Dated: May 2018
PLEASE READ THIS POLICY CAREFULLY BEFORE USING THIS WEBSITE
Protecting your data, privacy and financial details is very important to Vinterior Group Limited (“Vinterior”, “us” or “we”).
This policy (together with our Website Terms and Conditions and any other documents referred to in it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand the types of information we collect from you, how we use that information and the circumstances under which we will share it with third parties.
For the purpose of the EU General Data Protection Regulation 2016/679 (GDPR), the controller of your data is Vinterior Group Limited a company registered in England and Wales under company number 09647881 whose registered office is at of International House, 24 Holborn Viaduct, London, EC1A 2BN.
Information we may collect from you
We may collect and process the following data about you:
Information you give us. You may give us information about you by filling in forms on www.vinterior.co (our “Site”) or by corresponding with us by phone, e-mail or otherwise. Unless context otherwise requires, a reference to the Site shall be deemed to also refer to any Vinterior mobile application (“App”) where such App is available.
The information you give us may include (but is not limited to):
- Information you provide when you register to use our Site, subscribe to our service, contact third parties via the Site, and when you report a problem with our Site.
- Personal information such as your name, address, e-mail address and phone number, personal description, geographic location, financial and payment information, photograph, and copies of identification documents.
- Buying or selling information you provide during a transaction, or other transaction-based content that you generate or that is connected to your account as a result of a transaction you are involved in.
- Other content that you generate, or that is connected to your account (such as adding items to your cart, creating listings, and other uses of the site.
- Information we collect about you. With regard to each of your visits to our Site we may automatically collect the following information:
- Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and
- Information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our Site (including date and time); what you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.
- Information we receive from other sources. We may receive information about you if you use any of the other websites we operate or the other services we provide. We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.
Uses made of the information
We use information held about you in the following ways:
Information you give to us. We will use this information:
- to carry out our obligations arising from any contracts entered into between you and us (including the Website Terms and Conditions and to provide you with the information, products and services that you request from us;
- to provide you with information about other goods and services we offer that are similar to those that you have already purchased;
- to provide you with information about goods or services we feel may interest you from third parties (further details of whom are set out in the ‘Disclosure of your Information’ section below). We will only contact you by email with information about goods and services similar to those which were the subject of a previous sale to you, and you will be given an option to unsubscribe with each communication;
- to notify you about changes to our service;
- to ensure that content from our Site is presented in the most effective manner for you and for your computer or mobile device.
Information we collect about you. We will use this information:
- to administer our Site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- to improve our Site to ensure that content is presented in the most effective manner for you and for your computer or mobile device;
- to allow you to participate in interactive features of our service, when you choose to do so;
- as part of our efforts to keep our Site safe and secure;
- to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
- to make suggestions and recommendations to you and other users of our Site about goods or services that may interest you or them.
The Legal Basis for Processing Your Information
In accordance with GDPR, the main grounds that we rely upon in order to process your information are as follows:
- Necessary for entering into or performing a contract. In order to perform obligations which arise under any contract we have entered into with you, it will be necessary for us to process your information.
- Necessary for compliance with a legal obligation. We are subject to certain legal requirements which may require us to process your information. We may also be obliged by law to disclose your information to a regulatory body or law enforcement agency.
- Necessary for the purposes of legitimate interests. Either we or a third party will need to process your information for the purposes of our (or a third party’s) legitimate interests, provided that we have established that those interests are not overridden by your rights and freedoms (including your right to have your information protected). Our legitimate interests include responding to requests and enquiries from you or a third party, optimising our website and user experience, informing you about our services and ensuring that our operations are conducted in an appropriate and efficient manner.
- Consent. In some circumstances, we may ask for your consent to process your information in a particular way.
For example, if you have given your consent, we may disclose your personal data (for example, a first name, first initial of your surname and photograph) to a third party (for example, the recipient or your peer-to-peer counterparty) in order to fulfil a request. Similarly, if you have given your consent, we may also use details of your transaction together with your first name, first initial of your surname and photograph for marketing and advertising purposes.
