THE CIRCLE OF STYLE – PRIVACY POLICY

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your Personal Data. It also explains your rights in relation to your Personal Data and how to contact us or supervisory authorities in the event you have a complaint. We collect, use and are responsible for certain Personal Data about you. When we do so we are subject to the UK General Data Protection Regulation (“UK GDPR”).

OUR WEBSITE
This privacy policy relates to your use of our website which is available from: https://thecircleofstyle.com/ (our “Website”). Throughout our Website we may link to other Websites owned and operated by certain trusted third-parties to for example, make additional products and services available to you. These other third-party Websites may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to these other third-party Websites, please consult their privacy policies as appropriate.

KEY TERMS
It would be helpful to start by explaining some key terms used in this policy:

“Personal Data”Any information relating to an identified or identifiable individual
“Data Subject”The individual who the Personal Data relates to
“Special Category Personal Data”Personal Data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership Genetic and biometric data (when processed to uniquely identify an individual) Data concerning health, sex life or sexual orientation
“we”, “us”, “our”THE CIRCLE OF STYLE LIMITED, (company number: 12767249),
whose registered office is at: 18 St. Cross Street, 4th Floor, London, United Kingdom, EC1N 8UN

PERSONAL DATA WE COLLECT ABOUT YOU
We collect personal information about you when you access our Website, register with us, contact us, send us feedback, purchase items via our Website, post material to our Website and complete customer surveys or participate in competitions via our Website. We collect this personal information from you either directly, such as when you register with us, contact us or purchase products or services via our Website or indirectly, such as your browsing activity while on our Website (see ‘Cookies’ below). The Personal Data we collect about you or from you depends on the particular activities carried out through our Website. This information includes:

We collect and use this Personal Data to provide our items and services to you. If you do not provide Personal Data we ask for, it may delay or prevent us from providing our items and services to you.
We use Stripe as our payment processor: https://stripe.com/. Other than the type of payment card and last four digits of the card number, we do not record or maintain your credit card or bank account information. For more information on how payments are processed by Stripe, please refer to their privacy policy: https://stripe.com/gb/privacy.

HOW YOUR PERSONAL DATA IS COLLECTED
We collect most of this Personal Data directly from you—in person, by telephone, text or email, and/or via our Website. However, we may also collect information:HOW AND WHY WE USE YOUR PERSONAL DATA
Under data protection law, we can only use your Personal Data if we have a proper reason, e.g:A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. The table below explains what we use your Personal Data for and why.

WHAT WE USE YOUR PERSONAL DATA FOROUR REASONS
Providing products and services to youTo perform our contract with you or to take steps at your request before entering into a contract
Determining which items will suit / fit you / be the best match based on your preferenceTo perform our contract with you or to take steps at your request before entering into a contract
Preventing and detecting fraud against you or usFor our legitimate interests or those of a third party, i.e. to minimise fraud that could be damaging for you and/or us
Other activities necessary to comply with professional, legal and regulatory obligations that apply to our businessTo comply with our legal and regulatory obligations
Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodiesTo comply with our legal and regulatory obligations
Ensuring business policies are adhered to, e.g. policies covering security and internet useFor our legitimate interests or those of a third party, i.e. to make sure we are following our own internal procedures so we can deliver the best service to you
Operational reasons, such as improving efficiency, training and quality controlFor our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service to you at the best price
Ensuring the confidentiality of commercially sensitive informationFor our legitimate interests or those of a third party, i.e. to protect trade secrets and other commercially valuable information
To comply with our legal and regulatory obligations
Statistical analysis to help us manage our business, e.g. in relation to our financial performance, customer base, product range or other efficiency measuresFor our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service to you at the best price
Preventing unauthorised access and modifications to systemsFor our legitimate interests or those of a third party, i.e. to prevent and detect criminal activity that could be damaging for you and/or us
To comply with our legal and regulatory obligations
Updating customer recordsTo perform our contract with you or to take steps at your request before entering into a contract
To comply with our legal and regulatory obligations
For our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about existing orders and new products
Statutory returnsTo comply with our legal and regulatory obligations
Ensuring safe working practices, staff administration and assessmentsTo comply with our legal and regulatory obligations
For our legitimate interests or those of a third party, e.g. to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you
Marketing our services to (and the products/services of selected third parties):
—existing and former customers;
—third parties who have previously expressed an interest in our services;
—third parties with whom we have had no previous dealings.
For our legitimate interests or those of a third party, i.e. to promote our business to existing and former customers
External audits and quality checks, e.g. for the audit of our accountsFor our legitimate interests or a those of a third party, i.e. to maintain our accreditations so we can demonstrate we operate at the highest standards
To comply with our legal and regulatory obligations

Where we process Special Category Personal Data, we will also ensure we are permitted to do so under data protection laws, e.g.:

MARKETING
We may use your Personal Data to send you updates (by email, text message, telephone or post) about our items and services, including exclusive offers, promotions or new items and services. We have a legitimate interest in using your Personal Data for marketing purposes (see above ‘HOW AND WHY WE USE YOUR PERSONAL DATA’). This means we do not usually need your consent to send you marketing information. However, where consent is needed, we will ask for this separately and clearly. You have the right to opt out of receiving marketing communications at any time by:

We may ask you to confirm or update your marketing preferences if you ask us to provide further items and services in the future, or if there are changes in the law, regulation, or the structure of our business. We will always treat your Personal Data with the utmost respect and will never sell it to other organisations for marketing purposes.

