This notice sets out how https://sincerelys.shop/ . Processes your data if you are a customer or a user of sincerelys’s website or mobile applications. sincerelys’s services are neither aimed at nor intended for children.  If you are a child, then you must inform your parent or guardian of this notice.  

We are the data controller of your data.

Our data protection officer (DPO) is responsible for overseeing questions about this notice.  If you have any questions about this notice, including any requests to exercise your legal rights, then please contact our DPO at info@sincerelys.shop.

Changes to this notice and your Data
We may update this notice from time to time and will notify you of changes where we are required to do so by law.

The personal data we hold about you must be accurate and current.  Please keep us informed if your data changes during your relationship with us.  An easy way to do this is through your sincerelys.shop account, but please also feel free to contact us.

The Personal Data We Collect About You
Personal data 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, transfer, and otherwise process different kinds of personal data about you which we have grouped as follows:

• Identity Data includes name, 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/services you have purchased from us.
• Technical Data includes information collected when you access our website or mobile applications, your 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 or mobile applications.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback, and survey responses.
• Usage Data includes information about how you use our website, mobile applications, Wi-Fi, and similar electronic services.
• Marketing and Communications Data includes your marketing and communication preferences.
• CCTV Data includes footage from CCTV and other similar equipment that we operate in our stores.

Failure to provide 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 (e.g., to provide you with products/services).  In this case, we may have to cancel a product/service but we will notify you if this is the case at the time.

How we collect your Personal Data
We use different methods to collect data from and about you including as set out below:

• Direct interactions. You may give us your data in your direct interactions with us (e.g., Identity Data, Contact Data, and Financial Data) by filling in forms, through our mobile applications, or by corresponding with us by post, phone, email, or otherwise. This includes personal data you provide when you: (i) enquire about, apply for, or order our products/services; (ii) create an account; (iii) subscribe to our communications; (iv) request marketing to be sent to you; (v) enter a competition, promotion, raffle or survey; or (vi) give us feedback or contact us.
• Website, mobile applications, and cookies.  As you interact with our website and mobile applications, we will automatically collect Technical Data about your device, browsing actions, and patterns.  We collect this personal data by using cookies, server logs, and other similar technologies.  We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our Cookie Notice for further details.
• Technical Data from third party analytics providers, advertising networks, and search information providers.
• Contact Data, Financial Data, and Transaction Data from providers of technical, payment, and delivery services.

How We Process Your Data
We will only process your data when the law allows us to do so.  Most commonly, we will process your data in the following circumstances:

• Performance of a contract: Where we need to perform the contract we are about to enter into or have entered into with you.
• Legitimate interests: 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.
• Legal or regulatory obligation: Where we need to comply with a legal or regulatory obligation that we are subject to.
• Consent: Where you have given us consent to process your data for a specific purpose.

With limited exceptions (e.g., some of our electronic marketing), we do not rely on consent as a lawful basis for processing your data.  You have the right to withdraw consent to marketing at any time by contacting us.

Purposes and Lawful Bases for Processing Your Data
We have set out below a description of all the ways we plan to process your data, and which of the lawful bases we rely on to do so.  We have also identified what our legitimate interests are where appropriate.

Purpose/Activity: To register you as a new customer

• Type of personal data: (a) Identity Data, (b) Contact Data
• Lawful basis of processing: Performance of a contract

Purpose/Activity: To process and deliver your order (including managing payments, fees, and collecting and recovering money owed to us)

• Type of personal data: (a) Identity Data, (b) Contact Data, (c) Financial Data, (d) Transaction Data, (e) Marketing and Communications Data
• Lawful basis of processing: (a) Performance of a contract, (b) Legitimate interests (to recover debts due to us)

Purpose/Activity: To manage our relationship with you (including notifying you about changes to our terms or this notice and asking you to leave a review or take a survey)

• Type of personal data: (a) Identity Data, (b) Contact Data, (c) Profile Data, (d) Marketing and Communications Data
• Lawful basis of processing: (a) Performance of a contract, (b) Legal or regulatory obligation, (c) Legitimate interests (to keep our records updated and understand how customers use our products/services)

Purpose/Activity: To enable you to take part in a prize draw, competition, raffle, or complete a survey

