LEE STAFFORD PRIVACY NOTICE

INTRODUCTION

Welcome to Lee Stafford’s Privacy Notice. At Lee Stafford, we want you to know that we have your best interests at heart and in this Privacy Notice, we give you information on how we collect and process your personal data when you use our website, take part in any of our competitions, sign-up as a client with us (and purchase any of our products and/or services), apply for a job with us or are a service provider to us.

As data protection is really important to Lee Stafford, we may provide you with additional data privacy notices or information that is specific to your situation – and if we do, you need to read that additional information alongside this Privacy Notice (which is our key document and will always apply).

 

WHAT PERSONAL DATA DO WE COLLECT ABOUT YOU AND HOW?

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).

(A) Different kinds of personal data

In general, we collect, use, store and transfer different kinds of personal data and we’ve grouped them together below for you:

Type of data	What does this include?
Identity Data	This includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
Contact Data	This includes billing address, delivery address, email address and telephone numbers.
Financial Data	This includes bank account and payment card details.
Transaction Data	This includes details about payments from you and other details of products and services you have registered for with us or in the alternative, if you have requested an exchange or cancelled an order and request for a refund.
Technical Data	This includes internet protocol 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.
Profile Data	This includes agreements signed with you (such as our standard terms and conditions), your interests, preferences, feedback (such as reviews), survey responses and competition responses.
Usage Data	This includes information about how you use our website (including your IP address and the time of visit) and services.
Marketing and Communications Data	This includes your preferences in receiving marketing from us and your communication preferences (including in respect of cookies).

 

We also collect, use and share Aggregated Data such as statistical or demographic data for other purposes including research and analysis. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will 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 occasionally collect some special categories of personal data about you, information about your health (such as skin type and/or hair condition), and/or genetic and biometric data). We only obtain and process any data on this topic when we have a lawful basis in which to do so (i.e. you have given us your consent and chosen to provide us with this data).

Our products and services are not intended for children and therefore, we do not knowingly collect data relating to children.

(B) Our relationship with you

The personal data that we collect from you depends on our relationship with you. Below we’ve made a chart which explains the personal data that we collect, how we collect this data and what our legal basis is for collecting it (as we will only collect and process your personal data when the law allows us to do so).

Who are you?	What data do we collect about you?	How do we collect this personal data about you?	What’s our legal basis for collecting this personal data?
I am using the Lee Stafford website and am keen to find out more about what Lee Stafford can offer (i.e. I am browsing the website, submiting a query through the contact form and/or subscribing for its newsletters).	Technical Data and Usage Data (for tracking purposes). Identity Data, Contact Data and Marketing and Communications Data (if you enter into a competition, promotion or survey or sign-up for more information etc.).	Automated technologies à As you interact with our website, we automatically collect personal data about you by using cookies and similar technologies. Please see our Cookies Notice. Direct interactions à If you decide to contact us through our website or through other means, you will be directly providing us with your personal data.	Consent, in that you are choosing to provide us with your details so that we know to contact you about your query, send you a newsletter, process special catergy data or share your data with a third party. Necessary for our legitimate interests (i.e. for running our business, provision of services, to develop our business and to inform our marketing strategy). Necessary to comply with a legal obligation (i.e. in respect to our financial, tax and legal affairs or in instances where you no longer wish to be contacted with direct marketing material).
I am a client of Lee Stafford (i.e. I have entered into or am in the process of entering into a contractual agreement with Lee Stafford).	Technical Data and Usage Data (for tracking purposes). Identity Data, Contact Data, Financial Data, Transaction Data, Profile Data and Marketing and Communications Data (for when you enter into a formal relationship with us for a service or product).	Automated technologies à As you interact with our website (and/or services), we automatically collect personal data about you by using cookies and similar technologies. Please see our Cookies Notice. Direct interactions à If you decide to contact us through our website or through other means, you will be directly providing us with your personal data. We may receive personal data about you from third-parties (as detailed below).	Performance of a contract with you (i.e. processing an order submitted by you). Necessary for our legitimate interests (i.e. to recover debts due to us, to keep records to develop our business strategy). Necessary to comply with a legal obligation (i.e. in respect to our financial, tax and legal affairs).
I am a candidate applying for a job with Lee Stafford (and/or am subsequently in the process of signing an employment contract with Lee Stafford).	Technical Data and Usage Data (if you apply through our website). Identity Data and Contact Data (information submitted as part of your application).	Automated technologies à As you interact with our website, we automatically collect personal data about you by using cookies and similar technologies. Please see our Cookies Notice. Direct interactions à If you decide to apply for a job at Lee Stafford, you will be directly providing us with your personal data. Third-parties à We may receive personal data about you from various third-parties (such as recruitment agents or your referees).	Consent, in that you are choosing to provide us with your details so that we know to contact you about a vacancy. Performance of a contract with you.
I am a service provider to Lee Stafford.	Technical Data and Usage Data (for tracking purposes) Identity Data and Contact Data (if you register your interest to work with us).	Automated technologies à As you interact with our website, we automatically collect personal data about you by using cookies and similar technologies. Please see our Cookies Notice. Direct interactions à If you agree to provide us with a service, we will hold the personal data of your staff that have engaged with us.	Performance of a contract with you. Necessary for our legitimate interests (i.e. for running our business). Necessary to comply with a legal obligation (i.e. in respect to our financial, tax and legal affairs).

Please contact us on letschat@leestafford.com 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 above.

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.

(C) 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 and/or services). In this case, we may have to cancel goods and/or services you have with us – but we will notify you in advance.

(D) 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 this does occur and you wish to get an explanation as to how the processing for a new purpose is compatible with the original purpose, please contact us on letschat@leestafford.com. If we need to use your personal data, however, for an entirely 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.

