Protecting your privacy
Shimitu Ltd
Contents of this Privacy Notice
1. Introduction.
2. Who is Shimitu Ltd?
3. Explaining the legal bases we rely on.
4. When do we collect your personal data?
5. What sort of personal data do we collect?
6. How and why do we use your personal data?
7. Combining your data for personalised direct marketing.
8. How we protect your personal data.
9. How long will we keep your personal data?
10. Who do we share your personal data with?
11. Where your personal data may be processed.
12. What are your rights over your personal data?
13. How can you stop the use of your personal data for direct marketing?
14. If you live outside the UK
15. Any questions?
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1. Introduction
This Privacy Notice explains in detail the types of personal data we may collect about you when you interact with us.
It also explains how we’ll store and handle that data and keep it safe.
We know that there’s a lot of information here, but we want you to be fully informed about your rights, and how Shimitu Ltd uses your data.
We hope the following sections will answer any questions you have but if not, please do get in touch with us.
It’s likely that we’ll need to update this Privacy Notice from time to time. We’ll notify you of any significant changes via email, but you’re welcome to come back and check it whenever you wish.
When you are using the Shimitu websites, Shimitu Ltd is the data controller.
This Privacy Notice applies to international orders, however there are additional terms for certain countries which supplement this notice and take priority over any conflicting provisions. You’ll find more information in section 14.
For simplicity throughout this notice, ‘we’ and ‘us’ means Shimitu ltd and its brands.
2. Who is Shimitu?
Shimitu Ltd is a company registered in England and Wales Number: 13879471 At: 61 Bridge Street, Kington HR5 3DJ, United Kingdom.
3. Explaining the legal bases we rely on.
The law on data protection sets out several different reasons for which a company may collect and process your personal data, including:
Consent
In specific situations, we can collect and process your data with your consent.
For example, when you tick a box to receive email newsletters.
When collecting your personal data, we’ll always make clear which data is necessary in connection with a particular service.
Contractual obligations
In certain circumstances, we need your personal data to comply with our contractual obligations.
For example, if you order an item from us for home delivery, we’ll collect your address details to deliver your purchase and pass them to our courier.
Legal compliance
If the law requires us to, we may need to collect and process your data.
For example, we can pass on details of people involved in fraud or other criminal activity affecting Shimitu to law enforcement .
Legitimate interest
In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business, and which does not materially impact your rights, freedom or interests.
For example, we will use your purchase history to send you or make available personalised offers.
We also combine the shopping history of many customers to identify trends and ensure we can keep up with demand or develop new products/services.
We may also use your address details to send you direct marketing information by post, telling you about products and services that we think might interest you.
We may contact you regarding market research.
4. When do we collect your personal data?
● When you visit any of our websites, and use your account to buy products and services.
● When you make an online purchase and check out as a guest (in which case we just collect transaction-based data).
● When you create an account with us.
● When you engage with us on social media.
● When you join a Shimitu loyalty programme.
● When you contact us by any means with queries, complaints etc.
● When you ask one of our Partners to email you information about a product
or service.
● When you enter prize draws or competitions.
● When you book any kind of appointment with us or book to attend an event.
● When you choose to complete any surveys, we send you.
● When you comment on or review our products and services. Any individual may access personal data related to them, including opinions.
● When you fill in any forms.
● When you’ve given a third-party permission to share with us the information they hold about you.
● We collect data from publicly available sources when you have given your consent to share information or where the information is made public as a matter of law.
5. What sort of personal data do we collect?
● If you have a web account with us: your name, gender, date of birth, billing/delivery address, orders and receipts, email and telephone number.
For your security, we’ll also keep an encrypted record of your login password.
● Details of your interactions with us through contact centres and online.
For example, we collect notes from our conversations with you, details of any complaints or comments you make, details of purchases you made, items viewed or added to your basket, gift list and wish list choices, voucher redemptions, brands you show interest in, web pages you visit and how and when you contact us.
● Details of your shopping preferences.
● Details of your visits to our websites.
● Information gathered using cookies in your web browser.
● Open rates, click through rates on email marketing campaigns using Pixels.
● Personal details which help us to recommend items of interest.
We’ll only ask for and use your personal data collected for recommending items of interest and to tailor your shopping experience with us. Of course, it’s always your choice whether you share such details with us.
● Payment card information.
● Your comments and product reviews.
● To deliver the best possible web experience, we collect technical information about your internet connection and browser as well as the country and telephone code where your computer is located, the web pages viewed during your visit, the advertisements you clicked on, and any search terms you entered.
● Your social media username, if you interact with us through those channels, to help us respond to your comments, questions or feedback.
6. How and why we use your personal data?
We want to give you the best possible customer experience. One way to achieve that is to get the richest picture we can of who you are by combining the data we have about you.
We then use this to offer you promotions, products and services that are most likely to interest you. In the case of loyalty scheme members, we’ll also offer you relevant rewards.
The data privacy law allows this as part of our legitimate interest in understanding our customers and providing the highest levels of service. Of course, if you wish to change how we use your data, you’ll find details in the ‘What are my rights?’ section below.
