Privacy Policy
1. IMPORTANT INFORMATION AND WHO WE ARE
This Privacy Notice has been prepared in accordance with the General Data Protection Regulations (“GDPR”). The GDPR aims to protect and enhance the rights of data subjects. Virgin Pearl recognises the importance of the correct and lawful treatment of personal information and will only use personal data as set out in this Privacy Notice. This Privacy Notice explains in detail the types of personal data we may collect about you when you interact with us including through our websites. It also explains how we will store and handle that data and keep it safe.
We know that there is a lot of information here, but we want you to be fully informed about your rights, and how Virgin Pearl uses your data.
Our websites are not intended for children and we do not knowingly collect data relating to children.
It is important that you read this Privacy Notice together with any other privacy notice or Jewellerysavers terms and conditions we may provide on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data. This Privacy Notice supplements the other notices and is not intended to override them.
We hope the following sections will answer any questions you have but if not, please do get in touch with us.
2. THIRD-PARTY LINKS
Our websites may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our websites, we encourage you to read the privacy notice of every website you visit.
Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms and Conditions, accessible from our websites.
3. THE DATA WE COLLECT ABOUT YOU
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).
- Identity Data includes first name, maiden name, last name, username or similar identifier, title and gender.
- Contact Data includes billing address, delivery address, email address and telephone numbers.
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments to and from you.
- Technical Data includes 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 the websites.
- Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our websites, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
4. HOW WE USE YOUR PERSONAL DATA
- Where we need to perform the contract we are about to enter into or have entered into with you
- 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
- Where we need to comply with a legal or regulatory obligation
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
5. MARKETING
- We will store information relating to customers who have provided us with consent to process their personal data
- Upon customers request, we will update their preferences
6. PROMOTIONAL OFFERS FROM US
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased good or services from us or if you or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
7. DISCLOSURES OF PERSONAL DATA
- IT companies that build and monitor our websites.
- Operational companies such as packaging suppliers.
- Direct marketing companies who help us manage our electronic communications with you.
- Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way set out in this privacy notice.
- Under certain circumstances, we may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
8. PAYMENT PROCESSING
We may provide paid products and/or services within our websites. In that case, we use third-party services for payment processing.
We will not store or collect your payment card details unless you have previously given your verbal consent to do that. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.
9. INTERNATIONAL TRANSFERS
We do not transfer your personal data outside the European Economic Area (EEA).
10. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to 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.
- Encryption of credit cards details before they are saved in our database
- Access to credit cards details only given to the members of staff who are entitled to take payments
- Access to server and database subject to authentication
- Complex and secure SQL connection passwords (SQL is a standard language used to communicate with a database and thus to perform tasks such as update or retrieved data)
- We run the latest updates of the servers
- We use network security tools such as:
- Firewalls: designed to stop unauthorised traffic and filter it out
- Logwatch: a customizable log analysis system used to monitor activities in our server
- RkHunter: helps ensure that our server doesn’t get hacked by malicious exploit
- The web framework used to build our sites has built-in protection against cross site request forgery attacks
"DO NOT TRACK" SIGNALS
We do not support Do Not Track ("DNT"). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.
You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.
11. DATA RETENTION
Viggiano will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to fulfil the purposes we collected it for, including to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, enforce our legal agreements and policies and satisfying accounting or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Jewellerysavers will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.
12. YOUR LEGAL RIGHTS
An overview of your different rights
- 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.
- 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.
- 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 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 above), 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, at the time of your request.
- 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: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) 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.
13. ANY QUESTIONS?
We hope this Privacy Policy has been helpful in setting out the way we handle your personal data and your rights to control it.
If you have any questions that have not been covered, please contact our Data Protection Officer who will be pleased to help you:
Email us at info@viggianojewellery.com
Or write to us at Suite 110, 101 Clerkenwell Road, London, EC1R 5BX, United Kingdom.