Privacy Policy
British Fashion Council Privacy Notice
Last Updated June 2020
This document applies to individuals in the United Kingdom (“UK”) and European Economic Area (“EEA”) who use our websites https://www.londonfashionweek.co.uk// (“Sites”) and any of the products and services made available by British Fashion Council (“BFC”) and/or British Fashion Council Foundation (“BFCF”).
We respect the privacy of every person who visits or registers with or submits personal information through our Sites and we are further committed to ensuring a safe online experience. We also respect the privacy of every person who uses the products and services that we make available (from the Sites or otherwise), or who engages with us, whether as a designer, as an official partner, stakeholder or otherwise, in our capacity as the industry body of fashion in the UK.
1. Purpose of this privacy notice
This privacy notice (“Privacy Notice”) explains to data subjects in the EEA our approach to any personal information that we might collect from you or which we have obtained about you from a third party and the purposes for which we process your personal information. This Privacy Notice also sets out your rights in respect of our processing of your personal information.
This Privacy Notice informs you of the nature of the personal information about you that is processed by us and how you can request that we delete it, update it, transfer it and/or provide you with access to it.
This Privacy Notice is intended to assist you in making informed decisions when using the Sites and our products and services. Please take a moment to read and understand it. It should be read in conjunction with our Website Terms and Conditions and Cookie Policy.
This Privacy Notice only applies to the use of your personal information obtained by us; it does not apply to personal information collected during your communications with third parties.
2. About us
The Sites are made available by the BFC. The products and services made available through the Sites and otherwise are provided by the BFC and/or BFCF.
British Fashion Council is a private company limited by guarantee without share capital registered in England and Wales under registration number 02050620 with its registered office located at 33 Broadwick Street
British Fashion Council Foundation is a private company limited by guarantee without share capital registered in England and Wales under registration number 11917315 with its registered office located at Somerset House South Wing Strand, London, WC2R 1LA.
The data controller responsible for your personal information will be either the BFC and/or BFCF depending on the nature of your engagement and/or which products and services you are receiving. In certain circumstances, the BFC and BFCF may be joint data controllers. References to the terms “we” or “us” in this document are therefore references to the BFC and/or BFCF as applicable.
3. How to contact us
If you have any questions about this Privacy Notice or want to exercise your rights set out in this Privacy Notice, you can:
· Send us an email at: [email protected]
· Call us on: 0207 759 1999 and ask for Clara Mercer, Director of Communications
· Write to us at: Clara Mercer, Director of Communications British Fashion Council, Somerset House South Wing Strand, London, WC2R 1LA
4. How we collect and receive personal information
We collect and receive personal information using different methods:
Personal information you provide to us.
You may give us your personal information directly. This will be the case when, for example, you contact us with enquiries, complete forms on our Sites, subscribe to receive our marketing communications, give us your business card or provide feedback to us.
Personal information we collect from you automatically.
When you access and use our Sites, we will automatically collect certain technical information about your equipment, browsing actions and patterns. We collect this personal information by using cookies and other similar technologies (see the “Our Use of Cookies and Similar Technologies” section below).
Personal information received from third parties.
From time to time, we will receive personal information about you from third parties or garnered from third party websites (such as LinkedIn). Such third parties may include other industry bodies, our sponsors and charities, and our programme organisers’ partners. We may also receive personal information from analytics providers, payment providers and third parties that provide services to us so that we can operate our Sites and/or provide our services.
5. Personal information we collect and how we use it
Our primary reasons for collecting personal information from you are: (i) in the case of the BFC, to fulfil the duties bestowed upon us in our capacity as the industry body of fashion in the UK; (ii) to provide the products and services you have requested; (iii) to verify your identity (where applicable); (iv) to help us improve our Sites and our products and services and develop and market new products and services; (v) to carry out requests made by you on the Sites; (vi) to investigate or settle enquiries, complaints or disputes; (vii) to comply with applicable law, court order, other judicial process and the requirements of regulators; (viii) to enforce our agreements with you; (ix) to protect the rights, property and safety of us or third parties, including our members and users of the Sites; (x) to provide support for the provision of our products and services; (xi) to carry out recruitment activities; and (xii) to use as otherwise required or permitted by law.
