Privacy Policy

Eddie Franks understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits this website, www.eddiefranksrye.co.uk (“Our Site”) and will only collect and use personal data in ways that are described here, and in a way that is consistent with Our obligations and your rights under the law.

Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of this Privacy Policy is requested when; making an online purchase, registering/signing-up for an account, registering/signing-up to receive email newsletters/marketing communications and submitting information via any contact form on Our Site.

1. Definitions and Interpretation

In this Policy the following terms shall have the following meanings:

“Account”	means an account required to access and/or use certain areas and features of Our Site;
“Cookie”	means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in Part 14, below; and
“Our Site”	means this website, eddiefranksrye.co.uk
“UK and EU Cookie Law”	means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;

2. Information About Us

Our Site is owned and operated by W.J Bennett Menswear t/as Eddie Franks, a partnership company registered at the address of 99 High Street, Rye, East Sussex, TN31 7JN.

Eddie Franks main trading address is 13 High Street, Rye, East Sussex, TN31 7JF.
Our VAT number is: GB.347013675.
Our email address is: shop@eddiefranksrye.co.uk
Our telephone number is: 01797 229334.
Our postal address is: 13 High Street, Rye, East Sussex, TN31 7JF.

We are a member of the Federation of Small Bussinesses (FSB) and British Independent Retailers Association (Bira).

3. What Does This Policy Cover?

This Privacy Policy applies only to your use of Our Site. Our Site may contain links to other websites. Please note that We have no control over how your data is collected, stored, or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to them.

4. What is Personal Data?

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

5. What Are My Rights?

Under the Data Protection Legislation, you have the following rights, which We will always work to uphold:

The right to be informed about Our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 15.
The right to access the personal data We hold about you. Part 13 will tell you how to do this.
The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 15 to find out more.
The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that We hold. Please contact us using the details in Part 15 to find out more.
The right to restrict (i.e. prevent) the processing of your personal data.
The right to object to us using your personal data for a particular purpose or purposes.
The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
Rights relating to automated decision-making and profiling. We do not use your personal data in this way.

For more information about Our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 15.

It is important that your personal data is kept accurate and up-to-date. If any of the personal data We hold about you changes, please keep us informed as long as We have that data.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about Our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 15.

6. What Data Do We Collect and How?

Depending upon your use of Our Site, We may collect and hold some or all of the personal and non-personal data set out in the table below, using the methods also set out in the table. Please also see Part 14 for more information about Our use of Cookies and similar technologies and Our Cookie Policy. We do not collect any ‘special category’ or ‘sensitive’ personal data.

Data Collected	How We Collect the Data
Identity Information including Name, Title, Date-of-Birth and Gender.	By receiving submitted information when you create an account and purchase Our products. Also when you sign up to Our mailing lists, request information via our contact forms and email communications or contact us directly over the phone.
Contact information including Email Address, Billing Address, Delivery Address, Telephone Number, including Mobile Numbers.	By receiving submitted information when you create an account and purchase Our products. Also when you sign up to Our mailing lists, request information via our contact forms and email communications or contact us directly over the phone.
Payment and transaction information including card details and bank account numbers.	By receiving submitted information when you purchase Our products.
Profile information including usernames and login details, purchase and order information including purchase history and communication/marketing preferences.	By receiving submitted information when you create an account and purchase Our products. Also when you sign up to Our mailing lists, request information or contact us via our contact forms, email communications or directly over the phone.
Your correspondences and communications with us.	By receiving submitted information when you request information or contact us via our contact forms, email communications or directly over the phone.
Your usage experience regarding Our Site, products and services.	By using analytics services provided by Google Analytics.
Technical information including IP address, web browser type and version; operating system and your activity on Our Site.	By using analytics services provided by Google Analytics.

7. How Do We Use Your Personal Data?

Under the Data Protection Legislation, We must always have a lawful basis for using personal data.

Most commonly, we will use your personal data in the following circumstances:

Where we need to perform the contract we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.

Please take a look at the ICO website to find out more about the types of lawful basis that we will rely on to process your personal data.

With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email, telephone, and text message with information, news, and offers on our products and services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.

Purposes for which We Use Your Personal Data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are, where appropriate.

