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Privacy and Cookie Policy

 

INTRODUCTION 

Welcome to the Radley + Co Limited privacy notice.

Radley + Co respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) or when you visit any of our stores and tell you about your privacy rights and how the law protects you.

This privacy notice is provided in a layered format so you can click through to the specific areas set out below.  Please also use the Glossary at the back of the notice to understand the meaning of some of the terms used in this privacy notice.

This privacy notice will be updated from time to time as and when we make changes in our approach.  We will update the date on our privacy notice whenever we make changes and would encourage you to revisit it from time to time to stay up to date.  This version was last updated on 14.01.22 and historic versions can be obtained by contacting us.

1. [IMPORTANT INFORMATION AND WHO WE ARE]

2. [THE DATA WE COLLECT ABOUT YOU]

3. [HOW IS YOUR PERSONAL DATA COLLECTED]

4. [HOW WE USE YOUR PERSONAL DATA]

5. [DISCLOSURES OF YOUR PERSONAL DATA]

6. [INTERNATIONAL TRANSFERS]

7. [DATA SECURITY]

8. [DATA RETENTION]

9. [YOUR LEGAL RIGHTS]

10. [UNITED STATES SECTION]

11. [GLOSSARY]


1.  IMPORTANT INFORMATION AND WHO WE ARE 

PURPOSE OF THIS PRIVACY NOTICE 

This privacy notice aims to give you information on how Radley + Co collects and processes your personal data through your use of our website, your use of our stores, or your participation in a Radley + Co event, including any data you may provide when you sign up to our newsletter, purchase a product or service or take part in a competition.

This website is not intended for children and we do not knowingly collect data relating to children.

CONTROLLER 

Radley + Co Limited is the controller and responsible for your personal data (referred to as “Radley + Co”, “we”, “us” or “our” in this privacy notice).

We have appointed a Data Privacy Manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the Data Privacy Manager using the details set out below.

CONTACT DETAILS 

You can contact our Data Privacy Manager at:

Post:

Radley + Co Limited

Etheridge Avenue,

Brinklow,

Milton Keynes,

MK10 0BP

FAO: Data Privacy Manager

Email:     dataprivacy@radleyandco.com

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.

YOUR DUTY TO INFORM US OF CHANGES 

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.

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 notice of every website you visit.

 


2.  THE DATA WE COLLECT ABOUT YOU 

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 follows:

1.     Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender, and social media account names.

2.     Contact Data includes billing address, delivery address, email address, telephone numbers.

3.     Financial Data includes bank account details.

4.     Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.

5.     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.

6.     Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.

7.     Usage Data includes information about how you use our website, products and services.

8.     Marketing and Communications Data includes 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. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. 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 notice.

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 or services). 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.

PHISHING

Phishing is the practice of tricking someone into giving confidential information. Examples include falsely claiming to be a legitimate company when sending an email to a user, in an attempt to get the user to send private information that will be used for identity theft and fraud.

Radley will never ask you to send any personal details via email. If we require such details, for security reasons we will ask you to contact us by telephone. Should you receive an email claiming to be from Radley & Co requesting this kind of information please do not respond but contact us immediately.


3.  HOW IS YOUR PERSONAL DATA COLLECTED? 

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

1.     Direct interactions. You may give us your Identity, Contact 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:

1.     Buy or express an interest in our products or services, in-store or on our website;

2.     create an account on our website;

3.     subscribe to our newsletter;

4.     request that we send marketing materials to you;

5.     enter a competition, promotion or survey;

6.     take part in a Radley + Co event;

7.     submit a product review;

8.     speak to customer services.

2.  Automated technologies or interactions. As you interact with our website and the emails we send to you, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our IP Addresses and Cookies policy for more details.


4.  HOW WE USE YOUR PERSONAL DATA 

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:

1.     Where we need to perform the contract, we are about to enter into or have entered into with you.

2.     Where we have your consent.

3.     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.

4.     Where we need to comply with a legal or regulatory obligation.

You have the right to withdraw consent to marketing at any time by unsubscribing via the link provided with each marketing email we send to your or by contacting us on dataprivacy@radleyandco.com

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/Activity

Type of data

Lawful 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 notice
(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 enable you to partake in an event, prize draw, competition or complete a survey

(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications

(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
(c) Consent

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) Usage
(e) Marketing and Communications
(f) 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
(b) Usage

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) Usage
(e) Profile

1. Necessary for our legitimate interests (to develop our products/services and grow our business); or
2. Consent

MARKETING 

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.  Customers without an online profile may update their choices emailing customercare@radley.co.uk. You may also click ‘unsubscribe’ in any of the marketing emails we send to you.