A. We may collect and process the following personal information from you in the following circumstances:
· Site visitors: If you browse our Sites, contact us with an enquiry through our Sites or register an account with our Sites, we may collect and process: (i) your name and title; (ii) your date of birth; (iii) your gender; (iv) your contact information (including telephone number, postal address and/or email address); (v) information relating to your interactions with our Sites; (vi) your demographic information such as post code, preferences and interests; and (vii) any information you volunteer which is relevant to the provision of the products and services you have requested.
· Purchasers of event tickets and/or products: If you purchase event tickets or products, whether from our Sites or in in person on site at one of our events, we may collect and process: (i) your name and title; (ii) your contact information (including telephone number, postal address and/or email address); (iii) your payment details; (iv) information relating to your interactions with our Sites; (v) your demographic information such as postcode, preferences and interests; and (vi) any information you volunteer which is relevant to the provision of the tickets and/or products you have purchased.
· Designers, Buyers, Press, PR, Professional Advisors, Supporters, Government Stakeholders and others involved in the activities of the BFC: If you are involved with the BFC (including any of its events or initiatives such as London Fashion Week, London Fashion Week Men’s, The Fashion Awards), whether in your capacity as a designer, buyer, press or PR, photographer, professional advisor, supporter, government stakeholder or otherwise, we may collect and process the following personal information: (i) your name and title; (ii) your date of birth; (iii) your gender; (iv) your contact information (including telephone number, postal address and/or email address); (v) your biographical information; (vi) information about your show and/or collection; (vii) your likeness; (viii) your image; (ix) your voice; (x) your statements; (xi) any personal information contained in any form of personal identification, such as a passport; (xii) your payment details; (xiii) any information you volunteer which is relevant to our relationship with you; and (xiv) special categories of personal information (including without limitation information revealing racial or ethnic origin and information concerning physical and mental health) and personal information relating to criminal convictions and offences.
· Members and Patrons: If you are, or become, a Member or Patron of the BFC and/or one of its initiatives and charities such as Fashion Trust, we may collect and process: (i) your name and title; (ii) your date of birth; (iii) your gender; (iv) your contact information (including telephone number, postal address and/or email address); (v) your payment details; (vi) information relating to your interactions with our Sites; (vii) your demographic information such as postcode, preferences and interests; and (viii) any information you volunteer which is relevant to your membership or patronage.
· Individuals who work for our brand partners/sponsors: Corporate organisations are not data subjects, although any individuals who work for them are. If you work for one of our brand partners or sponsors and you are engaging with us on behalf of your organisation, whether through our Sites or otherwise, we may collect and process: (i) your name and title; (ii) your job title; (iii) your contact information (including telephone number, postal address and/or email address); (iv) any personal information contained in any form of personal identification; and (v) any information you volunteer which is relevant to our relationship with your organisation.
· Job applicants: If you apply for a job with us, we may collect and process: (i) your name and title; (ii) your current job title; (iii) your contact information (including telephone number, postal address and/or email address); (iv) personal information concerning your education, qualifications and employment history; and (v) any other personal information which appears in your curriculum vitae or which is relevant to your potential recruitment, which may include special categories of personal information (including without limitation information revealing racial or ethnic origin and information concerning physical and mental health) and information relating to criminal convictions and offences.
· Suppliers (including subcontractors and individuals associated with our suppliers and subcontractors) to the BFC: We collect and process personal information about our suppliers in order to manage the relationship, to receive services from our suppliers and, where relevant, to provide products and services to our stakeholders.
· Visitors and workers onsite at our events: We have security measures in place at our events, including CCTV and building access controls. There are signs in place showing that CCTV is in operation. The images captured are securely stored and only accessed on a need to know basis (e.g. to look into an incident). CCTV recordings are typically automatically overwritten after a short period of time unless an issue is identified that requires investigation (such as a theft). We require workers at our events to sign in and keep a record of visitors for a short period of time. Our visitor and worker records are securely stored and only accessible on a need-to-know basis (e.g. to look into an incident).
