PRIVACY POLICY

Last updated October 2021


1. Introduction

This Privacy Policy (together with our terms and conditions and any other documents referred to in it) describes the type of information that we collect from you ("you/your") when you purchase a product or service from us ("Services"), or the use of our website https://uk.parfums-de-marly.com ("Website"), how that information may be used or disclosed by us and the safeguards we use to protect it.

Our Website and Services may contain links to third party websites that are not covered by this Privacy Policy. We therefore ask you to review the privacy statements of other websites and applications to understand their information practices.

We have drafted this Privacy Policy to be as clear and concise as possible. Please read it carefully to understand our policies regarding your information and how we will treat it. By using or accessing our Website or the Services, you agree to the collection, use and disclosure of information in accordance with this Privacy Policy. This Privacy Policy may change from time to time and your continued use of the Website or the Services is deemed to be acceptance of such changes, so please check periodically for updates.

Please check back regularly to keep informed of updates to this Privacy Policy. Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of our Privacy Policy is deemed to occur upon your first use of our Website. If you do not accept and agree with this Privacy Policy, you must stop using our Website immediately.

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

If you have any comments on this Privacy Policy, please email them to customerservice.uk@pmarly.com


2. Who We Are

2.1 Here are our details:

- Our Website address is https://uk.parfums-de-marly.com

- Our company name is Euro Parfums UK Limited (a subsidiary of Euro Parfums FZE)

- Our company registered number is 12353164

- Our registered address is Saxon House Moseley's Farm Business Centre, Fornham All Saints, Bury St Edmunds, Suffolk, England, IP28 6JY

- Our trading name/brand name is “Parfums de Marly” which is a UK registered trade mark under registered numbers UK00003614290, UK00913290853, UK00914565791, UK00003614395, UK00913290861

- Our nominated representative who is responsible for overseeing questions in relation to this privacy policy is our UK Country Manager. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please email customerservice.uk@pmarly.com marked for the attention of our UK Country Manager.

2.2 We respect your right to privacy and will only process personal information about you or  provided by you in accordance with the Data Protection Legislation which for the purposes of this Privacy Policy shall mean: (i) the retained EU law version of the General Data Protection Regulation ((EU) 2016/679) (UK GDPR), the Data Protection Act 2018 and any other national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK and then (ii) any successor legislation to the UK GDPR or the Data Protection Act 2018 and other applicable privacy laws.


3. The data we collect about you

3.1 Personal data, or personal information, 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).

3.2 We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

- Identity Data includes first name, last name, username or similar identifier. When you contact us, either by email or via our contact us form we may collect information such as your first name, last name, email address and phone number.

- Contact Data includes billing address, invoicing address, email address and telephone numbers.

- Financial Data includes bank account and payment card details.

- Transaction Data includes details about payments and other details of our 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, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this Website.

- Usage Data includes information about how you use our Website and Services.

- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

- Cookies Data like many websites, we use "cookies" to enhance your experience and gather information about visitors and visits to our websites. Please refer to the "Do we use 'cookies'?" section below for information about cookies and how we use them and what kind.

- Third Parties and Information we receive from other sources. We may receive information about you if you use any of the other websites we operate or through the Services we provide. In this case we will have informed you when we collected that data that it may be shared internally and combined with data collected on our Website. We are also working closely with third parties (including, for example, business partners, suppliers, sub-contractors, advertising networks, analytics providers, and search information providers) and may receive information about you from them.

Analytics which includes third-party analytics services (such as Google Analytics and Pinterest) to evaluate your use of the Website, compile reports on activity, collect demographic data, analyse performance metrics, and collect and evaluate other information relating to our Website and internet usage. These third parties use cookies and other technologies to help analyse and provide us the data. By accessing and using the Website, you can manage these cookies in the setting preferences and where consent is given to the use of these cookies the processing of data about you by these analytics providers in the manner and for the purposes set out in this Privacy Policy.

3.3 Under UK GDPR we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following basis applies:

  1. a) You have given consent to the processing of your personal data for one or more specific purposes;
  2. b) processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;
  3. c) processing is necessary for compliance with a legal obligation to which we are subject;
  4. d) processing is necessary for the purposes of the legitimate interests pursued by us or by a third party such as our financial payments.

3.4 If you provide personal information to us about another data subject, you are responsible for ensuring that you have their consent to provide that data for the uses set out in this Privacy Policy and for bringing this Privacy Policy to their attention.


4. How we may collect and use your data

4.1 We, internal third parties (including members of the Parfum de Marley group of companies), third party data processors, agents and sub-contractors acting on our behalf) may collect, store and use your personal information by way of different methods to collect data from and about you including through:

Direct interactions. You may give us your information by filling in forms via our Website or by corresponding with us by email or using our ‘contact us' form or otherwise. This includes personal data you provide when you:

  1. a) present information to us on the Website;
  2. b) use any of our Services;
  3. c) create an account on our Website;
  4. d) subscribe to our Services or publications;
  5. e) request marketing to be sent to you; or
  6. f) give us some feedback.

4.2 In addition to the above, we may use the information in the following ways:

  1. a) To personalise your Website experience and to allow us to deliver the type of content and product offerings in which you are most interested.
  2. b) To administer a contest, promotion, survey or other site feature.
  3. c) If you have consented to receive our e-mail newsletter, we may send you periodic e-mails. If you would no longer wish to receive promotional e-mails from us, please unsubscribe using the link provided in the emails. If you have not opted-in to receive e-mail newsletters, you will not receive these e-mails.
  4. d) Present Website content effectively to you.
  5. e) Provide information, and services that you request, or (with your consent) which we think may interest you.
  6. f) Carry out our contracts with you.
  7. g) Provide the relevant Services to you.
  8. h) Tell you our charges.