PROMOTIONAL OFFERS FROM US 

We may use your Identity, Contact, Technical, Usage 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 (this is “marketing”).

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and, in each case, you have not opted out of receiving that marketing. You will also receive marketing communications from us if you have provided us with your details when you entered a competition or registered for a promotion and gave us your consent as part of that process.

THIRD-PARTY MARKETING 

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

OPTING OUT 

You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting us.

Opting out of marketing messages will not prevent you receiving non-marketing messages from us, for example relating to products ordered from us, responses to customer service queries etc.

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.

5.  DISCLOSURES OF YOUR PERSONAL DATA 

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

1.     External Third Parties as set out in the Glossary.

2.     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 notice.

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.

6.  INTERNATIONAL TRANSFERS 

Some of our external third parties are based in Asia Pacific and the USA, outside the European Economic Area (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:

1.     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 https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en

2.     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 https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en

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

7.  DATA SECURITY 

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.

8.  DATA RETENTION 

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.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.  We also keep this basic information about our customers for up to seven years following your most recent purchase from us, to enable us to deal efficiently with any after-sales queries that you may have.  We keep customer profile information that you have indicated you are happy for us to have in order to keep you up to date regarding our products, services and events and will keep this information until such time as you indicate you no longer wish us to keep this data, or until a maximum of seven years following your most recent positive interaction with a marketing communication (e.g. clicking on a link in an email taking you to our website) – whichever of these two periods is shorter.

In some circumstances you can ask us to delete your data: see [Request erasure] 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.

9.  YOUR LEGAL RIGHTS 

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

1.     [Request access to your personal data].

2.     [Request correction of your personal data].

3.     [Request erasure of your personal data].

4.     [Object to processing of your personal data].

5.     [Request restriction of processing your personal data].

6.     [Right to opt-out of automated profiling of your personal data]

7.     [Request transfer of your personal data].

8.     [Right to withdraw 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.


10. UNITED STATES SECTION
If you are a citizen of the United States accessing this website, in addition to the information referenced above in the privacy policy, please review this United States Privacy Section (“US Privacy Section”). As a reminder, by accessing, interacting with and/or using this website, you agree to all the terms of this policy, including this US Privacy Section. If you are a United States Citizen (“US Citizen”), Section 9 of the privacy policy is not applicable to your use and or/rights concerning your data and this website.

If you are a resident of California, please also see our Supplemental California Privacy Notice at Subparagraph F of this Section below.

A. DATA WE COLLECT ABOUT UNITED STATES CITIZENS

Radley collects the same personal information about United States Citizens as citizens of other jurisdictions. For more information, see Section 2 above.

B.  HOW IS YOUR PERSONAL DATA COLLECTED? 

Radley uses the same technology to collect personal information about United States Citizens as citizens of other jurisdictions, including automated technologies. For more information, see Section 3 and 9 above.

 

C. HOW DOES RADLEY USE UNITED STATE CITIZEN’S PERSONAL DATA?

In addition to those purposes set out in Section 4, We may use your personal data for the following purposes:

  • To fulfill any other purpose for which you provide it.
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
  • To allow you to participate in interactive features on our website.
  • In any other way we may describe when you provide the information.
  • For any other purpose with your consent.

 

PROMOTIONAL COMMUNICATIONS

United States Citizens may opt-out of promotional and marketing communications in the same manner as described in Section 4. This includes emailing customercare@radley.co.uk or usdataprivacy@radleyandco.com, clicking ‘unsubscribe’ in any of the marketing emails we send to you, or if you have an account, logging into the website and adjusting your marketing preferences.

Opting out of marketing messages will not prevent you from receiving non-marketing messages from us, for example, relating to products ordered from us, responses to customer service queries etc.

DISCLOSURE OF YOUR INFORMATION FOR THIRD-PARTY ADVERTISING (INCLUDING ONLINE BEHAVIORAL ADVERTISING):

Radley collects data for online behavioral advertising purposes. Radley then discloses this information to third parties for advertising purposes.

If you do not want us to share your personal data with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by logging into our website and adjusting your preferences in your account profile, by sending us an email with your request to usdataprivacy@radleyandco.com, or by following this link to the Digital Advertising Alliance’s (DAA) WebChoices Tool.