B. We use your personal information for the following purposes:
- Fulfilment of our commercial products and services.
Use of our Sites and our products and services: We collect and maintain personal information that you voluntarily submit to us during your use of the Sites and when you purchase products and/or services from us or use our products and/or services, whether through the Sites or otherwise. We may collect and process your personal information whether you are interacting with us on your own behalf or on behalf of any organisation you represent.
Your access to and use of our Sites, including any restricted members’ area, is subject to our Website Terms and Conditions. Certain products and services we offer through the Sites or otherwise are also subject to specific terms and conditions which shall apply to your purchase and use of such products and services. If you click on one of the social media links on our Sites, or otherwise interact with our social media accounts, such as on LinkedIn, Twitter, Facebook or Instagram, we may receive information relating to such interaction and to your own social media accounts.
Site account registration: If you register for an account on our Sites or register to access our Sites or a part of any one of our Sites (such as a Member Only section), we will use your personal information to process your account registration. Once you are registered, we will process your personal information to identify you when you log into secure areas of our Sites. We will also use your personal information so that we can administer your account with us and contact you about your account.
Events and products: We use your personal information so that we can fulfil the supply of tickets and products you have ordered from our Sites or on site at one of our events. We may also contact you to participate at one of our events, for example, by showcasing your collection, speaking at an event or attending it on behalf of your organisation. If relevant, we may collect and process any dietary requirements you may have and/or require your passport (if we are booking flights on your behalf). You may also feature in photographs taken at our events and such photographs may appear on our Sites, in print or on our social media channels.
Corporate or group booking: If you book an event on behalf of your organisation or a group (such as corporate hospitality at The Fashion Awards), we use your personal information to process and administer your organisation’s or group’s booking. If you are attending an event, we may process your personal information in order to identify you when you attend and for related record-keeping purposes. If relevant, we may collect and process any dietary requirements you and your guests may have. You and your guests may also feature in photographs taken at our events and such photographs may appear on our Sites, in print or on our social media channels.
Contributions to our Sites and publications: If you write an article or blog for us or contribute in any other way to publications we send to our members and/or publish on our Sites or in print, we may use your personal information (such as your name and the name of your organisation) to credit you for your contribution. If you provide photographs or other images in support of your article or blog, we may publish one or more of those images alongside your article or blog.
Brand partnerships: If your organisation is partnering with the BFC, we use your personal information (such as your name and contact details) to contact you in respect of the partnership and maintain the relationship.
What is our legal basis?
It is necessary for us to use your personal information to perform our obligations in accordance with any contract that we may have with you or it is in our legitimate interest or a third party’s legitimate interest to use personal information in such a way to ensure that we provide the products and services you have requested in an effective and efficient way.
- Fostering talent.
We organise various fashion initiatives and provide support to creative talent in order to sustain and promote British fashion as part of our duties as the industry body of fashion in the UK. This includes awarding scholarships to young creative talent, providing creative talent with access to our BFC network and providing them with regular mentoring and financial support (for example, through our NewGen scheme). We may use your personal information (such as your name, likeness, contact details, job / educational history and/or payment details) in order to provide that support.
What is our legal basis?
It is in our legitimate interest to use such information in order to provide talent with our support and promote emerging creative talent.
- Government relations and regulatory duties.
The BFC receives funding from the government and interacts with the government and other public bodies and charities to address key concerns facing the fashion industry and provide support in respect of access to talent, ease of trade, protection of intellectual property and continuing funding support for the development and growth of the fashion industry.
Where we use government funds to support designers or other creative talent, we are required to collect certain personal information (such as your name, contact information, payment details) and special categories of personal information (such as racial or ethnic origin, gender and disability information).
What is our legal basis?
It is our legal obligation to use your personal information to comply with any legal obligations imposed on us as part of the funding that we receive from various government bodies or in our legitimate interest to ensure that we can represent the issues facing the fashion industry.