DO WE DISCLOSE YOUR PERSONAL DATA TO OTHERS AND IF SO, WHO?

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

• Internal third-parties such as those within our group that are based within and outside of the USA such as in UK and EEA.

External third-parties suppliers that act as data processors such as:

• Third party servers - We use a third party server to host our ecommerce enabled website called Shopify Inc., the privacy policy of which is available here https://www.shopify.com/legal/privacy . Our website server automatically logs the IP address you use to access our website as well as other information about your visit such as the pages accessed, information requested, the date and time of the request, the source of your access to our website (e.g. the website or URL (link) which referred you to our website), and your browser version and operating system.

• Website and marketing software – for us to succesfully communicate with you and tailor our products and services to your needs (examples include Google and MailChimp).

• Payment service providers – for us to process any payments made by our clients to us (examples include PayPal and Sagepay).

• Technology companies that provide us with desktop and/or cloud-based products – for us to conduct our business and back-up data (which may include your personal data) whilst you are reviewing our website, applying to be our customer, applying for a vacancy with us or acting as one of our suppliers (examples include Merlin Communications and 02).
  
• Google Analytics -  We use the web analytics service provided by Google Analytics on our websites. This uses data collected by cookies, i.e. information about your use of our website and your surfing behavior, to be transmitted to a Google server in the USA and stored there. The purpose of this service is to evaluate usage data, to create various data in statistics for advertising purposes (such as anonymized information about age, gender, interests of our website users ets), to be able to provide more targeted and more interesting advertising for you, to regularly improve our website, and to provide feedback to get about your favorite products and services. We use this service strictly in accordance with data protection legal requirements and have entered into a data processing agreement with Google. Please note that the IP addresses transmitted by Google Analytics are integrated using a special code "ga ('set', 'anonymizeIp', true); anonymized before transmission.

If you reject the use of Google Analytics despite it anonymizing your IP address, you can prevent Google from processing the Usage Data generated by the cookies by downloading and installing the following technical browser plug-in (a so-called "add-on"): https://tools.google.com/dlpage/gaoptout?hl=en. Please note that this browser plug-in only works on your desktop or notebook, but not on mobile devices.

You can prevent Google Analytics from collecting your data on your mobile devices by setting an "opt out" cookie that blocks the collection of your data on future visits to our website. You can opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout

• Other external third parties which are not deemed to be processors such as:

 

• Professional advisers such as law firms, banks, and accountancy firms – which we need to engage with for the purposes of our business and may need to provide data (and this may include sharing your personal data).
  
• Regulators and other governmental authorities – which we need to engage with for the purposes of our business and may need to provide data (and this may include sharing your personal data).

• Third-parties to whom we may be in contact with to sell, transfer or merge parts of our business or our assets, or to attempt to acquire or merge with other companies. In this situation, it would result in the disclosure of your personal information  and we will ensure that it is kept confidential. If a change happens to our business, then the new owners (also known as data controllers) 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, except for when such third-parties are regulators and other governmental organisations.

Your personal data will never be sold to other third parties without your expressed prior consent.

 

HOW LONG DO WE RETAIN YOUR DATA?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

In some circumstances you can ask us to delete your data: see “what are your legal rights?” below for further information.

In some circumstances we will 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.

WHAT ARE YOUR LEGAL RIGHTS?

Under certain circumstances, you have rights under data protection laws in relation to your personal data which we have summarised for you below.

Legal right	What’s it all about?
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 we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data	This applies when 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 the 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: If you want us to establish the data's accuracy. Where our use of the data is unlawful, but you do not want us to erase it. 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. You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
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.
Withdraw consent at any time where we are relying on consent to process your personal data	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.

 

If you wish to exercise any of the rights set out above, please contact us on letschat@leestafford.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. Alternatively, we could refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity. This is a security measure also in your own interest 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 1 month. Occasionally it could take us longer than 1 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.

DATA SECURITY

We have within our group put in place appropriate technical and organisational security measures to prevent your personal data from being accidentally lost, falsified, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, 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 (i.e. in situations where there is a a data protection breach and it is of a high risk, we will personally inform you without delay).

COOKIES

A cookie is a small file of letters and numbers that are stored on your browser, the hard drive of your computer or mobile device, if you agree. 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. For more information about the cookies we use, please see our Cookies Notice.

THIRD-PARTY LINKS + SOCIAL PLUGINS

Our websites may include links to third-party websites. Clicking on those links 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 websites, we encourage you to read the privacy documentation of every website you visit.

We use Instagram and Facebook's social media plug-in. When you click on our website, your personal data will not be shared with Facebook until and unless you click on the social media-plug in and consent to sharing our website content via Facebook or Instagram. It is only in this situation that your personal data would be transferred to Facebook and it would have information about you. In this situation, we encourage you to read the privacy documentation of Facebook.

MARKETING

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. 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.

You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing. We will get your express opt-in consent before we share your personal data with any third-party for marketing purposes. You can ask us or third-parties to stop sending you marketing messages at any time by contacting us at any time on letschat@leestafford.com  and withdrawing your consent. Where you opt out of receiving these marketing messages, this will not apply to messages that we need to send you a result of performing a contract that we have with you (e.g. as we may be required to contact you about a payment due).

CONTACT US

As Lee Stafford takes managing your personal data seriously, we have a team who are responsible for overseeing the management and security of your personal data as well as answering any questions that you have about this Privacy Notice. If you would like to get in touch with this team, please kindly contact letschat@leestafford.com . 

This Privacy Notice is kept under regular review and was last updated on June 22, 2020.