By exercising your right to choose, your choice will stop the collection and transfer of data from the browser from which the choice is exercised and on any browsers or devices associated with that browser.

Radley adheres to the DAA Principles concerning consumers’ right to opt-out of online behavioral advertising.

NEVADA RESIDENTS:

Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request to this designated address: usdataprivacy@radleyandco.com.

CALIFORNIA RESIDENTS:

California residents may have additional personal data rights and choices. Please see Section F: California Privacy Rights Section for more information.

D. WHY WE COLLECT YOUR PERSONAL DATA

As outlined above, most of the personal data we collect is provided to us directly by you so that we can bring our services and products to you. Your personal data is collected for our legitimate business interests or those of our service providers as outlined below:

  • To allow the performance of services we provide throughout our platforms.
  • To make sure we can keep in touch with you to provide these services.
  • To allow us to be efficient so that we can deliver the best services possible.
  • To prevent and detect criminal and/or fraudulent activity that would be damaging to you and/or us.
  • To promote our business to new and existing customers.

We (and our service providers) may share your personal data in the following situations:

  • With website providers: We may share your personal data with website providers to monitor and analyze the use of our website.
  • With service providers: We may share your personal data with service providers to help us deliver our services to you.
  • For business transfers: We may share or transfer your personal data in connection with, or during negotiations of, any merger, sale of our company assets, financing, or acquisition of all or a portion of our business by another company.
  • With affiliates:  We may share your personal data with our affiliates. 
  • With business partners:  We may share your personal data with our business partners to offer you certain products, websites, or promotions.

With third party vendors:  We may share your personal data with third party vendors to provide behavioral remarketing or advertising services. 

E. DISCLOSURE OF YOUR PERSONAL DATA

We may have to share your personal data with parties as set out in the Glossary and as below: 

LAW ENFORCEMENT

We may disclose your personal data if we are required by law to do so or in response to legitimate requests of public authorities (e.g., a court or government agency).

DISCLOSURE THROUGH BUSINESS TRANSFERS

We may buy, merge, or partner with another company or business and in doing so acquire or transfer personal data.  Personal data collected through the websites may be among the transferred business assets.  In the event of an acquisition or merger, your personal data may be transferred so that we may continue to sell products to you.  In the course of such a transaction your personal data would likely be considered a business asset, and, notwithstanding limitations imposed by applicable data privacy legislation, you hereby agree to such a transfer.

OTHER REASONS FOR DISCLOSURE

We may disclose your personal data in the good faith belief that such action is necessary to:

·       Comply with a legal obligation.

·       Protect and defend the rights of Radley + Co.

·       Prevent or investigate possible wrongdoing in connection with the services.

·       Protect the personal safety of users of the services or the public.

·       Protect against legal liability.

THIRD-PARTY SERVICE PROVIDERS

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. In general, the third-party providers used by us will only collect, use and disclose your personal data to the extent necessary to allow them to perform the services they provide to us or in accordance with our agreement. The following are some examples of our use of third-party service providers:

 

  • Payment gateways and other payment transaction processors.
  • E-marketing firms that assist us with the administration of our website, promotional newsletters and emails, which helps us understand what our customers want and need from our service, including analysis of the results of particular surveys we may perform.
  • Outside shipping companies to deliver your product orders.
  • Third party advertising services.
  • Data aggregators.

However, some third-party service providers have their own privacy policies with respect to the information we are required to provide to them for your purchase-related transactions.  For these providers, we recommend that you read their privacy policies to learn about the manner in which your personal data will be handled by these providers.

In particular, remember that certain providers may be located in or have facilities that are located in a different jurisdiction than either you or us.  If you elect to proceed with a transaction that involves the services of a third-party service provider, your personal data may become subject to the laws of the jurisdiction(s) in which that service provider or its facilities are located. 

Once you leave our website and are redirected to a third-party website or application, including through the use of links as described below, you are no longer governed by this privacy policy or our Terms of Use.  Radley + Co is not responsible for, and expressly disclaims all liability of any kind whatsoever arising out of, in connection with, related to and/or resulting from any products, services, or information offered or provided by third-party service providers, or any of the activities of third-party service providers.  Radley + Co makes no warranty, express or implied, or guarantee regarding any third-party service providers, or any products, services or information offered or provided by third-party service providers, or any activities of third-party service providers.

