Identity Data

First name; last name; unique identifiers that we assign to your account; account passwords.

Contact Data

Delivery address; email address; telephone number.

Profile Data

Any ‘know your customer’ or ‘KYC’ information that we may collect, including identification documents (such as an ID card, passport, residence permit or driving licence) and personal data contained in such documents, including country of issue, nationality, date of birth and address; photos and images that identify you (e.g. selfies that we ask you to take to verify your identity or any other images that you provide to us); any relevant publicly available information in connection with KYC checks; any other data that you volunteer during our dealings with you (e.g. if you contribute to our journal or to publications on our Site).

Transaction Data

Details about payments made between you and us, including bank account details, payment information and billing address; details of Products that you purchase through the Website; details of goods that you sell through our Services; details of any of our promotions or competitions that you participate in.

Enquiry and Feedback Data

The content of any messages you send using our Contact Us Form or that you otherwise submit to us, or any survey responses that you submit to us.

Technical Data

IP address; device and user agent information (your browser type and operating system); general geolocation derived from your IP address (country, postcode).

Observed Data

Data that is observed about your use of our Website or interaction with our emails and/or data that we infer through your use of the Website and our Services. This data may include: details of when your current or previous sessions started; the referrer URL (web page that you were on when you clicked a link that sent you to our Website); information about the pages of our Website that you have visited and any Products that you have purchased or shown an interest in (including any products that you have added to your Watchdrawer or Wishlist).

Marketing and Communications Data

Any marketing or services communications preferences that you have provided to us.

Personal data you provide to us

You may give us your personal data directly, for example, when you register for an account or purchase Products on our Website, contact us, or subscribe to receive our marketing communications.

Personal data we observe and collect through Website use

When you access and use our Website, we may collect Technical Data and Observed Data. We may collect this personal data by using cookies and other similar technologies (see the Insight and Analysis section for further information).

Personal data that is supplied to us by third parties or is publicly available

We may collect or receive personal data, including Profile Data, about you from third parties or from publicly available information. Such third parties may include third parties that provide services to us so that we can provide our Website and our Services.

Website visitors

If you browse our Website or register an account on our Website, we will collect and process your personal data in connection with your interaction with us and our Website.

Customers

If you buy Products or receive our Services, we may collect and process your personal data in connection with the supply of the Products or our supply of the Services.

People who contact us

If you directly contact, provide feedback, or submit a complaint to us through our Website, surveys or otherwise, we will collect and process your personal data in connection with your interaction with us.

People who work for our suppliers

If you work for one of our suppliers and have responsibility for administering your organisation’s account with us or handling our orders, we will process your personal data in connection with your organisation’s relationship with us.

Visitors to our physical locations

If you attend our offices or other locations, we may process personal data that you volunteer or that we otherwise collect in connection with your visit. For example, you may volunteer personal data when signing in as a guest. CCTV footage may also be collected for security purposes.

Job applicants

If you apply for a job with us, whether through the Website or otherwise, we will collect and process your personal data in connection with your application.

To facilitate use of our Website

When you use our Website, we collect and process Technical Data to provide the Website to you, including to make sure we are providing the correct version of the Website.

Our legal basis for processing

It is in our legitimate interest to use personal data in such a way, to ensure that we provide access to our Website in a secure and effective way.

If you register and access an account on our Website

You may be required to register an account with us in order to gain access to certain features and functionality of our Website and/or to receive access to certain Services from us. Account applicants will need to complete the registration form and may be asked to provide Identity Data, Contact Data and Profile Data. We will use this data in order to process your registration, to protect our Website and Services against fraudulent activity, and for account verification. Once your account is registered, we will process your Identity Data and Profile Data to identify you when you log in to your account and access secure areas of our Website. We will also process certain Marketing and Communications Data so that we can administer your account and contact you about your account. We will also collect and process Observed Data and Technical Data when you use certain features and functionality on our Website. This data helps us understand how you use our Website so that we can improve it.

