Privacy

WANYOMO’S DATA AND PRIVACY POLICY

INTRODUCTION

Welcome to the WANYOMO privacy policy. To keep things simple, we refer to ourselves as WANYOMO and this document as the Policy.

WANYOMO respects your privacy and is committed to protecting your personal data. This Policy tells you:

  • how we look after your personal data when you visit our website, regardless of where you live;
  • about your privacy rights; and
  • how the law protects you.

There is a lot of technical language about data processing so we have included a <<GLOSSARY>> at the end of this Policy to help you understand the meaning of some of the terms we use in it.

  1. WHAT THIS POLICY DOES

WANYOMO collects and processes your personal data when you use our website, including any data you may provide through the website when you sign up to our newsletter, purchase a product, create a wish list, send an image of a product to an email or take part in a competition. We want you to be fully aware how and why we use your data. Sometimes we may ask for extra data and when we do, we will let you know why we need it. We keep this policy under review and you can request copies of older policies <<here>>.

This website is not intended for children and we do not knowingly collect data relating to children.

WANYOMO is the data Controller and responsible for your personal data. If you have any questions about this privacy policy, including any requests to exercise your legal rights please contact our data privacy manager who is responsible for overseeing questions in relation to this privacy policy here <<insert email and address>>>>.

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 appreciate the chance to deal with your concerns before you approach the ICO, so please contact us first and we will try to help.

  1. DATA WE COLLECT ABOUT YOU

We collect, use, store and transfer different kinds of personal data about you. Personal data or personal information, means any information about an individual from which that person can be identified. This can be:

  • Identity Data includes your name, title, date of birth and gender.
  • Contact Data includes your 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 and services you have purchased from us.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location and other technology on the devices you use to access the WANYOMO website.
  • Profile Data includes your username and password, purchases or orders made by you, your preferences and any feedback and survey responses.
  • Usage Data includes information about how you use our website, products and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us, third parties and your communication preferences.

Personal data does not include data where the identity has been removed (anonymous data).

We do collect, use and share a collection of statistical or demographic data which we call Aggregated Data to improve our service overall. This is not considered personal data in law as this data will not directly or indirectly reveal your identity. If we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we will treat the combined data as personal data and this Policy will apply to it.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership or information about your health.

We may ask you for biometric data such as a ring size or size preference for other items you wear. We will not retain this information WANYOMO the item has been delivered to you.

Please keep us informed if your personal data changes because it is important that the personal data we hold about you is accurate and up to date.

If you fail to provide personal data where we need to it by law, or under the terms of a contract we have with you, we may not be able to perform that contract. In this case, we may cancel an order and notify you of this.

  1. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you by using forms sent by email, post or phone and when you or get in touch with us, order products, subscribe to our newsletters of social media, complete a survey or enter a competition corresponding.

As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns using cookies and other similar technologies and we may also receive Technical Data about you if you visit other websites that use our cookies. Please see our <<cookie policy>> for more details.

Sometimes we may receive personal data about you from third parties such as Google or other search engines and Contact, Financial and Transaction Data from providers of payment and delivery services.

  1. HOW WE USE YOUR PERSONAL DATA?

We will only use your personal data as English law allows us to.  We may use your personal data to complete our contract with you and make sure you get your order; where it is necessary for our legitimate interests (or those of a third party); or where we need to comply with a legal obligation. Generally, we do not rely on consent as a legal basis for processing your personal data. This is known as the Lawful Basis we use to process your personal data.

  1. WHEN WE WILL USE YOUR PERSONAL DATA

It is easiest to show you how WANYOMO may use your data (and our legal grounds for doing so) in a table like this:

Purpose/Activity Type of data we collect Lawful basis for processing/basis of legitimate interest
Registering you as a customer (a) Identity

(b) Contact

§  Performing our contract with you
Processing/delivering your order including:

(a) Managing payments, fees and charges

(b) Collecting and recovering money owed to us

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Marketing & Communications

§  Performing our contract with you

§  Necessary for our legitimate interests (to recover debts due to us)

Managing our relationship with including:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

(a) Identity

(b) Contact

(c) Profile

(d) Marketing & Communications

§  Performing our contract with you

§  Necessary to comply with a legal obligation

§  Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To enable you to partake in a prize draw, competition or complete a survey (a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing & Communications