We will not process any special categories of personal information except where we have obtained your explicit consent.
· General enquiries.
We accept enquiries by email, telephone and post. When you make an enquiry, we will use your personal information to enable us to manage and respond to your enquiries and requests.
What is our legal basis?
It is in our legitimate interest to use your personal information in such a way to ensure that we provide a good standard of customer service to you.
- Your feedback about our performance, our products and services and the fashion industry.
From time to time, we may invite you to provide feedback about us, our products and services and the fashion industry in the form of online or postal surveys. We will use your personal information in any feedback you provide to help us improve the quality of service provided by us, to help gather insights for the wider fashion community and to lobby for change and support.
What is our legal basis?
It is in our legitimate interest to use the personal information provided by you in your feedback for the purposes described above.
- User insight and analysis.
We analyse your contact details with other personal information that we observe about you from your interactions with our Sites, with our email communications to you and with our products and services.
Where you have given your consent (where lawfully required), we use cookies, log files and other technologies to collect personal information from the computer hardware and software you use to access the Sites, or from your mobile device. This includes the following:
· An IP address to monitor Site traffic and volume;
· A session ID to track usage statistics on our Sites; and
· Information regarding your personal or professional interests, demographics, experiences with our products and services and contact preferences.
Our web pages and emails may contain cookies, web beacons and pixel tags (“Tags”). Tags allow us to track receipt of an email to you, count users who have visited a web page or opened an email and collect other types of aggregated information. Once you click on an email that contains a Tag, your contact information may subsequently be cross-referenced to the source email and/or the relevant Tag.
In some of our email messages, we use a “click-through URL” linked to certain websites administered by us or on our behalf. We may track click-through data to assist in determining interest in particular topics and measure the effectiveness of these communications.
Please see our Cookie Policy for further information.
This information is used to create insights about our visitors’ browsing habits on our Sites. Where we have your consent to do so, we will also use your location data for insight and analysis purposes.
By using this information, we are able to measure the effectiveness of our content and how visitors use our Sites and our products and services. This allows us to learn what pages of our Sites are most attractive to our visitors, which parts of our Sites are the most interesting and what kind of features and functionalities our visitors and clients like to see.
We also use this information to help us with the selection of future product and service lines and website design and to remember your preferences.
We may also use this information for marketing purposes (see the “Marketing Activities” section below for further details).
What is our legal basis?
Where your personal information is completely anonymised, we do not require a legal basis to use it as the information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymised personal information may be subject to other laws where your consent is required. Please see our Cookie Policy for further details.
Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information in such a way to ensure that we provide good quality products and services to you and our other visitors and clients.
We will only use your location data for insight and analysis purposes where we have your consent to do so.
- Marketing activities.
We carry out the following marketing activities using your personal information:
Postal marketing.
We may use your name and address to send you marketing communications by post. Such communications will include information about the events, products, services, offers and promotions we offer from time to time. These communications are not personalised to you.
What is our legal basis?
Where your personal information is completely anonymised, we do not require a legal basis to use it as the personal information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymised information may be subject to other laws where your consent is required. Please see our Cookie Policy for further details.
Where your personal information is not in an anonymous form, which will be the case with your postal address, it is in our legitimate interest to use your personal information for marketing purposes.
Email marketing.
We use your name and email address to send you marketing communications by email, where you have consented to receive such marketing communications or where we have another lawful right to do so. Such communications will include information about the events, products, services, offers and promotions we offer from time to time.
Our email marketing will include personalised and non-personalised email marketing. Personalised marketing is marketing which has been specifically tailored to you. For example, our personalised email marketing will feature our events, products, services, offers and/or promotions that we think are most likely to appeal to you based on our understanding of your interests. Non-personalised marketing is marketing about our events, products, services, offers and promotions generally and is not tailored to any particular individual.
Where we are sending you personalised email marketing, we will also use information that we observe about you from your interactions with our Sites, with our email communications to you and/or with our products and services in order to decide what sort of personalised marketing communications to send you. Please see the “User Insight and Analysis” section above for more details about the personal information collected and how it is collected.
