CONTENTS OF PRIVACY NOTICE
1. IMPORTANT INFORMATION AND WHO WE ARE
This Privacy Notice has been prepared in accordance with the General Data Protection Regulations (“GDPR”). The GDPR aims to protect and enhance the rights of data subjects. Treasure House Limited recognises the importance of the correct and lawful treatment of personal information and will only use personal data as set out in this Privacy Notice. This Privacy Notice explains in detail the types of personal data we may collect about you when you interact with us including through our websites (www.treasurehouseco.com and www.iwantgoldanddiamonds.com). It also explains how we will store and handle that data and keep it safe.
We know that there is a lot of information here, but we want you to be fully informed about your rights, and how Treasure House Limited uses your data.
Our websites are not intended for children and we do not knowingly collect data relating to children.
It is important that you read this Privacy Notice together with any other privacy notice or Treasure House Limited terms and conditions we may provide on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data. This Privacy Notice supplements the other notices and is not intended to override them.
We hope the following sections will answer any questions you have but if not, please do get in touch with us.
Treasure House Limited is the controller and responsible for your personal data (collectively referred to as “Treasure House”, “we”, “us”, or “our” in this privacy notice).
We have appointed a Data Protection Officer to oversee compliance with this Privacy Notice. If you have any questions about the Privacy Notice or how we handle your personal data, please contact our Data Protection Officer by email or post.
You have the right to request a copy of any information about you that Treasure House holds at any time, and also to have that information corrected if it is inaccurate. To ask for your information, please contact Data Protection Officer, Treasure House Company, 45 Kirby Street, Hatton Garden, London EC1N 8TE or email email@example.com. To ask for your information to be amended, please update your online account, contact us by email at firstname.lastname@example.org or by post.
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. We may change this Privacy Notice at any time by updating this page, so you should therefore check our websites from time to time to ensure you are aware of any changes.
Our websites may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may 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 notice of every website you visit.
2. THE DATA WE COLLECT ABOUT YOU
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).
- Identity Data includes first name, maiden name, last name, username or similar identifier, title and gender.
- Contact Data includes billing address, delivery address, email address and telephone numbers.
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments to and from you.
- Technical Data includes IP 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 the websites.
- Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our websites, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
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 or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
Direct interactions. You may give us your Identity, Contact and
Financial Data by
filling in forms or by corresponding with us by post, phone, email or otherwise. This
includes personal data when you:
- create a Trade Account with us
- ask us to email/post you information about a service we provide
- contact us via any means with a query, complaint or quotation request
Third parties or publicly available sources. We may receive personal
data about you from
various third parties as set out below:
- The Company of Master Jewellers Ltd
4. HOW WE USE YOUR PERSONAL DATA
- 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
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
PURPOSES FOR WHICH WE WILL 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.
Note that we may process your personal data for more than one lawful ground depending on the specific purposes for which we are using your data. Please contact us 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 below.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|Contacting you regarding orders||Identity, Contact||Performance of contract with you|
|Register you as a new customer||Identity, Contact, Financial||Performance of a contract with you|
|To process and deliver your order||Identity, Contact||Performance of a contract with you|
|Retain transactions||Financial||Necessary to comply with a legal obligation|
|Retain Credit Card Details||Financial||Consent|
|Email marketing information to you||Identity, Contact, Marketing and Communications||Necessary for our legitimate interests: to maintain our relationship with the customers and to keep them informed of our products, sales and promotions|
|Sending you marketing information by post||Identity, Contact, Marketing and Communications||Necessary for our legitimate interests: to maintain our relationship with the customers and to keep them informed of our products by sending them our annual catalogue|
|Contacting you to notify you of changes to our services (including postage charges, opening times, staff changes, the workings of our websites and any changes made)||Identity, Contact||Necessary for our legitimate interests: to maintain our relationship with customers and to improve customers user experience and allow a more efficient use of our digital platforms|
|Providing you with customer support||Identity, Contact, Profile||Necessary for our legitimate interests: to support customers in their purchases, allow them to know more about our products, stock availability, prices, scheduled deliveries; to support customers on the use of the website applications such as registration and login issues|
|To administer and protect our business and our websites (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data||Identity, Contact, Technical, Usage||Necessary for our legitimate interests: to help detecting and addressing technical issues and make sure our websites can be accessed by customers devices; to protect online security in case we notice suspicious activity|
|To enable you to participate in interactive features of our websites when you choose to do so||Identity, Contact, Profile, Usage, Marketing and Communications||Necessary for our legitimate interests: to improve customers user experience and allow them to select their favourite products, use the product search feature, menu selection; to allow for personalisation of content and layout|
- We will store information relating to customers who have provided us with consent to process their personal data
- Upon customers request, we will update their preferences
PROMOTIONAL OFFERS FROM US
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 (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased good or services from us or if you or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of any order you make with us.
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 you wish to get an explanation as to how the processing for the new purposes is compatible with the original purpose, please Contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
5. DISCLOSURES OF PERSONAL DATA
- IT companies that build and monitor our websites.
- Operational companies such as packaging suppliers.
- Direct marketing companies who help us manage our electronic communications with you.
- Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way set out in this privacy notice.
- Under certain circumstances, we may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
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
We may employ third party service providers to provide IT and system administration services. These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
We may provide paid products and/or services within our websites. In that case, we use third-party services for payment processing.
6. INTERNATIONAL TRANSFERS
We do not transfer your personal data outside the European Economic Area (EEA).
7. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to employees, agents, 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.
- Encryption of credit cards details before they are saved in our database
- Access to credit cards details only given to the members of staff who are entitled to take payments
- Access to server and database subject to authentication
- Complex and secure SQL connection passwords (SQL is a standard language used to communicate with a database and thus to perform tasks such as update or retrieved data)
- We run the latest updates of the servers
We use network security tools such as:
- Firewalls: designed to stop unauthorised traffic and filter it out
- Logwatch: a customizable log analysis system used to monitor activities in our server
- RkHunter: helps ensure that our server doesn’t get hacked by malicious exploit
- The web framework used to build our sites has built-in protection against cross site request forgery attacks
"Do Not Track" Signals
We do not support Do Not Track ("DNT"). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.
You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.
8. DATA RETENTION
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 requirements.
Treasure House will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.
9. YOUR LEGAL RIGHTS
An overview of your different rights
- 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.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, 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.
- Object to processing of your personal data where 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 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 above), 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, at the time of your request.
- Request 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: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) 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.
If you wish to exercise any of the rights set out above, please contact Data Protection Officer, Treasure House Company, 45 Kirby Street, Hatton Garden, London EC1N 8TE, or email email@example.com. To ask for your information to be amended, please update your online account, or contact us by email or post
If we choose not to action your request, we will explain to you the reasons for our refusal.
NO FEE USUALLY REQUIRED
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 may refuse to comply with your request in these circumstances.
WHAT WE MAY NEED FROM YOU
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure 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.
TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a 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.
10. 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.
If you are based outside the UK, you have the right to lodge your complaint with the relevant data protection regulator in your country of residence. Details can be found in Section 16.
11. ANY QUESTIONS?
If you have any questions that have not been covered, please contact our Data Protection Officer who will be pleased to help you:
Email us at firstname.lastname@example.org.
Or write to us at Data Protection Officer, Treasure House Company, 45 Kirby Street, London, EC1N 8TE.