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You have the right to object to us processing your personal data on the basis of our legitimate interests or for direct marketing purposes (including any related profiling we do to help ensure that our marketing is relevant to your interests). For more information about your right to object and how you can exercise it, see the section Your privacy rights.
We are the “data controller” of your personal data, which means that we determine the purposes and the means of use of the personal data we collect about you for the purposes of applicable data protection law (which includes the General Data Protection Regulation 2016 or “GDPR”).
Personal data is any information which identifies you personally whether directly (for example, your name) or indirectly (for example, information about your use of our website, products and services).
We collect the following personal data about you:
We use the data described above for the purposes set out in the How we use your personal data section below.
We use your personal data for the following purposes:
To process your orders and returns
We use your personal data to process any orders and returns you make in accordance with our terms and conditions.
To manage and administer your account
If you create an account with us, we use your personal data to identify you as a new or returning customer, and to manage and administer your account. This includes keeping a record of your account login details (such as your username) in case you need reminding of these in the future.
To communicate with you about your orders and the services we provide to you
To deliver direct marketing (involving profiling to tailor our communications to your interests)
Our marketing communications
Where you have given your consent or where we have a justifiable reason for doing so (and are permitted to do so by law – see further below), we will use your contact details to send you marketing communications by email and post about Rohan products, services, special offers, promotions, competitions and events that we think may be of interest to you.
You can unsubscribe or opt out of receiving our marketing communications at any time by:
If we collect your contact details in the course of you purchasing any products from us, provided you have not opted out, we are permitted by law to send you emails about similar products and services we offer. We may also send you post. We will always give you the option to opt out of receiving this information from us at the time we collect your contact details. Even if you don’t opt out at that stage, you can always choose to opt out at a later stage by following the steps above.
Our use of profiling to send tailored marketing communications
We want to ensure that the marketing communications we send to you are relevant to your interests. Consequently, we undertake analysis and profiling of the information you provide to us as well as your purchase history and other information we collect about how you use our website and services. This information helps us build a profile of you, meaning that if you sign up to receive marketing communications from us, you are more likely to receive information about Rohan products, services, special offers, promotions, competitions and events that we think are more relevant to you and your interests. It also means that we don’t send the same marketing communications to all of our customers, so you may not receive the same offers as another customer.
The legal ground for us using profiling to tailor our marketing communications to your interests is that it is in our legitimate interests to do so, having taken into account whether your interests and fundamental rights and freedoms are overridden by this type of processing. See Legal grounds for using your personal data for more information about our legitimate interests. If you don’t agree with us using profiling for this purpose, you can let us know (see How you can contact us). If you do object, we won't be able to continue to send you tailored marketing communications, which means you will receive less information from us and the information you receive from us may not be as relevant to you.
Email interaction technology
To manage, administer and improve our website and deliver relevant online advertising
We also use the information we collect about you based on your use of our website and services to:
To provide and improve customer support
We use your personal data to be able to provide and improve the customer support we provide to you (for example, where you have questions about our products and services or to assist you in locating our stores).
To run our competitions
If you choose to enter a competition that we run, we need to use your contact details and any other personal data that you provide at the time of entry so that we can manage the competition and let you know if you've won! If we ask for any other personal data as part of the competition, we will let you know at the time of entry exactly how we will use it.>
To respond to communications or enquiries from you, and address complaints and disputes
We use the personal data we hold about you to help us respond to any enquiries or complaints you have made, or address any dispute which may arise in the course of us providing our products and services to you.
Please note that if you contact us through a social media platform, please see the privacy statements of the social media platforms you use for details of how they use your personal data, who they share it with and how you can manage your privacy settings with them.
To conduct market research
We may invite you to be involved in market research. If you accept our invitation, we will use your feedback to improve our website and the products and services available through it. If you tell us that you don't want to be contacted for this purpose, or you don't accept our invitation, we will respect this choice and it won't affect your ability to access and use our website or interact with us in other ways.
To provide other services requested by you from time to time
We process your personal data to provide any other services requested by you from time to time, as described at the time we collect the data.
To maintain our records and improve data accuracy
We process personal data in the course of maintaining and administering our internal records. This includes processing your personal data to ensure that the information we hold about you is kept up to date and accurate. To help us achieve this, from time to time we may allow a third party analytics provider, Experian Ltd, to access certain records we hold about you (for example, your contact details) to check whether the information is still valid.
To conduct business analytics and reporting
We may aggregate the data we hold about you on an anonymous basis with other data for analytical and reporting purposes.
