16th May 2018
Date of next review April 2019
WCF Ltd, Crawhall, Brampton, Cumbria, CA8 1TN (trading as The Classic Boutique) ("We", "the Company", “The Classic Boutique”) are committed to protecting and respecting the confidentiality, integrity and security of the personal information we hold about each past or present customer, enquirer or visitor to our website ("you", "your").
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us, and how we comply with our responsibilities under applicable data protection laws ("Data Protection Laws"). Please read this policy carefully and if you have any questions or concerns please contact us using the information below.
For the purposes of the Data Protection Laws, the data controller of your personal information is WCF Ltd, Crawhall, Brampton, Cumbria, CA8 1TN.
Personal data collection
We only hold personal data about you which you have provided to us or to one of our authorised data processors or has been collected via social media metadata.
Categories of personal data we may collect and hold
We may collect the following information from our customers:
Purposes for which your personal data is used
We will use the personal data which you provide to us for the following purposes:-
Legal basis for Processing
In processing customer data WCF relies on the following legal bases:
We may process customer data on more than one legal basis. Please contact us if you need details as to which legal ground we are relying on to process any specific item of personal data.
Where we rely on consent to send marketing communications, you have the right to withdraw your consent at any time by contacting our customer services department or updating your marketing preferences online.
Disclosure of your personal data
We will not disclose personal information we hold about you to any third party except as set out below.
We may disclose personal data to third parties who are providing services to us, in particular to the IT companies that support our order processing and ecommerce systems, to the mailing houses and postal services that distribute our catalogues and products and to payment processors for the purposes of order payments and refunds. We also regularly de-dupe our customer databases against the Mail Preference Service and register of deceased and gone aways to ensure that our database is as accurate as it can be and that we are not mailing those customers who do not wish to be contacted.
We may also disclose personal data we hold to third parties:
(a) in the event that we sell any business or assets, in which case we may disclose personal data we hold to the prospective buyer of such business or assets; and/or
(b) if we are permitted by law to disclose your personal data to that third party or are under a legal obligation to disclose your personal data to that third party.
Updating your marketing preferences
We have no desire to contact those customers or enquirers who do not wish to receive marketing correspondence from ourselves or carefully selected third parties. We rely on freely given, specific, informed and unambiguous statements from our customers which signifies your agreement to the processing of your personal data for marketing purposes.
If you wish to change your marketing preferences there are various ways in which you can do this:
We utilise data profiling to evaluate customer data to enable us to make predictions about an individual and group and target or personalise our postal marketing communications accordingly. Our communications are designed to tell you about the benefits we can offer so that you have exclusive access to the best deals. We use the information we hold about you to tailor the content and try to ensure that the offers are as relevant to you as possible.
Data profiling is not used for email marketing. Your personal data is only profiled if you have consented directly to receive carefully selected postal mailings from third parties, have not subsequently opted out of direct marketing and have not opted out of direct mail via the Mail Preference Service. If you do not wish to have your data profiled in this way and you have not previously opted out of receiving selected communications from third parties, then please update your marketing preferences using one of the ways outlined above in this Policy.
We work with Epsilon International UK Ltd, a company that manages the Abacus Alliance on behalf of trusted UK retail partners and Club Canvas, part of Experian Ltd. The participating retailers are active in the clothing, collectibles, food and wine, gardening, gadgets and entertainment, health and beauty, household goods and home interiors categories. They share information on what their customers buy. The data profiler analyses this pooled information to understand customer’s wider buying patterns. From this information retailers, including WCF, can tailor their communications, sending people suitable offers that should be of interest to them based on what they like to buy.
We share, swap, sell and purchase data with non-competitive trusted third-party retailers by using data co-operatives. This allows us to target our marketing to those customers who are likely to be the most responsive. Before sharing any customer data or before using any customer data acquired via a data co-operative, we would ensure that the data co-operative has undertaken appropriate due diligence to ensure that any data we sent or received for the purposes of marketing is compliant under the data protection laws.
