May 10th 2018 – GDPR compliant policy
This policy (together with our terms of website use Terms of Website Use and any other documents referred to on it) sets out the basis on which we, Route 70 Limited, (trading as NINE IN THE MIRROR.COM) of 132-134 Lots road, Worlds End Studios, London SW10 0RJ (“we” or “us”) will process any personal data we collect from you, or which you provide to us, in the course of using our site www.nineinthemirror.com (“site”) for the purpose of UK Data Protection Act 2018 and GDPR (General Data Protection Regulation).
It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at email@example.com
This privacy notice provides you with details of how we collect and process your personal data through your use of our site.
Route 70 Limited is the data controller of your personal data and is responsible for the collection, use, disclosure, retention and protection of your personal information in accordance with the General Data Protection Regulation (GDPR).
Route 70 Ltd may transfer your personal information outside of the European Economic Area to our group companies and authorised third parties. Where we use third party service providers based outside of the European Economic Area, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. Where we use third party service providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
By providing us with your data, you warrant to us that you are over 13 years of age.
2. WHAT DATA DO WE COLLECT ABOUT YOU, FOR WHAT PURPOSE AND ON WHAT GROUND WE PROCESS IT
Personal data means any information capable of identifying an individual. It does not include anonymised data.
We may process the following categories of personal data about you:
- Communication Data that includes any communication that you send to us whether that be through the contact form on our website, through email, text, social media messaging, social media posting or any other communication that you send us. We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defence of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.
- Customer Data that includes data relating to any purchases of goods and/or services such as your name, title, billing address, delivery address email address, phone number, contact details, purchase details and your card details. We process this data to supply the goods and/or services you have purchased and to keep records of such transactions and to avoid any fraudulent activities. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract.
- User Data that includes data about how you use our website and any online services together with any data that you post for publication on our website or through other online services. We process this data to operate our website and ensure relevant content is provided to you, to ensure the security of our website, to maintain back- ups of our website and/or databases and to enable publication and administration of our website, other online services and business. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business.
- Technical Data that includes data about your use of our website and online services such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is from our analytics tracking system. We process this data to analyse your use of our website and other online services, to administer and protect our business and website, to deliver relevant website content and advertisements to you and to understand the effectiveness of our advertising. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business and to grow our business and to decide our marketing strategy.
Marketing Data that includes data about your preferences in receiving marketing from us and our third parties and your communication preferences. We process this data to enable you to partake in our promotions such as competitions, prize draws and free give-aways, to deliver relevant website content and advertisements to you and measure or understand the effectiveness of this advertising. Our lawful ground for this processing is our legitimate interests which in this case are to study how customers use our products/services, to develop them, to grow our business and to decide our marketing strategy.
We may use Customer Data, User Data, Technical Data and Marketing Data to deliver relevant website content and advertisements to you (including Facebook adverts or other display advertisements) and to measure or understand the effectiveness of the advertising we serve you. Our lawful ground for this processing is legitimate interests which is to grow our business. We may also use such data to send other marketing communications to you. Our lawful ground for this processing is either consent or legitimate interests (namely to grow our business).
Sensitive Data: We offer the option for you to share with us your due date. We ask for this to give you a personalised product and content offer during your pregnancy and beyond. This is entirely optional. We require your explicit consent for processing sensitive data. When you submit your details and if you share to choose your due date, you are consenting to the processing of this data. We will use this information to provide you with personalised products/services/information. You have at any time the right to ask us to delete your Due Date from our records. We will in any case only keep the Due Date until 1 year anniversary of the Due Date and it will be automatically deleted from our records after a year.
We will only use your personal data for the purpose it was collected or for a reasonably compatible purpose if necessary. For more information on this please email us at firstname.lastname@example.org.
We may process your personal data without your knowledge or consent where this is required or permitted by law.
3. HOW WE COLLECT YOUR PERSONAL DATA
We collect, process and retain personal information from you and any devices you may use when you navigate to NINE IN THE MIRROR.COM web or mobile view, by transacting, by registering an account and otherwise interacting with us.
We may also collect personal information from you if you physically enter one of our pop-up stores or attend an event when you provide us with that information by filling out a form, emailing us, or signing up to our mailing list.
We may automatically collect certain data from you as you use our website by using cookies and similar technologies.
To make full use of the online shopping and personalised features on NINE IN THE MIRROR, your computer, tablet or mobile phone will need to accept cookies, as we can only provide you with certain personalised features of this website by using them.
We may receive data from third parties such as analytics providers such as Google based outside the EU, advertising networks such as Facebook based outside the EU, such as search information providers such as Google based outside the EU, providers of technical, payment and delivery services, such as data brokers or aggregators.
We may also receive data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.
The personal information we collect includes the following:
- Personal information including payment related information you give us when you register or purchase through the site;
- Content that you generate when interacting with our customer services team including details we require to contact you and verify your identity;
- Other content that you generate through browsing activity including intended purchases, your marketing preferences, completion of surveys, wish lists, and participation in promotional activity; and
- Device identifiers such as IP addresses, cookie IDs, IDFAs and other device identifiers, connection information such as statistics on your page views, traffic to and from the sites, referral URL, ad data, your browsing history, hashed email addresses, and your web log information.
If you give us personal data about someone else, you must do so only with their explicit and prior consent.