AGE OF CONSENT

This website is not intended for use by those under the age of 18, nor is it targeted to those under the age of 18. If you use the website, you hereby represent and warrant that you are at least 18 years of age. No one under the age of 18 may provide any information to or on the website. We do not knowingly collect personal data from those under the age of 18, nor do we knowingly sell or otherwise disclose the personal data of those under the age of 18. If you are under the age of 18, do not (i) use or provide any information on the website or through any of its features, (ii) use any of the interactive or fillable features of the website, or (iii) provide any information about yourself to us, including your name, address, telephone address, e-mail address or any other information that could be used to identify you. In compliance with the Children’s Online Privacy Protection Act, any information we receive from users we believe to be under the age of 18 will be purged from our database. 

F.  CALIFORNIA PRIVACY RIGHTS SECTION

If you are a California resident, you have certain data protection rights. This Addendum supplements the information contained in the United States Privacy Policy above, and applies solely to all visitors, users, and others who reside in the state of California. Under the California Consumer Privacy Act of 2018 (CCPA) and California Civil Code § 1798.83, you have the right to exercise the certain rights outlines below.  

  1. INFORMATION WE COLLECT

Our website has collected the following categories of personal information from consumers within the last twelve months.

Category

We Collected such Personal Information for the Following Purpose

Identifiers such as name, mailing address, phone number, IP address, email address, and account name

We may use this information for any of the purposes described in Section 4 above

Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) including name, address, telephone number and credit card number

We may use this information for any of the purposes described in Section 4 above

 

Protected classification characteristics under California or federal law including gender identity

We may use this information for any of the purposes described in Section 4 above 

Commercial information including records of products purchased

We may use this information for any of the purposes described in Section 4 above and to optimize your shipping experience with us

Biometric information.

N/A

 

 

Internet or other similar network activity including browsing history, how you use our website, information collected by cookies and your preferences

We use this information for any of the purposes described in Section 4 above and to support reporting and marketing purposes

 

Geolocation data

N/A

Sensory datda

N/A

Professional or employment-related information

N/A

Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))

N/A

Inferences drawn from other personal information

N/A

 

Over the past twelve months, we may have disclosed the categories of Personal Information listed above as necessary to fulfill our business purposes. Such disclosures include sharing such information with payment gateways and other payment transaction processors, outside shipping companies, and e-marketing and advertising services.

We may also share your Personal Information, including the categories of information in the chart above, by selling it to third parties as defined under CCPA, subject to your right to opt-out of those sales. Our Personal Information sales do not include information about individuals we know are under the age of 16. In the preceding twelve months, Radley + Co has not sold any Personal Information about California residents. However, moving forward, Radley + Co may provide the above categories of Personal Information to the following types of third parties:

  • Internet Cookie Data Recipients: We work with one or more third party that may place cookies on your computer to receive information about traffic to our website, browsing and purchasing activity on our online services. These third parties may collect information about individuals’ internet or other similar network activity and browsing patterns, IP address, page interaction and information obtained via cookies with these third parties and may retain rights to use some of this information for their own purposes.
  • Data Aggregators: We work with one or more third parties to administer and analyze the effectiveness of our advertising or promotional campaigns, to reach out to new customers, to improve our marketing and grow our business.

If you would like to opt-out of the sale of your Personal Information, please see Section 2A below.

  1. CCPA RIGHTS

California residents have the following rights:

  1. Right to Opt-Out of the Sale of Personal Information and Opt-In Rights: 

If you are age 16 or older, you have the right to direct us to not sell your Personal Information at any time (the "right to opt-out"). We do not sell the Personal Information of consumers we actually know are less than 16 years old, unless we receive affirmative authorization (the "right to opt-in") from either the consumer who is between 13 and 15 years old, or the parent or guardian of a consumer less than 13 years old. Consumers who opt-in to Personal Information sales may opt-out of future sales at any time.

To exercise the right to opt-out, you (or your authorized representative) may submit a request to us emailing us at usdataprivacy@radleyandco.com or calling 1-855-436-8690.

 

Once you make an opt-out request, we will wait at least twelve months before asking you to reauthorize Personal Information sales. However, you may change your mind and opt back into Personal Information sales at any time by emailing us at usdataprivacy@radleyandco.com or calling 1-855-436-8690.

You do not need to create an account with us to exercise your opt-out rights. We will only use Personal Information provided in an opt-out request to review and comply with the request.

