Clearwaters Footwear respects the privacy of every individual; whether they be a customer or any prospective customer. We have a legal duty to safeguard and protect any personal information that we collect or you provide us with. This statement outlines what information we may collect from you, how we use, store and process the information, how you can check what information we have about you and how you can instruct us to amend or erase the information if required. This policy pertains to all internal systems, websites and third-party users used by Clearwaters Footwear for the storage and use of all personal information.
We may collect, store and process information you send to us that is considered personal identifiable data by the General Data Protection Regulation 2018 (GDPR). We may hold the following information for all customers in order to maintain a legitimate business and active working relationship with you and have the appropriate lawful basis for processing:
- Company, trading or individual name
- Invoice and delivery addresses
- Staff contact names and details for different departments
- Email, fax and phone numbers
- Preferences on how you would like to be kept up to date
- Your company registration and VAT number (if applicable)
- Purchase history of goods and services from us
- What type of services or goods you provide
- Your payment information such as credit card and debit card details
- Information collected through your use of our websites or social media pages
Any of the above is required by Clearwaters Footwear to make sure we issue goods, services, notices and documents correctly to you as instructed. By providing the information in the first instance, you are providing consent for its use within our business requirements. We encourage customers to inform us of any changes to their information immediately in order for us to maintain accurate records at all times.
We would ask you to note that all telephone calls into and from our office are recorded for training and monitoring purposes and for clarification of any verbal instructions that you provide to us. We may share these recordings with our legal representatives should this be necessary.
In relation to personal information provided about end users; Clearwaters Footwear recognises that our customer (provider of the information) is the Data Controller and Clearwaters Footwear becomes the Data Processor of this information. By providing the information required for the goods or services, you are consenting to the use of this data as the Controller. As the processor, we will notify the controller immediately if we receive a subject access request or a request to rectify, block or erase any personal data from the end user.
We will process the information in accordance to all Data Protection laws and the controller’s instructions only in order to provide the goods and services as required. We shall not contact the end user unless directed to do so by the controller. By giving us this instruction you are confirming that they have given you consent to provide the information to us and for contact to be made. It is our legal obligation to notify the controller immediately if we consider that any of your instructions infringe the Data Protection Legislation and applicable data laws.
No information will be transferred outside of the EU unless the controller has explicitly requested it. Where requested, we will provide appropriate safeguards and protection in relation to the transfer.How We Use Your Information
It is very important to us that we provide all goods and services that meet the expectations of our customers. We use the information collected from you for:
- The purposes of facilitating the supply of goods and/or services
- Provide relationship management and file opening procedures
- Administration and management purposes
- In order to comply with our legal obligations under the contract with you, including billing requirements
- To provide you with information about our services if you have consented to receive
- To deal with any customer complaints
On occasion, where you tell us you are happy to receive information from us, we will use your information for various commercial communications and marketing purposes. We are continually developing products and services based on information and feedback we receive from customers, which we may share with you.
From time to time we may email or post you marketing literature on any new services or products we think you may be interested in. You can opt in or out of marketing information at any time by pressing the unsubscribe button at the bottom of any marketing email we send you.
If you shop online with us, we may store your personal information within our website. This enables you to purchase our products and services online without having to fill in your personal information every time you shop online with us. If your account has been inactive for a long period of time, we reserve our right to deactivate your account.
The information you provide may also be used to help combat fraud and to identify you and your account before disclosing any confidential information. The information provided may be used to prevent, detect, mitigate and investigate fraud, security breaches or other potentially prohibited or illegal activities.
Our use of the information is subject to your instructions, the General Data Protection Regulation 2018 and our duty of confidentiality. Please note that our work for you may require us to give information to third parties such as other professional advisers who are also required to maintain confidentiality in relation to your files.Who Sees Your Information
We may disclose your information to any of our employees, subcontractors or associated companies as reasonably necessary to provide you with our goods and services. Any third parties we use are carefully chosen and we ensure they are also fully compliant with all data protection regulations before we share any data with them.
To ensure that the products and services you buy from us are delivered to the correct address, we work with trusted third parties who are based outside of Clearwaters Footwear and share with them the personal information you have provided. For example, your name, address for delivery, contact telephone number and any delivery preferences you have outlined to us.
