Privacy and Cookies Policy
This website (the “Website”) is owned and operated by Spencer Hart Savile Row Limited (a company registered in England and Wales with company registration number 6035573 and its registered office at 3rd Floor, 58 Queen Anne Street, London W1G 8HW) (“we”, “our”, “us”).
We are committed to protecting and respecting your privacy. This policy sets out the basis on which any personal data we collect from you, or that you provide to us, through the Websitewill be processed by us. Please read the following carefully to understand our practices regarding your personal data and how we will use it.
We are the data controller of any personal data you provide to us and are subject to applicable data protection laws.
We are registered with the Information Commissioner’s Office (“ICO”) under registration number ZA306993.
If you have any questions about this policy or your data, or to exercise any of your rights as described in this policy or under applicable data protection laws, please contact: Teddy Lai – Financial Controller
By post: 3rd Floor, 58 Queen Anne St, London, W1G 8HW
By email: firstname.lastname@example.org
By telephone: +44 (0)207 935 3355
Data Protection Principles
Anyone processing personal data must comply with the principles of processing personal data as follows:
- Lawfulness, fairness and transparency – data must be processed lawfully, fairly and in a transparent manner.
- Purpose limitation – data must be collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes.
- Data minimization – data must be adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
- Accuracy – data must be accurate and, where necessary, kept up to date.
- Storage limitation – data must be kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed.
- Integrity and confidentiality – data must be processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage by using appropriate technical or organisational measures.
This policy describes the personal data that we collect, and explains how we comply with these principles.
Data we may collect
You may give us personal data by filling in forms on the Website or by corresponding with us by phone, email, or otherwise. This may include your name, address, contact number, email address, and relevant sizing.
We may collect, store, and use data in respect of your visits to the Website and about your computer, tablet, mobile, or other device through which you access the Website. This includes the following information:
- technical data, including the Internet protocol (IP) address, your login information, your browser type and settings, time zone setting, browser plug-in types and versions, operating system and platform, and geographical location; and
- data in respect of your visits and use of the Website, including the full Uniform Resource Locators (URL), clickstream to, through and from our Site, pages you viewed and searched for, page response times, length of visits to certain pages, referral source/exit pages, page interaction information (such as scrolling, clicks and mouse-overs), and website navigation and search terms used.
What we do with your data
We use your data to correspond with you by phone, email, or otherwise, and to provide you with information that you request from us.
Where it is in our legitimate interest to do so, we use your data:
- to administer the Website including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- to improve the Website to ensure that content is presented in the most effective manner for you and for your computer, mobile device or other item of hardware through which you access the Website;
- as part of our efforts to keep the Website safe and secure; and
- to measure or understand the effectiveness of any advertising we serve to you and others, and to deliver relevant advertising to you.
Where you have given us consent, we shall provide you with information about any new products, services, events, promotions, special offers and other information which we think will be of interest to you. You can withdraw your consent at any time, but without affecting the lawfulness of processing based on consent before its withdrawal. You can update your details or change your privacy preferences at any time by contacting us as given in “Contacting us” above.
Sharing your data with third parties
If you have not objected to our processing of your personal data for direct marketing purposes (see “Right to object” below), we may share your personal data with our event organisers who may contact you to invite you to events held by us and who may process your response to any such invitation.
We may share your personal data with third parties where there is a legitimate reason to do so including for the following reasons:
- in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
- if all or substantially all of our assets are acquired by a third party, in which case personal data held by it about its employees will be one of the transferred assets;
- if we are under a duty to disclose or share your personal data in order to comply with any legal obligation.
Save as set out in this policy, we do not sell your personal data or disclose it to any third parties without your consent.
Security of your data
We store your personal data in hard copy and in electronic format in Office 365. We take all reasonable technical and organisational measures to safeguard your personal data and ensure it is treated securely and in accordance with this policy.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the Website; any transmission is at your own risk. Once we have received your data, we will use strict procedures and security features to try to prevent unauthorised access.
The data that we collect from you is stored on servers located within the European Economic Area (the “EEA”). We do not intend to transfer your personal data outside of the EEA, but if we do we will notify you before doing so.
How long we keep your data
Personal data received by us will only be retained for as long as necessary to fulfil the purposes described in this policy or for the maximum period of time as required by law, after which time it will be destroyed in a secure manner.
Access to your data and updating your data
You have the right to access data which we hold about you. If you so request, we shall provide you with a copy of your personal data which we are processing.
You also have the right to receive your personal data in a structured and commonly used format so that it can be transferred to another data controller (“data portability”).
We want to make sure that your personal data is accurate and up to date. You may ask us to correct or remove data you think is inaccurate or incomplete.
Right to object
You have the right to object at any time to our processing of your personal data for direct marketing purposes.
Where we process your data based on our legitimate interests
You also have the right to object, on grounds relating to your particular situation, at any time to processing of your personal data which is based on our legitimate interests. Where you object on this ground, we shall no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.
Your other rights
In certain circumstances, you have the right to:
- request the erasure of your personal data (‘right to be forgotten’);
- restrict the processing of your personal data to processing to which you have given your consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of others.
Exercising your rights
You can exercise any of your rights as described in this policy and under data protection laws by contacting us as given in “Contacting Us” above.
Save as described in this policy or provided under applicable data protection laws, there is no charge for the exercise of your legal rights. However, if your requests are manifestly unfounded or excessive, in particular because of their repetitive character, we may either: (a) charge a reasonable fee taking into account the administrative costs of providing the data or taking the action requested; or (b) refuse to act on the request.
Where we have reasonable doubts concerning the identity of the person making the request, we may request additional data necessary to confirm your identity.
In order to improve the Website, we may use small files commonly known as “cookies”. A cookie is a small amount of data which often includes a unique identifier that is sent to your computer or mobile phone (your “device”) from the Website and is stored on your device’s browser or hard drive.
The Website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates.
If you follow a link to any of these websites, please note that we do not accept any responsibility or liability for the processing of your personal data through these websites.
Please address any complaints to us using the details set out in the “Contacting Us” section above.
In addition, you have the right to complain to the Information Commissioner’s Office (https://ico.org.uk/) about our data processing activities in relation to your data if you think they infringe applicable data protection laws (ICO helpline on 0303 123 1113).
Updates to this policy
We may review and, if appropriate, update this policy from time to time. Any changes we may make to this policy will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to our policy.
This policy was last updated on 20th February 2018.