What is our legal basis?
Where your personal information is completely anonymised, we do not require a legal basis to use it as the personal information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymised personal information may be subject to other laws where your consent is required. Please see our Cookie Policy for further details.
Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information for marketing purposes.
We will only send you marketing communications by email where you have consented to receive such communications, or where we have another lawful right to do so.
We will only use your location data where we have your consent to do so.
Online and social media remarketing.
We use information that we observe about you from your interactions with our Sites, with our email communications to you and/or with our services to provide you with personalised advertising on online and social media channels operated by Facebook (including Instagram) and/or Google where you are a registered user of such services. Please see the “Insight and Analysis” section above for more details about the personal information collected and how it is collected. We do this using Facebook Custom Audiences and/or Google Customer Match. Please note that such activity is also subject to the privacy choices you have elected to make on such services.
What is our legal basis?
Where your personal information is completely anonymised, we do not require a legal basis to use it as the personal information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymised personal information may be subject to other laws where your consent is required. Please see our Cookie Policy for further details.
Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information for marketing purposes.
We will only engage in online and social media remarketing where you have consented to us using your email address and sharing your email address in an encrypted format with Facebook and/or Google respectively for marketing purposes.
- Prize draws, prize competitions and other promotions.
From time to time, we may run prize draws, prize competitions and other promotions on our Sites, at our events (e.g. London Fashion Week), through our BFC initiatives and/or on our social media accounts. For the purposes of administering such promotions, we may process your name, contact details (including email address, postal address and/or telephone number, as applicable), social media handle (if relevant), payment details (if relevant), and any other personal information volunteered by you in your promotion entry. Our promotions may be subject to separate terms and conditions which you may be required to accept as a condition of entry.
What is our legal basis?
It is necessary for us to use your personal information to perform our obligations in accordance with any contract that we may have with you (e.g. the terms and conditions applicable to the promotion to which you may be asked to agree as a condition of entry) or it is in our legitimate interest to use your personal information to enable you to participate in any prize draws, prize competitions and other promotions.
- Recruitment.
We use your personal information for recruitment purposes, in particular, to assess your suitability for any position for which you may apply at the BFC, whether such application has been received by us online, by email or by hard copy and whether submitted directly by you or by a third party recruitment agency on your behalf. We also use your personal information to communicate with you about the recruitment process, to keep records about our recruitment process and to comply with our legal and regulatory obligations in relation to recruitment.
We will process any personal information about you that you volunteer when you apply for a job with us. We may also process your personal information obtained from any third parties we work with in relation to our recruitment activities, including without limitation, recruitment agencies, background check providers, credit reference agencies and your referees. Such information may also include special categories of personal information (such as information about your health, any medical conditions and your health and sickness records) and information relating to criminal convictions and offences if that information is relevant to the role you are applying for.
We also use your personal information for the purposes of reviewing the BFC’s equal opportunity profile in accordance with applicable legislation. This involves the processing of certain special categories of personal information, such as personal information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, personal information concerning a person’s physical and mental health, sex life or sexual orientation. The BFC does not discriminate on the grounds of gender, race, ethnic origin, age, religion, sexual orientation, disability or any other basis covered by local legislation. All employment-related decisions are made entirely on merit.
What is our legal basis?
Where we use your personal information in connection with recruitment, it will be in connection with us taking steps at your request to enter into a contract we may have with you or it is in our legitimate interest to use personal information in such a way to ensure that we can make appropriate and informed recruitment decisions.
We will not process any special categories of personal information or personal information relating to criminal convictions or offences except where we are able to do so under applicable legislation or with your explicit consent.
- Receipt of services from suppliers.
If we have engaged you or the organisation you represent to provide us with products or services (for example, if you or the organisation you represent provide us with services such as IT support or financial advice), we will collect and process your personal information in order to manage our relationship with you or the organisation you represent, to receive products and services from you or the organisation you represent and, where relevant, to provide our services to others.
