Privacy Policy

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Purpose of this Privacy Policy

This Privacy Policy aims to give you information on how we collect and processes your personal data through your use of this Website, including any data you may provide through our Website when you make an enquiry, sign up to our newsletter, or purchase our goods.

It is important that you read this Privacy Policy together with any other privacy policy or fair processing notice 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 Website is not intended for children and we do not knowingly collect data relating to children.

A data controller, according to applicable data protection laws means a person who determines the purposes for which and the manner in which any personal data is to be processed. A data processor means any person (other than an employee of the data controller) who processes the data on behalf of the data controller.

We are the data controller in respect of any personal data that you share with us, (as part of your purchase of the goods that we make available for you to buy through the Website, when you register for an account, or that we collect through the Website.

If you are buying good through the Website our Terms and Conditions will apply to that transaction.

Contact us

Our full details are:

Full name of legal entity: UggBugg Fashions Ltd

Name: Data Controller

Email address: [email protected]

Postal address: Unit 2, Apollo Business Park, Apsley Grove, Ardwick, Manchester, M12 6AW.

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 chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the Privacy Policy and your duty to inform us of changes

We reserve the right to modify this Privacy Policy at any time, so please check for change notices on a regular basis. If we decide to change our Privacy Policy in a material way, we will post a prominent change notice on the Website so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. If we have a legal basis to email you (as set out below), we will also email you to tell you that we have updated this Privacy Policy)

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

If you disagree with the terms of this Privacy Policy or any updated privacy policy, you may stop using our Website.

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 policy of every website you visit.

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).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data including first name, and last name.
  • Contact Data including billing address, delivery address, email address and telephone numbers.
  • Financial Data including payment card details.
  • Transaction Data including details about payments to and from you and other details of goods 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 all data in relation to the account you create with us such as, your username and password (if applicable), and purchases or orders made by you.
  • Marketing and Communications Data including 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. 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.

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 fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

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

 

  • Direct interactions. You may give us your Identity, Contact, Profile, Marketing and Communications and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
    • purchase our goods;
    • create an account on our Website;
    • subscribe to our service or publications;
    • request marketing to be sent to you; or
    • give us some feedback.
  • Automated technologies or interactions. As you interact with our Website, we may automatically collect Technical and Usage Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our paragraph 5 for further details.

 

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:

  • 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.

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/ActivityType of dataLawful basis for processing including basis of legitimate interest
To register you as a new customer (a) Identity
(b) Contact
Performance of a contract with you
To process and deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or Privacy Policy
(b) Asking you to leave a review or take a survey
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To administer and protect our business and this Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity
(b) Contact
(c) Technical
(a) 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)
(b) 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 (a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications
(e) 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 (a) Technical 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 (a) Identity
(b) Contact
(c) Technical
(d) Profile
Necessary for our legitimate interests (to develop our products/services and grow our business)

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising, and we will only send marketing communications to you if we have your consent to do so or a legitimate interest in contacting you for such purposes. You will receive marketing communications from us if you have requested information from us and, in each case, you have not opted-out from receiving that marketing.


We may use your personal data to form a view on what we think you may want or need, or what may be of interest to you.

Promotional offers from us

We may use your Identity, Contact, Technical, Marketing and Communications 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 goods or services from us or if you provided us with your details when you enquired about our goods or service and, in each case, you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

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 contacting us. at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product purchase.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.


If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.


Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

The Website use cookies. Cookies are tiny text files which identify your computer or device to our server as a unique user when you visit certain pages on the Website and they are stored by your Internet browser on your Device’s hard drive. Cookies can be used to recognise your Internet Protocol address, saving you time while you are on the Website.

We only use cookies for your convenience in using the Website and not for obtaining or using any other information about you (for example targeted advertising). Your browser can be set to not accept cookies, but this would restrict your use of the Website.

If you want to find out more information about cookies, go to http://www.allaboutcookies.org or to find out about removing them from your browser, go to http://www.allaboutcookies.org/manage-cookies/index.html.