We also share data with a small number of registered UK charities for a small fee.
Your data is only shared you have not opted out of receiving carefully selected postal mailings from third parties and you have not opted out of direct mail via the Mail Preference Service. If you do not wish to receive postal communications from carefully selected third parties, you should update your marketing preferences using one of the ways outlined above in this Policy.
Where we purchase customer data from other trusted third-party retailers for the purposes of one-off mailings, the data is deleted once the mailing has been completed unless the individual places an order and becomes a WCF customer.
Access and other rights
You may request to see the personal information we hold about you either digitally or on file at any point by making a request in writing to us via The Company Secretary, WCF Ltd, Crawhall, Brampton, Cumbria, CA8 1TN or via email on email@example.com. This request will be responded to within 30 working days. You will be provided with a copy of the personal information we hold about you. If we require more time to respond fully to any request, we will notify you in writing within the 30-day period referred to. Any additional copies of any information we provide to you may be subject to a reasonable fee.
You also have other rights under Data Protection Laws in relation to your personal data. In particular, you may have (i) the right to request that we rectify or erase information we hold about you in certain circumstances, (ii) the right to ask us to limit our processing of your information, (iii) the right (if we are processing information based on your consent, such as for marketing purposes) to withdraw your consent, (iv) the right to object to certain processing of your information (including the right to object to processing of your personal data for direct marketing purposes at any time), (v) the right to ask us to move, copy or transfer your personal information to another organisation.
If you wish to exercise any of these rights, please contact us via the Company Secretary at Crawhall, Brampton, Cumbria, CA8 1TN or via email on firstname.lastname@example.org.
Accuracy of personal data
We try to ensure that the information we hold about you is accurate and kept up-to-date and may ask you to re-confirm certain information when you place an order. However, if at any time you believe that any information we are holding about you is inaccurate, out-of-date or incomplete, please notify us in writing via Customer Services, The Classic Boutique, WCF Home Shopping, at Crawhall, Brampton, Cumbria, CA8 1TN, by calling 0330 024 1945 or via email at email@example.com as soon as possible. We will promptly correct or delete any information found to be incorrect.
We have put in place what we consider to be appropriate security measures against unlawful or unauthorised processing of the personal data we hold about you, and against the accidental loss of, or damage to, such personal data.
Transferring personal data outside the EEA
Except if appropriate safeguards are in place, we will not transfer any data to a country outside of the European Economic Area ("EEA") or to a person based outside the EEA (unless required to do so by applicable EU or member state law to which we are subject) and, in such circumstances, we shall inform you of such requirement (unless prohibited by applicable EU or member state law on important grounds of public interest). If we or one of our data processors enters into EU Standard Contractual Clauses (or their equivalent in the UK) with a third party outside the EEA to whom personal information is being transferred, this will be deemed "appropriate safeguards" for the purposes of this Policy.
Those customers living overseas should note that postal address information will be shared with the postal services to allow catalogues and parcels to be delivered.
Retention of data
We are committed to ensuring that we do not retain personal data for any longer than is necessary for the purposes for which it was obtained. As we operate no time limit product returns we hold order information indefinitely to enable us to fulfil this customer services guarantee. We also retain your marketing preferences in the event that your account is re-activated if you respond to an advertisement or marketing piece. Credit card tokens are held until expiry of the credit card.
You can update your marketing preferences at any time by using one of the methods outlined above.
Third Party Links
This 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 their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
Changes to this policy
If you have any queries about this policy or your personal data, or you wish to submit an access request or raise a complaint about the way your personal data has been handled, please do so in writing and address this to the Company Secretary, WCF Ltd, Crawhall, Brampton, Cumbria, CA8 1TN or via email on firstname.lastname@example.org.
If you are not satisfied with our response to any queries or complaints you raise with us or believe we are not processing your personal data in accordance with the Data Protection Laws you have the right to lodge a complaint at the Information Commissioner’s Office (https://ico.org.uk/).