The personal information we collect from you may include your name, job title, contact information (including email address, telephone number and postal address), bank account or other payment details and any other personal information you volunteer which is relevant to our relationship with you or the organisation you represent.
Our legal basis for processing
It is necessary for us to use your personal information to perform our obligations in accordance with any contract that we may have with you or the organisation you represent or it is in our legitimate interest to use personal information in such a way to ensure that we have an effective working relationship with you or the organisation you represent and are able to provide our services to you and others in an effective way.
- Business administration and legal compliance.
We use your personal information for the following business administration and legal compliance purposes:
· To comply with our legal obligations;
· To enforce our legal rights;
· To protect the rights of third parties; and
· In connection with a business transition such as a merger, reorganisation, acquisition by another company, or sale of all or a portion of our assets.
What is our legal basis?
Where we use your personal information in connection with a business transition, to enforce our legal rights or to protect the rights of third parties, it is in our legitimate interest to do so. For all other purposes described in this section, it is our legal obligation to use your personal information to comply with any legal obligations imposed on us, such as a court order.
We will not process any special (or sensitive) categories of personal information or personal information relating to criminal convictions or offences except where we are able to do so under applicable legislation or with your explicit consent.
- Any other purposes for which we wish to use your personal information that are not listed above, or any changes we propose to make to the existing purposes, will be notified to you using the contact details that we hold for you.
6. If you fail to provide your personal information
Where we are required by law to collect your personal information, or we need to collect your personal information under the terms of a contract we have with you, and you fail to provide that personal information when we request it, we may not be able to perform the contract we have or are trying to enter into with you. This may apply where you do not provide the personal information we need in order to provide the services you have requested from us or to process an application for employment with us. In this case, we may have to cancel your application or the provision of the relevant services to you, in which case we will notify you.
7. How we obtain your consent
Where our use of your personal information requires your consent, you can provide such consent:
· At the time we collect your personal information following the instructions provided; or
· By informing us by email, post or telephone using the contact details set out in the “How to Contact Us” section above.
8. Our use of cookies and similar technologies
Our Sites may use certain cookies, web beacons, pixel tags, log files and other technologies. Please see our Cookie Policy to find out more about the cookies and other technologies we use, the purposes for which we use them and how to manage, block or delete them.
9. Third party links and services
Our Sites contains links to third party websites and services. When you use a link to go from our Sites to another website or you request a service from a third party, this Privacy Notice no longer applies.
Your browsing of and interactions with any other websites, or your dealings with any third party service provider, is subject to that website’s or third party service provider’s own rules and policies.
We do not monitor, control or endorse the privacy practices of any third parties.
We encourage you to become familiar with the privacy practices of every website you visit or third party service provider that you deal with and to contact them if you have any questions about their respective privacy notices and practices.
This Privacy Notice applies solely to personal information collected by us through our Sites, through the supply of our products and services and/or in connection with our business operations and through the exercise of our duties as the industry body of fashion in the UK.
10. Sharing personal information
We will only share personal information with others when we are legally permitted to do so. When we share personal information with others, we put contractual arrangements and security mechanisms in place to protect the personal information and to comply with our data protection, confidentiality and security standards.
When processing your personal information we may need to share it with third parties as follows:
· Other organisations within our group of companies: We may share personal information with other organisations within our group of companies (including our charitable organisations) where necessary for administrative purposes or where those organisations assist us in the provision of our products and services or in the fulfilment of our duties as the industry body of fashion in the UK.
· Third-party organisations that provide applications/functionality, data processing or IT services: We use third parties to support us in providing our products services and to help provide, run and manage our internal IT systems. Such third parties may include, for example, providers of information technology, cloud based software as a service providers, identity management, website hosting and management, data analysis, data back-up, security and storage services. The servers powering and facilitating that cloud infrastructure are located in secure data centres around the world, and personal information may be stored in any one of them. We also share your personal information with third-party service providers to assist us with insight analytics. These providers are described in our Cookie Policy.