For card based financial payments, we use payment systems of trusted third parties to ensure that your payment is safe and that your details are not being used fraudulently. We use systems of fraud analysis which ensure that genuine and accurate payment details are being provided to us for any purchase.
External firms or organisations may conduct audit or quality checks on our practice. These external firms or organisations are required to maintain confidentiality in relation to your files.
We may also purchase services and data from credit reference agencies to verify the contact details and personal information you have provided to us.
To prevent fraud or any other criminal activity, we will share your information with other third parties including the police, law enforcement agencies, court, regulator, credit reference and fraud prevention agencies; to protect our or another person’s rights, property or safety.How Long We Keep Your Information
Clearwaters Footwear will only retain customers’ personal information for as long as it needs it to carry out a particular purpose or meet a particular obligation. How long we keep it depends on the type of information and purpose. We may sometimes store and process the information you provide for a longer period of time where required to. For example: we might need to resolve a dispute; stop any fraudulent activity and abuse; prove that you had an account with us; the police may need it as evidence; to ensure that any allegation of fraudulent use of identity can be properly investigated or to follow our legal obligations.
We may also keep information about how you use our products or services for research purposes. In this instance the information will be pseudonymised and made anonymous so that the data cannot be attributed to a specific individual. In each case, the length of time that we need to keep the information may be different but we will only keep the information for as long as it is needed. When we no longer need to keep your personal information, we will delete your contact details, any associated documents and any other information that could identify you personally. By deletion, we mean put ‘beyond use’ as defined by the Information Commissioners Office guidelines.Social Media
Our website may post links to social network sites such as Facebook, Twitter etc. We provide access to these sites so we can generate interest in our products and services. We cannot control how your data is collected, stored, used or shared by these sites or to whom it is disclosed. Please ensure that you review the privacy policies and settings on these social networking sites to make sure that you understand the information that they are sharing.
Our own and third party cookies are used throughout this site. Some are required for the functioning of the site and allow us to provide our services, others improve the usability and allow for personalisation.Information Security
Clearwaters Footwear will take reasonable technical and organisational precautions to prevent loss, unauthorised access, misuse, disclosure or alteration of the personal information you provide. We use leading technologies, firewalls and encryption software to safeguard your data; and keep strict security access control standards to prevent any unauthorised access to it.
All data protection measures are reviewed and tested on a regular basis to ensure compliance and to protect against a data loss event. As technology develops, we will implement new systems where necessary to ensure the highest level of security at all times.
Please remember, any emails or other communications you send over the internet may not be safe unless they have been encrypted. The transmission of data over the internet is inherently insecure and we cannot guarantee the security of data sent via this method. If someone gets access to your emails without your permission or your personal information is shared publicly, we cannot accept responsibility as this is out of our control.Your Rights
Clearwaters Footwear fully comply with and are registered under the data protection laws in the United Kingdom and take all reasonable steps to prevent any unauthorised access to your personal data.
- You have the right to request copies of the personal information we hold about you.
- You have the right to request to amend any incomplete or factual inaccuracies on the information we hold.
- You have the right to request we delete any personal information we have on record. Please note that there may be circumstances where you ask us to erase your information but we are legally entitled to retain it.
- You have the right to request that we restrict the processing of your information in certain circumstances. Again, there may be circumstances where you ask us to restrict the processing of your information, but we are legally entitled to refuse that request.
- You have the right to withdraw your consent to the use of your information where we are relying on that consent (for example; you can opt out of receiving marketing messages from us). Please note that we may still be entitled to process your information if we have another legitimate reason (other than consent) for doing so.
- You have the right to make a complaint with the Information Commissioner via www.ico.org.uk if you think that any of your rights have been infringed by us.
Any requests as detailed above must be, for legal reasons, made in writing and directed by email to firstname.lastname@example.org.
We will provide the information within 40 calendar days of receiving the request. Any subject access requests are subject to an administration fee of £10 and the request will not be processed until the fee has been received by us. We may withhold such personal information to the extent permitted by law only.Revisions
As appropriate we reserve the right to revise and amend this statement at any time. Any revised changes will apply to our terms and conditions and this website from the date of publication. Please check this page regularly to ensure you are fully aware of any changes to the policy.