INTRODUCTION

May 2018

About Guilty Dolls and this Privacy Policy

Guilty Dolls Limited is a company incorporated and registered in England and Wales with company number 09881983 and having its registered office at Guilty Dolls 19 Montpelier Avenue, Bexley, Kent, United Kingdom, DA5 3AP (referred to in this Policy as Guilty Dolls, “we, “us” and “our”). We are a “data controller” of your information for the purposes of the Data Protection Act 2018 and the EU General Data Protection Regulation (GDPR) (together with the Data Protection Laws) (i.e. we are responsible for, and control the processing of, your personal information). We will use your personal data fairly, lawfully and in a transparent manner, and in accordance with the Data Protection Laws.

Controller, Data Subject, Processor and Processing shall have the respective meanings given to them in applicable Data Protection Laws from time to time (and related expressions, including process, processed, and processes shall be construed accordingly) and international organisation shall have the meaning given to it in the GDPR;

This Privacy Policy outlines how Guilty Dolls will use, store and share your personal data, and supplements any other fair processing or privacy notices provided to you.

This policy applies to any personal data that we collect about you when you:

  • Visit our website www.guiltydolls.com (our “website”);
  • Create an account with us (whether online or in-store);
  • Contact us, for example by telephone, email, post or through submitting a form on our website;
  • Place an order with us;
  • Interact with our digital content on your computer or mobile device;
  • Sign up to receive email newsletters or catalogues;
  • Attend a Guilty Dolls sponsored event;
  • Enter a competition;
  • Call Customer Care;
  • Send us an enquiry.

Guilty Dolls takes the privacy and security of your personal data very seriously. We only capture information from you that we need to deliver our services effectively and to keep in contact with you on the basis necessary to fulfil our obligations or as agreed between us. We will only use your personal data for any purpose that is necessary to fulfil our commitments to you, comply with regulation or to fulfil an activity that you have consented to participate in.

At Guilty Dolls, we identify a customer when visiting our Website or stores with regard to the use, storage, deletion and other processing of personal data. These are:

  • An Account Holder: Someone who has registered for an Account and chosen to save basic information about themselves to facilitate an enhanced customer experience based on our knowledge of that individual
  • A Guest User: Someone who purchases products or registers for communications but does not create an Account

To understand what personal information is collected on our Website when purchasing products or registering for an account or email newsletter, (including how it is captured and subsequently used to ensure a great service for you), please see the details below.

At Guilty Dolls, we believe it is important to share with you why we capture some data about you and the circumstances when we might be required to share it with third parties to deliver our services and comply with regulations.

Once we have your data, if at any time you wish to change your communication preferences please go to the ‘My Account’ section on the Website, or email privacy@guiltydolls.com If you require information on any of your rights in regards to the use of your Personal Data please see the section ‘Your Rights’ toward the end of this Policy.

We will at all times seek to comply with the requirements of the Data Protection Laws in respect of all data that we collect from you, including ensuring that your personal information given to us is kept appropriately secure and is processed lawfully.

 

DATA COLLECTION AND HOW WE USE IT

DATA COLLECTION AND HOW WE USE IT

When you create an account with us online, place an order, interact with our digital content on your computer or mobile device, sign up to receive email newsletters or catalogues, attend a Guilty Dolls sponsored event, enter a competition, call customer care, or send us an enquiry, we will collect certain personal information from you necessary to perform our services. Please select from the different sections of this Privacy Policy to learn more about what personal information we collect and what we use it for.

  1. Personal details, ‘My Account’ management
  2. Marketing communication & preferences
  3. Personalised experience
  4. Information about your device
  5. Location information
  6. How we will use your personal information
  7. The basis for using your information
  8. Communication preferences
  9. Communication with Guilty Dolls Customer Care
  1. Personal details, ‘My Account’ management

When you register for an Account with us we will collect personal data from you and you can view this in the ‘My Account’ section. This may include but is not limited to your name, postal address, billing address, phone numbers, e-mail address and payment information, order history and your preferences relating to what and how we may communicate with you.