We may allow you to share information with social media sites, or use social media sites to create your account or to connect your account with the respective social media site. Those social media sites may give us automatic access to certain personal information retained by them about you (e.g., content viewed by you, content liked by you and information about the advertisements you have been shown or may have clicked on). Where this information is received by us, we will use this information to further personalise your experience with NINE IN THE MIRROR.
4. HOW WE USE THE DATA WE COLLECT
We collect and process your personal data for the following purposes:
- When you purchase a product from NINE IN THE MIRROR we ask you for the personal data necessary to allow us to fulfil our contract with you including taking payment, any related anti-fraud checks if you choose to pay by credit/debit card, billing, shipping and delivery of the product and possible handling of the return.
- When you visit NINE IN THE MIRROR, we will use some data about your use of the website to help us improve the website and our promotion of the website. This will include data about how you came to the website; the date and time of your visit; products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction data (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.
- When you register on NINE IN THE MIRROR, we will collect the data necessary to ensure that we can recognise you on return visits and provide you with the services registration offers, such as creating a Wish List or subscribing to emails or marketing communications. If you would prefer not to continue receiving these emails, you can unsubscribe at any time using the link on the bottom of the email, or by contacting our Customer Care team.
- If you have purchased from NINE IN THE MIRROR, we will use the personal data we hold about you, including your purchase history, to contact you regarding products and services that may be of interest to you. If you would prefer not to be contacted in this way, you can unsubscribe from emails at any time using the link on the bottom of the email or by contacting our Customer Care team.
- We analyse contact data, purchase history, web browsing data and lifestyle data to tailor our marketing communications, web site presentation and internet advertising to meet your preferences. For example, if you have been browsing or have previously purchased a particular designer, we may send you an email to tell you that these are now on sale or display similar products to you as part of our internet advertising.
- When you contact our Customer Care team, we will use the personal data you provide and that we have collected to respond to your requests for help or information.
5. MARKETING COMMUNICATIONS
Our lawful ground of processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business).
Under the Privacy and Electronic Communications Regulations, we may send you marketing communications from us if (i) you made a purchase or asked for information from us about our goods or services or (ii) you agreed to receive marketing communications and in each case you have not opted out of receiving such communications since. Under these regulations, if you are a limited company, we may send you marketing emails without your consent. However you can still opt out of receiving marketing emails from us at any time.
We do not share your personal data with third parties but if we do in future, before we share your personal data with any third party for their own marketing purposes we will get your express consent. You can ask us or third parties to stop sending you marketing messages at any time by clicking on the unsubscribe link in our emails OR by emailing us at email@example.com at any time].
If you do not want us to use your information for marketing purposes, please contact us directly by emailing firstname.lastname@example.org or you can click on the unsubscribe link at the bottom of every email that we send you at any time.
If you opt out of receiving marketing communications this opt-out does not apply to personal data provided as a result of other transactions, such as purchases, warranty registrations etc.
6. DISCLOSURES OF YOUR PERSONAL DATA
We may disclose your personal information to legal entities to authorised third parties. We do not disclose your personal information to third parties for marketing purposes.
We protect your information using measures that reduce the risks of loss, misuse, unauthorised access, disclosure and alteration. We minimise the amount of personal information we disclose to what is directly relevant and necessary to accomplish the specified purpose.
We may have to share your personal data with the parties set out below:
- Payment providers to facilitate purchases
- Fulfilment providers to facilitate order management, packaging and delivery
- Marketing and advertising providers in order to personalise your experience
- Service providers who provide IT and system administration services
- Professional advisers including lawyers, bankers, auditors and insurers
- Government bodies that require us to report processing activities.
- Third parties to whom we sell, transfer, or merge parts of our business or our assets.
If you purchase a Molli product from NINE IN THE MIRROR, we will share your Customer Data i.e. data relating to any purchases of goods and/or services such as your name, title, billing address, delivery address email address, phone number, contact details, purchase details and your card details with Molli as they will fulfil your Molli order. In order for Molli to process this data to supply the goods and/or services you have purchased and to keep records of such transactions and to avoid any fraudulent activities.
We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.
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.
7. INTERNATIONAL TRANSFERS
We share your personal data within our group of companies which involves transferring your data outside the European Economic Area (EEA).]
Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.
Many of our third parties service providers are based 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 do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is in place:
We will only transfer your personal data to countries that the European Commission have approved as providing an adequate level of protection for personal data by; or
- Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or
- If we use US-based providers that are part of EU-US Privacy Shield, we may transfer data to them, as they have equivalent safeguards in place.
If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.
8. DATA RETENTION
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.
When deciding what the correct time is to keep the data for we look at its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.
For tax purposes the law requires us to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers.
In some circumstances we may anonymise your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Please note we will automatically remove your DUE DATE from our records if you have given us this information one year after the due date anniversary.
9. YOUR LEGAL RIGHTS
Under data protection laws you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data, and (where the lawful ground of processing is consent) to withdraw consent.
You can see more about these rights at:
If you wish to exercise any of the rights set out above, please email us at email@example.com.
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 or we may refuse to comply with your request in these circumstances.
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.
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.
If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.
- SAFEGUARDING YOUR PERSONAL INFORMATION
All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL Encryption. SSL certificate provided by Geo Trust.
We take your privacy very seriously, and will take all reasonable steps to protect your personal data, but please be aware that any data which you send to our site is sent at your own risk. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
- ACCESS TO INFORMATION
You have the right under the General Data Protection Regulations to access the information which we hold about you. If you wish to exercise this right, please send your request to firstname.lastname@example.org