Our legal basis for processing

It is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you, or it is in our legitimate interest to use your personal data in such a way to ensure that we provide access to the Website and our Services in a secure and effective way.

If you interact with our social media pages

If you click on one of the social media links on our Website or otherwise interact with our social media pages such as on Instagram or YouTube (including interacting with any ‘like’ or similar embedded features on our Website or social media accounts), we and the relevant social media platform may collect Technical Data and Observed Data relating to such interaction.

For more information about how we use the Observed Data, please see the Insight and Analysis section.

The relevant social media platform may also be a controller in respect of the personal data that is collected via your use of our social media pages and may use that personal data for additional purposes. For details of how the relevant social media platform uses your personal data, please see the privacy policy of the relevant social media platform.

Our legal basis for processing

It is in our legitimate interest to use personal data in the ways described above, to promote our Website, and the Products and Services via social media. For information about the legal basis that we rely on to use Observed Data, please see the Insight and Analysis section below.

If we interview you for our journal or your otherwise contribute to publications on our Site

If we interview you for a journal article that we publish on the Site or if you contribute in any other way to publications we publish on our Site, we may record our interview or our communications with you in order to produce the content that we publish on our Site. We may publish the personal data that you contribute (which may include certain of your Identity Data and Profile Data) as part of the published content and to credit you for your contribution. If you provide photographs or other images in support of your contribution, we may publish one or more of those images alongside your interview.

Our legal basis for processing

Where we use your content in connection with interviews, articles or other content that we publish on our Site, it is in our legitimate interest to use any personal data that you provide to us, to produce the content and publish it on our Site.

To supply Products and Services to you

We collect and maintain personal data that you submit to us for the purpose of supplying Products and Services that you have purchased or requested via our Website.

The personal data we process may include certain of your Identity Data, Contact Data, and Transaction Data (as applicable).

We process this information so that we can fulfil the supply of the Products and Services, fulfil any contractual obligations that we owe in respect of the supply of the Products and Services, and to maintain our records of transactions.

Our legal basis for processing

It is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you for the Products and Services, or it is in our legitimate interest or a third party’s legitimate interest to use personal data in such a way to ensure that we provide the Products and Services in an effective, safe and efficient way.

We may maintain records of relevant transactions to comply with legal obligations that we owe, or to establish, exercise or defend any legal claims in connection with the supply of the Products and Services.

To handle any communication that you submit about our Website or the Products and Services, and to improve our Website, the Products and Services

There are various ways in which you are able to contact us, including by email, telephone or the Contact Us Form on our Website. In addition, from time to time we may invite you to complete surveys to provide feedback about us.

When you contact us or otherwise provide feedback to us, we will collect and process your Enquiry and Feedback Data, together with any Identity Data, Contact Data, Transaction Data or Technical Data that is relevant to your communication.

We will use such data to help us to identify and resolve any issue that you have or to otherwise respond to your communication, and to monitor and improve our Website, Products and our Services (including to assist with the selection of future product and service lines).

Our legal basis for processing

It is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you for the Products and Services, or it is otherwise in our legitimate interest to use your personal data in the ways described above to ensure that we are able to help you with your enquiry, provide a high standard of service, and improve our Website, Products and Services.

To train our personnel

We may use Enquiry and Feedback Data, and data relating to how our personnel have responded to your communication or survey response, to evaluate how we have handled your enquiry or feedback and to train our personnel in respect of their handling of enquiries and feedback. 

Our legal basis for processing

It is in our legitimate interest to use the personal data provided by you so that we can train our personnel to ensure that they handle enquires and feedback effectively and provide a high standard of customer service.

If you participate in one of our promotions

From time to time, we may run prize draws, prize competitions and other promotions on our Website and/or on our social media accounts. For the purposes of administering such promotions, we may process your Identity Data, Contact Data, Transaction Data and any other personal data relevant to your promotion entry.

Our promotions are subject to separate terms and conditions, which you may be required to accept as a condition of entry.

