Issued: 20th of January 2020

At HEROWN we are committed to protecting and respecting your privacy. This notice explains when and why we collect personal information about the people who visit our website www.herownstore.com, or who request information or enquire about a product from us. This notice explains how we use the data, the conditions under which we may disclose it to others and how we keep it secure.

Our privacy practices are in line with requirements set out in the General Data Protection Regulation (GDPR) and the Data Protection Act 2018.

Our services will evolve in order to give you the best service possible. We may change this notice from time to time so please check this page to ensure that you’re happy with any changes made. By using our website, you’re agreeing to be bound by this policy.

Any questions regarding this notice and our privacy practices should be sent by email to: hello@herownstore.com

WHO ARE WE ARE WHO DOES THIS APPLY TO:

This notice is an information piece for those who interact with any part of our organisation. The policies explained in this notice apply to all external data subjects.

Our services are not directed to children under the age of 18 and we do not knowingly collect personal information from children. If you are under the age of 18, please stop using our services.

Any information that you provide to us is controlled by JORUM OF SCOTLAND LIMITED, registered in Scotland, under Company Number SC615032, with its registered office at 3/8 Rodney Street, Edinburgh EH7 4EN, referred to as "we", "us" or "our" in this Privacy Policy.

If you have any questions about how we collect, store or use personal data, please contact us at JORUM OF SCOTLAND LIMITED, 12 St Stephen Street, Edinburgh, EH3 5AL, or at: hello@herownstore.com

HOW DO WE OBTAIN INFORMATION FROM YOU?

We obtain information about you when you use our website, buy from us, or contact us in any way (email, social media, calls, mail). We primarily collect your data when you buy from us, contact us about products and services, or if you register to receive our email newsletter.

Other examples of when we collect data are when you:

• use the Site (including collecting data on your browsing habits)

• register for, or create an account with us

• search for, purchase and/or return products to us

• request an e-receipt from us

• communicate with us by telephone, email or otherwise

• sign up for our newsletters or to receive other marketing communications from us

• participate in any discussion board or other social media function on or linked to the Site

• enter any prize draw, or participate in any promotion organised by us (such as if you refer a friend)

• or complete any survey that we send you, for example if we ask for feedback.

WHAT TYPE OF DATA DO WE PROCESS?

We take a variety of different data sets for a number of reasons. We will detail how we use the data later in this Privacy Policy. Here we explain what type of data we collect.

Some of the data you may choose to give us includes:

• personal details such as your name, date of birth, address, email and telephone number

• information you provide us when accessing our services using your social media account

• account login and password details

• financial and payment information

• details relating to your transaction history with us

• details of your shopping and product preferences

• and photographs submitted digitally by you for display on the Site.

Some of the data we may collect from you due to your interaction with our site includes:

• technical information: such as your time zone setting, the Internet Protocol (IP) address used to connect your computer to the Internet, your computer or mobile device and connection information such as your browser type and version and your operating system and platform.

• information about your visit and traffic pattern: such as the full Uniform Resource Locators (URL) clickstream to, through and from our Site (including date and time), frequency, duration and usage of services, products you viewed and searched for; page response times, download errors, length of visits to certain pages, page interaction information, basket contents and methods used to browse away from the page; and

• email addresses and phone numbers used to contact our customer service number.

We may also collect information from third parties, or combine your information with information lawfully obtained from third parties such as technical, payment and delivery service providers, advertising networks, social media platforms, analytics service providers and search information providers.

We also collect non-personal information or may anonymise personal information in order to make it non-personal. Non-personal information is information that does not allow a specific individual to be identified.

COOKIES

Like many other websites, the HEROWN website uses Cookies. A "Cookie" is a small data file saved in your web browser. They obtain information relating to your session (visit) to the Site. It allows us to recognise your computer (but not specifically who is using it) upon entering our site by associating the identification numbers in the Cookie with other customer information you have provided to us. That customer information is stored on secured databases.

We use Cookies to keep track of what you have in your basket and to remember you when you return to our site. It also tells us which website you came to us from. You can disable cookies on your computer by changing the preferences or options menus in your browser. However, it is possible that some parts of our Site will not operate correctly if you disable cookies.

Please refer to our Cookie Policy for full details of precisely how, when and why we use Cookies.

HOW DO WE USE YOUR DATA?

