Privacy Notice

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Privacy Notice

Protecting your privacy

This Privacy Notice explains in detail the types of personal data we may collect about you when you interact with us. It also explains how we’ll store and handle that data, and keep it safe.

We know that there’s a lot of information here, but we want you to be fully informed about your rights, and how Threadster Group uses your data; for example, we will explain things such as our paper data disposal, and how we may combine data across Threadster Group to build a picture of you. 

We hope the following sections will answer any questions you have but if not, please do get in touch with us.

Threadster Group (Threadster Limited) is the British retail and manufacturing company that operates Mrs Bow Tie (MrsBowTie.com), and other brands. 

The primary domain for Mrs Bow Tie is www.mrsbowtie.com, which serves all countries that the business ships to. There are also international versions of this domain, such as www.us.mrsbowtie.com, which is specific to the United States of America. This Privacy Notice applies to all domains, brands and areas of the business. 

For simplicity throughout this notice, ‘we’ and ‘us’ means the Group and its brands.

The law on data protection sets out a number of different reasons for which a company may collect and process your personal data, including:

- CONSENT
In specific situations, we can collect and process your data with your consent. For example, when you tick a box to receive email newsletters. 

When collecting your personal data, we’ll always make clear to you which data is necessary in connection with a particular service.

- CONTRACTUAL OBLIGATIONS
In certain circumstances, we need your personal data to comply with our contractual obligations. For example, if you order an item from us for home delivery, we’ll collect your address details to deliver your purchase, and pass them to our courier.

- LEGAL COMPLIANCE
If the law requires us to, we may need to collect and process your data. For example, we can pass on details of people involved in fraud or other criminal activity affecting the Group to law enforcement.

- LEGITIMATE INTEREST
In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests.

For example, we will use your purchase history to send you or make available personalised offers. We also combine the shopping history of many customers to identify trends and ensure we can keep up with demand, or develop new products/services. We might also use your address details to send you direct marketing information by post, telling you about products and services that we think might interest you.

When you visit any of our websites, and use your account to buy products and services, or redeem vouchers from Threadster Group on the phone, or online.

When you make an online purchase and check out as a guest (in which case we just collect transaction-based data).

When you create an account with us.

When you purchase a product or service online or by phone but don’t have (or don’t use) an account.

When you engage with us on social media.

When you download or install one of our apps. 

When you join our Reward Program.

When you contact us by any means with queries, complaints etc.

When you ask one of our Partners to email you information about a product or service.

When you enter prize draws or competitions.

When you book any kind of appointment with us or book to attend an event.

When you choose to complete any surveys we send you. 

When you comment on or review our products and services. Any individual may access personal data related to them, including opinions. So if your comment or review includes information about the Partner who provided that service, it may be passed on to them if requested.

When you’ve given a third party permission to share with us the information they hold about you.

When you use our car park or visit our premises, which have CCTV systems operated for the security of both customers and Partners. These systems may record your image during your visit.

- If you have a web account with us: your name, gender, date of birth, billing/delivery address, orders and receipts, email and telephone number. For your security, we’ll also keep an encrypted record of your login password. Your login password is not visible or accessible to any employees of Threadster Group.

- Details of your interactions with us through contact centres, online or by using one of our apps. For example, we collect notes from our conversations with you, details of any complaints or comments you make, details of purchases you made, items viewed or added to your basket, voucher redemptions, products you show interest in, web pages you visit and how and when you contact us.

- Copies of documents you provide to prove your age or identity where the law requires this (including your passport and driver's licence). This will include details of your full name, address, date of birth and facial image. If you provide a passport, the data will also include your place of birth, gender and nationality.

- Details of your shopping preferences.

- Details of your visits to our websites or apps, and which site you came from to ours.

- Information gathered by the use of cookies in your web browser.

- Personal details which help us to recommend items of interest. For example, you might tell us your neck size, which we might store to help ensure you get the correct item in future purchases.

- To deliver the best possible web experience, we collect technical information about your internet connection and browser as well as the country and telephone code where your computer is located, the web pages viewed during your visit, the advertisements you clicked on, and any search terms you entered.

- Your social media username, if you interact with us through those channels, to help us respond to your comments, questions or feedback.

- Your image and car registration number plate may be recorded on CCTV when you visit our premises or car park.

- Your comments and product reviews.

- Payment card information.

We want to give you the best possible customer experience. One way to achieve that is to get the richest picture we can of who you are by combining the data we have about you.

We then use this to offer you promotions, products and services that are most likely to interest you. In the case of loyalty scheme members, we’ll also offer you relevant rewards.

The data privacy law allows this as part of our legitimate interest in understanding our customers and providing the highest levels of service.

Of course, if you wish to change how we use your data, you’ll find details in the ‘What are my rights?’ section below.

Remember, if you choose not to share your personal data with us, or refuse certain contact permissions, we might not be able to provide some services you’ve asked for. For example, if you’ve asked us to let you know when an item comes back into stock, we can’t do that if you’ve withdrawn your general consent to hear from us.