Our legal basis for processing

It is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you (e.g. the promotion terms and conditions) or it is in our legitimate interest to use your personal data to enable us to administer our promotion fairly and effectively and to ensure that we comply with self-regulatory codes governing the operation of promotions.

To help us to personalise our Website, Services and content, and to understand more about the users of our Website and our Services

We and our third-party partners use cookies, web beacons, pixel tags and other similar technologies (which we generically refer to as “Cookies”) or may otherwise collect Observed Data through your use of our Website and Services and any emails that you receive from us. Please see our Cookie Notice for further information, including details of our third-party partners.

We and our third-party partners use Observed Data and Transaction Data to personalise your experience on the Website and to personalise the content that we deliver to you through our advertising and marketing activities referred to in the Advertising and Marketing section.

In addition, we and our third-party partners may use Observed Data and Transaction Data on an aggregated basis or in a way that does not directly identify you, for the following purposes:

·       to understand more about the users of our Website and Services and to analyse and improve our Website, the Products and our Services;

·       to count users who have visited our Website or opened an email to learn what parts of our Website are of most interest to users, to measure the effectiveness of our content, and to understand what features and functionalities our visitors like to see;

·       to help us understand the type of advertising and marketing content that is most likely to appeal to our visitors and customers; and

·       to help us with the selection of future product and service lines, Website design and to remember your preferences.

In some of our email messages, we use a “click-through URL” linked to certain websites administered by us or on our behalf. We may track click-through data to assist in determining interest in particular topics and measure the effectiveness of these communications.

Our legal basis for processing

Where your data is collected through the use of non-essential cookies, we rely on consent to collect your personal data and for the onward processing purpose. Please see our Cookie Notice for further details.

Where we use Observed Data and Transaction Data in connection with our advertising and marketing activities, please see the Advertising and Marketing section for details of the legal basis that we rely on.

In other cases, it is in our legitimate interest to use Observed Data and Transaction Data to understand more about and to improve our Website, Products and Services.

To send you marketing communications by email

We use your Identity Data, Contact Data and Marketing and Communications Data to send you (or the organisation you represent) marketing communications by email. Our marketing will include press releases and information about us, our Website, our Products and Services, and the offers and promotions we offer from time to time.

Our marketing communications may include personalised and non-personalised marketing. Personalised marketing has been specifically tailored to you and will include content that we think is most relevant to you, based on Transaction Data and Observed Data. Please see the Insight and Analysis section for more details about how we may collect Observed Data.

Non-personalised marketing is marketing that is not tailored to you.

Our legal basis for processing

It is in our legitimate interest to use your personal data for marketing purposes, for example to decide what marketing content we think may appeal to you.

However, we will only send marketing communications to you by email where we have permission to do so (for example when you have consented to receiving marketing when you sign up to our newsletter or if we collect permission to send you marketing when you purchase Products or use our Services).

In addition, please see the Insight and Analysis section to learn about the legal basis that we rely on to collect Observed Data via the use of Cookies.

Online advertising through third-party tools

Our third party advertising partners may provide tools that we can use to display our advertisements to people who we think are more likely to be interested in our Website, the Products and Services.

For example, an advertising partner may have determined that you are someone who is likely to be interested in luxury goods, using data that they have collected about you (which we do not receive). If we want to display our advertising to people interested in luxury goods on third party websites that use the services of our advertising partner, we may ask our advertising partner to display our advertising to you.

Our legal basis for processing

If you are someone who has seen this advertising, it is in our legitimate interests that the relevant third party advertising partner uses the data that you have provided to it to advertise our Website, the Products and our Services, although please note that we do not receive this data and you should exercise your rights in respect of such data in accordance with the privacy notice of the relevant online service that displays our advertising to you.

Online advertising through Observed Data

We and our third party partners may use Observed Data to display advertising or other data that is collected through your interactions with third party websites and services, to provide you with, and analyse the effectiveness of, advertising when you visit or use other websites and/or services.

