Farlows Privacy & Social Media Policy
We recognise the importance of protecting the privacy of personal and financial information and have introduced strict policies and security measures to protect your information and will use the information we collect in accordance with:
- The Data Protection Act 1998.
- The Privacy and Electronic Communications (EC Directive) Regulations 2003.
- The EU General Data Protection Regulation (Regulation EU 2016/679), effective from 25th May 2018 (GDPR).
What information do we collect?
We may collect personal identification information from users in a variety of ways including, but not limited to, when users visit our site, register on the site, complete a form, subscribe to a newsletter or request a catalogue. Additionally, we may collect personal information in connection with other activities, services, features or resources we make available on our site, including the checkout facility.
The personal information we may collect, use, store and transfer includes:
1. Identity data
Includes: first name, last name, username or similar identifier, marital status, title, date of birth and gender.
2. Contact data
Includes: billing address, delivery address, email address and telephone numbers.
3. Financial data
Includes: bank account and payment card details.
4. Transaction data
Includes: details about payments to and from you and other details of products and services you have purchased from us.
5. 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 our website.
6. Profile data
Includes: your username and password, purchases or orders made by you, your interests, preferences and feedback or survey responses.
7. Usage data
Includes: information about how you use our website, products and services.
8. Marketing and communications data
Includes: your preferences in receiving marketing from us and your communication preferences. This helps us to manage our relationship with you and ensures you only receive communications from us that are relevant and timely.
Users may, however, visit and use our site anonymously.
We will collect personal identification information from users only if they voluntarily submit such information to us. Users can always refuse to supply personal identification information, except that it may prevent them from engaging in certain site related activities and it may adversely impact upon our ability to fulfil any contract we may have with that user.
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How we use collected information
Farlows collects and uses personal information for the following legitimate purposes:
1. To improve customer service
Your information helps us to respond more effectively to your customer service requests.
2. To improve our site
We continually strive to improve our websites based on the information and feedback we receive from you.
3. To process transactions
We may use the information users provide about themselves when placing an order only to service that order. We do not share this information with outside parties, except to the extent necessary to provide the service.
4. To send periodic emails:
The email address users provide for order processing will be used to send information and updates regarding their order. It may also be used to respond to any enquiries, and/or other requests or questions pertaining to the order.
If users have also specifically opted in to our mailing list, they will also receive emails that may include company news, updates and related product or service information. If at any time the user would like to unsubscribe from receiving future emails, we include unsubscribe instructions within each email, or a user may contact us via our website or the contact information provided at the end of this policy.
- This website uses the Google AdWords remarketing service to advertise on third party websites (including Google) to previous visitors to our site. This could mean that we advertise to previous visitors who haven’t completed a task on our site, for example using the contact form to make an enquiry. This could be in the form of an advertisement on the Google search results page, or a site in the Google Display Network.
- You can set preferences for how Google advertises to you using the Google Ad Preferences page.
- This website also uses the Facebook remarketing service to understand and deliver ads that are more relevant to you. We may also use this service to learn whether someone who saw an ad on Facebook later visited our website. You can find out more information on how to opt-out of the collection and use of information for ad targeting at www.aboutads.info/choices
How we protect your information and security
- We adopt appropriate data collection, storage and processing practices and security measures to safeguard all data and protect against unauthorised access, alteration, disclosure or destruction of your personal information.
- Sensitive and private data exchange between the site and its users happens over a SSL secured communication channel and is encrypted and protected with digital signatures.
- We will not transfer, process or store your data anywhere that is outside of the European Economic Area.
- However, while we take all reasonable steps to protect your personal information, you accept that no digital data transmission can be guaranteed to be secure from access by unintended recipients and will not hold us responsible for any breach of security, unless this is due to our negligence.
Third party data sharing
- We do not store payment card details and we do not share customer details with any third parties, other than those details that parties may require to assist us to fulfil your order.
- We may share client information within the Farlows and Sportfish organisation (Farlows Group Limited), including other commonly-owned brands, so that you may be informed of other products that may be of interest to you.
