ARLO & JACOB
1st NOVEMBER 2014 VERSION
1. About This Document
Arlo & Jacob are committed to protecting and respecting your privacy. This policy describes for your information how any personal data we collect from or about you, or that you provide to us, is processed by us. Please read this policy carefully. This policy is not intended to and does not create any contractual rights or form part of any contract. In this policy "you" and "your" refer to the individual whose personal data we may process from time to time.
2. Information About Us
3. How Do We Obtain Customer Data?
3.1 Data you supply
We obtain data when you order goods from us, including the data you supply through any website or telephone order process. We obtain data when you fill in a form or otherwise submit information to our website, including where you register or subscribe for anything or set up an account. We also obtain data if you register with us to receive offers and newsletters from us.
In accordance with the General Data Protection Regulations (EU 2016/679), we employ strict physical, electronic and administrative security measures to protect your information from access by unauthorised persons and against unlawful processing, accidental loss, destruction and damage both on-line and off-line. The transmission of information via the internet is, however, not secure and therefore we cannot guarantee the security of data sent to us electronically by you. Any transmission of such data is therefore entirely at your own risk. If you have any questions relating to security of your data, please contact us using the details set out in the Contact Us section.
3.2 Data we generate
We also generate and hold data specific to your orders or other contracts with us, including products ordered, payments made, and delivery, performance, complaints and returns information.
3.3 Telephone calls
We may record telephone conversations to use in our internal staff training programme and for security, fraud prevention and evidential purposes.
3.4 Website browsing
4.1 Contact and identity information
Your contact and identity. This includes your name, postal, invoicing, and delivery addresses, telephone, mobile, and fax numbers, and email addresses.
4.2 Your account information
Information concerning any accounts, registrations, subscriptions, or memberships with us, and website preference information.
4.3 Payment information
Your payment details, including payment card data. We use a third party provider to process your payments securely. The provider will gather your credit or debit card information and payment history. They only retain your card information for a limited period of time, to process the specific order in relation to which you provided that information.
4.4 Enquiry and order information
We generate and hold information specific to your enquiries and orders with us for our products and services, including a record of your orders, payments made, order tracking, fulfilment and delivery, claims, returns and refunds.
4.5 Website usage information
4.6 Relationship information
We hold on record information relating to any communications and dealings we have with you, including enquiries and complaints.
5.1 Operate our website
We use your data to operate our website and provide you with the services, facilities and functions of our website. This includes managing any accounts or registrations you have with our website and making changes to your settings and profile at your request.
5.2 Customer relationship
Generally, your data allows us to provide you with personalised services and correspond with you separately. The information you provide will be kept confidential and used to support and manage your customer relationship with us, including maintaining your account, informing you of changes and general news in relation to our site, and handling your enquiries and complaints.
5.3 Performing orders
We use your data for the purposes of performing, administering and managing your orders and contracts with us, including taking payment, fulfilling your order, updating you on the status of your order, to request feedback on your customer service experience, and for handling any complaints, issues, returns and warranty claims.
5.4 Business improvement
We use your data along with other data we hold to carry out general (anonymous) assessment, analysis and research in relation to our business, products, services and customers, including to assist in the provision of services and products to you, and to facilitate reviews, developments and improvements to the services and products offered to you.
We may use your data to report aggregate information concerning usage of our website to our advertisers. We normally create anonymous statistical data about browsing actions and patterns, and do not identify any individual.
5.6 Security, quality control, evidence and training
We record data for the purpose of security, keeping evidence, fraud prevention, quality control and training.
We may use your data for the purposes of direct marketing in accordance with paragraph 6 below.
6. Marketing And Newsletter
6.2 What we will send to you
If you have consented to direct marketing then we may send to you from time to time by email or post, updates, newsletters and other marketing messages relating to us and our products and services, including promotions and offers. As part of our customer service offering we also provide a regular newsletter service. This service provides you with details of special offers and product promotions as well as information on new products.
6.3 How to subscribe
If you have not already subscribed to receive our newsletter and other marketing messages, then please contact us at the address provided above, or submit your details using any form provided on our website, or change the appropriate account setting in any account you have on our website.
6.4 Opting out
If you wish to opt out of receiving the newsletter and other marketing messages, you can do so by contacting us at the address provided above, or, where relevant, by un-ticking any relevant box in your online account details or clicking on the "Unsubscribe" link in promotional emails sent to you. You can subscribe again at any time by following the procedures above.
7. Disclosure Of Your Information
We do not share your data with any third parties except as provided in this policy or as required by law. In particular, we will not share information about you with third parties for direct marketing by those third parties without your further consent.
7.2 Third party service providers
In order to perform your orders, collect payment, provide you with a service, and market our products to you, we may disclose your data to third parties (such as credit and debit card processing companies, outside suppliers, sub-contractors, distributors and delivery companies) for such purposes.
7.3 Business improvement
We may share user experience information or other customer level data with companies within our group as well as our trusted third parties, agents and business partners for the purpose of accomplishing our business improvement objectives. These third parties will only use your data for those purposes and will only have access to the data needed to perform the specific service they are providing.
7.4 Administration and legal
We may use and disclose to third parties any information we hold about you and your payment record for the purposes of administration and enforcement of any contract we have with you and related purposes. We may also supply your information to relevant authorities and other third parties where required in connection with any legal process or any legal obligations binding on us.