We may also obtain information about you as a result of authentication or identity checks (for example in connection with our standard fraud checks when you make a purchase on our Website). We use this information to identify you as a customer, to process your order, to enable us to deliver products and services, to process payments, to update our records, and to generally manage your account with us. If we are not able to obtain this information we may not be able to provide services to you or respond to your queries.

To fulfil our services to you we may also use third-party services as Data Processors to provide elements of our overall service such as couriers for delivery of parcels and payment service providers for taking and approving the payment.

Where we have given you (or where you have chosen) a password that enables you to access certain parts of our Website such as ‘My Account’, you must keep this password confidential. Please never share your password with anyone. No one from Guilty Dolls will ever ask you to disclose it.

If you have an online customer account, you can amend or update your personal information by logging into the ‘My Account’ section on our Website and amending your details as appropriate. This can include managing your communication preferences, contact and delivery information.

  1. Marketing communication & preferences

Guilty Dolls would like to send you information by email or post about products, services, competitions, sales and special offers which may be of interest to you. There are several ways you can consent to our marketing: you can tick the relevant boxes on our account registration form; you can tick the relevant boxes in the ‘My Account’ section of the Website, or by contacting our Customer Services team by email at privacy@guiltydolls.com

If you have consented to marketing communication, by opting in, we will send you marketing messages until you specify otherwise in your ‘My Account’ section or by contacting our Customer Services team at privacy@guiltydolls.com

You can opt out at any time and from specific methods of marketing. Please see the ‘How do I unsubscribe from communication’ section below. Alternatively, you can email privacy@guiltydolls.com

  1. Personalised experience

In order to offer you a personalised and relevant experience on our Website and in store, we may collect information about the products you purchase, where you purchased the products from and other information related to your purchases.

We may also collect information about your browsing history, including the product pages you visit and the content you are looking at. We do this to help us analyse how users use the website (including behaviour patterns), to understand more about our website users and to assist us in improving your online experience.

You can opt out of a personalised experience at any time by emailing privacy@guiltydolls.com

  1. Information about your device

We may also collect information on how you access our digital content and services and the type of device and internet browser you are using. This includes information relating to your device type, your IP address and your visit source (i.e. a website from which you visited our Website). This information helps us ensure we are able to provide effective technical services to enable you to access the right content from where you are located in a format appropriate to the device you are using and to troubleshoot any issues you may have if you report them to us.

For information about cookies and other technologies which are used on our Website, please see our Cookie Policy.

  1. Location information

We use your active location information (i.e. that relating to your mobile phone physical location or the IP address from which you access our Website) to ensure you are directed to the relevant Website for the country you are residing in to ensure the right currency and options are presented to you. We do not use your location information for any other purposes.

  1. How we will use your personal information

We use your information (i) for research about our customers’ behaviour and our products and services generally; (ii) to develop and improve our services; (iii) to administer and improve our website to ensure that content is presented in the most effective manner; (iv) to notify you about changes to our goods and services; and (v) to provide customer support. By analysing and monitoring your personal data we can enhance the customer experience and be more relevant with our marketing and communication.

You can opt out at any time and from specific methods of marketing. Please see the ‘How do I unsubscribe from communication?’ section below. Alternatively, you can email privacy@guiltydolls.com

  1. The basis for using your information

Necessary for the entry into or performance of a contract

When you order or purchase products from us we will enter into a contract with you to supply the products to you. In order for us to fulfil our obligations under such contract, we will need to collect, process and share (as further detailed below) your personal information. Failure to provide the requisite personal information including the required financial information in relation to such orders or purchases, or objecting to this type of processing / exercising your deletion rights, will, unfortunately, mean we cannot provide our products to you.