We use personal information about you in connection with the following purposes:

The information we collect enables us to:

• Fulfil your requests and manage your accounts with us – for example so that we can:

• process orders, deliver products and services, process payments and carry out any other obligations arising from any contracts entered into between you and us;

• provide you with customer service functions such as following up on abandoned shopping carts, or to see if there was a problem with your use of the Site;

• notify you about changes to our Site, or services; and

• maintain and update your Account with us.

Tailor our communication with you and profiling – for example so that we can:

• with your consent, keep you informed about products or services that are similar to those that you have already purchased or enquired about, or that might be of particular interest to you;

• with your consent, provide you with information that might be of particular interest to you (such as upcoming HEROWN events and product launches), or contact you about surveys and user groups. Participation in surveys is entirely voluntary and you are under no obligation to take up an invitation from us to participate;

• analyse your personal information to create a profile of your interests and preferences so that we can contact you with information relevant to you. We may make use of additional information about you when it is available from external sources to help us do this effectively.

• offer you the opportunity to take part in prize draws. Entry to prize draws is entirely voluntary, and you are under no obligation to take up an invitation from us to enter; and

• measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you, which may be based on your activity on our website(s) or those of third parties.

Otherwise enhance your interaction and experience with us – for example so that we can:

• monitor our Site including for internal operations, trouble shooting, testing, research, statistical and survey purposes;

• improve and optimise our Site customer experience and develop new services;

• analyse how you and other users interact with our Site;

• customise your experience when using our Site or other services;

• measure the effectiveness of any advertising we serve and to fulfil our contractual obligations;

• deliver relevant advertising to you;

• prevent fraudulent transactions or other illegal activities; and

• keep our business records.

Any of these functions may be carried out by us or appointed third parties who must process any personal information in accordance with this Privacy Notice.
Who can access your information is more particularly described with the ‘Who we share Information with’ section of this policy.

WHO WE SHARE INFORMATION WITH:

We will not sell or rent your personal information to any third party without your express consent unless we are required or permitted to do so by law.

In order to ensure that we offer the best service and can carry out the functions more particularly described within the ‘How do we use your data?’ section above, it may be necessary for us to share the information we collect (which may include your personal data) with carefully selected and trusted business partners, suppliers and sub-contractors for the fulfilment of any contract we enter into with them and with you.

When we use third party providers, we use only the information necessary to deliver the service and we are required to have a contract in place that requires them to keep your information secure.

For example, we may share:

• your name, delivery address, email and phone number with our partner courier companies in case they need to contact you in relation to a delivery;

• your identity, billing address and payment card information with our payment processors so that payment for an order can be collected;

• your identity and payment card information with our payment processors to conduct PCI 3DS security checks, so that they can check your card is not being used without consent;

• your transaction history information with business partners who facilitate discount schemes you have registered with;

• technical and other service providers who help us provide and deliver the Site experiences;

• analytics and search engine providers that assist us in the improvement and optimisation of the Site and our services;

• business partners and service providers who assist us in carrying out customer relationship management services (such as monitoring and responding to customer orders and queries) and analysing the results of customer surveys and requests for feedback;

• advertisers and advertising networks that require the data to select and serve relevant adverts to you and others; and

• members of our corporate group (which means our holding company and its subsidiaries).

Those of our partners who need to access personal information to perform their business services may not use the data for other purposes.

Where we share financial details, these will always be entered on a secured page and transferred using SSL, a cryptographic protocol designed to provide communication security over the Internet.

In the event that we sell or buy any business or assets, it may become necessary to disclose your personal data to the prospective seller or buyer of such transactions. Your information may also be transferred to another company in the event of sale of the whole or part of our business to a third party.

In certain circumstances we may be obliged to disclose personal information relating to you to third parties, for example, in order to conform to any requirements of law or to comply with any legal process, to prevent and detect fraud and to protect and defend our rights and property.

MORE ABOUT HOW WE COMMUNICATE WITH YOU:

We send two types of emails: customer service emails required to maintain the Site and our services, and newsletters or other marketing communications containing information about product, news, special offers and information that may be of particular interest to you.

While customer service emails are necessary to help you benefit from our services, you may choose not to receive marketing communications when you set up your Account. You may also choose not to receive marketing communications at any time, by clicking the « unsubscribe » link or by following the instructions to unsubscribe provided by us in any marketing communications or by modifying your subscription preferences in your Account.

By signing up for our newsletters or to receive other marketing communications from us, you accept that your personal data may be used for such purposes. You consent to receive such marketing communications from us using any contact method which you have provided us with such as by post, email and telephone.