· Credit card companies and other payment providers: We may share personal information with third parties who assist us with the processing of card payments and refunds.
· Delivery and courier companies: We use third-party delivery companies and couriers to help deliver the products that our customers and members order from our Sites, such as tickets and products, as well as our postal marketing.
· Event partners and suppliers: When we run events, we will share your personal information with third-party services providers that are assisting us with the operation and administration of that event. If we are running an event in partnership with other organisations, we will share your personal information with such organisations for use in relation to the event.
· Third-party email marketing and CRM specialists: We share personal information with specialist suppliers who assist us in managing our marketing database and sending out our email marketing communications and membership-related communications.
· Third-party organisations that assist us with the administration of our promotions: We share personal information with specialist suppliers who assist us in administering our competitions, prize draws and other promotions.
· Recruitment agencies and related organisations: We may share your personal information with external recruiters, third party providers that undertake background checks on our behalf and other entities within our group of companies.
· Auditors, lawyers, accountants and other professional advisers: We share personal information with professional services firms who advise and assist us in relation to the lawful and effective management of our organisation and in relation to any disputes we become involved in.
· Law enforcement or other government and regulatory agencies: We may share personal information with law enforcement or other government and regulatory agencies or other third parties as required by, and in accordance with, applicable law or regulation. Where we allocate government funds to you, we will need to share your information with the government as evidence that those funds have been appropriately allocated.
· Other third parties: Occasionally, we may receive requests from third parties with authority to obtain disclosure of personal information, such as to check that we are complying with applicable law and regulation, to investigate an alleged crime, to establish, exercise or defend legal rights. We will only fulfil requests for personal information where we are permitted to do so in accordance with applicable law or regulation
This list is non-exhaustive and there may be circumstances where we need to share personal information with other third parties in order to provide our products and services and carry out our regulatory duties as effectively as we can.
11. Transfers outside the eea
Where necessary in order to deliver our services or to fulfil our role as the industry body of fashion in the UK, we will transfer personal information to countries outside the UK and EEA.
Non-EEA countries do not have the same data protection laws as the UK and the EEA. In particular, non-EEA countries may not provide the same degree of protection for your personal information, may not give you the same rights in relation to your personal information and may not have a data protection supervisory authority to help you if you have any concerns about the processing of your personal information. However, when transferring your personal information outside the EEA, we will comply with our legal and regulatory obligations in relation to the personal information including having a lawful basis for transferring personal information and putting appropriate safeguards in place to ensure an adequate level of protection for the personal information.
We will take reasonable steps to ensure the security of your personal information in accordance with applicable data protection laws.
When transferring your personal information outside the UK and EEA, we will ensure that we have a lawful basis for the transfer. Our lawful basis will be either consent (i.e. we may ask for your consent to transfer your personal information outside the UK and EEA at the time you provide your information) or one of the following safeguards:
· Adequacy decisions: We may transfer your personal information to countries that have been deemed to provide an adequate level of protection for personal information by the European Commission. For further details, see https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en.
· Model clauses: Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal information the same protection it has in Europe. For further details, see https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.
· EU-U.S. Privacy Shield: Where we have partners or suppliers based in the US, we may transfer personal information to them if they are registered with the EU-U.S. Privacy Shield, which requires them to provide similar protection to personal information shared between the EEA and the U.S. For further details, see https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/eu-us-privacy-shield_en.
Please contact us if you would like further information on the specific mechanisms used by us when transferring your personal information outside the UK and EEA.
12. How long we keep your personal information
Regarding personal information we have processed, we will retain personal information for as long as is necessary and in compliance with our obligations under the EU General Data Protection Regulation (or similar legislation around the world). We may then destroy such files without further notice or liability.
If any personal information is only useful for a short period (e.g. for a specific marketing campaign), we may delete it at the end of that period.
If you have opted out of receiving marketing communications from us, we will need to retain certain personal information indefinitely so that we know not to send you marketing communications again.
13. Confidentiality and security of your personal information
We are committed to keeping the personal information you provide to us secure and we will take reasonable precautions to protect your personal information from loss, misuse or alteration.
