a web server to a web browser and is stored by the browser. The
identifier is then sent back to the server each time the browser requests a
page from the server.
9.2 Cookies
may be either "persistent" cookies or "session" cookies: a
persistent cookie will be stored by a web browser and will remain valid until
its set expiry date, unless deleted by the user before the expiry date; a
session cookie, on the other hand, will expire at the end of the user session,
when the web browser is closed.
9.3 Cookies
do not typically contain any information that personally identifies a user, but
personal information that we store about you may be linked to the information
stored in and obtained from cookies.
10. Cookies that we use
10.1 We
use cookies for the following purposes:
(a) authentication
- we use cookies to identify you when you visit our website and as you navigate
our website. Cookies used for
this purpose are: Zen Cart Plugin;
(b) status
- we use cookies to help us to determine if you are logged into our website. Cookies used for this purpose are: Zen Cart
Plugin;
(c) personalisation
- we use cookies to store information about your preferences and to personalise
the website for you Cookies
used for this purpose are: Zen Cart Plugin;
(d) security - we use cookies as an element of
the security measures used to protect user accounts, including preventing
fraudulent use of login credentials, and to protect our website and services
generally. Cookies used for this purpose are: Zen Cart Plugin;
(e) advertising - we use cookies to help us to
display advertisements that will be relevant to you Cookies used for this purpose are: Zen Cart Plugin and
Facebook Pixel;
(f) analysis - we use cookies to help us to
analyse the use and performance of our website and services. Cookies used for this purpose are: Zen Cart
Analytics;
(g) cookie consent - we use cookies to store your
preferences in relation to the use of cookies more generally. Cookies used for this purpose are: Zen Cart
Plugin;
11. Cookies
used by our service providers
11.1 Our
service providers use cookies and those cookies may be stored on your computer
when you visit our website.
11.2 We use Zen Cart Analytics to do an analysis
of the use of our website. Zen Cart analytics gathers information about website
use by means of cookies. The information gathered relating to our website is
used to create reports about the use of our website. Zen Cart’s privacy policy
is available at:
https://www.zen-cart.com/content.php?5&
11.3 We occasionally use Google AdSense
interest-based advertisements on our website. These are tailored by Google to
reflect your interests. To determine your interests, Google will track your
behaviour on our website and on other websites across the web using cookies.
Google will track your behaviour on our website and on other websites across
the web using cookies. This behaviour tracking allows Google to tailor the
advertisements that you see on other websites to reflect your interests (but we
do not publish interest-based advertisements on our website). You can view,
delete or add interest categories associated with your browser by visiting: https://adssettings.google.com. You can also opt out of the AdSense
partner network cookie using those settings or using the Network Advertising
Initiative's multi-cookie opt-out mechanism at: http://optout.networkadvertising.org. However, these opt-out mechanisms
themselves use cookies, and if you clear the cookies from your browser your
opt-out will not be maintained. To ensure that an opt-out is maintained in
respect of a particular browser, you may wish to consider using the Google
browser plug-ins available at: https://support.google.com/ads/answer/7395996
11.4 We
use Wavenet to provide our internet facilities.
Wavenet is
committed to data security and has invested heavily in robust systems that are
both ISO27001:2013 and GDPR complaint with regular audits by external UKAS
approved certification auditors. You
can view the privacy policy of this service provider at:
https://www.wavenetuk.com/about-us/legal-and-compliance/privacy-policy/
12. Managing cookies
12.1 Most
browsers allow you to refuse to accept cookies and to delete cookies. The
methods for doing so vary from browser to browser, and from version to version.
You can however obtain up-to-date information about blocking and deleting
cookies via these links:
(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome)
(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox)
(c) http://www.opera.com/help/tutorials/security/cookies/ (Opera)
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer)
(e) https://support.apple.com/kb/PH21411 (Safari)
(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge)
12.2 Blocking
all cookies will have a negative impact upon the usability of many websites.
12.3 If
you block cookies, you will not be able to use all the features on our website.
13. Our details
13.1 This
website is owned and operated by Victoria
Baxter, Founder Silver by Victoria and Jewelzonline.
13.2 Our
principal place of business is at 27
Burns Drive, Dronfield, Derbyshire, S18 1NJ, United Kingdom
13.3 You
can contact us:
(a) by
post, to the postal address given above
(b) using
our website contact form
(c) by
telephone, on the contact number published on our website from time to time
(d) by
email, using the email address published on our website from time to time.
14. Data protection officer
14.1 Our
data protection officer's contact details are: Victoria Baxter at the above address.