- Further, to maintain our website and provide our client communications, we contract with selected third parties. As necessary, your personal information may be processed by these third parties, solely for the purpose of assisting us in these endeavours and subject to strict contractual confidentiality obligations. If we are acquired by another entity, information about our clients may be made available to the new entity.
- Users may find advertising or other content on our site that links to the sites and services of our partners, suppliers, advertisers, sponsors, licensors and other third parties. We do not control the content or links that appear on these sites and are not responsible for the practices employed by websites linked to or from our site. In addition, these sites or services, including their content and links, may be constantly changing. These sites and services may have their own privacy policies and customer service policies. Browsing and interaction on any other website, including websites which have a link to our site, is subject to that website's own terms and policies.
- We will only retain your personal data for as long as is necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, warranty 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.
Your legal rights
You have rights under data protection laws in relation to your personal information, as indicated below:
1. Request access to your personal information
You have the right to request a copy of the personal information that we hold about you. Please use the contact details at the end of this policy if you would like to exercise this right, or any of the rights listed below. If you are a European citizen and consider our use of your personal information to be unlawful, you have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.
2. Request correction of your personal information
You have the right to request that we correct the personal information we hold about you if it is incorrect, although we may need to verify the accuracy of any new information you provide.
3. Request erasure of your personal information
You have the right to request that we delete or remove personal information where there is no good, or legal, reason for us continuing to process or hold it.
4. Object to processing of your personal information
You have the right to object to the processing of your personal information where we are relying on a legitimate interest (or those of a third party) if you feel it may impact on your fundamental rights and freedoms.
5. Request restriction of processing your personal information
You have the right to request that we suspend the processing of your personal information if:
- You want us to establish the information’s accuracy.
- You need us to hold the information even if we no longer require it, if you need it to establish, exercise or defend legal claims.
- You have objected to our use of your information but we need to verify if we have legitimate grounds to use it.
6. Request transfer of your personal information
You have the right to request that the personal information we hold about you is transferred to you or to a third party. This right only applies to information which you initially provided consent for us to use, or where we used the information to perform a contract with you.
7. Right to withdraw consent
In circumstances where we rely on your consent to process your personal information, you have the right to withdraw your consent at any time, but 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.
8. No fee usually required
No fee will usually be charged by us for you to access your personal information (or to exercise any other rights). However, we may charge a reasonable fee if your request is unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
9. 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 information. This is a security measure to ensure that personal information is not disclosed to any person who does not have the legal right to receive it.
10. Time limit to respond
We try to respond to all legitimate requests within one month, although it may take longer if your request is complex. In this case, we will notify you and keep you updated.
Social Media Policy
Conversations via social media happen constantly. These following points should help you when participating in social media. Have fun, be smart and use sound judgement when using social media.
Whether you are an official company representative or not, when you are talking about our company, our brands, or our business via your personal social media networks, please keep in mind these following points:
- You are personally responsible for your actions. We encourage everyone to get online, have fun and participate in conversation, but use sound judgment and common sense.
- Our companies’ policies still apply.
- Be conscientious when mixing your business and personal lives; be sure to know your work policies regarding personal use of social media while at work or on company devices.
- Be aware that we reserve the right to report and/or remove malicious or factually incorrect material regarding our brands, our company or our business.
- Comments should be related to the topic of our business or the post/page. Any material promoting other services or spam will be reported and/or removed.
- The use of obscene, threatening or harassing language is strictly prohibited.
- Personal attacks of any kind are prohibited.
- Comments or the posting of material that constitutes illegal activity or breaches copyrights or trademarks is prohibited.
Acceptance of these terms
By using this site, you signify your acceptance of this policy and terms of service. If you do not agree to this policy, please do not use our site. Your continued use of the site following the posting of changes to this policy will be deemed to be your acceptance of those changes.
Please contact us if:
- You have any questions regarding the practices of this site.
- You would like to object to any processing of your personal information that we carry out for our legitimate interests.
- You have any questions about the information we hold about you, or to change your contact preferences.
By telephone: +44 (0)207 484 1021
By email: firstname.lastname@example.org
By post: Farlows, 9 Pall Mall, London, SW1Y 5NP
Last updated 16th April 2018