We collect, use and are responsible for certain personal information about you. When we do so we are subject to the General Data Protection Regulation, which applies across the European Union (including in the United Kingdom) and we are responsible as 'controller' of that personal information for the purposes of those laws.
It would be helpful to start by explaining some key terms used in this policy:
|We, us, our||The Orvis Inc. UK Limited|
|Personal information||Any information relating to an identified or identifiable individual|
|Special category personal information||
Personal information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership
Genetic and biometric data
Data concerning health, sex life or sexual orientation
PERSONAL INFORMATION WE COLLECT
We may collect and use the following personal information about you:
- your title, name and contact information, including email address and telephone number;
- browser information and online identifiers (such as your browser types, browser version host operating system, browser language and your IP address);
- information about your visit to our site (such as full Uniform Resource Locators (URL) clickstream to, through and from our site, whether your visit was directly from a marketing email we have sent, products viewed or searched for, page response times, download errors, lengths of visits to certain pages, page interaction information (such as scrolling, clicks and mouse overs) and methods used to browse away from the page);
- information from third parties such as digital marketing networks and social media networks such as Facebook, Instagram, Pinterest and Google to help manage your account, improve your shopping experience and get relevant marketing message across to you;
- aggregated information (such aggregate traffic information collected from your visit to our Site);
- your purchasing history including saved items and payment information (encrypted), such as payment methods, billing address details and other information related to payment;
- your personal interests: we store preferences for mailing/email advertising;
- information to enable us to undertake address verification checks you;
- your responses to our surveys, polls, focus groups, interviews, ethnography studies, user testing, competitions and promotions;
- details of any agreement or objection to receiving marketing information from us;
- images of you captured with in store CCTV cameras; and
- details of any contact with our customer services teams such as a record of your correspondence with us or any calls that you make to us.
This personal information is required to provide products to you and for us to complete the transactions for you. If you do not provide personal information we ask for, it may delay or prevent us from providing products to you.
HOW YOUR PERSONAL INFORMATION IS COLLECTED
We collect most of this personal information directly from you—in person, by telephone, text or email, post, social media, and/or via our website and mobile site. However, we may also collect information:
- about you from third parties where we carry out identity verification credit checks against your name using third party databases;
- about you from third parties for marketing where you have provided your express consent to the third party for your information to be shared for such purpose;
- we may work with third party information providers such who specialise in consumer profiling and provide demographic or other data to help better understand you, your purchasing behaviour and preferences;
- about you from online advertising and marketing companies to help us display the advertising content most relevant to you and to analyse our campaigns;
- we may collect information about you from third parties who we have partnered with to run competitions;
- we may collect information about you via our IT systems including our instore point of sale systems and CCTV.
HOW AND WHY WE USE YOUR PERSONAL INFORMATION
Under data protection law, we can only use your personal information if we have a proper reason for doing so, e.g.:
- to comply with our legal and regulatory obligations;
- for the performance of our contract with you or to take steps at your request before entering into a contract;
- for our legitimate interests or those of a third party; or
- where you have given consent.
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
The table below explains what we use (process) your personal information for and our reasons for doing so:
|What we use your personal information for||Our reasons|
|To provide products to you||For the performance of our contract with you or to take steps at your request before entering into a contract|
|To prevent and detect fraud against you or us||For our legitimate interests or those of a third party, i.e. to minimize fraud that could be damaging for us and for you|
Conducting checks to identify our customers and verify their identity
Screening for financial and other sanctions or embargoes
Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business, e.g. under health and safety regulation or rules issued by our professional regulator)-
|To comply with our legal and regulatory obligations|
|Gathering and providing information required by for relating to audits, enquiries or investigations by regulatory bodies||To comply with our legal and regulatory obligations|
|Ensuring business policies are adhered to, e.g. policies covering security and internet use||For our legitimate interests or those of a third party, i.e. to make sure we are following our own internal procedures so we can deliver the best service to you|
|Operational reasons, such as improving efficiency, training and quality control||For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price|
|Ensuring the confidentiality of commercially sensitive information||
For our legitimate interests or those of a third party, i.e. to protect trade secrets and other commercially valuable information
To comply with our legal and regulatory obligations
|Statistical analysis to help us manage our business, e.g. in relation to our financial performance, customer base, product range or other efficiency measure||For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price|
|Preventing unauthorized access and modifications to systems||
For our legitimate interests or those of a third party, i.e. to prevent and detect criminal activity that could be damaging for us and for you
To comply with our legal and regulatory obligations
|Updating and enhancing customer records||
For the performance of our contract with you or to take steps at your request before entering into a contract
To comply with our legal and regulatory obligations
For our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about existing orders and new products
|Statutory returns||To comply with our legal and regulatory obligations|
|Ensuring safe working practices staff administration and assessments||
To comply with our legal and regulatory obligations
For our legitimate interests or those of a third party, e.g. to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you
Marketing our services and those of selected third parties to:
For our legitimate interests or those of a third party, i.e. to promote our business to existing and former customers.