  1. Right to Know and Data Portability:

You have the right to request that we disclose certain information to you about our collection and use of your personal data over the past twelve months (the "right to know"). Once we receive your request and confirm your identity, we will disclose to you:

  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting or selling that personal information.
  • The categories of third parties with whom we share that personal information.
  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
    • sales, identifying the personal information categories that each category of recipient purchased; and
    • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
  • The specific pieces of personal information we collected about you (also called a data portability request).
  1. Right to Delete:

Subject to certain exceptions set out below, upon receipt of a verifiable request from you, we will:

  • Delete or deidentify your Personal Information from our records; and
  • Direct any service providers to delete your Personal Information from their records.

Please note that we may not delete your Personal Information if it is necessary to:

  • Complete the transaction for which your Personal Information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between us and you.
  • Detect and protect against security incidents, fraudulent or illegal activity, or for prosecuting those responsible for such activity.
  • Debug, identify, or repair errors that impair existing functionality.
  • Exercise free speech.
  • Comply with the California Electronic Communications Privacy Act.
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all applicable ethics and privacy laws.
  • Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us.
  • Comply with an existing legal obligation.
  • Otherwise use your Personal Information, internally, in a lawful manner that is compatible with the context in which you provided the information.
  1. Right to Not be Discriminated Against:

You have the right not to be discriminated against by us because you exercised any of your rights under the CCPA.  This means we cannot:

  • Deny goods or services to you; or
  • Provide a different level or quality of services to you.

Please note that we may charge a different price or rate to you if that difference is reasonably related to the value provided to us by your Personal Information.

  1. Exercising Your Rights:

To exercise your rights to under CCPA, please submit a request by either:

Calling us at 1-855-436-8690

Emailing us at usdataprivacy@radleyandco.com

You may only submit a request to know twice within a 12-month period. Your request under CCPA must:

  • provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We may ask you to provide certain information to verify your identity. We will only use Personal Information provided in the request to verify the requestor's identity or authority to make it. We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

  1. CALIFORNIA’S SHINE THE LIGHT LAW

In addition to CCPA, California Civil Code § 1798.83 permits users that are residents of California to request the following information regarding our disclosure of your Personal Information to third parties for those third parties’ direct marketing purposes: (i) a list of certain categories of Personal Information that we have disclosed to certain third parties for their direct marketing purposes during the immediately preceding calendar year; (ii) the identity of certain third parties that received Personal Information from us for their direct marketing purposes during that calendar year; and (iii) where the nature of the third parties’ business is not reasonably determinable, examples of the products or services marketed (if we have that information). If you are a California resident and would like to make such a request, please email us at usdataprivacy@radleyandco.com.

  1. “DO NOT TRACK” POLICY AS REQUIRED BY CALIFORNIA ONLINE PRIVACY PROTECTION ACT (CALOPPA)

The Services does not respond to, or support Do Not Track (“DNT”) signals. 

Do Not Track is a preference you can set in your web browser to inform websites you do not want to be tracked.  You can enable or disable DNT by visiting the preferences or settings page of your web browser.

  1. CHANGES TO OUR CALIFORNIA ADDENDUM

We reserve the right to amend this California Addendum at our discretion and at any time. When we make changes to this privacy policy, we will post the updated notice on the website and update the notice's effective date. Your continued use of our website following the posting of changes constitutes your acceptance of such changes.

If you would like to access, correct, amend or delete any Personal Information we have about you, register a complaint, or simply want more information, please contact our Privacy Compliance Officer at the below:

Email: usdataprivacy@radleyandco.com

Phone: 1-855-436-8690

11.  GLOSSARY  

LAWFUL BASIS  

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/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 you have explicitly given us permission to process your personal data.  In such circumstances we will have asked you a specific question and you will have entered information or ticked a tick-box to indicate your consent.

THIRD PARTIES  
EXTERNAL THIRD PARTIES  

  1. Service providers acting as processors based in the UK or EU who provide marketing, IT, e-commerce and system administration services.
  2. Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK and EU who provide consultancy, banking, legal, insurance and accounting services.
  3. 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.
  4. Customer service call, email, webchat, display advertising and website behavioural service providers, acting as processors or controllers, based in the UK, EU or USA.
  5. Social media platforms, search engines and service providers based in the USA.
  6. As part of our fraud monitoring, detection and prevention methods and on the basis of our legitimate business interests, we use a third-party fraud monitoring, detection and prevention service provider for all website/online sales. The third-party service provider we currently engage is Signifyd, Inc. In order for their fraud monitoring, detection and prevention service to operate, Signifyd, Inc. will process your personal data, such as your name and contact information, payment information, transaction information and device information. Signifyd, Inc., as an independent and separate data controller, is solely responsible for their use of your personal data and will use it for the purposes set out in their privacy policy: https://www.signifyd.com/privacy.