§  Performing our contract with you

§  Necessary for our legitimate interests; to study how customers use our products & services to develop them and grow our business

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity

(b) Contact

(c) Technical

§  Necessary for our legitimate interests in running our business; administration, IT, network security, fraud prevention, business structure

§  comply with a legal obligation

To deliver relevant website content & advertisements to you and measure or understand the effectiveness of the advertising we serve to you (a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing & Communications

(f) Technical

Necessary for our legitimate interests; to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences (a) Technical

(b) Usage

Necessary for our legitimate interests; to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy
To make suggestions and recommendations to you about goods or services that may be of interest to you (a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

(f) Marketing & Communications

Necessary for our legitimate interests; to develop our products/services and grow our business

We may process your personal data on more than one lawful ground depending why we are using it.

MARKETING

We strive to provide you with choices regarding personal data uses, particularly around marketing and advertising. You can update your preferences <<here>>. You can withdraw consent to marketing at any time <<here>>.

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 (we call this marketing). You will receive marketing communications from us if you have requested information from us or purchased goods from us and you have not opted out of receiving that marketing.

THIRD-PARTY LINKS

This website includes 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 policy of every website you visit.

THIRD-PARTY MARKETING

We will get your express consent before we share your personal data with any third party for marketing purposes.

OPTING OUT

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you.

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 purchase, warranty registration or other transactions.

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, please note that some parts of this website may become inaccessible or not function properly. For information about the cookies we use, click <<here>>.

CHANGE OF PURPOSE

We will only use your personal data for the purposes we collected it for, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. You can ask us for more details about this by contacting us <<here>>.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain how we want to use it. 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.

  1. DISCLOSURES OF YOUR PERSONAL DATA

We may share your personal data with the parties shown and for the purposes listed in the table above.

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.

We share your personal data within suppliers to the WANYOMO Group so that your order can be fulfilled. This will involve transferring your data outside the European Economic Area (EEA). Many of our suppliers are based outside the 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 the party receiving it treats it with a similar degree of protection as we do by ensuring either:

  • We 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 of which countries that is see <<European Commission: Adequacy of the protection of personal data in non-EU countries>>.
  • Our suppliers use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
  • 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 Europe and the US. For further details, see <<European Commission: EU-US Privacy Shield.>>
  1. 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, 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 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.

  1. HOW LONG WILL WE USE YOUR PERSONAL DATA FOR?

We will only retain your personal data for as long as reasonably necessary to fulfil the purpose we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

When we decide how long to keep your data for, we consider the amount, nature and sensitivity of the data, the potential risk of harm from unauthorised use or disclosure of it, the purposes for which we process it and whether we can achieve those through other means, as well as the applicable legal, regulatory, tax, accounting or other requirements.

In some circumstances we might anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this anonymous information indefinitely.

  1. IT’S YOUR 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 or ask us to suspend our processing of your personal data because:

  • you want us to establish the data’s accuracy.
  • our use of the data is unlawful but you do not want us to erase it.
  • 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.
  • you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request 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. 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 your consent to us processing your data at any timeThis 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 withdraw your consent, we have to keep a record of that request.

You will not have to pay a fee to access your personal data or to exercise the rights above. We may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive and we can refuse to comply in these circumstances.

If you want to request, object or withdraw your consent to our processing <<click here>>

When you may a request, 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.

We try to respond to all legitimate requests within one month. Occasionally it could 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.

  1. TERMS WE USE IN THIS POLICY

THE LAWFUL BASIS FOR PROCESSING:

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). 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.

Performance of 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.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

THIRD PARTIES WE MAY SHARE DATA WITH

Internal Third Parties are other companies in the WANYOMO Group who are based [SPECIFIC COUNTRIES] and provide IT and system administration services and undertake reporting to WANYOMO.

External Third Parties are

  • Service providers acting as processors based [SPECIFY COUNTRIES] who provide IT and system administration services.
  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in [SPECIFY COUNTRIES].
  • HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
  1. Fraud prevention agencies who may be asked to undertake identity verification in certain circumstances.
  • Logistics agencies who will provide delivery of goods to you, so that they can locate you and identify you.
  • [ANY OTHER THIRD PARTIES, for example, market researchers, fraud prevention agencies, price comparison sites and so on.]