Here’s how we’ll use your personal data and why:

To process any orders that you make by using our websites, apps or in store. If we don’t collect your personal data during checkout, we won’t be able to process your order and comply with our legal obligations. For example, your details may need to be passed to a third party to supply or deliver the product or service that you ordered, and we may keep your details for a reasonable period afterwards in order to fulfil any contractual obligations such as refunds, guarantees and so on.

To respond to your queries, refund requests and complaints. Handling the information you sent enables us to respond. We may also keep a record of these to inform any future communication with us and to demonstrate how we communicated with you throughout. We do this on the basis of our contractual obligations to you, our legal obligations and our legitimate interests in providing you with the best service and understanding how we can improve our service based on your experience.

To protect our business and your account from fraud and other illegal activities. This includes using your personal data to maintain, update and safeguard your account. We’ll also monitor your browsing activity with us to quickly identify and resolve any problems and protect the integrity of our websites. We’ll do all of this as part of our legitimate interest. For example, using automated monitoring of IP addresses to identify possible fraudulent log-ins from unexpected locations.

To process payments and to prevent fraudulent transactions. We do this on the basis of our legitimate business interests. This also helps to protect our customers from fraud.

If we discover any criminal activity or alleged criminal activity through our use of CCTV, fraud monitoring and suspicious transaction monitoring, we will process this data for the purposes of preventing or detecting unlawful acts. We aim is to protect the individuals we interact with from criminal activities.

With your consent, we will use your personal data, preferences and details of your transactions to keep you informed by email, web, text, telephone and through our contact centres about relevant products and services including tailored special offers, discounts, promotions, events, competitions and so on. Of course, you are free to opt out of hearing from us by any of these channels at any time.

To send you relevant, personalised communications by post in relation to updates, offers, services and products. We’ll do this on the basis of our legitimate business interest. You are free to opt out of hearing from us by post at any time.

To send you communications required by law or which are necessary to inform you about our changes to the services we provide you. For example, updates to this Privacy Notice, product recall notices, and legally required information relating to your orders. These service messages will not include any promotional content and do not require prior consent when sent by email or text message. If we do not use your personal data for these purposes, we would be unable to comply with our legal obligations.

To display the most interesting content to you on our websites or apps, we’ll use data we hold about your favourite brands or products and so on. We do so on the basis of your consent to receive app notifications and/or for our website to place cookies or similar technology on your device. For example, we might display a list of items you’ve recently looked at, or offer you recommendations based on your purchase history and any other data you’ve shared with us.

To administer any of our prize draws or competitions which you enter, based on your consent given at the time of entering.

To develop, test and improve the systems, services and products we provide to you. We’ll do this on the basis of our legitimate business interests.

To comply with our contractual or legal obligations to share data with law enforcement.

To send you survey and feedback requests to help improve our services. These messages will not include any promotional content and do not require prior consent when sent by email or text message. We have a legitimate interest to do so as this helps make our products or services more relevant to you. Of course, you are free to opt out of receiving these requests from us at any time by updating your preferences in your online account.

We also use anonymised data from customer purchase histories to identify trends in different countries and regions. This may then guide which products we display in particular stores.

Sometimes, we’ll need to share your details with a third party who is providing a service (such as delivery couriers or a business receiving your order). We do so to maintain our appointment with you. Without sharing your personal data, we’d be unable to fulfil your request.

We want to bring you offers and promotions that are most relevant to your interests at particular times. To help us form a better, overall understanding of you as a customer, we combine your personal data gathered across Threadster Group as described above, for example your shopping history at both www.mrsbowtie.com and www.us.mrsbowtie.com. For this purpose we also combine the data that we collect directly from you with data that we obtain from third parties to whom you have given your consent to pass that data onto us – such as the Land Registry.

We know how much data security matters to all our customers. With this in mind we will treat your data with the utmost care and take all appropriate steps to protect it.

We secure access to all transactional areas of our websites and apps using ‘https’ technology.

Access to your personal data is password-protected, and sensitive data (such as payment card information) is secured by SSL encryption.

We regularly monitor our system for possible vulnerabilities and attacks, and we carry out penetration testing to identify ways to further strengthen security.

All information printed into physical form (such as the manufacturing order form used during the manufacturing of your order) is securely destroyed. Using a third party company, all documents containing information about customers are placed in confidential waste bags, which are collected from our premises and incinerated.

Whenever we collect or process your personal data, we’ll only keep it for as long as is necessary for the purpose for which it was collected.

At the end of that retention period, your data will either be deleted completely or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning.

We sometimes share your personal data with trusted third parties. For example, delivery couriers, for fraud management, to handle complaints, to help us personalise our offers to you and so on.

Here’s the policy we apply to those organisations to keep your data safe and protect your privacy:

- We provide only the information they need to perform their specific services.

- They may only use your data for the exact purposes we specify in our contract with them.