YOUR LEGAL RIGHTS  

You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that UK and EU data protection laws allow us to retain certain information even though you have made a request for erasure. If you have transacted with us, the information we retain for tax and accounting purposes includes your order/transaction number, product and price paid, tax rate, method of payment, the country we shipped to and your post/zip code. If you have raised a customer care issue with us, we keep details of this for six months in order to efficiently solve your query.     

Object to processing of your 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 your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your 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 as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.  In such circumstances we may reserve the right to delete your personal data rather than hold it but restrict processing, where our processes are not set up to enable a restriction.

Request the transfer of your personal data to you 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 you initially provided consent for us to use or where we used the information to perform a contract with you.

Request to opt out of automated profiling of your personal data.  You have the legal right to opt-out of any automated profiling of your personal data that could have a legal consequence for you, and have a human being involved in the processing decision rather than it being automated.  The only profiling of this type that we undertake is in our marketing activities, in which we tailor our marketing communications to your transactional history and product preferences.  If you wish to opt-out of this automated profiling please contact us, though please be aware that our systems are not configured to send un-tailored marketing communications to you, so in practice opting out of automated profiling will result in you being opted out of receiving marketing communications from us.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

IP ADDRESSES AND COOKIES

What are cookies?
Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.
Cookies are small files of letters and numbers that we store on your browser or the hard drive of your device if you agree when you visit the website. These may be cookies, web pixels, beacons or other web files and will all be referred to as “cookies” in this policy.

We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users' browsing actions and patterns and does not identify any individual.

For the same reason, we may obtain information about your general internet usage by using a cookie file which is stored on the hard drive of your computer. Cookies contain information that is transferred to your computer's hard drive. They help us to improve our site and to deliver a better and more personalised service. They enable us:

  • To estimate our audience size and usage pattern.
  • To store information about your preferences, and so allow us to customise our site according to your individual interests.
  • To speed up your searches.
  • To recognise you when you return to our site.

We may use your data to provide you, via email, post, telephone or SMS with information, products or services that you request from us or which we feel may be of interest to you, or share your details with selected third parties which we believe may be of interest to you, where you have consented to be contacted for such purposes.
We will use information held about you to carry out our obligations arising from any contracts entered into between you and us.


Adjusting your cookie settings
By adjusting the privacy and security settings on your device, you can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.


Our use of cookies
The cookies that we use fall into six categories:
Strictly Necessary Cookies - These cookies are required for the operation of our website. They enable services you have specifically asked for, they allow you to move around the website and use certain features, such as accessing secure pages.
Session Cookies – These cookies allow the site to ‘remember’ content from page to page for example shopping basket. These cookies expire when the user leaves the site or closes the browser.
Analytical or Performance Cookies - These cookies collect information about how you use the website, for example pages you go to and any error messages you experience. These cookies don't gather information that identifies you, they are anonymous and help to improve how the website works.
Functionality Cookies - These cookies are used to recognise you when you return to our website and allow our website to remember choices you make, and tailor the website to provide enhanced content for you.
Targeting Cookies - These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to you. They are also used to limit the number of times you see an advertisement. We may also share this information with third parties for this purpose.
Persistent cookies - This type of cookie is saved on your computer for a fixed period (usually a year or longer) and is not deleted when the browser is closed. Persistent cookies are used where we need to know who you are for more than one browsing session. For example, we use this type of cookie to store your preferences, so that they are remembered for the next visit.

You can find more information about the individual cookies we use and the purposes for which we use them in the table below:


Strictly necessary cookies:


Cookie Title
Cookie Name

Module/Service

Purpose

VIEWED_PRODUCT_IDS

Enterprise/PageCache

Provide viewed product IDs from cookie.

geoip

MX/Geoip

Geoip functionality. Redirect if cookie enabled.

frontend

Core

Session ID on the server

BIGipServerPOOL

SERVERID

Load balancing

scarab.visitor

scarabresearch.com

Store and track visits across websites.

category_id

Core

Current category ID

ow_cookie_notice

Optimiseweb/CookieNotice

Notice block shown\hidden\closed

nocache

MX/Varnish

Turn Off\On Varnish Cache

Analytical or performance cookies


Cookie Title
Cookie Name

Module/Service

Purpose

_uetvid
_uetsid
_dc_gtm_UA-10478651-1

Google Tag Manager

Store and track visits across websites.