4.3 If you are already our customer, we will only contact you electronically about things similar to what was previously sold to you.

4.4 If you are a new customer, you will only be contacted if you agree to it.

4.5 We may keep a record of those links which are used the most to enable us to provide the most helpful information, but we agree to keep such information confidential and you will not be identified from this information.

4.6 In addition, if you don't want us to use your personal data for any of the other reasons set out in this section in 4, you can let us know at any time by contacting us at customerservice.uk@pmarly.com and we will delete your data from our systems. However, you acknowledge this will limit our ability to provide the best possible products and services to you.

4.7 In some cases, the collection of personal data may be a statutory or contractual requirement, and we will be limited in the products and services we can provide you if you don't provide your personal data in these cases.

4.8 We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  1. a) Where we need to perform the contract we are about to enter into or have entered into with you.
  2. b) 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.
  3. c) Where we need to comply with a legal or regulatory obligation, for example compliance with health and safety, tax or other statutory obligations.

4.9 Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to our marketing communications or sending third party direct marketing communications to you via email. You have the right to withdraw consent to marketing at any time by clicking the unsubscribe link in the email.

4.10 As already indicated above, with your permission and/or where permitted by law, we may also use your data for marketing purposes which may lead to us contacting you by email and/or telephone with information, news and offers on our Services. We agree that we will not do anything that we have not agreed to under this Privacy Policy, and we will not send you any unsolicited marketing or spam. We will take all reasonable steps to ensure that we fully protect your rights and comply with our obligations under the UK GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, as amended.

4.11 When you register on our Website, we (or a third party on our behalf) also store the personal information you provide in the user profile. All Website users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.


5. Cookies

5.1 All Cookies used by and on our website are used in accordance with current UK Cookie Law.

5.2 Please look at our Cookie Policy which is available on our Website for more cookie information.


6. Your data and security

6.1 We use a company called Shopify who provide software used by us to run our business. If you visit our website or make a purchase from us, Shopify collect and use information about you on our behalf and at our direction. For further information about Shopify and the way in which they collect information, including what information they collect and how it is used, please visit Shopify's privacy information and policy. Where we do store or transfer data outside the UK, we will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the UK GDPR. Such steps may include, but not be limited to, the use of legally binding contractual terms between us and any third parties we engage with and the use of approved Model Contractual Arrangements. Your acceptance of this Privacy Policy shall be your consent permitting us to store or transfer data outside the UK if it is necessary for us to do so.

6.2 Data security is of great importance to us, and to protect your data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through our Website. 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.

6.3 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.

6.4 By giving us your personal data, you agree to this arrangement. We will do what we reasonably can to keep your data secure.

6.5 Any payments made by you, will be encrypted.

6.6 We have implemented security measures such as a firewall to protect any data and maintain a high level of security.

6.7 Notwithstanding the security measures that we take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to us data via the internet and you take the risk that any sending of that data turns out to be not secure despite our efforts.

6.8 If we give you a password upon registration on our Website, you must keep it confidential. Please don't share it.

6.9 We will keep personal data for as long as is necessary which is usually the life of our relationship and up to a period of three years after our relationship have ended. We may however be required to retain personal data for a longer period of time to ensure we comply with our legislative and regulatory requirements. We review our data retention obligations to ensure we are not retaining data for longer than we are legally obliged to.


7. Disclosing your information

We are allowed to disclose your information in the following cases:

7.1 We are allowed to disclose your information in the following cases:

7.1.1 If we want to sell our business, or our company, we can disclose it to the potential buyer.

7.1.2 We can disclose it to other businesses in our group.

7.1.3 We can disclose it if we have a legal obligation to do so, or in order to protect other people's property, safety or rights.

7.1.4 We can exchange information with others to protect against fraud or credit risks.

7.2 We may contract with third parties to supply services to you on our behalf. These may include payment processing companies (Shopify International Limited, PayPal, Stripe), search engine facilities, advertising and marketing. In some cases, these third parties may require access to some or all of your data.

7.3 When making a purchase on our Website, your payment details are captured and sent to Stripe or PayPal for processing. In order to process your payment your details are transmitted to the acquiring bank in order to authorise payments. We do not store credit or debit card details.

7.4 Where any of your data is required for such a purpose, we will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under UK GDPR and the law.  Any third party that we share data with will not be permitted to use it for any other purpose than fulfilling their contract with us.


8. Your legal rights

8.1 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. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

  • If you want us to establish the data's accuracy.
  • Where our use of the data is unlawful but you do not want us to erase it.
  • Where 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 the 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. Note that 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 consent at any time where we are relying on consent to process your personal data. However, this 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.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

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


9. Links to other sites

Please note that our terms and conditions and our policies will not apply to other websites that you get to via a link from our Website. We have no control over how your data is collected, stored or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.


10. Changes

If we change our Privacy Policy, we will post the changes on this page so please check this page for our current policy.


11. Terms and Conditions

Please also visit our website terms and conditions establishing the use, disclaimers, and limitations of liability governing the use of our Website.


12. Your agreement

By using our Website and by way of acknowledgment, you agree to our Privacy Policy.


13. Dispute Resolution

13.1 We will use our best efforts to negotiate in good faith and settle any dispute that may arise out of or relate to this Privacy Policy or any breach of it.

13.2 Any dispute shall not affect our ongoing obligations under this Privacy Policy.

13.3 This Privacy Policy and any dispute or claim relating to or connected with it (including non-contractual disputes or claims) shall be governed by and construed in accordance with the laws of England and Wales and the courts of England and Wales are the only place where disputes or claims relating to or connected with this Privacy Policy (including non-contractual disputes or claims) may be decided.

 

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