Our legal basis for processing

Please see the Insight and Analysis section to learn about the legal basis that we rely on to collect data via the use of Cookies.

Where we use your personal data to display online personal advertising to you, we rely on the consent that you have provided in respect of the collection of such data, or it is otherwise in our legitimate interests to promote our Website, the Products and our Services to you.

Our third-party partners may rely on a different lawful basis in respect of their use of your personal data. As set out in our Cookie Notice, please read the privacy notice of the relevant third-party provider.

Customer Match Advertising

We may share your Contact Data (usually your email address, in an encrypted or ‘hashed’ form) with third-party providers of social media platforms and other similar services, such as Facebook and other similar platforms (“Platforms”), so that the third-party provider can try to “match” your data with the registration data of the relevant Platform.

Where there is a successful match, our advertising will be displayed to you when you use the relevant Platform (e.g. on your Facebook newsfeed). This is known as “customer match” or “custom audience” advertising because we “customise” the audience that we want to reach on the relevant Platform.

In some cases, we may also share your Contact Data with third-party providers in order to exclude you from seeing our advertising (because we are trying to reach people that are not yet our customers).

Some of the advertising that you see may be personalised to you. The data that we use to personalise our advertising, such as your Technical Data and Observed Data, will not be provided to the third-party providers of the Social Platforms. Please see the Insight and Analysis section to learn more about how we personalise advertising to you.

This activity is also subject to the privacy choices you have elected to make on the relevant Platforms.

Our legal basis for processing

It is in our legitimate interests to use your personal data as described above in order to promote our Website, the Products and our Services to you when you use the relevant Platforms.

Lookalike Advertising

Where we have displayed our advertisements to people as described above, we may also ask our third party advertising partners to find people that share similar interests and characteristics to those persons, which will be based on information that the third party advertising partner has collected about you and those similar persons (which we do not receive).

This is known as “lookalike” audience advertising because we are trying to show our advertising to people who “look like” our Website users, and other persons that are likely to be interested in our advertising.

If you are someone who has seen this advertising, please note that this activity is based on data that you have provided to the relevant third party (which we do not receive) and is also subject to the privacy choices you have elected to make on such third-party services.

Our legal basis for processing

Please see the sections above for details of the lawful basis that we rely on to display our advertising to persons that we think are most likely to be interested in our Website, the Products and our Services.

It is in our legitimate interests to further use your personal data to request that our third party advertising partners find other people who share similar interests and characteristics with you (and therefore who are also most likely to be interested in our Website, the Products and our Services).

If you are someone who has seen this advertising, it is in our legitimate interests that the relevant third party advertising partner uses the data that you have provided to it to advertise our Website, the Products and our Services, although please note that we do not receive this data and you should exercise your rights in respect of such data in accordance with the privacy notice of the relevant online service that displays our advertising to you.

If we use your personal data in connection with our recruitment activities

We use your personal data for recruitment purposes, in particular, to assess your suitability for any of our positions that you apply for, whether such application has been received by us online, by email or by hard copy and whether submitted directly by you or by a third-party recruitment agency on your behalf. We also use your Identity Data and Contact Data to communicate with you about the recruitment process, to keep records about our recruitment process and to comply with our legal and regulatory obligations in relation to recruitment.

We will process any personal data about you that you volunteer, including during any interview, when you apply for a position with us. We may also process your personal data obtained from any third parties we work with in relation to our recruitment activities, including without limitation, recruitment agencies, background check providers, credit reference agencies and your referees.

The personal data we process may include your Identity Data, Contact Data, details of your education, qualifications and employment history, any other personal data which appears in your curriculum vitae or application, any personal data that you volunteer during an interview or your interactions with us, or any personal data which is contained in any reference about you that we receive. Such information may also include special categories of personal data (such as information about your health, any medical conditions and your health and sickness records) and information relating to criminal convictions and offences if that information is relevant to the role you are applying for.