Please note that we collect data from the Website about use of the Website using an analysis tool which uses cookies that are (able to be) used to generate pseudonyms for a user’s profile. This means that cookies (which may be stored on your Device after you leave the App) can store information about your visit.

The Website uses the following cookies

cookie typepurpose
Google Analytics This is used to collect information about how visitors use the Sites. The cookies collect information anonymously, including the number of visitors to the Sites, where visitors have come to the Sites from and the pages they have visited. We use this information to compile reports and to help us improve the Sites.
Google AdWords This cookie is used to track visits and orders placed from advertising on Google’s search and display network. This cookie is triggered when a user visits and makes a purchase via Google’s sponsored ads and is triggered on the confirmation page
Google Tag Manager These cookies are used to collect information about how visitors use the Sites. The cookies collect information in an anonymous form, including the number of visitors to the Sites, where visitors have come to the Sites from and the pages they visited.
FRONTEND This cookie holds your session ID on the server.
CUSTOMER This cookie is an encrypted version of the customer ID within the store.
CUSTOMER_INFO This cookie is an encrypted version of the customer group the customer belongs to.
CUSTOMER_AUTH This cookie tells us if you are currently logged on to the store.
Facebook Facebook use cookies. These are used to anonymously record that a user has clicked on a Facebook add link that referred the user to the Sites.

We may have to share your personal data with the external third-parties set out below for the purposes set out in the table in paragraph 4:

  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.
  • HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
  • The following service providers acting as processors who provide us with services:
    • UKFast.Net Limited, whose hosting services we use.
    • One Creations Software (Pvt) Ltd and Magento Inc, who service we utilise to provide our shopping cart system on the Website.
    • The following providers of delivery and courier services that we use to deliver goods that you purchase using the Website:
      • Royal Mail PLC;
      • Yodel Delivery Network Limited;
      • wnDirect Limited; and
      • DHL International GmbH.
    • The following providers of marketing services:
      • Bronto;
      • Trustpilot Ltd;
      • Webgains Limited;
      • The Beans Group Limited;
      • Klevu.
    • The following providers of warehouse management:
      • Veeqo Limited; and
      • Peoplevox Ltd.

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 as set out in this Privacy Policy. 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.

We may transfer your personal data outside the European Economic Area (the “EEA”).

Many of our external third parties are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it 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. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
  • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

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. 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.

How long will you use my personal data for? 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.

Details of retention periods for different aspects of your personal data are available upon request by contacting us.

In some circumstances you can ask us to delete your data: see paragraph 10 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.

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

(1) To request access to personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data held about you and to check that we are lawfully processing it
(2) To request correction of the personal data that we hold. This enables the correction of any incomplete or inaccurate data we hold, though we may need to verify the accuracy of the new data provided to us.
(3) To request erasure of personal data. This enables the deletion or removal personal data where there is no good reason for us continuing to process it. A request can also be made for deletion or removal of personal data where the right to object to processing has been successfully exercised (see below), where we may have processed information unlawfully or where we are required to erase personal data to comply with local law. Note, however, that we may not always be able to comply with requests of erasure for specific legal reasons with notification of this given, if applicable, at the time of any request.
(4) To object to processing of 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 personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process information which overrides your rights and freedoms.
(5) To request restriction of processing of personal data. This enables a request to be made to us to suspend the processing of 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 because it is needed to establish, exercise or defend legal claims; or (d) you objected to use of data but we need to verify whether we have overriding legitimate grounds to use it.
(6) To request the transfer of personal data back to whom it belongs 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 we were given consent to use.
(7) To withdraw consent at any time where we are relying on consent to process personal data. However, this will not affect the lawfulness of any processing carried out before the withdrawal of consent. If consent is withdrawn, we will not be able to provide our services. We will advise you of this at the time of the withdrawal of consent.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

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.

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 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.

Time limit to respond

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.

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Consent means processing your personal data on the basis that you have specifically authorised us to do so. You are able to withdraw your consent at any time.