Disclosure of your information
We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
We may share your information with selected third parties including:
- business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
- advertisers and advertising networks that require the data to select and serve relevant adverts to you and others;
- analytics and search engine providers that assist us in the improvement and optimisation of our Site; and
We may disclose your personal information to third parties:
- in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
- if Vinterior or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets;
- if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply the Website Terms and Conditions and any other documents referred to on it; or to protect the rights, property, or safety of Vinterior, our users, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
Where we store your personal data
To the extent that any of your data is provided to third parties outside the EEA, or accessed by third parties from outside the EEA, we will ensure that appropriate safeguards are in place in accordance with the GDPR (such as the European Commission’s standard contractual clauses, or the EU/US Privacy Shield).
All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
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 use strict procedures and security features to try to prevent unauthorised access.
We restrict access of your personal information to those employees of Vinterior who have a business reason for knowing such information. We continuously educate and train our employees about the importance of confidentiality and privacy of customer information. We maintain physical, electronic and procedural safeguards that comply with the relevant laws and regulations to protect your personal information from any unauthorised access.
How long we hold your information
We will only retain your information 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. The criteria that we use to determine retention periods will be determined by the nature of the data and the purposes for which it is kept, the sensitivity of the data and the potential risk of harm from unauthorised use or disclosure.
You have certain rights in relation to the personal data that we hold about you. Details of these rights and how to exercise them are set out below. Please note we will require evidence of your identity before we are able to respond to your request.
- Right of Access. You have the right at any time to ask us for a copy of the personal information that we hold about you and to check that we are lawfully processing it. Where we have good reason, and if the GDPR permits, we can refuse your request for a copy of your personal information, or certain elements of the request. If we refuse your request or any element of it, we will provide you with our reasons for doing so.
- Right of Correction or Completion. If personal information we hold about you is not accurate or is out of date and requires amendment or correction you have a right to have the data rectified or completed.
- Right of Erasure. In certain circumstances, you have the right to request that personal information we hold about you is erased e.g. if the information is no longer necessary for the purposes for which it was collected or processed or our processing of the information is based on your consent and there are no other legal grounds on which we may process the information.
- Right to Object to or Restrict Processing. In certain circumstances, you have the right to object to our processing of your personal information. For example, if we are processing your information on the basis of our legitimate interests and there are no compelling legitimate grounds for our processing which override your rights and interests.
You may also have the right to restrict our use of your personal information, such as in circumstances where you have challenged the accuracy of the information and during the period where we are verifying its accuracy.
You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data.
- Right of Data Portability. In certain instances, you have a right to receive any personal information that we hold about you in a structured, commonly used and machine-readable format.
In such circumstances, you can ask us to transmit that information to you or directly to a third party organisation.
While we are happy for such requests to be made, we are not able to guarantee technical compatibility with a third party organisation's systems. We are also unable to comply with requests that relate to personal information of others without their consent.
You can exercise any of these rights at any time by contacting us at [email protected].
Our Site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates, including Stripe or any other third party payments provider we use from time to time to process transactions entered into via the Site. If you enter into a transaction via the Site, or follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
Access to information
Depending on applicable laws, you may have the right to access information held about you. Your right of access can be exercised in accordance with the relevant data protection legislation. Any access request may be subject to a fee to meet our costs in providing you with details of the information we hold about you.
Right to withdraw consent
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. You can do this by contacting us using the details in the 'Contact' section below.
Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
If you are unhappy about our use of your information, you can contact us using the details in the Contact section below. You are also entitled to lodge a complaint with the UK Information Commissioner's Office using any of the below contact methods:
- Telephone: 0303 123 11113
- Website: https://ico.org.uk/concerns/
- Post: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
If you live or work outside of the UK or you have a complaint concerning our activities outside of the UK, you may prefer to lodge a complaint with a different supervisory authority. A list of relevant authorities in the EEA can be accessed here.