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What comes next is the legal bit that the lawyers tell me we need on the website and it's in legal language...

  • OUR APPROACH
    • This privacy policy (“Privacy Policy”) sets out how we, CJ Cosmetics Limited a company incorporated in England and Wales under company number 11067225 with registered office address 151 Hempstead Road, Watford, United Kingdom WD17 3HF (“we”, “us” or “our”) process the personal data of our website visitors and customers in the European Union (“users”, “you” or  “your”).
    • If you have any questions about this Privacy Policy, please contact our Data Protection Compliance Manager at enquiries@cjharleyst.com.
    • By proceeding with access to the Site you are deemed to have accepted the Website Terms and Conditions www.cjharleyst.com/pages/terms (including the terms of this Privacy Policy). Please read them carefully as they affect your rights and liabilities under the law. If you do not agree with the Terms and Conditions as they apply to the Site, then please refrain from accessing or using the Site.
  • WHAT IS PERSONALLY IDENTIFIABLE INFORMATION (PII) / PERSONAL DATA?
    • Personal data or PII means any information relating to a person who can be identified either directly or indirectly; it may include name, address, email address, phone number, credit / debit card number, IP address, location data, purchase history (“Personal Data”).
  • CHANGES TO THIS PRIVACY POLICY
    • We may amend this Privacy Policy at any time. Any changes we may make will be posted on this page, so please check back frequently. Your continued use of the Site and our services after posting will constitute your acceptance of, and agreement to, any changes.
  • WHAT INFORMATION DO WE COLLECT?
    • We may collect and store the following information:
  • Information you give us. This includes:
    • Information provided to us when purchasing products through our Site, raising general enquiries or requesting further information. When you do, we may ask for your name, age, contact details to store with your account.
    • If you contact us, we may keep a record of that correspondence and/or any video or audio uploads or telephone calls.
    • Details of transactions you carry out through our Site and of the fulfilment of your orders.
    • Payment details including but not limited to the name on your bank card, the invoice address and partial card number.
    • Information we get from your use of our Site.
      • When you visit the Site we may automatically collect information about your computer or device, including your IP address, information about your visit, your browsing history, and how you use the Site, like when you view particular content on our Site or view and interact with our ads and/or content.
      • Information we generate from our Site.
        • We store information that we generate from our analysis of the data you and other users of our Site have provided and in connection with your use of our Site, such as products you have bought.
        • PURPOSES FOR WHICH WE PROCESS PERSONAL DATA
          • We will only process your Personal Data, in accordance with applicable law, for the following purposes:
            • creating and maintaining your user account, if you become our registered user;
            • handling and fulfilling your orders, requests for good or services. This may also include processing of information that we receive from third parties, for example, address data to verify your correct address;
            • offering our content or services to you in a personalised way, for example, we may provide suggestions based on your previous searches to enable you to identify suitable content quicker;
            • obtaining payment from you, if you purchase any of our products and/or services;
            • enabling our suppliers and service providers to carry out certain functions on our behalf, including payment processing, verification, technical, logistical or other functions, as may be required, in order to fulfil your orders;
            • resolving any returns, refunds or disputes, if you lawfully exercise your rights or if you wish to dispute any part of our offering;
            • sending you personalised marketing communications, where you have agreed that we may do so, in order to keep you informed of our and our selected partner’s products and services, which we consider may be of interest to you;
            • serving personalised advertising to your devices; delivering ads based on your interests ascertained from your past searches, visits of subpages and purchases on our Sites, and other data obtained through the use of "cookies" placed on your devices. Please see our Cookies statement below;
            • ensuring the security of our Site, preventing or detecting fraud or abuses of our Site, for example, by requesting verification information in order to reset your account password;
            • developing and improving our products and services, for example, by reviewing visits to our Site and its various subpages, demand for specific content, goods and services and user comments; and
            • to comply with applicable law, for example, in response to a request from a court or regulatory body, where such request is made in accordance with the law.
