Purpose of this Privacy Notice
Maintaining the security of your data is a priority at Guthrie & Ghani Ltd, where we are committed to respecting your privacy rights and protecting your personal data at all times. We seek to process and handle your data fairly and legally at all times. We also believe it is important to be transparent about what data we collect about you and how we use it.
- About the Policy and Who We Are
This notice, which applies whether you visit our store, use your mobile device or go on-line, will inform you as to how we look after your personal data (regardless of where you visit us from). It provides you with information about:
How we use your data;
- what personal data we collect;
- how we ensure your privacy is maintained and
- your legal rights relating to your personal data.
This privacy notice aims to give you information on how Guthrie & Ghani Ltd collects and processes your personal data in-store, through your use of our website, including any data you may provide through the website when you sign up to our newsletter, purchase a product or service or take part in a competition.
Please note our website is not intended for children and we do not knowingly collect data relating to children.
Guthrie & Ghani Ltd is the controller and responsible for your personal data (collectively referred to as "Guthrie & Ghani Ltd”, "we", "us" or "our" in this privacy notice).
The Director of Guthrie & Ghani Ltd is the registered data controller with the Information Commissioner’s Office. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the Director of Guthrie & Ghani Ltd using the details set out below.
Our full details are:
Full name of legal entity: Guthrie & Ghani Ltd
Email address: firstname.lastname@example.org
Postal address: 169, Alcester Road, Moseley, Birmingham, B13 8JR
Telephone number: +44 (0)121 449 8419
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, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
- The Data We Collect About You
Personal data, or personal information, refers to 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 grouped together as follows:
- Identity Data includes first name, surname name, username or similar identifier, title, date and month of birth (not year).
- Contact Data includes billing address, delivery address, email address and telephone numbers (including mobile numbers) for the purposes of following-up orders, responding to queries and shipping products;
- Financial Data payment card details are collected but not stored by us. They are processed by a secure third party card processing company.
- 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 our website.
- Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and any survey responses.
- Usage Data includes information about how you use our website, social media interactions, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use Aggregated Data such as statistical or demographic data. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific marketing campaign or website feature. 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. In accordance with this privacy notice we will not combine or connect Aggregated Data with your personal data so that you can directly or indirectly be identified.
Data We Do Not Collect
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, etc).
- How is Your Personal Data Collected?
Cooshoo use different methods to collect data from and about you, this will vary dependent on if you make a purchase in-store or on-line as detailed below:
- Direct interactions. You may give us your Identity, Contact and Financial Data verbally in-store, by filling in forms or by corresponding with us by post, phone, email or other digital method. This includes personal data you provide when you:
- make a purchase
- apply for our products or services;
- create an account on our website;
- subscribe to our service or publications;
- request marketing to be sent to you;
- enter a competition, promotion or survey; or
- give us some feedback.
This list is not exhaustive and, in specific instances, we may need to collect additional data for the purposes set out in this Policy. Some of the above personal data is collected directly, for example when you set up an on-line account on our websites, or send an email to our customer services team. Other personal data is collected indirectly, for example your browsing or shopping activity.
- How We Use Your Personal Data
We will only use your data to enable us to give you the best service/product and the best and most secure experience. Outlined below are the most common ways we will use your personal data:
- to provide goods and services to you;
- to make a tailored website available to you;
- to manage any registered account(s) that you hold with us;
- to verify your identity;
- for crime and fraud prevention, detection and related purposes;
- with your agreement, to contact you electronically about promotional offers and products and services which we think may interest you;
- for market research purposes - to better understand your needs;
- to enable Guthrie & Ghani Ltd to manage customer service interactions with you; and
- where we have a legal right or duty to use or disclose your information (for example in relation to an investigation by a public authority or in a legal dispute).
We will only use your personal data when the law allows us to.
Marketing Emails and 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.
When you sign up to our newsletter we collect your name and email address, this information is stored in our secure Mailchimp account which has two-factor authentication login enabled. You can also optionally provide us with the day and month of your birthday. This information is used to send you a discount code to use in our shop and is automatically sent when it is your birthday. As Mailchimp is based in the USA they store your birthday in the format of MM/DD, do for example if your birthday was the 31st May it would be stored as 05/31.