Legitimate business interests

We use your personal information as set out in this Policy for the legitimate interests of our business to enable us to:

  • Provide you with information about our products, services, competitions, sales and special offers which may be of interest to you;
  • Develop and improve our products and services for you and others;
  • Understand you better and enhance your experience with Guilty Dolls ;
  • Analyse and monitor your personal data so we can be more relevant with our marketing and communication;
  • Carry out research to understand our website visitors and other customers’ behaviour, how they use our website and services so we can develop and improve our products and services for you and others;
  • Record details from calls to our Customer Care Team in order to enable us to provide a better service to our customers and for quality assurance purposes;
  • Record details if you contact us via our Website using our Live chat service in order to ensure a high level of customer service in terms of understanding any issues you may have faced with ordering from our Website.

We are required to carry out a balancing test of our legitimate business interests in using your personal data outlined above against your interests and rights under the Data Protection Laws. As a result of our balancing test, which is detailed below, we have determined, acting reasonably and considering the circumstances, that we are able to process your personal data in accordance with the Data Protection Laws on the basis that we have a legitimate business interest.

Legitimate interest We have a legitimate business interest in processing your information as we wish to:

§ Provide you with information about our products, services, competitions, sales and special offers which may be of interest to you;

§ Develop and improve our products and services for you and others;

§ Understand you better and enhance your experience with Guilty Dolls ;

§ Analyse and monitor your personal data so we can be more relevant with our marketing and communication;

§ Carry out research to understand our website visitors and other customers’ behaviour, how they use our website and services so we can develop and improve our products and services for you and others;

§ Record details from calls to our Customer Care Team in order to enable us to provide a better service to our customers and for quality assurance purposes.

§ Record details if you contact us via our Website using our live chat service in order to ensure a high level of customer service in terms of understanding any issues you may have faced with ordering from our Website.

Necessity We consider that it is reasonably necessary for us to process your personal data for the purposes of our legitimate interests outlined above as we process your personal data only so far as is necessary to achieve the purposes outlined above and as explained in this privacy policy.
Impact of processing We consider that it is reasonable for us to process your personal data for the purposes of our legitimate interests outlined above as the processing of your personal data for these purposes does not unreasonably intrude on your privacy.

Consent

We may, on occasion, send you marketing messages by email and post about us, our products, events, promotions and services where you have not unsubscribed and where you have purchased similar goods or services from us or where you have otherwise consented. You can opt out at any time and from specific methods of marketing. Please see the ‘How do I unsubscribe from communication’ section below. Alternatively, you can email privacy@guiltydolls.com

  1. Communication preferences

If you have consented to receive promotional information or updates from Guilty Dolls, we will contact you with information about our products, events, promotions and services by post or by e-mail. Occasionally we may get in touch to request feedback on our Website and/or at an event, in order to improve our products and services.

You can opt out at any time and from specific methods of marketing. Please see the ‘How do I unsubscribe from communication’ section below. Alternatively, you can email privacy@guiltydolls.com

  1. Communication with Guilty Dolls Customer Care

please note that our Customer Care team may record details from your interaction for up to 30 days, in order to enable us to better service our customers, and for quality assurance purposes. If you contact us via our Website we will store the conversations for 13 months in order to ensure a high level of customer service in terms of understanding any issues you may have faced with ordering from our Website.

 

HOW DO I UNSUBSCRIBE FROM COMMUNICATION?

You can opt out of marketing communication such as email newsletters and catalogues at any time. All you need to do is change your communication preferences in ‘My Account’. You can do that either as indicated in the particular communication, e.g. by using the unsubscribe link which is included on all emails.

If you choose to opt out of marketing emails, this can take up to two weeks for the change to flow through our systems.

Please remember, if you do ‘opt out’ of receiving this information you are more likely to miss out on offers and rewards.

Even if you have opted out of receiving emails we will continue to send you transactional emails about your purchases or requesting feedback on products purchased for the purposes of performing our contract with you. You can also unsubscribe from product emails by clicking on the unsubscribe link within these emails.