We also use your personal data for the purposes of reviewing our equal opportunity profile in accordance with applicable legislation. We do not discriminate on the grounds of gender, race, ethnic origin, age, religion, sexual orientation, disability or any other basis covered by local legislation. All employment-related decisions are made entirely on merit.

Our legal basis for processing

Where we use your personal data in connection with recruitment, it will be in connection with us taking steps at your request to enter into a contract we may have with you or it is in our legitimate interest to use personal data in such a way to ensure that we can make the best recruitment decisions.

We will not process any special (or sensitive) categories of personal data or personal data relating to criminal convictions or offences except where we are able to do so under applicable legislation or with your explicit consent.

If we have engaged you or the organisation you represent to provide us with products or services

If we have engaged you or the organisation you represent to provide us with products or services (for example, if you or the organisation you represent provide us with services such as IT support or financial advice), we will collect and process your personal data in order to manage our relationship with you or the organisation you represent, to receive products and services from you or the organisation you represent and, where relevant, to provide the Products and our Services to others. The personal data we collect from you may include your Identity Data and Contact Data and any other personal data you volunteer which is relevant to our relationship with you or the organisation you represent.

Our legal basis for processing

It is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you or the organisation you represent, or it is in our legitimate interest to use personal data in such a way to ensure that we have an effective working relationship with you or the organisation you represent and are able to receive the products and services that you or your organisation provides, and provide the Products and our Services to others, in an effective way.

If we need to use your personal data in connection with the administration of our security measures

We have security measures in place at our premises, including CCTV and building access controls. There are signs in place showing that CCTV is in operation. The images captured are securely stored and only accessed on a need to know basis (e.g. to look into an incident). CCTV recordings are typically automatically overwritten after a short period of time unless an issue is identified that requires investigation (such as a theft).

We may require visitors to our premises to sign in on arrival and where that is the case we will keep a record of visitors for a short period of time. Our visitor records are securely stored and only accessible on a need-to-know basis (e.g. to look into an incident).

Our legal basis for processing

It is in our legitimate interests to process your personal data so that we can keep our premises secure and provide a safe environment for our personnel and visitors to our premises.

If we need to use your personal data to comply with our legal obligations or in connection with the administration of our business

We may use your personal data: (i) to comply with our legal obligations; (ii) to enforce our legal rights; (iii) to protect the rights of third parties; and (iv) in connection with a business transition such as a merger, reorganisation, acquisition by another company, or sale of any of our assets.

Our legal basis for processing

Where we use your personal data in connection with a business transition, to enforce our legal rights or to protect the rights of third parties, it is in our legitimate interest to do so. For all other purposes described in this section, we have a legal obligation to use your personal data to comply with any legal obligations imposed upon us, such as a court order.

We will not process any special (or sensitive) categories of personal data or personal data relating to criminal convictions or offences except where we are able to do so under applicable legislation or with your explicit consent.

Third-party suppliers who provide applications/ functionality, data processing or IT services

We share personal data with third parties who support us in providing our Website and help provide, run and manage our internal IT systems. Such third parties may also include, for example, providers of information technology, cloud-based software-as-a-service providers, identity management, website design, hosting and management, data analysis, data back-up, security and storage services. The servers powering and facilitating that cloud infrastructure are located in secure data centres around the world, and personal data may be stored in any one of them. We also share your personal data with third-party service providers to assist us with insight analytics. These providers are described in our Cookie Notice.

Payment providers and banks

We share personal data with third parties who assist us with the processing of payments and refunds.

Delivery and courier companies

We share personal data with suppliers who assist us in the delivery of our Products and Services to our customers.

Advertising partners

We share personal data with third party advertising partners, including those set out in the Joint Controller Activities section below and in our Cookie Settings tool. This data is used to provide you with, and measure the effectiveness of, online personalised advertising and for other advertising related activities.

Third-party email marketing and CRM specialists

We share personal data with specialist suppliers who assist us in managing our marketing database and sending out our email marketing communications and account-related communications.

Third-party suppliers who assist us in conducting KYC checks

We share personal data with specialist suppliers, including Sum and Substance Limited, who assist us in carrying out KYC checks on our behalf.