You can sign up to our newsletter on our website or by writing down your email address in store, or at a show on the newsletter sign up sheet. This sheet states that we will email you 1-2 times per week and that you can opt out at any time. These hand written sheets are manually added to the Mailchimp data base by members of staff and are then stored securely in a locked filing cabinet for up to 1 year from the date of signup.
We send marketing emails 1-2 times per week to promote workshop dates, events, special offers and sales and new products that we have available in store. We also occasionally use the email data base to share information when we are recruiting for a new position within the company.
We have one main email list which is subcategorised into customers who have opted in or out of receiving information about our Birmingham events and workshops. We also subcategorise the list when customers have expressed explicit interest in a particular event or workshop. You can update your email preferences at any time using the link at the bottom of all of our emails or by contacting us.
Anyone who signed up to the newsletter list prior to 25th May 2018 will continue to receive email marketing from us unless the opt out using the unsubscribe link at the bottom of all of our emails. We have carried out a legitimate interests assessment and have found that when we collected data from customers (name and email address) that it was done in a transparent way and that the information was stored and processed securely.
You can ask us to stop sending you marketing messages at any time by following the “unsubscribe” links on any marketing message sent to you or by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.
Google Analytics retains some data that can identify you as a returning user to the site. This data is purged after a maximum of 26 months after your first/last visit.
Change of Purpose
We will only use your personal data for the purposes for which we collected it. 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.
- How We Hold and Share Your Information
In order to provide our services to you, including processing payments and providing a website, we use third party systems to hold and share your data with. These are:
- an in-store EPOS system (Vend);
- our on-line ecommerce platform hosts (Craft);
- financial payment gateways (Stripe, Sage Pay, Global Payments, Square Pay) and
- marketing and email software providers (Mailchimp).
This may involve transferring your data outside the European Economic Area (EEA).
Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
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 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.
- Disclosures of Your Personal Data to External Third Parties
We may have to share your personal data with third parties to where it is necessary to comply with a legal or regulatory obligations as outlined below:
- Service providers acting as processors based in the UK, EU and US who provide IT and system administration services.
- Professional acting as processors including banking services.
- HM Revenue & Customs, regulators and other authorities acting as processors based in the United Kingdom who require reporting of processing activities in certain circumstances.
- Drop Ship Suppliers (e.g. DPD, UPS) acting as processors based in the UK and EU who receive your personal data in order to fulfil your order and send you our products directly.
- Fulfilment and courier companies acting as processors based in the UK who receive your personal data in order to fulfil your order.
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 e.g. for marketing and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Our website contains links to third-party websites, plug-ins and applications. 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.
- Data Security
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. In addition, we limit access to your personal data to those employees and other third parties who as a business need to know (e.g. to process payments). They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
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.
- Data Retention
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. Different retention periods apply for different types of data, however the longest we will normally hold any personal data is 6 years.
- Your Legal Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the following rights:
- the right to ask for a copy of personal data that we hold about you (the right of access);
- the right (in certain circumstances) to request that we delete personal data held on you; where we no longer have any legal reason to retain it (the right of erasure or to be forgotten);
- the right to ask us to update and correct any out-of-date or incorrect personal data that we hold about you (the right of rectification);
- the right to opt out of any marketing communications that we may send you and to object to us using / holding your personal data if we have no legitimate reasons to do so (the right to object);
- the right (in certain circumstances) to ask us to ‘restrict processing of data’; which means that we would need to secure and retain the data for your benefit but not otherwise use it (the right to restrict processing); and
- the right (in certain circumstances) to ask us to supply you with some of the personal data we hold about you in a structured machine-readable format and/or to provide a copy of the data in such a format to another organisation (the right to data portability).
If you wish to exercise any of the above rights, please contact us using the contact details set out at the beginning of this document.
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.
Changes to the Privacy Notice and Your Duty to Inform Us of Changes
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.
Policy Last Updated
This version was last updated on 25th May 2018.