We have implemented information security policies, rules and technical measures to protect the personal information that we have under our control from:
· Unauthorised access;
· Improper use or disclosure;
· Unauthorised modification; and
· Unlawful destruction or accidental loss.
All our employees and data processors (i.e. those who process your personal information on our behalf, for the purposes listed above) who have access to and are associated with the processing of personal information are obliged to respect the confidentiality of the personal information of all users of our Sites and our products and services.
14. Personal information of children under 16
Our Sites and the commercial products and services that we offer are not specifically targeted at children under 16. If you are under 16, we ask that you obtain your parent’s or guardian’s consent before submitting personal information to us or requesting any products or services from us.
If you are a parent or guardian of a child under 16, please ensure that you supervise your child’s use of our Sites and our products and services and ensure they obtain your consent before submitting any personal information to us or requesting any products or services from us.
For the purpose of safeguarding the rights, interests and freedoms of children, we may ask you to verify your age in order to continue using our Sites and/or any of our products and services you may have requested.
15. How to access your information and your other rights
You have the following rights in relation to the personal information we hold about you:
- Your right of access.
If you ask us, we will confirm whether we are processing your personal information and, if so, provide you with a copy of that personal information (along with certain other details). If you require additional copies, we may charge a reasonable fee for producing those additional copies.
- Your right to rectification.
If the personal information we hold about you is inaccurate or incomplete, you are entitled to have it rectified. If we have shared your personal information with others, we’ll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we will also tell you who we’ve shared your personal information with so that you can contact them directly.
- Your right to erasure.
You can ask us to delete or remove your personal information in some circumstances, such as where we no longer need it or where you withdraw your consent (where applicable). If we have shared your personal information with others, we will let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we will also tell you who we have shared your personal information with so that you can contact them directly.
- Your right to restrict processing.
You can ask us to block or suppress the processing of your personal information in certain circumstances, such as where you contest the accuracy of that personal information or you object to us processing it. It won’t stop us from storing your personal information, though. We will tell you before we lift any restriction. If we have shared your personal information with others, we will let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we will also tell you who we have shared your personal information with so that you can contact them directly.
- Your right to data portability.
You have the right, in certain circumstances, to obtain personal information you have provided to us (in a structured, commonly used and machine readable format) and to reuse it elsewhere or to ask us to transfer it to a third party of your choice.
- Your right to object.
You can ask us to stop processing your personal information, and we will do so, if we are:
· Relying on our own or someone else’s legitimate interest to process your personal information, except if we can demonstrate compelling legal grounds for the processing;
· Processing your personal information for the purposes of personalised direct marketing; or
· Processing your personal information for the purposes of non-personalised direct marketing.
- Your rights in relation to automated decision-making and profiling.
You have the right not to be subject to a decision when it is based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for the entering into, or the performance of, a contract between you and us.
- Your right to withdraw consent.
If we rely on your consent (or explicit consent) as our legal basis for processing your personal information, you have the right to withdraw that consent at any time. You can exercise your right of withdrawal by contacting us using our contact details in the “How to Contact Us” section above or by using any other opt-out mechanism we may provide, such as an unsubscribe link in an email.
- Your right to lodge a complaint with the supervisory authority.
If you have a concern about any aspect of our privacy practices, including the way we have handled your personal information, please contact us using the contact details provided in the “How to Contact Us” section above. You can also report any issues or concerns to the Information Commissioner’s Office (ICO). You can find details about how to report a concern on the ICO website at https://ico.org.uk/concerns/ or by calling their helpline on 0303 123 1113.
16. Changes to this Privacy Notice
We may make changes to this Privacy Notice from time to time.
To ensure that you are always aware of how we use your personal information we will update this Privacy Notice from time to time to reflect any changes to our use of your personal information. We may also make changes as required to comply with changes in applicable law or regulatory requirements. We will notify you by email or via a pop-up message on our Sites of any significant changes. However, we encourage you to review this Privacy Notice periodically to be informed of how we use your personal information.