You may also receive marketing communications containing information and special offers from third parties by post only if you have consented to receiving such communications.

WHAT ARE YOUR RIGHTS AND HOW CAN YOU CONTROL THE DATA WE HOLD ON YOU?

We will not contact you for marketing purposes by email, phone or text message unless you have given your consent. You can change your marketing preferences at any time by updating your account online, following the unsubscribe link or instructions in our emails, or by emailing: hello@herownstore.com at any time.

The Right to Object:
In some instances, you may have the right to ask us to stop processing your data. This will be the case where we process your data because we have a legitimate interest in doing so (such as where we contact you to follow up on a complaint you made). This right does not always apply but you are always able to raise an objection to our processing and we will do our best to comply, where we are legally able to.

The Right to Erasure:
In a similar way to how you can object to our processing your data, you have the right in some instances to have us destroy all the data we hold on you.We maintain and follow a retention policy and your data will not be held for longer than the defined retention period without good reason and without consulting our data privacy experts.
Nonetheless, should you want us to remove our records of your data prior to the end of our defined retention period, please contact: hello@herownstore.com

HOW CAN I ACCESS AND UPDATE MY INFORMATION?

The accuracy of your information is important to us. We’re working on ways to make it easier for you to review and update any information that we hold about you. If you change email address, or any of the other information we hold is inaccurate or out of date, please email us at: hello@herownstore.com

You have the right to ask for a copy of the non- business personal information HEROWN hold about you. This is often called a Subject Access Request. You can do this by contacting: hello@herownstore.com

If you wish to raise a complaint on how we have handled your personal data, you can contact our Data Guardian who will investigate the matter. Email: hello@herownstore.com

If you are not satisfied with our response or believe we are processing your personal data, you can complain to the Information Commissioner’s Office (ICO) using the following details:
Phone number - 0303 123 1113
Email - registration@ico.org.uk
Website address: https://ico.org.uk/

KEEPING YOUR INFORMATION SAFE

When you give us personal information, we take steps to ensure that it is treated securely. Any sensitive information will always be entered on a secured page and transferred using SSL, a cryptographic protocol designed to provide communication security over the Internet. When you are on a secure page, a lock icon will appear on the web browser.

Non-sensitive details are transmitted normally over the Internet, and this can never be guaranteed to be 100% secure. While we strive to protect your personal information, we cannot guarantee the security of any information you transmit to us, and you do so at your own risk. Once we receive your information, we make our best efforts to ensure its security on our systems.

Where we have given (or where you have chosen) a password which enables you to access certain parts of our websites, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

We will hold your data for no longer than we need it for, or if you have advised you wish us to delete it (and we have no legal requirement to keep it), we will delete it per our retention policy. You can request this from us by emailing: hello@herownstore.com

KEEPING CHILDREN SAFE

It is important to protect the privacy of children aged 18 or under. If you are aged 18 or under‚ please ask your parent or guardian's permission beforehand whenever you provide us with personal information.

If we learn that we have collected the personal information of a child under the relevant minimum age without parental consent, we will take steps to delete the information as soon as possible.

Parents who believe that their child has submitted personal information to us and would like to have it deleted may contact us at: hello@herownstore.com

LINKS TO OTHER WEBSITES

Our website may contain links to other websites run by other organisations. This privacy policy applies only to our website www.herownstore.com‚ so we encourage you to read the privacy statements on the other websites you visit. We cannot be responsible for the privacy policies and practices of other sites even if you access these using links from our website.

If you linked to our website from a third-party site, we cannot be responsible for the privacy policies and practices of the owners and operators of that third-party site and recommend that you check the policy of that third-party site.

TRANSFERRING YOUR INFORMATION OUTSIDE OF THE EUROPEAN UNION

HEROWN is based in the UK, currently a member of the European Union, and we operate internationally. Generally, we store your data within the European Economic Area (EEA). However, we may need to transfer your personal information outside the EEA to a country which may not have equivalent protections for your data as your country of residence.

For example, this may happen if any of our servers are from time to time located in a country outside of the EU or, for example, where your data is processed by staff operating outside the EEA who work for us or for one of our suppliers.

If we transfer your data outside of the EEA, we will take steps to ensure that your rights and freedoms in respect of the processing of your personal data are adequately and appropriately protected and comply with all legal requirements.

If you use our services while you are outside the EU, your information may be transferred outside the EU in order to provide you with those services.

By submitting your personal data, you are agreeing to this transfer, storing or processing.