_gcl_au

Google Tag Manager

Store and track conversions.

_ga
_gid

Google Analytics

Count and track pageviews.

GA Event - EE Add to Cart
GA Event - EE Checkout
GA Event - EE Checkout Option
GA Event - EE Product Click
GA Event - EE Product Detail
GA Event - EE Product Impression
GA Event - EE Promotion Click
GA Event - EE Purchase
GA Event - EE Remove from Cart
GA Event - Email Click
GA Event - Empty Cart
GA Event - Exit Click
GA Event - JS Error
GA Event - Scroll Tracking
GA Pageview - All pages
GA Pageview - Error Page

Google Analytics

Support marketing and onsite analytics on each page and key behaviours, collecting browser behaviour data. This includes recognising onsite behaviours such as products, category, content and checkout pages. Technical information such as device, browser type and time on site. And buying behaviour such as items purchased, spends, vouchers used.

_fbp

Facebook

Store and track visits across websites.

Content Square - Delivery
Content Square - Payment
Contentsquare - E-commerce
Contentsquare - Main UK
Contentsquare - Main US

Content Square

Support onsite analytics, collecting browser behaviour data. This includes recognising onsite behaviours such as products, category, content and checkout pages. Technical information such as device, browser type and time on site, and buying behaviour such as items purchased, spends, vouchers used.

Fifty Tag

Fifty

Support analysis of paid social marketing activity on Facebook and Instagram, collecting browser behaviour data. This includes recognising onsite behaviours such as products, category, content and checkout pages. Technical information such as device, browser type and time on site. And buying behaviour such as items purchased, spends, vouchers used.

Targeting cookies


Cookie Title
Cookie Name

Module/Service

Purpose

Affilinet - Add to Cart
Affilinet - Profiling - Cat Page
Affilinet - Profiling - Default Pages Tag
Affilinet - Profiling and Order Confirmation
Affilinet - Profiling- Product Page

Awin / Affilinet

Support affiliate marketing activity, collecting browser behaviour data. This includes recognising onsite behaviours such as products, category, content and checkout pages. Technical information such as device, browser type and time on site. Buying behaviour such as items purchased, spends, vouchers used.

Bing
Bing Revenue Tracking

Bing

Support paid per click Microsoft ads on Bing marketing activity, collecting browser behaviour data. This includes recognising onsite behaviours such as products, category, content and checkout pages. Technical information such as device, browser type and time on site. Buying behaviour such as items purchased, spends, vouchers used.

Connexity - Conversion Tag

Connexity

Gather conversion insights.

Conversant - Conversion
Conversant - Pageview
Conversion Linker

Conversant Epsilon

Support understanding of onsite customer journey behaviour collecting browser behaviour data. This includes recognising onsite behaviours such as products, category, content and checkout pages. Technical information such as device, browser type and time on site. Buying behaviour such as items purchased, spends, vouchers used.

Emarsys

Emarsys

Tags & cookies to support email marketing activity, collecting browser behaviour data. This includes recognising onsite behaviours such as products, category, content and checkout pages. Technical information such as device, browser type and time on site. Buying behaviour such as items purchased, spends, vouchers used.

Facebook - Add To Cart
Facebook - All Pages Pixel
Facebook - Checkout
Facebook - PDP
Facebook - Purchase

Facebook

Support Paid social marketing activity on Facebook and Instagram, collecting browser behaviour data. This includes recognising onsite behaviours such as products, category, content and checkout pages. Technical information such as device, browser type and time on site. Buying behaviour such as items purchased, spends, vouchers used.

Mention Me - Checkout
Mention Me - Purchase

Mention me

Support refer a friend marketing activity, collecting browser behaviour data. This includes recognising onsite behaviours such as products, category, content and checkout pages. Technical information such as device, browser type and time on site. Buying behaviour such as items purchased, spends, vouchers used.

Pinterest

Pinterest

Support social media marketing activity on Pinterest, collecting browser behaviour data. This includes recognising onsite behaviours such as products, category, content and checkout pages. Technical information such as device, browser type and time on site. Buying behaviour such as items purchased, spends, vouchers used.

Rakuten - All pages
Rakuten - Channel Cookie Set
Rakuten - Purchase

Rakuten

Support affiliate marketing activity, collecting browser behaviour data. This includes recognising onsite behaviours such as products, category, content and checkout pages. Technical information such as device, browser type and time on site. Buying behaviour such as items purchased, spends, vouchers used.