To comply with our legal obligations and to detect, prevent and investigate other actual or suspected violations of law or misuse of our website
In certain circumstances, we use your personal data only to the extent required in order to enable us to comply with our legal obligations, including to detect, prevent and investigate fraud or to facilitate the exercise of your consumer rights. In addition, we may need to use your personal data to detect, prevent and investigate any other actual or suspected violations of law or misuse of our website.
Applicable data protection law requires us to only process your personal data if we satisfy one or more legal grounds. These are set out in law and we rely on a number of different grounds for the processing we carry out, depending on the purposes of the processing. These are as follows:
Necessary for the performance of a contract and to comply with our legal obligations
Much of the personal data we collect about you is necessary for the performance of certain contracts between us. This includes most of the information you provide to us when completing transactions with us, creating an account on our website, or entering any competitions that we run from time to time, in order that we can comply with our terms and conditions for the use of our website, for the sale of our products and for the operation of any competitions.
In certain circumstances, we also use your personal data only to the extent required in order to enable us to comply with our legal obligations, including to detect, prevent and investigate fraud or to facilitate the exercise of your consumer rights.
Necessary for the purposes of our legitimate interests
It is sometimes necessary to collect and use your personal data for the purposes of our legitimate interests as a business, which are to:
To help us achieve these outcomes, we profile your personal data, including by combining the data we collect about how you use our website and services with other information we hold about you.
Please note that where we wish to rely on this legal ground, we are required by law to conduct balancing tests to determine whether our legitimate interests are overridden by your interests or your fundamental rights and freedoms. We may continue to process your personal data on the basis of our legitimate interests only if we determine that your interests, rights and freedoms are not overridden by our legitimate interests.
We have considered these matters and where we think there is a risk that your interests or fundamental rights and freedoms may be affected we will not process your personal data unless there is another legal ground for us to do so (either that we have obtained your consent to the processing or it is necessary for us to perform our contract with you or to comply with our legal obligations).
Please contact us if you would like further information regarding our balancing tests (see How you can contact us).
In certain limited circumstances, we also process your personal data after obtaining your consent to do so for the purposes of:
You don’t have to provide your consent, and can withdraw it at any time.
We may from time to time need to disclose your personal data to third parties in order to provide you with our services and ensure the effective operation of our website and Rohan retail stores. The providers of such services are granted access to certain personal data to the extent necessary for them to perform the services that we request. Any personal data that is processed by third parties must be processed in accordance with applicable data protection law and subject to contractual obligations, including regarding security and confidentiality. The third parties are:
We may also disclose your personal data:
Additionally, where you have consented to cookies:
The personal data we collect about you is stored by us on secure servers located within the European Economic Area (“EEA”) and processed by us in the UK.
We do this by ensuring that at least one of the following safeguards is implemented:
Please contact us if you would like more information about the countries to which your personal data is transferred and the specific safeguards that are used to protect your personal data when it is transferred outside the EEA (see How you can contact us).
We retain your personal data for no longer than is necessary for the purpose(s) for which it was collected. What this means in practice will vary between different types of data. When determining the relevant retention periods, we take into account factors including:
Otherwise, we securely erase your personal data from our systems when it is no longer needed.
The table in this section below explains what rights you have with regard to your personal data. These rights are not absolute and are subject to certain exceptions and qualifications.
For more information about your rights or if you would like to exercise any of your rights, you are welcome to contact us using the contact details set out below under How you can contact us.
Please note that if you ask us to stop using your personal data in a certain way or erase your personal data, and this type of use or personal data is required by us in order to facilitate your use of our website or services in any way, you may not be able to use our website or services as you did before. This does not include your right to withdraw your consent to receiving marketing communications from us, which you can do so at any time without restriction.
This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the erasure of the personal data that we hold about you where:
This is not a general right to erasure; there are exceptions. For example, we have the right to continue using your personal data if such use is necessary for compliance with our legal obligations or for the establishment, exercise or defence of legal claims.
You have the right to restrict further processing of your personal data where:
You have the right to object to processing in the following circumstances:
If you would like to exercise your privacy rights or if you are unhappy with how we have handled your personal data, please contact us by:
If you’re not satisfied with our response to any enquiry or complaint or believe our use of your personal data does not comply with applicable data protection law, you can make a complaint to the Information Commissioner’s Office (ICO) by:
We do not knowingly collect personal data from children under the age of 16. If you become aware that your child or any child for which you have parental responsibility has provided their personal data to us without your consent, please contact us using the contact details set out above under How you can contact us.
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