          • Your consent, as the data subject, to the processing as specified in this Privacy Policy is the primary legal ground for our processing of your Personal Data. However, there may be circumstances where we may also rely on other valid legal grounds for the processing of your Personal Data, such as:
            • your request for content, goods or services necessitating steps including processing of your Personal Data to be taken prior to entering into contract with you and any processing that is necessary for the performance of such contract; and
            • legitimate interests pursued by us as a business, except where such interests are overridden by your interests and fundamental rights. We will rely on this legal ground in relation to the processing set out in paragraphs 1.9 and 5.1.10, in which we have a legitimate interest; and
            • compliance with a legal obligation to which we are subject, such as, for example, the processing for the purposes set out in paragraph 1.11.

        •  DISCLOSURE OF INFORMATION
          • There are circumstances where we wish to disclose or are compelled to disclose your Personal Data to third parties. This will only take place in accordance with the applicable law and for the purposes listed above. These scenarios include disclosure:
            • to our subsidiaries, branches or associated offices;
            • to our outsourced service providers or suppliers to facilitate the provision of our services or goods to our Users, for example, the disclosure to our data centre provider for the safe keeping of your Personal Data, webhosting provider through which your Personal Data may be collected, identity verification partners in order to verify your identity against public databases;
            • to our advertising partners who enable us to deliver personalised ads to your devices or similar advertising;
            • subject to your consent, to our marketing partners, who may contact you by post, email, telephone, SMS or by other means. If you do not wish to be contacted, you may unsubscribe by contacting us at enquiries@cjharleyst.com;
            • to third party service providers and consultants in order to protect the security or integrity of our business, including our databases and systems and for business continuity reasons;
            • to another legal entity, on a temporary or permanent basis, for the purposes of a joint venture, collaboration, financing, sale, merger, reorganisation, change of legal form, dissolution or similar event. In the case of a merger or sale, your Personal Data will be permanently transferred to a successor company;
            • to public authorities where we are required by law to do so; and
            • to any other third party where you have provided your consent.
            • RETENTION OF PERSONAL DATA
              • Your Personal Data will be retained until your last use or purchase of our services or goods and normally for a period of three years thereafter, unless longer retention is required by applicable local law or where we have a legitimate and lawful purpose to do so. However, we will not retain beyond this period any of your Personal Data that is no longer required for the purposes set out in this Privacy Policy. The retention of your Personal Data will be subject to periodic review.
              • We may keep an anonymised form of your Personal Data, which will no longer refer to you, for statistical purposes without time limits, to the extent that we have a legitimate and lawful interest in doing so.
            • YOUR PERSONAL DATA AND YOUR LEGAL RIGHTS
              • Data protection law provides Data Subjects with numerous rights, including the right to: access, rectify, erase, restrict, transport, and object to the processing of, their Personal Data. Data Subjects also have the right to lodge a complaint with the relevant data protection authority if they believe that their Personal Data is not being processed in accordance with applicable data protection law.
              • Right to make subject access request (SAR). Data Subjects may, where permitted by applicable law, request copies of their Personal Data. If you would like to make a SAR, i.e. a request for copies of the Personal Data we hold about you, you may do so by writing to the Data Protection Compliance Manager whose contact details are above. The request should make clear that a SAR is being made. You may also be required to submit a proof of your identity and a fee.
              • Right to rectification. You may request that we rectify any inaccurate and/or complete any incomplete Personal Data.
              • Right to withdraw consent. You may, as permitted by applicable law, withdraw your consent to the processing of your Personal Data at any time. Such withdrawal will not affect the lawfulness of processing based on your previous consent. Please note that if you withdraw your consent, you may not be able to benefit certain service features for which the processing of your Personal Data is essential.
              • Right to object to processing, including automated processing and profiling. You may, as permitted by applicable law, request that we stop processing your Personal Data In relation to automated processing and profiling, you may object to the processing and you will have the right to obtain human intervention.
