Privacy notice

    1. INTRODUCTION

    This privacy notice provides you with details of how we collect and process your personal data through your use of our site https://pollywiggins.co.uk

    By providing us with your data, you warrant to us that you are over 13 years of age.

    Polly Wiggins is the data controller and we are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).

    Our contact details are:

    • Full name of legal entity: Polly Wiggins
    • Email address: polly@pollywiggins.co.uk

    If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO). If you have a complaint, please do contact us first so that we can try to resolve it for you. More information on how to make a complaint is given at the end of this notice.

    It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at polly@pollywiggins.co.uk

    1. WHAT DATA WE COLLECT ABOUT YOU, FOR WHAT PURPOSE AND ON WHAT GROUND WE PROCESS IT

    Personal data means any information capable of identifying an individual. It does not include anonymised data.

    We may process the following categories of personal data about you:

    • Communication Data that includes any communication that you send to us whether that be through the contact form on our website, through email, text, social media messaging, social media posting or any other communication that you send us. We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defence of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.
    • User Data that includes data about how you use our website and any online services together with any data that you post for publication on our website or through other online services. We process this data to operate our website and ensure relevant content is provided to you, to ensure the security of our website, to maintain back- ups of our website and/or databases and to enable publication and administration of our website, other online services and business. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business.
    • Technical Data that includes data about your use of our website and online services such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is from our analytics tracking system. We process this data to analyse your use of our website and other online services, to administer and protect our business and website, to deliver relevant website content and advertisements to you and to understand the effectiveness of our advertising. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business and to grow our business and to decide our marketing strategy.
    • Marketing Data that includes data about your preferences in receiving marketing from us and our third parties and your communication preferences. We process this data to enable you to partake in our promotions, to deliver relevant website content and advertisements to you and measure or understand the effectiveness of this advertising. Our lawful ground for this processing is our legitimate interests which in this case are to study how customers use our products/services, to develop them, to grow our business and to decide our marketing strategy.We may use User Data, Technical Data and Marketing Data to deliver relevant website content and advertisements to you (including Social Media adverts or other display advertisements) and to measure or understand the effectiveness of the advertising we serve you. Our lawful ground for this processing is legitimate interests which is to grow our business. We may also use such data to send other marketing communications to you. Our lawful ground for this processing is either consent or legitimate interests (namely to grow our business).
    • Transaction Data that may include details about payments between us and other details of purchases made by you from Polly Wiggins Careers Services. Our lawful ground for this processing is to fulfil any contract made for the purchase of goods or services. 

    Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have ordered but if we do, we will notify you at the time.

    We do not carry out automated decision making or any type of automated profiling.

    Sensitive Data

    We do not collect any Sensitive Data about you. Sensitive data refers to data that 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. We do not collect any information about criminal convictions and offences.

    Change of purpose

    We will only use your personal data for a purpose it was collected for or a reasonably compatible purpose if necessary. If we need to use your personal data for a purpose unrelated to the purpose for which we collected the data, we will notify you and we will explain the legal ground of processing.

    We may process your personal data without your knowledge or consent where this is required or permitted by law.

    1. HOW WE COLLECT YOUR PERSONAL DATA

    We collect data about you through a variety of different methods including:

    • Direct interactions: You may provide data by filling in forms on our site (or otherwise) or by communicating with us by post, phone, email or otherwise, including when you:
      • order our products or services;
      • create an account on our site;
      • subscribe to our service or publications;
      • request resources or marketing be sent to you;
      • enter a competition, prize draw, promotion or survey; or
      • give us feedback.
    • Automated technologies or interactions: As you use our site, we may automatically collect Technical Data about your equipment, browsing actions and usage patterns. We collect this data by using cookies, server logs and similar technologies. We may also receive Technical Data about you if you visit other websites that use our cookies. Please see our cookie policy for further details.
    • Third parties or publicly available sources: We may receive data from third parties such as analytics providers such as Google based outside the EU, advertising networks such as Meta based outside the EU, such as search information providers such as Google based outside the EU, providers of technical, payment and delivery services, such as data brokers or aggregators.
    1. HOW WE USE YOUR PERSONAL DATA

    We will only use your personal data when legally permitted. The most common uses of your personal data are:

    • Where we need to perform the contract between us.
    • 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 ground for processing your personal data, other than in relation to sending marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by emailing us at polly@pollywiggins.co.uk

    Marketing communications 

    You will receive marketing communications from us if you have told us you are happy to receive them. 

    You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you, or by emailing us at polly@pollywiggins.co.uk at any time.

    Where you opt out of receiving our marketing communications, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

    1. DISCLOSURES OF YOUR PERSONAL DATA

    We may have to share your personal data with the parties set out below:

    • Service providers who provide IT and system administration services.
    • Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
    • HM Revenue & Customs, regulators and other authorities based in the United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances.
    • Third parties to whom we sell, transfer, or merge parts of our business or our assets.

    We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

    1. INTERNATIONAL TRANSFERS

    Data protection laws limit our ability to transfer personal data outside the UK and countries, such as those within the European Economic Area (EEA), which are subject to an adequacy decision (i.e. the countries which are subject to the same or very similar data protection laws). This is to help ensure that a consistent level of data protection applies to your data at all stages of processing. 

    Whenever we transfer your personal data out of the UK or EEA, we do our best to ensure a similar degree of security of data 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; or
    • Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or
    • Where we use providers based in the United States, we may transfer data to them if they are part of the EU-US Data Privacy Framework.

    If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.

    1. 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 those employees, agents, contractors and other third parties who have a business need to know such data. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

    We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

    1. DATA RETENTION

    We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, 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.

    By law we have to keep basic information about our customers (including contact and transaction data) for six years after they cease being customers for tax purposes.

    In some circumstances you can ask us to delete your data: see below for further information.

    In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

    1. YOUR LEGAL RIGHTS

    Under data protection laws you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent.

    You can see more about these rights at:

    https://ico.org.uk/for-organisations/uk-gdpr-guidance-and-resources/individual-rights

    If you wish to exercise any of the rights set out above, please email us at polly@pollywiggins.co.uk

    You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

    We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

    We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

    1. 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.

    1. COOKIES

    A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

    Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

    Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

    Cookies that we use

    We use cookies for the following purposes:

    • We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google’s privacy policy is available at: https://policies.google.com/privacy 

    Cookies used by our service providers

    • Our service providers use cookies and those cookies may be stored on your computer when you visit our website. 

    Managing cookies

    You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

    1. HOW TO COMPLAIN

    If you have any concerns about our use of your personal information, you can make a data protection complaint to us:

    Email: polly@pollywiggins.co.uk

    If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO. 

    ICO helpline number: 0303 123 1113
    ICO website: https://www.ico.org.uk/make-a-complaint