PRIVACY POLICY

Emma Pulbrook respects the privacy of every person who visits or registers with www.emmapulbrook.com (the “Site”) and who uses the services that we make available from the Site (our “Services”) and we are committed to ensuring a safe online experience.

By using or accessing the Website, you signify your agreement to be bound by our Privacy Policy. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, YOU MAY NOT ACCESS OR OTHERWISE USE THE SERVICE.

1. Purpose of this Policy
This privacy policy (“Privacy Policy”) explains our approach to any personal information that we might collect from you or which we have obtained about you from a third party and the purposes for which we process your personal information. This Privacy Policy also sets out your rights in respect of our processing of your personal information. For more information read below.

This Privacy Policy will inform you of the nature of the personal information about you that is processed by us and how you can request that we delete, update, transfer it and/or provide you with access to it.

This Privacy Policy is intended to assist you in making informed decisions when using the Site and our Services. Please take a moment to read and understand it. Please note that it should be read in conjunction with our Website Terms of Use.

Please also note that this Privacy Policy only applies to the use of your personal information obtained by us, it does not apply to your personal information collected during your communications with third parties.


2. Who are we and what do we do?
The Site and our Services are operated by Emma Pulbrook. For more information read below.

I may transfer the personal information I collect about you to recipients in countries other than the country in which the information originally was collected.  Those countries may not have the same data protection laws as the country in which you initially provided the information.  When I transfer your information to recipients in other countries (such as the U.S.), we will protect that information as described herein.

If you are located in the European Economic Area (“EEA”), I will comply with applicable legal requirements providing adequate protection for the transfer of personal information to recipients in countries outside of the EEA. Within the EEA, Emma Pulbrook is the data controller responsible for your personal information and is registered at the UK Information Commissioner’s Office.

3. How to contact us?
If you have any questions about this Privacy Policy or want to exercise your rights set out in this Privacy Policy, please contact me by sending an e-mail to epulbrook@gmail.com.

4. What personal information do I collect and how do I use it?
Our primary goal in collecting personal information from you is to: (i) verify your identity; (ii) help us improve our products and services and develop and market new products and services; (iii) carry out requests made by you on the Site; (iv) investigate or settle inquiries or disputes; (v) comply with any applicable law, court order, other judicial process, or the requirements of a regulator; (vi) enforce our agreements with you; (vii) protect the rights, property or safety of myself or third parties, including our other clients and users of the Site; (viii) provide support for the provision of our Services; and (ix) use as otherwise required or permitted by law.

In particular, we use your personal information for the following purposes:

• Fulfilment of products and services.  For more information read below.

We collect and maintain personal information that you voluntarily submit to myself during your use of the Site and/or my Services. I use the contact and payment details you have provided to us so that we can fulfill the supply of products and services you have ordered from our Site. This includes your purchase of products, your attendance at events hosted by us or our third party partners, alterations to products and customizations to products.

Who do we share your personal information with for this purpose?
We will share your personal information with the following categories of third parties:

• To deliver products and process returns – delivery and courier companies;

• Events – any applicable third party hosting the event; ticketing companies such as Eventbrite;

What is our legal basis?
It is necessary for us to use your personal information to perform our obligations in accordance with any contract that we may have with you.

• Client service enquiries. For more information read below.

Our Site uses various user interfaces to allow you to request information about our products and services: these include printed and electronic enquiry forms and a telephone enquiry service. Contact information may be requested in each case, together with details of other personal information that is relevant to your enquiry. This information is used in order to enable us to respond to your requests.

Who do we share your personal information with for this purpose?
We do not share your personal information for this purpose.

What is our legal basis?
It is in our legitimate interest

• to use your personal information in such a way to ensure that we provide the very best customer service we can to you

Your feedback about our products and services. For more information read below.
From time to we will contact you to invite you to provide feedback about our products and services in the form of online, postal or in-store surveys. We use this information to help us improve the quality of service provided by our staff and in our stores. We also use your feedback to monitor the quality of our products and services and to assist with the selection of future product and service lines.

