Privacy policy 

 Introduction 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 uses your data; for example, we will explain things such as our credit checking procedure, and how we combine data 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.  It’s likely that we’ll need to update this Privacy Notice from time to time. We’ll notify you of any significant changes via email, but you’re welcome to come back and check it whenever you wish.  Who WE are Our company is trading as Floe & Harmony Ltd. 

This Privacy Notice applies to mainland UK orders.  For simplicity throughout this notice, ‘we’ and ‘us’ means Floe & Harmony ltd Explaining the legal business we rely on. 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 Floe & Harmony Ltd 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 will also send you direct marketing emails when you shop with us and do not choose to opt out – this is often called a ‘soft opt in’.  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.  With your consent, or when you shop with us and do not choose to opt out from receiving our emails (‘soft opt in’) we will use your personal data, preferences and details of your transactions to keep you informed by email about relevant products and services including tailored special offers, discounts, promotions, events, competitions and so on. This is only applicable in the UK.  When do we collect your personal data?  When you visit our websites, and use your account to buy products and services, or redeem vouchers 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 shop online, we capture information through cookies and similar technologies, you can manage these when you visit our site. When you engage with us on social media. When you contact us by any means with queries, complaints etc. When you ask us to email you information about a product or service. When you enter prize draws or competitions. When you choose to complete any surveys we send you. When you comment on or review our products and services.  What sort of personal data do we collect?  If you have a web account with us: your name, gender, date of birth, billing/delivery address, orders and receipts, email and telephone number. Details of your interactions with us. 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, gift list and wish list choices, voucher redemptions, brands you show interest in, web pages you visit and how and when you contact us.  Details of your shopping preferences. Details of your visits to our website, and which site you came from to ours. Information gathered by the use of cookies in your web browser. Learn more about how we use cookies and similar technologies. Personal details which help us to recommend items of interest. We’ll only ask for and use your personal data collected for recommending items of interest and to tailor your shopping experience with us. Of course, it’s always your choice whether you share such details with us.  Payment card information. Your comments and product reviews. 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. Learn more about this. Your social media username, if you interact with us through those channels, to help us respond to your comments, questions or feedback. How and why do we use your personal data?  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.  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.  Here’s how we’ll use your personal data and why:  To process any orders that you make by using our website. 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 send you email notifications when you place a product in your basket and you abandon your browsing before completing your checkout. We do this based on our legitimate interest. 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, by checking your password when you login and using automated monitoring of IP addresses to identify possible fraudulent logins 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 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, or whenever you purchase with us and do not choose out of receiving our updates, we will use your personal data, preferences and details of your transactions to keep you informed by email about relevant products and services including tailored special offers, discounts, promotions, events, competitions and so on. This is only applicable within the UK. Of course, you are free to opt out of hearing from us by any of these channels 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. For example, we’ll record your browser’s Session ID to help us understand more when you leave us online feedback about any problems you’re having to comply with our contractual or legal obligations to share data with law enforcement. For example, when a court order is submitted to share data with law enforcement agencies or a court of law 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. To build a rich picture of who you are and what you like, and to inform our business decisions, we’ll combine data captured from Floe & Harmony Website, third parties and data from publicly available lists as we have described in the section ‘What Sort of Personal Data do we collect?’ We’ll do this on the basis of our legitimate business interest. Combining you for personalised direct marketing 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 Floe & Harmony website.  How we protect your personal data 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 and tokenised to ensure it is protected. We regularly monitor our system for possible vulnerabilities and attacks, and we carry out penetration testing to identify ways to further strengthen security.  How long will we keep your personal data?  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.  For example, when you place an order, we’ll keep the personal data you give us for five years so we can comply with our legal and contractual obligations.  Who do we share your personal data with?  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. Examples of the kind of third parties we work with are:  IT companies who support our website and other business systems. Operational companies such as delivery couriers. Direct marketing companies who help us manage our electronic communications with you. Google/Facebook to show you products that might interest you while you’re browsing the internet. This is based on either your marketing consent or your acceptance of cookies on our websites. See our Cookies Notice for details. Data insight companies to ensure your details are up to date and accurate.  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. 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 the Partnership 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. For further information please contact our Data Protection Officer.  What are your rights to your personal data?  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. The deletion of the data we hold about you, in specific circumstances; 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). A computer file in a common format (CSV or similar) containing the personal data that you have previously provided to us, and the right to have your information transferred to another entity where this is technically possible. Restriction of the use of your personal data, in specific circumstances, generally while we are deciding on an objection you have made. That we stop processing your personal data, in specific circumstances; for example, when you have withdrawn consent, or object for reasons related to your individual circumstances. 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 (so where no human has yet reviewed the outcome and criteria for the decision). You can contact us to request to exercise these rights at any time by completing an online form. If we choose not to action your request, we will explain 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, such as administration of an extended warranty.  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.  How can you stop the use of your personal data used for marketing?  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, log in into your www.floeandharmony.co.uk or 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. Email us on info@floeandharmony.co.uk Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated.  Contacting the regulator if you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.  You can contact them by calling 0303 123 1113.  Or go online to www.ico.org.uk/concerns (opens in a new window; please note we can’t be responsible for the content of external websites) Any Questions?  

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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 our Data Protection Officer who will be pleased to help you:  Email us at info@floeandharmony.co.uk