• Type of personal data: (a) Identity Data, (b) Contact Data, (c) Profile Data, (d) Usage Data, (e) Marketing and Communications Data
• Lawful basis of processing: (a) Performance of a contract, (b) Legitimate interests (to understand how customers use our products/services, to develop them and grow our business)

Purpose/Activity: To administer and protect our business, website, and mobile applications (including troubleshooting, data analysis, testing, system maintenance, support, reporting, and hosting of data)

• Type of personal data: (a) Identity Data, (b) Contact Data, (c) Technical Data
• Lawful basis of processing: (a) Legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise), (b) Legal obligation

Purpose/Activity: To deliver relevant content and advertisements to you and measure or understand the effectiveness of our advertising

• Type of personal data: (a) Identity Data, (b) Contact Data, (c) Profile Data, (d) Usage Data, (e) Marketing and Communications Data, (f) Technical Data
• Lawful basis of processing: Legitimate interests (to understand how customers use our products/services, to develop them, to grow our business, and to inform our marketing strategy)

Purpose/Activity: To use data analytics to improve our website, mobile applications, products/services, marketing, customer relationships and experiences

• Type of personal data: (a) Technical Data, (b) Usage Data
• Lawful basis of processing: Legitimate interests (to define types of customers for our products/services, to keep our website and mobile applications updated and relevant, to develop our business, and to inform our marketing strategy)

Purpose/Activity: To make suggestions and recommendations to you about products/services that may be of interest to you

• Type of personal data: (a) Identity Data, (b) Contact Data, (c) Technical Data, (d) Usage Data, (e) Profile Data, (f) Marketing and Communications Data
• Lawful basis of processing: Legitimate interests (to develop our products/services and grow our business)

Purpose/Activity: To keep our stores safe and secure

• Type of personal data: CCTV Data
• Lawful basis of processing: Legitimate interests (to keep our stores secure and those within them safe)

Change of Purpose
We will only process your data for the purposes for which we collected it unless we reasonably consider that any further processing is compatible with the original purpose.  If you would like an explanation as to how further processing is compatible with the original purpose, then please contact us.

If we need to process your data for an unrelated purpose, then we will notify you and we will explain the lawful basis which allows us to do so.

We may process your data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Marketing and Exercising your Right to opt-out of Marketing
You will receive marketing communications from us if you have requested information from us or purchased products/services from us and you have not opted out of receiving that marketing. 

If you ask us to stop processing your data for marketing purposes (e.g., by following the opt-out links on any electronic marketing sent to you or by otherwise contacting us), then we will do so.

No Third-Party Marketing
We do not share your data with any third parties for their marketing purposes.

Cookies

You can set your browser to refuse all or some browser cookies or to alert you when websites set or access cookies.  If you disable or refuse cookies, then some parts of our website or mobile applications may become inaccessible or not function properly.  For more information about the cookies we use, please see our Cookie Notice.

Disclosures of your Personal Data
We may have to share your data with the parties set out below for the purposes for which we collected the personal data.

• Service providers who provide IT and system administration services.
• Professional advisers including lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance, and accounting services.
• HMRC, regulators, and other authorities.
• 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 process your data in the same way as set out in this notice.

We require all third parties to respect the security of your data and to treat it by the law.  We do not allow our third-party service providers to process your data for their purposes and only permit them to process your data for specified purposes and by our instructions.

International Transfers
In some cases, the parties who we use to process personal data on our behalf are based outside the EEA so their processing of your data will involve a transfer of data outside the EEA.

Whenever we transfer your 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 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 that 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.

If you would like further information on the specific mechanism used by us when transferring

Data Security
We have put in place appropriate security measures to prevent your data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed.  In addition, we limit access to your data to those employees, agents, contractors, and other third parties who have a business need to know.  They will only process your data on our instructions and they are subject to a duty of confidentiality.

Data Retention
We will only retain your data for as long as reasonably necessary to fulfill the purposes we collected it for, including to satisfy any legal, regulatory, tax, accounting, or reporting requirements and for the establishment or defense of legal claims.

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 data, the purposes for which we process your data, and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances, we may anonymize your data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Your Legal Rights and how to make a Complaint
Under certain circumstances, you have rights under data protection laws about your data.  In summary, these are the rights of access, rectification (i.e., correction), erasure (also known as the “right to be forgotten”), restriction, objection, data portability, and withdrawal of consent.  If you wish to exercise any of these rights, then please contact us.