What is our legal basis?
It is in our legitimate business interests to use the information you provide to us in your feedback for the purposes described above

• Customer insight and analysis. For more information click read below. 

We analyse your contact details with other personal information that we observe about you from your interactions with our Site, our email communications to you and/or with our products and services, such as the products and services you have purchased or viewed.

Where you have given your consent (where lawfully required), we use cookies, log files and other technologies to collect personal information from the computer hardware and software you use to access the Sites, or from your mobile. This includes the following

• an IP address to monitor Sites traffic and volume;

• a session ID to track usage statistics on our Sites;

• information regarding your personal or professional interests, demographics, buying habits, experiences with our products and contact preferences. 

Our web pages and e-mails contain “cookies” "web beacons" or “pixel tags.” (“Tags”). Tags allow us to track receipt of an e-mail to you, to count users that have visited a web page or opened an e-mail and collect other types of aggregate information. Once you click on an e-mail that contains a Tag, your contact information may subsequently be cross-referenced to the source e-mail and the relevant Tag.

In some of our e-mail 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.

This information is used to create profiles and insights about your shopping habits and the shopping habits of our other customers. Where we have your consent to do so, we will also use your location data for customer insight purposes. 

By using this information, we are able to measure the effectiveness of our content and how visitors use our Sites and our Services. This allows us to learn what pages of our Site are most attractive to our visitors, which parts of our Sites are the most interesting and what kind of offers our registered users like to see.

We also use this information to help us with the selection of future product and service lines, store and websites design and to remember your shopping preferences such as garment size.

We also use this information for marketing purposes (see the marketing section below for further details).

Who do we share your personal information with for these purposes?
We share your personal information with a variety of third party service providers to assist us with customer insight analytics.

Some of our third party providers are located in the USA and their use of your personal information is governed by [EU Model Contracts] [US Privacy Shield].

What is our legal basis?
Where your personal information is completely anonymized, we do not require a legal basis to use it as the information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymized personal information may be subject to other laws where your consent is required.

Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information in such a way to ensure that we provide the very best products and services to you and our other customers.

We will only use your location data for customer insight purposes where we have your consent to do so

• Marketing communications. 

We carry out the following marketing activities using your personal information:

• Postal marketing. For more information read below.

We use information that we observe about you from your interactions with our Site, our email communications to you and/or with our products and services (see the Customer Insight and Analysis section above for more details of the information collected and how it is collected) and/or your address details, to send you marketing communications by post.

Who do we share your personal information with for these purposes?
We share your personal information with a variety of third party postal providers who assist us in delivering our postal marketing campaigns to you, including the post office.

What is our legal basis?
Where your personal information is completely anonymized, we do not require a legal basis to use it as the personal information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymized information may be subject to other laws where your consent is required.

Where your personal information is not in an anonymous form, such as your postal address, it is in our legitimate interest to use your personal information for postal marketing.

We will only use your location data where we have your consent to do so.

• Email marketing. For more information read below.

We use information that we observe about you from your interactions with our Site, our email communications to you and/or with our products and services (see the Customer Insight and Analysis section above for more details of the information collected and how it is collected) and/or your email address, to send you marketing communications by email, where you have consented to receive such marketing communications, or where we have another lawful basis to do so.

Who do we share your personal information with for these purposes?
We share your personal information with a variety of third party email marketing providers who assist us in delivering our email marketing campaigns to you.

What is our legal basis?
Where your personal information is completely anonymized, we do not require a legal basis to use it as the personal information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymized personal information may be subject to other laws where your consent is required.

Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information for marketing purposes.

We will only send you marketing communications via email where you have consented to receive such marketing communications, or where we have a lawful right to do so.

• Online personalized advertising. For more information read below.