We may provide aggregate statistics (including information derived from your data) about our sales, traffic patterns, and related website information, to trustworthy third parties, but these statistics will include no personally identifying information.
7.6 Business function outsourcing
Where we use third parties to host, provide, operate or supply any part of our website, databases, systems, business, or services, or carry out on our behalf any of our business functions or actions (including sending mail, processing payments, providing marketing assistance, providing customer and advertising analysis, and providing customer services), then then we may provide your personal data to them as required to perform these functions.
7.7 Feedback and other interactive parts of our website
Where any facility on our website is clearly designed to make certain of your personal data public (e.g. posts you make to any public forum or reviews facility) then any personal data you provide in that forum or other facility, which is provided in circumstances where it is clear that it is intended to be published, will be disclosed to the public accordingly, subject to moderation by us.
8. How Long Do We Keep Your Personal Data?
We keep your personal data for as long as is reasonably necessary for the purposes described above, and if longer, for the length of statutory claims limitation periods where your personal data may be relevant to any possible liability we may have to you, or for any duration required by law.
9. Where Do We Store Your Personal Data?
We (and any affiliate, subcontractor or other person processing your personal data on our behalf) may transfer, store and otherwise process your personal data anywhere in the world. Where we disclose your personal data to third parties, that disclosure may also involve a transfer of your personal data anywhere in the world, and those third parties may themselves transfer, store or otherwise process that information anywhere in the world. In each case, we will comply with any legal requirements concerning the transfer of your personal data by us to any third party outside the European Economic Area ("EEA").
10. What Security Measures Do We Apply?
10.1 Our measures
We are obliged by law to put in place appropriate technical and organisational measures against unauthorised or unlawful processing of your personal data and against accidental loss or destruction of, or damage to, your personal data. We have accordingly implemented security policies, rules and technical measures with a view to achieving this, and all information you provide to us is therefore stored on secure servers.
10.2 Transfer of data to us over the internet
We use Secured Socket Layer (“SSL”) software in order to encrypt the personal information that you provide to us whilst it is in transit over the internet from your browser to our website. This will work if your browser is SSL enabled (which most are). You can verify that this is working by looking for the symbol of a closed lock or solid key on the bottom bar of your browser window, and checking that the prefix for the web address in the browser address bar has changed from “http” to “https”. Unfortunately, the transmission of information via the internet is not completely secure and we cannot guarantee the security of your data transmitted to our site or that SSL is completely secure.
11. Your Rights
You have the following rights in relation to your personal data under the Data Protection Act 1998. If you wish to exercise any of these rights, then please contact us using the contact information set out above.
11.1 Finding out what data we hold
11.2 Stopping marketing
If we are sending you marketing messages, the Data Protection Act gives you a right to ask us to stop doing this. We will provide you with details of how to do this, each time we send you a marketing message. Alternatively, please contact us using our contact details in this policy or on our website.
11.3 Use causing distress
You have the right to ask us to stop using any data for any purpose, where that purpose is causing you substantial distress. If you have any concerns regarding our use of your data, please contact us using our contact details in this policy.
11.4 Changes to your information
You have the right to ask for the rectification, erasure or blocking of any of your personal information which is inaccurate or not up to date. You may make a request to us to change or modify your information at any time. Further if you are aware at any time that any of the information that you have given to us has changed then please let us know at the earliest opportunity.
You may have the right to claim compensation for damage and (in certain cases) distress you suffer if we do not comply with data protection laws.
11.6 Complaints to applicable authority
The laws we comply with are regulated by the Information Commissioner (www.ico.gov.uk) in the United Kingdom. In addition to your rights above, it is open to you, if you have a complaint or concern, to seek assistance from this regulator, which has powers to compel us to comply with applicable laws and fine us for non-compliance. However, before you do so, we would hope that you will contact us first to discuss any complaint or concerns you have.
12.1.1 Per-session cookies
These are used while you are logged on to our site to record temporary data relating to your visit to our site, to manage the delivery of web pages to you and any registration and ordering processes, and to help us monitor traffic through the site.
12.1.2 Auto logon cookie
This stores some personal information between visits to our site in order to allow you to log on automatically.
12.1.3 Usage cookie
This stores historic data about your visits to our site and allows us to personalise your experience, providing features such as special offers, and allowing you to store items in your shopping basket between visits.
12.1.4 Advertising cookies
We use Google Display Advertising and have Google Analytics tracking code to support this. Analytics collect data about our site’s traffic and this is used to implement our Online Advertising and Remarketing whereby our ads are shown on sites across the internet. Ourselves and third-party vendors (including Google) use first-party cookies (such as the DoubleClick cookie) together to inform, optimise, and serve ads based on users past visits to our website. We cannot gain personally identifiable information from these cookies. You can opt-out of Analytics through Google’s Ads Preferences Manager. You may also wish to use the Google Analytics opt-out browser add-on. It is worth noting that opting out of advertising cookies will not mean you won’t see adverts, just simply that they won’t be tailored to you any longer.
12.2 Blocking cookies
If you do not want to use “cookies” most Internet browser programs will permit you to turn them off. Should you do this, you will be able to access our site as normal, but some processes that depend on cookies may not work properly.