Purpose/Activity	What Data We Use	Our Lawful Basis
Registering you as a customer on Our Site.	Identity, Contact and Profile	Necessary for our legitimate interests for the performance of a contract with you.
Manage your account and provide customer services to you including processing and fulfilling your order(s), communicating with you about an order and managing refunds, returns and credits for Our products.	Identity, Contact, Profile and Transactional.	Contractual necessity in order to meet our obligations under our contract with you i.e. to deliver a product you have ordered. Also necessary for our legitimate interests handle our customer contact efficiently and effectively.
In the event that you do not complete your registration or order, we may use any contact information you have provided us to follow up on your partial registration or order.	Identity, Contact, Profile	Necessary for our legitimate interests in order to remind you of your partial registration or order and so that you can (if you wish) complete the registration or order.
To manage our relationship with you including notifying you about changes to our terms or privacy policy and to communicate with you i.e. responding to any queries that you may submit.	Identity and Contact	Necessary to comply with legal obligation and necessary for our legitimate interests to keep you up to date with information about our services and to respond to your queries.
To contact you about leaving a review, providing feedback or taking a survey for a product once your order has been completed.	Identity, Contact and Marketing/Communications	Necessary for our legitimate interests to keep our records updated and to study how customers use our products.
To administer and protect our business and website including billing/administrative activities, trouble shooting, data analysis, testing, system maintenance, security, support, reporting and hosting data.	Identity, Contact, Profile and Technical.	Necessary for our legitimate interests for running our business (the provision of administration and IT services, network security and to detect and prevent fraudulent activity). And necessary to comply with legal obligation.
To provide and manage your access to Our Site.	Identity, Profile and Technical.	Necessary for our legitimate interests for the performance of a contract with you and to ensure we provide you with a safe service.
To personalise and tailor your experience on our site and to measure and understand the effectiveness of the marketing we serve you.	Identity, Contact, Usage, Marketing/Communication and Technical.	Necessary for our legitimate interests (to study how customers use our products/ services, to grow our business and to inform our marketing strategy).
To personalise and tailor our services for you including suggestions and recommendations to you about goods or services that may be of interest to you.	Identity, Contact and Marketing/Communication.	Necessary for our legitimate interests (to develop our products/services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy).
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences.	Technical, Usage and Profile.	Necessary for our legitimate interests (to develop our products/services and to grow our business).
Supplying you with information about products and services, promotions and discounts, by email that you have opted-in-to (you may opt-out at any time by unsubscribing using the links provided in our emails).	Identity, Contact and Marketing/Communication.	Necessary for our legitimate interests to study how customers use our products/services, to grow our business and to inform our marketing strategy.

Change of Purpose:

We will only use your personal data for the purpose(s) for which it was originally collected.

If We need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, We will inform you and explain the legal basis which allows us to do so.

In some circumstances, where permitted or required by law, We may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.

8. How Long Will We Keep Your Personal Data?

Whenever we collect your personal data we will only keep it for as long as necessary to fulfil the original purpose it was collected or as required by our legal and regulatory obligations.

Under UK law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for a minimum six years for tax purposes. We also keep this basic information about our customers for up to seven years following your most recent purchase from us, to enable us to deal efficiently with any after-sales queries that you may have.

In some circumstances we may 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.

9. How and Where Do We Store or Transfer Your Personal Data?

We may store or transfer some or all of your personal data in countries that are not part of the European Economic Area (the “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein). These are known as “third countries” and may not have data protection laws that are as strong as those in the UK and/or the EEA. This means that we will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation.

We will only transfer your personal data to third countries whose levels of data protection are deemed ‘adequate’ by the European Commission. More information is available from the European Commission.

Where we transfer your data to a third party based in the US, the data may be protected if they are part of the EU-US Privacy Shield. This requires that third party to provide data protection to standards similar to those in Europe. More information is available from the European Commission.

Please contact us using the details below in Part 15 for further information about the particular data protection mechanisms used by us when transferring your personal data to a third country.

The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:

limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;
procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so;
monitoring of systems storing and processing information;
use of secure technologies (e.g. SSL, encryption).

10. Do We Share Your Personal Data?

We will not share any of your personal data with any third parties for any purposes, subject to the following exceptions.

If We sell, transfer, or merge parts of Our business or assets, your personal data may be transferred to a third party. Any new owner of Our business may continue to use your personal data in the same way(s) that We have used it, as specified in this Privacy Policy.

In some limited circumstances, We may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

11. How Can You Control Your Personal Data?

In addition to your rights under the Data Protection Legislation, set out in Part 5, when you submit personal data via Our Site, you may be given options to restrict Our use of your personal data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in Our emails and, at the point of providing your details and by managing your Account).

You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.

12. Can You Withhold Information?

You may access certain areas of Our Site without providing any personal data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.

You may restrict our use of Cookies. For more information, see Part 14 and our Cookie Policy.

13. How Can You Access Your Personal Data?

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 15.

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We will respond to your subject access request within two working weeks and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

14. How Do We Use Cookies?

Our Site may place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by us and are used only by us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve our products and services. By using Our Site you may also receive certain third-party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, and/or parties other than us. Third-party Cookies are used on Our Site for the purpose of maintaining security and maintaining and administering accounts. In addition, Our Site uses analytic services provided by Google Analytics, which also use Cookies. Website analytics refers to a set of tools used to collect and analyse usage statistics, enabling us to better understand how people use Our Site. For more details, please refer to our Cookie Policy.

15. How Can You Contact Us?

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details:

Our email address is: shop@eddiefranksrye.co.uk

Our telephone number is: 01797 229334.

Our postal address is: 13 High Street, Rye, East Sussex, TN31 7JF.

16. Changes to this Privacy Policy

We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if We change Our business in a way that affects personal data protection.

Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date. This Privacy Policy was last updated on 13th May, 2019.