We use information that we observe about you from your interactions with our Site, our email communications to you and/or with our products [and services in our stores] (see the Customer Insight and Analysis section above for more details of the information collected and how it is collected) to provide you with personalized online advertising.

Who do we share your personal information with for these purposes?
We share your personal information with a variety of third party service providers who assist us with our online personalized advertising campaigns.

What is our legal basis?
Where your personal information is completely anonymized, we do not require a legal basis to use it as the personal information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymized personal information may be subject to other laws where your consent is required.

Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information for marketing purposes.

• Social media remarketing. For more information read below.

We use information that we observe about you from your interactions with our Sites, our email communications to you and/or with our products and services in our stores (see the Customer Insight and Analysis section above for more details of the information collected and how it is collected) to provide you with personalized advertising on social media channels operated by Facebook and/or Google where you are a registered user of such services.

We do this using Facebook Customer Audiences and/or Google Customer Match respectively [others?]. Please note that such activity is also subject to the privacy choices you have elected to make on such services.

Who do we share your personal information with for these purposes?
We share your email address with third party service providers who assist us with social media remarketing campaigns.

Your encrypted email address is also shared by us or our third party service providers  with Facebook and/or Google under the terms of their Facebook Customer Audiences and/or Google Customer Match services respectively.

What is our legal basis?
Where your personal information is completely anonymized, we do not require a legal basis to use it as the personal information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymized personal information may be subject to other laws where your consent is required.

Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information for marketing purposes.

We will only engage in social media remarketing where you have consented to us [using your email address] [sharing your email address in an encrypted format with Facebook and/or Google respectively] for marketing purposes.

Social media insight. For more information read below.
Where you are a registered user of Facebook, or of a Google service, we will use your email address in an encrypted format to enable Facebook and Google to find other registered users of their services that share similar interests to you based on:

• information that we observe about you from your interactions with our Sites, our email communications to you and/or with our products and services in our stores (see the Customer Insight and Analysis section above for more details of the information collected and how it is collected); and

• the information Facebook and/or Google hold about you. 

We do this using Facebook Lookalike Audiences and/or Google Similar Audience respectively. Please note that such activity is subject to the privacy choices you have elected to make on such services.

Who do we share your personal information with for these purposes?
We share your email address with third party service providers who assist us with social media remarketing campaigns.

Your encrypted email address is also shared by us or our third party marketing consultancies with Facebook and/or Google under the terms of their Facebook Customer Audiences and/or Google Customer Match respectively.

What is our legal basis?
Where your personal information is completely anonymized, we do not require a legal basis to use it as the personal information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymized personal information may be subject to other laws where your consent is required.

Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information for marketing purposes.

• Business administration and legal compliance. For more information read below.

We use your personal information for the following business administration and legal compliance purposes:

• to comply with our legal obligations;

• to enforce our legal rights; 

• protect rights of third parties; and

• in connection with a business transition such as a merger, acquisition by another company, or sale of all or a portion of our assets.

Who do we share your personal information with for these purposes?
We will share your personal information with professional advisers such as lawyers and accountants and/or governmental or regulatory authorities.

What is our legal basis?
Where we use your personal information in connection with a business transition, 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, it is our legal obligation to use your personal information to comply with any legal obligations imposed upon us such as a court order.

Where we share your sensitive personal information, we shall obtain your consent to do so.

• Any other purposes for which we wish to use your personal information that are not listed above, or any other changes we propose to make to the existing purposes will be notified to you using your contact details.

5. How do we obtain your consent?
Where our use of your personal information requires your consent, you can provide such consent

• at the time we collect your personal information following the instructions provided; or

• by informing us by e-mail, post or phone using the contact details set out in this Privacy Policy.

6. Our use of cookies and similar technologies
Our Sites use certain cookies, pixels, beacons, log files and other technologies of which you should be aware.


