1.1 We are committed to safeguarding the privacy of our website visitors and customers; in this policy we explain how we will handle your personal data.
1.3 Our website incorporates privacy controls which affect how we will process your personal data.
2. How we use your personal data
2.1 In this Section 2 we have set out:
(a) the general categories of personal data that we may process;
(b) the purposes for which we may process personal data; and
(c) the legal bases of the processing.
2.2 We may process data about your use of our website and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our internal analytics tracking system and google analytics. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.
2.3 We may process your account data ("account data"). The account data may include your first name, last name, email address, submitted billing and delivery addresses, submitted prescriptions, previous order and transaction details. The source of the account data is you. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.
2.4 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters ("notification data"). The notification data may include your first name, last name, email address, number of orders, products ordered, address and pages visited. The source of the account data is you and our internal tracking system. The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent.
2.4 We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website ("transaction data"). The transaction data may include you first name, last name, email address, billing address, delivery address, telephone number, order and prescription details, card and transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely our interest in the proper administration of our website and business.
2.5 We may process information contained in or relating to any communication that you send to us ("correspondence data"). The correspondence data may include your first name, last name, email address, telephone number, communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
2.6 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
2.7 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
2.8 In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
3. Providing your personal data to others
3.1 We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.
3.2 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
3.3 Financial transactions relating to our website and services may be handled by our payment services providers, Authorize.net and Paypal. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers' privacy policies and practices at https://www.authorize.net/ and https://www.paypal.com
3.4 In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
4. International transfers of your personal data & our data processors
4.1 In this Section 4, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).
4.2 The following companies act as our data processers. We have in place DPA agreements with each of them to ensure that they only process your data in accordance with the current law.
|Corporate Entity||Data Category||Use|
|Usage Data,||Anonymous data for tracking website usage, page views. Used for advertising to show or not show ads to visitors.|
|ZendDesk||Correspondence Data,||Used to communicate with you through the live chat help system should you wish to use this.|
|Authorize.Net||Transaction Data,||Used to process your payment to us for orders.|
|PayPal||Transaction Data,||Used to process your payment to us for orders.|
|Amazon AWS||Usage Data, Notification Data, Account Data, Transaction Data, Correspondence Data,||Our hosting provider used to serve our website and retain off site data back ups.|
|InfusionSoft||Notification Data, Account Data,||Used to send you email notifcations and email newsletters if you are subscribed to our newsletter.|
|Usage Data,||Used for advertising to show or not show ads visitors.|
|Bing||Usage Data,||Used for advertising to show or not show ads visitors.|
|TrustPilot||Account Data,||Used to request service and product reviews|
5. Retaining and deleting personal data
5.1 This Section 5 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
5.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
5.3 We will retain your personal data as follows:
(a) "Usage Data" will be retained for a minimum period of six months from the date of your last website visit and for a maximum period of 38 months.
(b) "Account Data" will be retained as long as you have an active account on our system. The account data will be retained for a maximum period of three months following the date of a request to close your account.
(c) "Notification Data" will be retained as long as you have an active subscription to our newsletter and for a maximum period of two months following the date of your request to unsubscribe.
(d) "Transaction Data" will be retained for a minimum period of nine years following the transaction date and for a maximum period of twelve years following the transaction date.
(e) "Correspondence Data" will be retained for a minimum period of one year following the date the communication was made and for a maximum period of four years following the date the communication was made.
5.4 Notwithstanding the other provisions of this Section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
6.1 We may update this policy from time to time by publishing a new version on our website.
6.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
6.3 We may notify you of changes to this policy by email or through the private messaging system on our website.
7. Your rights
7.1 In this Section 7, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
7.2 Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
7.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
7.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
7.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary for: exercising the right of freedom of expression and information; compliance with a legal obligation; or the establishment, exercise or defence of legal claims.
7.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
7.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
7.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
7.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
7.10 To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
7.11 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
7.12 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
7.13 You may exercise any of your rights in relation to your personal data by written notice to us.
8. Third party websites
8.1 Our website includes hyperlinks to, and details of, third party websites.
8.2 We have no control over, and are not responsible for, the privacy policies and practices of third parties.
9. Personal data of children
9.1 Our website and services are targeted at persons over the age of 16
9.2 If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.
10. Updating information
10.1 Please let us know if the personal information that we hold about you needs to be corrected or updated.
11. About cookies
11.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
11.2 Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
11.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
12. Cookies that we use
|AJAXBOOKMARKS_MARKED_PRODUCTS||Saves frames that you add to favourites your page when not logged in to your account.|
|frontend||Stores your session ID|
|frontend_cid||Stores your session ID on secured pages|
|saw_hoveradd||Used to prevent our hover ad newsletter optin form from being displayed more than once.|
|infusion_tracking||Internal page view tracking cookie.|
|epc-initiated||Used for page caching purposes.|
|epc-no-primary-cache||Used for page caching purposes.|
|epc-ic||Used for page caching purposes.|
|external_no_cache||A flag that indicates if caching is disabled.|
|rewardpoints_offer_key||Stores reward points offer coupon key.|
|infusion_contact_id||Stores internal page tracking subscriber id|
|infusion_tagged_pages||Stores internal page tracking visited pages|
|infusion_tracker_expires||Stores internal page tracking cookie expiry date|
13. Cookies used by our service providers
|MUID, MUIDB||Bing analytics service that connects data from the Bing advertising network with actions performed on the Website.|
|_cfduid||Zopim allows us to live chat in order to provide support. The cookie “__cfduid” internaly identifies the Zopin user and saves their preferences regarding Zopim’s internal unit use. “__zprivacy” y “__zlcid” might also be created.|
|1P_JAR||Google advertising cookie used for user tracking and ad targeting purposes|
|NID||Google tracking cookie|
|fr||Used to control online advertising and for re-targeting, optimization, and reporting of online adverts on Facebook|
14. Managing cookies
14.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);
(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
(c) http://www.opera.com/help/tutorials/security/cookies/ (Opera);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(e) https://support.apple.com/en-us/HT201265 (Safari, iPad & iPhone); and
(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
14.2 Blocking all cookies will have a negative impact upon the usability of many websites.
14.3 If you block cookies, you will not be able to use all the features on our website including placing an order.
15. Cookie preferences
16. Our details
16.1 This website is owned and operated by Fashion Specs Direct Ltd.
16.2 We are registered in England and Wales under registration number 5986776, and our registered office is at 61 Rodney Street, Liverpool, L1 9ER.
16.3 Our principal place of business is at Spex4less, Everite House, Carr Lane, Hoylake, Wirral, CH47 4BG.
16.4 You can contact us:
(a) by post, to the postal address given above;
(b) using our website contact form;
(c) by telephone, on the contact number published on our website from 9.00am to 5.00pm.
(d) by email, using the email address published on our website.