              • Right to erasure. You may request that we erase your Personal Data and we will comply, unless there is a lawful reason for not doing so. For example, there may be an overriding legitimate ground for keeping your Personal Data, such as, a legal obligation that we have to comply with, or if retention is necessary for us to comply with our legal obligations.
              • Right to data portability. In certain circumstances, you may request that we provide your Personal Data to you in a structured, commonly used and machine readable format and have it transferred to another provider of the same or similar services. This is only relevant to our where our processing of your Personal Data is based on your consent or performance of a contract and the processing is carried out by automated means. We will comply with such transfer as far as it is technically feasible. Please note that a transfer to another provider does not imply erasure of your Personal Data which may still be required for legitimate and lawful purposes.
              • Your right to lodge a complaint with the supervisory authority. We suggest that you contact us about any questions or if you have a complaint in relation to how we process your Personal Data. However, you do have the right to contact the relevant supervisory authority directly. To contact the Information Commissioner’s Office in the United Kingdom, please visit the ICO website for instructions.
            • COOKIES
              • Our Site uses cookies, which are small text files stored on a user’s computer by their web browser. We use cookies to cookies to distinguish you from other users of our Site, store information about your preferences, speed up your searches, recognise you when you return to our Site and estimate our audience size and usage pattern. This helps us to provide you with a good experience when you browse our Site and also allows us to improve our Site. For details on the specific categories of our cookies and what they are used for please see below.
              • Our use of cookies includes:
            • Strictly necessary cookies
              • These cookies enable services you have specifically asked for. For the types of cookies that are strictly necessary, no consent is required. These cookies are essential in order to enable you to move around the Site and use its features, such as accessing secure areas of the Site. Without these cookies the services you have asked for, such as shopping baskets or e-billing, cannot be provided.
            • Tracking cookies and pixels
              • Tracking cookies are used to provide information on the pages that are viewed. This information is anonymous, not shared with anyone else and used on our Site. Tracking cookies set from our Site will be predominantly from Google Analytics.
              • Tracking pixels may also be set in emails and banner display advertising to monitor the number of times that an email or banner has been seen. They are not used for any other purpose.
              • Cookies may also be set to see how well certain banners ads are received. This helps to identify how many times an advertisement has been seen, clicked on or downloaded.
              • Functionality cookies
                • These cookies remember choices you make to improve your experience. These cookies allow the Site to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customise. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites.
                • Targeting or advertising cookies
                  • These cookies collect information about your browsing habits in order to make advertising relevant to you and your interests. These cookies are used to deliver adverts more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. They remember that you have visited a website and this information is shared with other organisations such as advertisers. Quite often targeting or advertising cookies will be linked to site functionality provided by the other organisation.
                  • How do I turn off cookies?
                    • If you do not want to accept cookies, you can change your browser settings so that cookies are not accepted. If you do this, please be aware that you may lose some of the functionality of the Site. For further information about cookies and how to disable them please go to the Information Commissioner’s webpage on cookies at https://ico.org.uk/for-the-public/online/cookies/ or visit https://www.youronlinechoices.eu
                    • Consent for cookies
                      • By using this Site, navigating around it and using our services, you agree to the use of cookies. Given the nature of the cookies we use on our Site, we feel that an implied consent mechanism is appropriate and the least intrusive to our users’ experience of our Site. Please note that if you choose to reject cookies, certain parts of this site may not be available to you or may not function properly.
                    • CHILDREN
                      • Please note that this Site is not intended for children under the age of 16.
                    • LINKED WEBSITES
                      • Please note that any websites that may be linked to our Sites are subject to their own privacy policy.
                    • CONTACTING US
                      • We have endeavoured to make our terms and conditions and Privacy Policy as straightforward as possible.  However legal terms can be complicated.  If you want to get in touch regarding our services or have a general question, please contact us at: enquiries@cjharleyst.com.

                     

                    Last updated: September 2018