WHO WE SHARE YOUR PERSONAL DATA WITH
We routinely share Personal Data with:

We only allow our service providers to handle your Personal Data if we are satisfied they take appropriate measures to protect your Personal Data. We also impose contractual obligations on service providers to ensure they can only use your Personal Data to provide services to us and to you. We may also need to:If you would like more information about who we share our data with and why, please contact us (see ‘HOW TO CONTACT US’ below).

WHERE YOUR PERSONAL DATA IS HELD
Personal data may be held at our place of business and those of our, third party agencies, service providers, representatives and agents as described above (see above: ‘WHO WE SHARE YOUR PERSONAL DATA WITH’). Some of these third parties may be based outside the UK/EEA. For more information, including on how we safeguard your Personal Data when this happens, see below: ‘TRANSFERRING YOUR PERSONAL DATA OUT OF THE UK AND EEA’.

HOW LONG YOUR PERSONAL DATA WILL BE KEPT
We will keep your Personal Data while you have an account with us or while we are providing items and services to you. Thereafter, we will keep your Personal Data for as long as is necessary:

We will not keep your Personal Data for longer than necessary. Different retention periods apply for different types of Personal Data.

TRANSFERRING YOUR PERSONAL DATA OUT OF THE UK AND EEA
To deliver services to you, it is sometimes necessary for us to share your Personal Data outside the UK/EEA, e.g: with our service providers located outside the UK/EEA. Under data protection law, we can only transfer your Personal Data to a country or international organisation outside the UK/EEA where:

These are explained below

ADEQUACY DECISION
We may transfer your Personal Data to certain countries, on the basis of an adequacy decision. These include:

The list of countries that benefit from adequacy decisions will change from time to time. We will always seek to rely on an adequacy decision, where one exists.
Other countries we are likely to transfer Personal Data to do not have the benefit of an adequacy decision. This does not necessarily mean they provide poor protection for Personal Data, but we must look at alternative grounds for transferring the Personal Data, such as ensuring appropriate safeguards are in place or relying on an exception, as explained below.

TRANSFERS WITH APPROPRIATE SAFEGUARDS
Where there is no adequacy decision, we may transfer your Personal Data to another country or international organisation if we are satisfied the transfer complies with data protection law, appropriate safeguards are in place, and enforceable rights and effective legal remedies are available for Data Subjects. The safeguards will usually include using legally-approved standard data protection contract clauses.

TRANSFERS UNDER AN EXCEPTION
In the absence of an adequacy decision or appropriate safeguards, we may transfer Personal Data to a third country or international organisation where an exception applies under relevant data protection law, e.g:

We may also transfer information for the purpose of our compelling legitimate interests, so long as those interests are not overridden by your interests, rights and freedoms. Specific conditions apply to such transfers and we will provide relevant information if and when we seek to transfer your Personal Data on this ground.

FURTHER INFORMATION
If you would like further information about data transferred outside the UK, please contact us by email:
hello@circleofstyle.com

YOUR RIGHTS
You have the following rights, which you can exercise free of charge:

AccessThe right to be provided with a copy of your Personal Data
RectificationThe right to require us to correct any mistakes in your Personal Data
Erasure (also known as the right to be forgotten)The right to require us to delete your Personal Data—in certain situations
Restriction of processingThe right to require us to restrict processing of your Personal Data in certain circumstances, e.g. if you contest the accuracy of the data
Data portabilityThe right to receive the Personal Data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third-party - in certain situations
To objectThe right to object:
—at any time to your Personal Data being processed for direct marketing (including profiling);
—in certain other situations to our continued processing of your Personal Data, e.g processing carried out for the purpose of our legitimate interests.
The right to receive the Personal Data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third-party - in certain situations
Not to be subject to automated individual decision makingThe right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

For further information on each of those rights, including the circumstances in which they apply, please contact us (see ‘HOW TO CONTACT US’ below) or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights.
If you would like to exercise any of those rights, please:

KEEPING YOUR PERSONAL DATA SECURE
We have appropriate security measures to prevent Personal Data from being accidentally lost, or used or accessed unlawfully. We limit access to your Personal Data to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

HOW TO COMPLAIN
Please contact us if you have any query or concern about our use of your information (see below ‘HOW TO CONTACT US’). We hope we will be able to resolve any issues you may have. You also have the right to lodge a complaint with the Information Commissioner or any relevant European data protection supervisory authority. The Information Commissioner may be contacted at https://ico.org.uk/make-a-complaint or telephone: 0303 123 1113.

CHANGES TO THIS PRIVACY POLICY
This privacy policy was last updated on 4 March 2021. We may change this privacy notice from time to time—when we do we will inform you via our Website or other means of contact such as email.

HOW TO CONTACT US
Individuals in the UK
You can contact us by email if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.
Our contact details are shown below:
hello@circleofstyle.com

DO YOU NEED EXTRA HELP?
If you would like this notice in another format (for example audio, large print, braille) please contact us (see ‘HOW TO CONTACT US’ above).

Copyright © The Circle of Style 2021