Remember, if you choose not to share your personal data with us, or refuse certain contact permissions, we might not be able to provide some services you’ve asked for.
For example, if you’ve asked us to let you know when an item comes back into stock, we can’t do that if you’ve withdrawn your general consent to hear from us.
Here’s how we’ll use your personal data and why:
● To process any orders that you make by using our websites. If we don’t collect your personal data during checkout, we won’t be able to process your order and comply with our legal obligations.
For example, your details may need to be passed to a third party to supply or deliver the product or service that you ordered, and we may keep your details for a reasonable period afterwards in order to fulfil any contractual obligations such as refunds, guarantees and so on.
● To respond to your queries, refund requests and complaints. Handling the information you sent enables us to respond. We may also keep a record of these to inform any future communication with us and to demonstrate how we communicated with you throughout. We do this based on our contractual obligations to you, our legal obligations and our legitimate interests in providing you with the best service and understanding how we can improve our service based on your experience.
● To protect our business and your account from fraud and other illegal activities. This includes using your personal data to maintain, update and safeguard your account. We’ll also monitor your browsing activity with us to quickly identify and resolve any problems and protect the integrity of our websites. We’ll do all of this as part of our legitimate interest.
For example, by checking your password when you login and using automated monitoring of IP addresses to identify possible fraudulent logins from unexpected locations.
● To process payments and to prevent fraudulent transactions. We do this based on our legitimate business interests. This also helps to protect our customers from fraud.
● If we discover any criminal activity or alleged criminal activity through our use of fraud monitoring and suspicious transaction monitoring, we will process this data for the purposes of preventing or detecting unlawful acts. We aim is to protect the individuals we interact with from criminal activities.
● With your consent, we will use your personal data, preferences and details of your transactions to keep you informed by email, web, text, telephone and through our contact centres about relevant products and services including tailored special offers, discounts, promotions, events, competitions and so on. This is only applicable within the UK. Of course, you are free to opt out of hearing from us by any of these channels at any time.
● To send you communications required by law, or which are necessary to inform you about our changes to the services we provide you. For example, updates to this Privacy Notice, product recall notices, and legally required information relating to your orders. These service messages will not include any promotional content and do not require prior consent when sent by email or text message. If we do not use your personal data for these purposes, we would be unable to comply with our legal obligations.
● To display the most interesting content to you on our websites, we’ll use data we hold about your favourite products and so on. We do so, based on your consent to receive notifications and / or for our website to place cookies or similar technology on your device. For example, we might display a list of items you’ve recently looked at or offer you recommendations based on your purchase history and any other data you’ve shared with us.
● To develop, test and improve the systems, services and products we provide to you. We’ll do this based on our legitimate business interests.
● To comply with our contractual or legal obligations to share data with law enforcement.
● To send you survey and feedback requests to help improve our services. These messages will not include any promotional content and do not require prior consent when sent by email or text message. We have a legitimate interest to do so as this helps make our products or services more relevant to you.
● To build a rich picture of who you are and what you like, and to inform our business decisions, we’ll combine data captured from Shimitu, third parties and data from publicly available lists as we have described in the section What Sort of Personal Data do we collect?
● To ensure that all your purchases are correctly assigned to you we track your payment card token id, this is an id given to your debit or credit card by the banking industry we do this whether you have logged into your account or check out as a guest.
7. Combining your data for personalised direct marketing.
We want to bring you offers and promotions that are most relevant to your interests at times. To help us form a better, overall understanding of you as a customer, we combine your personal data gathered as described above. For this purpose, we also combine the data that we collect directly from you with data that we obtain from third parties to whom you have given your consent to pass that data onto us.
8. How we protect your personal data.
We know how much data security matters to all our customers. We will treat your data with the utmost care and take all appropriate steps to protect it. We secure access to all transactional areas of our websites and apps using ‘https’ technology. Access to your personal data is password-protected, and sensitive data such as payment card information is secured and encrypted to ensure it is fully protected. We regularly monitor our system for possible vulnerabilities and attacks.
9. How long will we keep your personal data?
Whenever we collect or process your personal data, we’ll only keep it for as long as is necessary for the purpose for which it was collected. At the end of that retention period, your data will either be deleted completely or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning.
Some examples of customer data retention periods:
Orders
When you place an order, we’ll keep the personal data you give us for five years so we can comply with our legal and contractual obligations.
If your order included a warranty, the associated personal data will be kept until the
end of the warranty period.
10. Who do we share your personal data with?
We sometimes share your personal data with trusted third parties.
For example, delivery couriers, for fraud management, to handle complaints and to help us personalise our offers to you and so on.
Here’s the policy we apply to those organisations to keep your data safe and protect your privacy:
● We provide only the information they need to perform their specific services.
● They may only use your data for the exact purposes we specify in our contract with them.
● We work closely with them to ensure that your privacy is respected and always protected.
● If we stop using their services, any of your data held by them will either be deleted or rendered anonymous.