- We work closely with them to ensure that your privacy is respected and protected at all times.

- If we stop using their services, any of your data held by them will either be deleted or rendered anonymous.

Sharing your data with third parties for their own purposes:

- We will only do this in very specific circumstances, for example, with your consent, given at the time you supply your personal data, we may pass that data to a third party for their direct marketing purposes. An example of this is, if you enter a holiday competition and tick a box agreeing that the travel company can send you promotional information directly. Or if we run a joint event with a restaurant, and you agree to receive direct communications from them.

- For fraud management, we may share information about fraudulent or potentially fraudulent activity in our premises or systems. This may include sharing data about individuals with law enforcement bodies.

- We may also be required to disclose your personal data to the police or other enforcement, regulatory or Government body, in your country of origin or elsewhere, upon a valid request to do so. These requests are assessed on a case-by-case basis and take the privacy of our customers into consideration.

- We may, from time to time, expand, reduce or sell Threadster Group and this may involve the transfer of divisions or the whole business to new owners. If this happens, your personal data will, where relevant, be transferred to the new owner or controlling party, under the terms of this Privacy Notice.

Sometimes we will need to share your personal data with third parties and suppliers outside the European Economic Area (EEA), such as Australia or the USA.

International orders

If you are based outside the UK and place an order with us, we will transfer the personal data that we collect from you to the Group in the UK.

Protecting your data outside the EEA

The EEA includes all EU Member countries as well as Iceland, Liechtenstein and Norway. We may transfer personal data that we collect from you to third-party data processors in countries that are outside the EEA.

If we do this, we have procedures in place to ensure your data receives the same protection as if it were being processed inside the EEA. For example, our contracts with third parties stipulate the standards they must follow at all times.

Any transfer of your personal data will follow applicable laws and we will treat the information under the guiding principles of this Privacy Notice.

An overview of your different rights

You have the right to request:
- Access to the personal data we hold about you, free of charge in most cases.
- The correction of your personal data when incorrect, out of date or incomplete. For example, when you withdraw consent, or object and we have no legitimate overriding interest, or once the purpose for which we hold the data has come to an end (such as the end of a warranty).
- That we stop using your personal data for direct marketing (either through specific channels, or all channels).
- That we stop any consent-based processing of your personal data after you withdraw that consent. Review by a Partner of any decision made based solely on automatic processing of your data (i.e. where no human has yet reviewed the outcome and criteria for the decision).

You have the right to request a copy of any information about you that the Partnership holds at any time, and also to have that information corrected if it is inaccurate. To ask for your information, please contact Data Protection, Threadster Group, 33b West Way, Andover, SP10 5JG. To ask for your information to be amended, please update your online account, or contact our Customer Services team.

If we choose not to action your request we will explain to you the reasons for our refusal

Your right to withdraw consent
Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent

Where we rely on our legitimate interest
In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.

Direct marketing
You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We must always comply with your request

Checking your identity
To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Notice. If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.

There are several ways you can stop direct marketing communications from us:

- Click the ‘unsubscribe’ link in any email communication that we send you. We will then stop any further emails from that particular division.

- If you have an account, visit the ‘My Account’ area and change your preferences.

- In our apps, you can manage your preferences and opt out from one or all of the different push notifications by selecting or deselecting the relevant options in the ‘Settings’ section. Write to Data Protection, Threadster Group, 33b West Way, Andover, SP10 5JG.

Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated.

For all non-UK customers

By using our services or providing your personal data to us, you expressly consent to the processing of your personal data by us or on our behalf. Of course, you still have the right to ask us not to process your data in certain ways, and if you do so, we will respect your wishes.

Sometimes we’ll need to transfer your personal data between countries to enable us to supply the goods or services you’ve requested. In the ordinary course of business, we may transfer your personal data from your country of residence to ourselves and to third parties located in the UK.

By dealing with us, you are giving your consent to this overseas use, transfer and disclosure of your personal data outside your country of residence for our ordinary business purposes.

This may occur because our information technology storage facilities and servers are located outside your country of residence, and could include storage of your personal data on servers in the UK.

We’ll ensure that reasonable steps are taken to prevent third parties outside your country of residence using your personal data in any way that’s not set out in this Privacy Notice. We’ll also make sure we adequately protect the confidentiality and privacy of your personal data.

In order to be able to offer you Klarna’s payment options, we will pass to Klarna certain of your personal information, such as contact and order details, in order for Klarna to assess whether you qualify for their payment options and to tailor the payment options for you.

General information on Klarna you can find here. Your personal data is handled in accordance with applicable data protection law and in accordance with the information in Klarna’s privacy policy.

We hope this Privacy Notice has been helpful in setting out the way we handle your personal data and your rights to control it.

If you have any questions that haven’t been covered, please contact us by post and who will be pleased to help you: Data Protection, Threadster Group, 33b West Way, Andover, SP10 5JG.

This notice was last updated on 24/05/2018.

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