You can opt out of a personalised web experience at any time. Please see ‘Your Rights’ section below. Alternatively, you can email privacy@guiltydolls.com

 

YOUR PERSONAL INFORMATION AND HOW LONG WE KEEP IT

We will only keep your information as long as you have an account with us and for 5 years after your last purchase or otherwise as required for our business operations records or by law. If you are a guest user, we will only keep your information for 24 months after your order has been fulfilled or otherwise as required for our business operations records or by law. This information will be kept secure at all times and only used for the legitimate purpose we require it or that you have consented to. After the stated period of time expires, we will anonymise all of your personal data, however, some order information will be stored as an unknown customer.

Where information is entered but not completed, such as in adding items to your shopping basket but not completing checkout, we will delete this data after 30 days for a Guest User and 60 days for an Account Holder.

 

COOKIES AND HOW WE USE THEM

We use cookies, local storage and other similar technologies which may place codes on or access information from and/or about your device to elevate your user experience and the quality of our Website and service. This includes remembering what you have added to your basket, your wish list and what you have browsed. We will also recognise you when you visit our Website and where you have visited from. Please see the Cookie Policy for more information.

 

OTHER PEOPLE WHO MIGHT USE YOUR INFORMATION

In certain circumstances, we may share your information with carefully selected partners or service providers who perform functions as a Data Processor on our behalf such as:

  • Creating an account, fulfilling orders, processing payments, fraud risk management, and data management on our behalf;
  • Handling our order dispatch service and other deliveries;
  • Website hosting services;
  • Assisting Guilty Dolls in promoting our products and services in order to provide you with enhanced customer services and/or share information about Guilty Dolls products and services with you;
  • Assisting Guilty Dolls with analysing our customer data in order to better understand, profile and monitor customer patterns so we can consistently improve our products and services and understand what may be of interest to you and other customers;
  • Other support services.

In each case, we will only provide these partners or service providers with the information which they need to carry out their services. They will not be permitted to use the information for other purposes and will be bound by the same duty of care as us regarding data privacy. They will only be allowed to use your information in the way in which we instruct them and as permitted by the Data Protection Laws.

We may also share aggregated or anonymised information that does not identify you with partners or service providers.

Financial institutions and payment processing partners

Payments on our Website are made through our payment solutions providers. You will be providing credit or debit card information directly to our providers who process payment details in a secure manner.

Legal disclosures

In certain circumstances we may disclose personal information relating to you to third parties in order to conform to any requirements of law, to comply with any legal process, for the purposes of obtaining legal advice, for the purposes of credit risk reduction, to prevent and detect fraud and/or to protect and defend the rights and property of Guilty Dolls .

Business or process change partners

In the event that we or a part of our business undergo re-organisation or are sold to a third party, any personal information we hold about you may be transferred and/or disclosed to that re-organised entity or third party.

Overseas transfers of data

The personal information that you provide through our Website is processed within the European Economic Area (EEA). We may transfer information that we collect from you to our affiliated companies, partners and service providers who assist Guilty Dolls in delivering and promoting its products and services and to selected service providers/Data Processors who perform functions on our behalf, based in countries outside of the EEA or your country of residence and this information may be stored and processed in such countries which may not be countries that the European Commission has deemed to have adequate security in place. We have therefore incorporated the European Commission approved clauses into our agreement with such partners and service providers to ensure the security of your personal data. A copy of the European Commission approved model clauses is available here: http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32010D0087&from=en] Whether the personal information you provide to us is processed by us, our affiliated companies, partners or services providers within the EEA or outside of it, we will take steps to ensure that your personal information will be afforded the same level of protection required of us under and in accordance with this Privacy Policy and applicable data protection laws and in accordance with current legally recognised data transfer mechanisms. We transfer such data as we deliver our products globally and work across the world and work with a number of worldwide partners to deliver our products. Additionally, our partners may change over time. We always strive to have appropriate safeguards in place with each of our suppliers.

 

THIRD PARTY LINKS

Our Website may from time to time contain links to other websites not controlled by us. You will know when the link is taking you to another website as a new window will pop up. Whilst we try to ensure all third-party links are to websites which are compliant with Data Protection Laws, we cannot guarantee this is always the case. If you click on any of the links to such websites from our Website, you should review that website’s privacy statements or