We will use email addresses to market to existing customers who are not opening our emails to find them on Facebook and show appropriate adverts.
|Profiling and building our social demographic profile - external of our customer base||
To profile our existing customer base to ensure the marketing is going to the highest propensity to response.
For our legitimate interests or those of a third party, i.e. to ensure our prospecting marketing reaches our intended audience
|Credit reference checks via external credit reference agencies||For our legitimate interests or those of a third party, to confirm the authenticity and validity of your mailing address.|
|External audits and quality checks, e.g. for ISO or Investors in People accreditation and the audit of our accounts||For our legitimate interests or a those of a third party, i.e. to maintain our accreditations so we can demonstrate we operate at the highest standards.|
The above table does not apply to special category personal information, which we will only process with your explicit consent.
We may use your personal information to send you updates (by email, social media, Boldchat, text message, telephone or post) about our products including exclusive offers, promotions or new products.
We have a legitimate interest in processing your personal information for promotional purposes (see above 'How and why we use your personal information'). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.
We will always treat your personal information with the utmost respect You have the right to opt out of receiving promotional communications at any time by:
- contacting us at Customer Services, Orvis, Unit 4, Parnell Court, East Portway Industrial Estate, Andover, SP10 3LX
- using the 'unsubscribe' link in emails;
- self-removal from the applicable Social Media group;
- using the function on electronic adverts to remove them.
We may ask you to confirm or update your marketing preferences if you instruct us to provide further products in the future, or if there are changes in the law, regulation, or the structure of our business.
WHO WE SHARE YOUR PERSONAL INFORMATION WITH
We routinely share personal information with:
- companies within the Orvis group;
- third parties we use to help deliver our/ products to you, e.g. payment service providers, warehouses and delivery companies;
- other third parties we use to help us run our business, e.g. marketing agencies, profiling agencies, website hosts; Email and social media platforms and applications; Print Marketing and postal suppliers; repair and alteration providers;
- third parties approved by you, e.g. social media sites you choose to link your account to or third party payment providers.
We only allow our service providers to handle your personal information if we are satisfied, they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors, e.g. in relation to ISO accreditation and the audit of our accounts.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
We may also need to share some personal information with other parties, such as potential buyers of some or all our business or during a re-structuring. Usually, information will be anonymised, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
WHERE YOUR PERSONAL INFORMATION IS HELD
Information may be held at our offices and those of our, group companies, third party agencies, service providers, representatives and agents as described above (see above: 'Who we share your personal information with').
Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below: 'Transferring your personal information out of the EEA'.
HOW LONG YOUR PERSONAL INFORMATION WILL BE KEPT
We will keep your personal information while you have an account with us, or we are providing products to you. Thereafter, we will keep your personal information for as long as is necessary:
- to respond to any questions, complaints or claims made by you or on your behalf;
- to show that we treated you fairly;
- to keep records required by law.
We will not retain your personal information for longer than necessary for the purposes set out in this policy.
When it is no longer necessary to retain your personal information, we will delete or anonymise it.
TRANSFERRING PERSONAL INFORMATION OUT OF THE EEA
To deliver services to you, it is sometimes necessary for us to share your personal information outside the European Economic Area (EEA), e.g.:
- with our offices outside the EEA;
- with your service providers if you or they are based outside the EEA;
- With our service providers located outside the EEA.
These transfers are subject to special rules under European and UK data protection law.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
- Where we use certain service providers, we may 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.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
You have the following rights, which you can exercise free of charge:
|Access||The right to be provided with a copy of your personal information (the right of access)|
|Rectification||The right to require us to correct any mistakes in your personal information|
|To be forgotten||The right to require us to delete your personal information—in certain situations|
|Restriction of processing||The right to require us to restrict processing of your personal information in certain circumstances, e.g. if you contest the accuracy of the data|
|Data portability||The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to third a party—in certain situations|
The right to object:
|Not to be subject to decision making automated individual||The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you|
For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner's Office (ICO) on individuals' rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please:
- email, call or write to us see below: 'How to contact us'; and
- let us have enough information to identify you (e.g. your full name, address and customer or matter reference number);
- let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
- let us know what right you want to exercise and the information to which your request relates.
KEEPING YOUR PERSONAL INFORMATION SECURE
We have appropriate security measures to prevent personal information from being accidentally lost or used or accessed unlawfully. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.orq. Get Safe Online is supported by HM Government and leading businesses.
HOW TO COMPLAIN
We hope that can resolve any query or concern you may raise about our use of your information.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns or telephone: 0303 123 1113.
This privacy notice was published on 29th September 2020 and last updated on 14th July 2020.
We may change this privacy notice from time to time—when we do, we will inform you via our website or other means of contact such as email.
HOW TO CONTACT US
|Our contact details:|
The Orvis Company Inc. (trading as “Orvis” in the UK)
Attn: Customer Services
East Portway Industrial Estate
Telephone number: 0333 400 4188
DO YOU NEED EXTRA HELP?
If you would like this notice in another format (for example audio, large print, braille) please contact us (see 'How to contact us' above).