Examples of the kind of third parties we work with are:
● IT companies who support our website and other business systems.
● Operational companies such as delivery couriers to contact you about your order delivery & occasionally service review messages.
● Direct marketing companies who help us manage our electronic communications with you.
● Data insight companies to ensure your details are up to date and accurate.
Sharing your data with third parties for their own purposes:
We will only do this in very specific circumstances, for example:
● For fraud management, we may share information about fraudulent or potentially fraudulent activity in our premises or systems. This may include sharing data about individuals with law enforcement bodies.
● We may also be required to disclose your personal data to the police or other enforcement, regulatory or Government body, in your country of origin or elsewhere, upon a valid request to do so. These requests are assessed on a case-by-case basis and take the privacy of our customers into consideration.
● We may, from time to time, expand, reduce or sell Shimitu and this may involve the transfer of divisions or the whole business to new owners. If this happens, your personal data will, where relevant, be transferred to the new owner or controlling party, under the terms of this Privacy Notice.
For further information please contact our Data Protection Officer.
11. Where your personal data may be processed.
Shimitu Ltd processes your data in the UK and the USA which are outside of the EU. We may also need to share your personal data with third parties and suppliers outside the European Economic Area (EEA)
Protecting your data outside the UK
The EEA includes all EU Member countries as well as Iceland, Liechtenstein and Norway.
We may transfer personal data that we collect from you to third-party data processors in countries that are outside the UK. For example, this might be required in order to fulfil your order, process your payment details or provide support services.
If we do this, we have procedures in place to ensure your data receives the same protection as if it were being processed in the UK. For example, our contracts with third parties stipulate the standards they must always follow. If you wish for more information about these contracts, please contact our Data Protection Officer. Any transfer of your personal data will follow applicable laws and we will treat the information under the guiding principles of this Privacy Notice.
12. What are your rights over your personal data?
An overview of your different rights
You have the right to request:
● Access to the personal data we hold about you, free of charge in most cases.
● The correction of your personal data when incorrect, out of date or incomplete.
● The deletion of the data we hold about you, in specific circumstances. For example, when you withdraw consent, or object and we have no legitimate overriding interest, or once the purpose for which we hold the data has come to an end.
● Restriction of the use of your personal data, in specific circumstances, generally whilst we are deciding on an objection you have made.
● That we stop processing your personal data, in specific circumstances. For example, when you have withdrawn consent, or object for reasons related to your individual circumstances.
● That we stop using your personal data for direct marketing (either through specific channels, or all channels).
● That we stop any consent-based processing of your personal data after you withdraw that consent.
You can contact us to request to exercise these rights at any time. If we choose not to action your request, we will explain to you the reasons for our refusal.
Your right to withdraw consent.
Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent.
Where we rely on our legitimate interest
In cases where we are processing your personal data based on our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.
Direct marketing
You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We must always comply with your request.
Checking your identity
To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Notice. If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.
13. How can you stop the use of your personal data for direct marketing?
There are several ways you can stop direct marketing communications from us:
● Click the ‘unsubscribe’ link in any email communication that we send you. We will then stop any further emails from that division.
● If you have an account, log in and visit the ‘My Account’ area and change your preferences.
14. If you live outside the UK
For all non-UK customers:
When placing an order with Shimitu, browsing our website, including for analytics and website usage research, and/or agreeing to receive direct marketing electronic communications as described in this Privacy Notice and our Cookies Policy. Your personal data will be processed by us or on our behalf. Of course, you still have the right to ask us not to process your data in these ways, and if you do so, we will respect your wishes.
Sometimes we will need to transfer your personal data between countries to enable us to supply the goods or services you have requested. In the ordinary course of business, we will transfer your personal data to the UK and the USA. We may also transfer your personal data to third parties located in the UK to your country of residence. We shall endeavour to ensure that reasonable steps are taken to procure that all such third parties outside of your country of residence shall not use your personal data other than for the services they provide and for which they need the personal
data, and to adequately protect the confidentiality and privacy of your personal data.
We will ensure that any third parties only process your personal data in accordance with their legitimate interests. These third parties may be subject to laws that differ from the laws which apply in the country where you reside. We do not actively take steps to ensure that any overseas recipient of your personal data complies with the laws which apply in your country.
If you have any questions, please contact our Data Protection Officer, and we will respond within your local timeframe response requirements. To complain about an alleged breach of this Privacy Notice or our privacy obligations at law, please provide us with as much detail as possible in relation to your complaint. We will take any privacy complaint seriously and any complaint will be assessed with the aim of resolving any issue in a timely and efficient manner.
15. Any questions?
We hope this Privacy Notice has been helpful in setting out the way we handle your personal data and your rights to control it.
If you have any questions that haven’t been covered, please contact our Data Protection Officer who will be pleased to help you:
Email us at: dataprotect@shimitu.com or write to us at: Data Protection Officer, Shimitu Ltd., 61 Bridge Street, Kington HR5 3DJ, United Kingdom.
This notice was last updated on 10 February 2022.