Twitter

Twitter

Support paid social media marketing activity on Twitter, collecting browser behaviour data. This includes recognising onsite behaviours such as products, category, content and checkout pages. Technical information such as device, browser type and time on site. Buying behaviour such as items purchased, spends, vouchers used.

Unidays - Purchase

Unidays

Support student discount marketing activity, collecting browser behaviour data. This includes recognising onsite behaviours such as products, category, content and checkout pages. Technical information such as device, browser type and time on site. Buying behaviour such as items purchased, spends, vouchers used.

We may change the cookies we use from time to time so we recommend that you review this cookies policy and your cookie settings regularly.
Third Party Cookies
Please note that third parties may also use cookies, over which we have no control. These named third parties may include, for example, advertising networks and providers of external services like web traffic analysis services. These third party cookies are likely to be analytical cookies or performance cookies or targeting cookies. Please see the list set out above.
Certain Radley third party providers use cookies and other similar technologies such as log files and pixel tags to collect information regarding your interests and preferences (e.g. products or pages you have viewed on our website) in order to provide personalised and tailored advertisements to you online, including on other third party websites. This also involves tracking such information across multiple devices. We provide these third party providers’ affiliates and processors with personal data, who then make this information pseudonymous before then providing it to the third party provider. Therefore, these third party providers will not have access to any personally identifiable data, but rather data that has been made pseudonymous by their affiliates and processors, with whom they have a contractual relationship. “Pseudonymous” means the information cannot be attributed to a specific person without the use of additional information. The third party provider will match this pseudonymous data with other data, for example collected via the use of cookies and other similar technologies such as log files and pixel tags, to provide tailored advertisements to you.
To learn more about the use of this information or to make choices about receiving personalised advertising provided by third parties, please visit the European Digital Interactive Advertising Alliance by clicking here: http://www.youronlinechoices.eu or view individual partners by clicking on the links below:

Vendor

Role

Data & Privacy Policy

Affilinet / Awin

Affiliate Marketing

https://www.awin.com/gb/legal/privacy-policy

Bing

Paid Search Advertising

https://about.ads.microsoft.com/en-gb/resources/policies/privacy-and-data-protection-policies

Content Square

Conversion Rate Optimization & Analytics

https://contentsquare.com/gb-en/privacy-center/

Conversant Epsilon

Display Marketing

https://emea.epsilon.com/privacy-policy

Emarsys

Email Service Provider

https://emarsys.com/privacy-policy/

Facebook

Social Platform

https://www.facebook.com/policy.php

Fifty

Social Media Agency

https://fifty.io/privacy-policy.php

Google

Analytics & Paid Search Advertising

https://policies.google.com/privacy?hl=en-US

Mention Me

Refer a Friend Program

https://mention-me.com/help/privacy_policy_s

Pinterest

Social Platform

https://policy.pinterest.com/en-gb/privacy-policy

Rakuten

Affiliate Marketing

https://www.rakuten.com/help/article/privacy-policy-360002101688

Twitter

Social Platform

https://twitter.com/en/privacy

Unidays

Student Discount Scheme

https://www.myunidays.com/GM/en-GB/privacy-policy

  
We may use the data in accordance with the preferences expressed in your acceptance of the Radley cookie policy and terms and conditions of use of the Radley website. Our website uses cookies/advertising IDs for the purpose of advertising. This enables us to show our advertisements to visitors who are interested in our products on partner websites and apps. Re-targeting technologies use your cookies or advertising IDs and display advertisements based on your past browsing behaviour.


SECURITY

We realise how important it is to securely store any information that you provide us. The Radley transactional web site currently uses high-level Secure Socket Layer (SSL) encryption technology, the most advanced security software currently available for online transactions. You can therefore rest assured that we take the security of your payment and personal details very seriously. We may vary this in the future if we feel you will benefit from greater security whilst using our website.

You can tell whether a webpage is secure as 'https' will replace the 'http' at the front of the www.radley.co.uk in your browser address window, also a small locked padlock will appear in your browser window.



COMPLAINTS

If you feel that Radley is not abiding by its posted privacy policy, you should first contact the Online Customer Service Department or telephone +44 (0) 207 741 1055. You can also write to us at: Radley + Co Limited, Etheridge Avenue, Brinklow, Milton Keynes, MK10 0BP