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Privacy Policy

Introduction

Welcome to STW Group Limited’s privacy policy
STW Group Limited respects your privacy and is committed to protecting your personal data. This privacy policy tells you how we look after your personal data, including when you visit our website (regardless of where you visit it from) and about your privacy rights and how the law protects you.


Important information and who we are

Purpose of this privacy policy
This privacy policy aims to tell you how STW Group Limited collects and processes your personal data, including any data you may provide through our website, when you sign up for our newsletter, purchase a product or take part in a competition.

This website is not intended for children, however, we may collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy 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 policy supplements other notices and privacy policies and is not intended to override them.

Controller
STW Group Limited is the controller and responsible for this website.

This privacy policy is issued on behalf of Viktor and Eugenie – a brand belonging to STW Group Limited. When we mention “STW Group”, “we”, “us” or “our”, we are referring to the Viktor and Eugenie brand.

Contact Details
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about it, including any requests to exercise your legal rights, please contact the data privacy manager using one of the following ways:
Email address: enquiries@viktorandeugenie.com
Postal address: 207 Regent Street, London, W1B 3HH
Telephone number: +44 (0) 20 3930 3141

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 opportunity to deal with your concerns before you approach the ICO and so please contact us first.

Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review. This version was last updated on 28/10/2020

It is important that the personal data we hold about you is accurate and current. Please tell us if your personal data changes during your relationship with us or alternatively you can amend your details by logging onto your account on the ‘Sign In’ section of our site.

Third-party links
Our website 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 what they do with your personal data. When you leave our website, we encourage you to read the privacy policy of every website you visit.


The data we collect about you

Personal data, or personal information, means any information about an individual from which they can be identified. It does not include data where the identity has been removed (anonymous data).

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, maiden name, last name, username or similar identifier, marital status, title, date of birth, 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 and other details of the products 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.
  • 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 website and products.
  • 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 the purpose of carrying out our business. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data will 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 and that 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 offenses.

If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you do not provide that data when requested, we may not be able to perform the contract we have, or are trying to make, with you (for example, to provide you with goods). In this case, we may have to cancel an order which you have placed with us but we will notify you if this is the case at
the time.


How is your personal data collected?

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your Identity, Contact, and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes the personal data you provide when you:
    •  apply for our products;
    • create an account on our website;
    • subscribe to our publications;
    • request marketing to be sent to you;
    • enter a competition, promotion, or survey; or
    • give us some feedback.
  • Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies, server logs, and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.
  • Third parties or publicly available sources. We will receive personal data about you from third parties and public sources as set out below.
    • Technical Data from the following parties:
    • analytics providers such as Google who may be based outside the UK;
    • advertising networks such as Amazon SES, Survey Monkey, Facebook, Twitter, Instagram based inside and outside the UK; and
    • search information providers who may be based outside the UK.
  • Contact, Financial and Transaction Data from providers of technical, payment, and delivery services who may be based outside the UK.
  • Identity and Contact Data from social media platforms and data brokers or aggregators who may be based outside the UK.
  • Identity and Contact Data from publicly available sources based in the UK such as Companies House and the Electoral Register.

How we use your personal data

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:

  • When 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 although we will get your consent before sending third-party direct marketing communications to you via email or text message. You have the right to withdraw consent to our direct marketing at any time by contacting us.

Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.

Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you as a new customer
  1. Identity
  2. Contact
Performance of a contract with you

To process and deliver your order including:

  1. Manage payments, fees and charges
  2. Collect and recover money owed to us
  1. Identity
  2. Contact
  3. Financial
  4. Transaction
  5. Marketing and Communications
  1. Performance of a contract with you
  2. Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you which will include:

  1. Notifying you about changes to our terms or privacy policy
  2. Asking you to leave a review or take a survey
  1. Identity
  2. Contact
  3. Profile
  4. Marketing and Communications
  1. Performance of a contract with you
  2. Necessary to comply with a legal obligation
  3. Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to partake in a prize draw, competition or complete a survey
  1. Identity
  2. Contact
  3. Profile
  4. Usage
  5. Marketing and Communications
  1. Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
  1. Identity
  2. Contact
  3. Technical
  1. Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
  2. Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
  1. Identity
  2. Contact
  3. Profile
  4. Usage
  5. Marketing and Communications
  6. Technical
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
  1. Technical
  2. Usage
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you
  1. Identity
  2. Contact
  3. Technical
  4. Usage
  5. Profile
  6. Marketing and Communications
Necessary for our legitimate interests (to develop our products/services and grow our business)
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