Third-party suppliers who assist us in administering our promotions

We share personal data with specialist suppliers who assist us in administering our prize draws, prize competitions and other promotions.

Third-party suppliers who assist us in producing interviews for our Site

We share personal data with specialist suppliers who assist us by transcribing interviews that we record, as part of producing articles and other content for our Site.

Recruitment agencies and related organisations

We share personal data with external recruiters, third-party providers that undertake background checks on our behalf and other entities within our group of companies.

Auditors, lawyers, accountants and other professional advisers

We share personal data with professional services firms who advise and assist us in relation to the lawful and effective management of our organisation and in relation to any disputes we may become involved in.

Law enforcement or other government and regulatory agencies and bodies

We share personal data with law enforcement or other government and regulatory agencies or other third parties as required by, and in accordance with, applicable law or regulation.

Other third parties

Occasionally, we may receive requests from third parties with authority to obtain disclosure of personal data, such as to check that we are complying with applicable law and regulation, to investigate an alleged crime, or to establish, exercise or defend legal rights. We will only fulfil requests for personal data where we are permitted to do so in accordance with applicable law or regulation.

Adequacy decisions

We may transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission and/or the UK Government (as applicable).

Model clauses

Where we use certain service providers, we may use specific standard contractual clauses approved by the European Commission and/or the UK Government which give personal data the same protection it has in Europe and/or the UK.

Your right of access

If you ask us, we will confirm whether we are processing your personal data and, if so, provide you with a copy of that personal data (along with certain other details). If you require additional copies, we may charge a reasonable fee for producing those additional copies.

Your right to rectification

If the personal data we hold about you is inaccurate or incomplete, you are entitled to have it rectified. If we have shared your personal data with others, we’ll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we will also tell you who we’ve shared your personal data with so that you can contact them.

Your right to erasure

You can ask us to delete or remove your personal data in some circumstances, such as where we no longer need it or where you withdraw your consent (where applicable). If we have shared your personal data with others, we will let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we will also tell you who we have shared your personal data with so that you can contact them directly.

Your right to restrict processing

You can ask us to “block” or suppress the processing of your personal data in certain circumstances such as where you contest the accuracy of that personal data or you object to us processing it for a particular purpose. This may not mean that we will stop storing your personal data but, where we do keep it, we will tell you if we remove any restriction that we have placed on your personal data to stop us processing it further. If we’ve shared your personal data with others, we’ll let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal data with so that you can contact them directly.

Your right to data portability

You have the right, in certain circumstances, to obtain personal data you have provided to us (in a structured, commonly used and machine-readable format) and to reuse it elsewhere or to ask us to transfer it to your chosen third party.

Your right to object

You can ask us to stop processing your personal data, and we will do so, if we are: (i) relying on our own or someone else’s legitimate interest to process your personal data, except if we can demonstrate compelling legal grounds for the processing; or (ii) processing your personal data for direct marketing purposes.

Your rights in relation to automated decision-making and profiling

You have the right not to be subject to a decision when it is based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for the entering into, or the performance of, a contract between you and us.

Your right to withdraw consent

If we rely on your consent (or explicit consent) as our legal basis for processing your personal data, you have the right to withdraw that consent at any time. You can exercise your right of withdrawal by contacting us using our contact details in the How to Contact Us section above or by using any other opt-out mechanism we may provide, such as an unsubscribe link in an email.

Your right to lodge a complaint with the supervisory authority

If you have a concern about any aspect of our privacy practices, including the way we have handled your personal data, please contact us using the contact details provided in the How to Contact Us section above. You can also report any issues or concerns to a national supervisory authority in the Member State of your residence or the place of the alleged infringement. You can find a list of contact details for all EU supervisory authorities at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

As we are incorporated in the United Kingdom, our regulatory authority is the Information Commissioner’s Office (“ICO”). Contact details for the ICO can be found on its website at https://ico.org.uk.