7. Third Party Links and Services
Our Sites contain links to third party websites and services. Please remember that when you use a link to go from our Sites to another website or you request a service from a third party, this Privacy Policy no longer applies. For more information read below.

Your browsing and interaction on any other websites, or your dealings with any other third party service provider, is subject to that website’s or third party service provider’s own rules and policies. 

We do not monitor, control, or endorse the privacy practices of any third parties.

We encourage you to become familiar with the privacy practices of every website you visit or third party service provider that you deal with and to contact them if you have any questions about their respective privacy policies and practices.

This Privacy Policy applies solely to personal information collected by us through our Service and does not apply to these third party websites and third party service providers.


8. How long do we keep your personal information for?
We keep your personal information for a period of three [3] years from the date of our last interaction with you.

If your information is only useful for a short period e.g. for specific marketing campaigns we may delete it.


9. Confidentiality and security of your personal information
We are committed to keeping the personal information you provide to us secure and we will take reasonable precautions to protect your personal information from loss, misuse or alteration. For more information read below.

We have implemented information security policies, rules and technical measures to protect the personal information that we have under our control from

• unauthorised access;

• improper use or disclosure;

• unauthorised modification; and

• unlawful destruction or accidental loss.

All of our employees and data processors (i.e. those who process your personal information on our behalf, for the purposes listed above), who have access to, and are associated with the processing of personal information, are obliged to respect the confidentiality of the personal information of all users of our Services.


10. How to access your information and your other rights?
You have the following rights in relation to the personal information we hold about you

• Your right of access. For more information read below.

If you ask us, we’ll confirm whether we’re processing your personal information and, if so, provide you with a copy of that personal information (along with certain other details). If you require additional copies, we may need to charge a reasonable fee.

• Your right to rectification. For more information read below.

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

• Your right to erasure. For more information read below.

You can ask us to delete or remove your personal information in some circumstances such as where we no longer need it or if you withdraw your consent (where applicable). If we’ve shared your personal information with others, we’ll let them know about the erasure where possible. 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 information with so that you can contact them directly.

• Your right to restrict processing. For more information read below.

You can ask us to ‘block’ or suppress the processing of your personal information in certain circumstances such as where you contest the accuracy of that personal information or you object to us processing it. It won’t stop us from storing your personal information though. We’ll tell you before we lift any restriction. If we’ve shared your personal information 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 information with so that you can contact them directly.

• Your right to data portability. For more information read below.

With effect from 04 March 2020, you have the right, in certain circumstances, to obtain personal information you’ve provided us with (in a structured, commonly used and machine readable format) and to reuse it elsewhere or to ask us to transfer this to a third party of your choice.

• Your right to object. 

You can ask us to stop processing your personal information, and we will do so, if we are:

• relying on our own or someone else’s legitimate interests to process your personal information, except if we can demonstrate compelling legal grounds for the processing; or

• processing your personal information for direct marketing.Your rights in relation to automated decision-making and profiling. For more information read below.

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

• Your right to withdraw consent. For more information read below.

If we rely on your consent (or explicit consent) as our legal basis for processing your personal information, you have the right to withdraw that consent at any time.

• Your right to lodge a complaint with the supervisory authority. For more information read below.

If you have a concern about any aspect of our privacy practices, including the way we’ve handled your personal information, you can report it to the UK Information Commissioner’s Office (ICO). You can find details about how to do this on the ICO website at https://ico.org.uk/concerns/ or by calling their helpline on +44 (0)303 123 1113.


11. Changes to this Privacy Policy
We may make changes to this Privacy Policy from time to time. For more information read below.

To ensure that you are always aware of how we use your personal information we will update this Privacy Policy from time to time to reflect any changes to our use of your personal information. We may also make changes as required to comply with changes in applicable law or regulatory requirements. We will notify you by e-mail of any significant changes. However, we encourage you to review this Privacy Policy periodically to be informed of how we use your personal information.

EFFECTIVE DATE
This Privacy Policy was last updated in March 2020.