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Privacy Policy

Welcome to the SANBEET website (www.sanbeet.com).

At SANBEET we are committed to protecting and respecting your privacy. This notice describes what personal data we collect, how we will use that data and how we keep your data safe. For all other information regarding our services, please refer to our Terms & Conditions.

1) Who is the data controller?

Under the data protection law, the data controller is responsible for ensuring that your data is held securely, that you are given accurate information about how your data is used, and that your rights regarding your data are respected.

The SANBEET website is owned and run by MACHIAVELLI LIMITED. For the purpose of the UK Data Protection Act 2018 and the General Data Protection Regulation 2016 (the Law), the data controllers for any personal data we hold about you are MACHIAVELLI LIMITED of Kemp House, 160 City Road, London, The United Kingdom, EC1V 2NX.

The term “our online services” refers to SANBEET, our mobile and tablet applications, our pages on third party social media platforms such as Instagram, Facebook, Twitter, Pinterest and Google+ and any other websites or apps we own or run from time to time. The term “our services” refers to our online services and any of our other products and services, offered from time to time. If you use any of our services, we will refer to you are using the terms “user”, “visitor”, “you”, “your”, “yours” in this policy.

2) What personal data do we collect?

We collect and process only the data that is required to allow us to provide our services to you. We collect the following data when you browse or shop at www.sanbeet.com:

  1. a) We process the personal data required to complete and dispatch your purchase, including your name, billing address, delivery address, payment details, mobile number, telephone number and email address. We collect your email address in order to send you confirmation of your order; we collect your telephone number so that we can contact you if there are any issues with the order.
  2. b) We collect your email address when you sign up to receive SANBEET News.
  3. c) If you register for a SANBEET account, we collect your name, email address, password, country, day and month of birth and additional information regarding your favourite designers and your marketing preferences.
  4. d) When you contact our Customer Care team, we may collect additional data to help us resolve any queries relating to your order, delivery, payments, marketing, the website or any other queries.
  5. e) We collect and process data about your browsing on sanbeet.com, including the pages you visit and how you interact with these pages. If you have registered for an account, we collect browsing data about your access to the dedicated areas of the website.
  6. f) If you are a customer of sanbeet.com, or if you have given us your consent, we collect and process your personal data for direct marketing activities.
  7. g) If you provide us with someone else’s data – for example, if you purchase a product to be delivered to a friend or as a gift, or provide us with someone’s data as part of our refer-a-friend scheme – we will collect and process the personal data required to complete the transaction such as the name, delivery address and other contact details for your friend. If you are receiving an item as a gift, we will process your data only to fulfil the gift request and our contractual obligations.
  8. h) When you use the App version of our website, we will ask for your consent to collect personal data from you in order to send you brief messages (“push notifications”) about products and services that we believe may be of interest to you. With your consent, we will also collect data regarding your use of the App and your IP address, in order to improve our service to you. You can disable push notification at any time by updating the App settings in your mobile device.
  9. i) When you call our Customer Care team, your call will be recorded for training and fraud prevention purposes.

3) How do we use the personal data we collect?

We collect and process your personal data for the following purposes:

  1. a) To fulfil our contract with you, including taking payment, shipping and delivery;
  2. b) To provide you with relevant information about our products and services via our marketing communications and advertising;
  3. c) To help you take full advantage of our website, including placing and holding items in your shopping bag and using services such as Wish Lists;
  4. d) To improve the performance of our website and our promotion of the website;
  5. e) To allow our Customer Care team to help you with queries and requests;
  6. f) To send you updates to important information such as our Terms & Conditions.

4) What is our legal basis for processing your personal data?

Under the Law we must have a valid reason for using your personal data and we may not collect, store or use data about you that is not compatible with that reason. There are four valid reasons for our use of your personal data:

  1. a) Most of the data we collect from you is necessary to allow us to fulfil our contract with you or to enter into a contract with you e.g. you provide a billing address and email address when you purchase an item from sanbeet.com so that we can process your payment and send you order confirmation.
  2. b) In certain circumstances, we will ask for your permission or consent to use your personal data e.g. if we would like to send you marketing information about items we believe may be of interest to you via email. If you have given your consent to our use of your personal data, you are entitled to withdraw this consent at any time.
  3. c) We may also have a legitimate interest in using your personal data e.g. to ensure that the content of our website is presented to you and your device as effectively as possible, or to ensure that our marketing communications are relevant to your interests. If this is our reason for using your data, we must make sure that our interests do not override yours and you are entitled to object to this use of your data.
  4. d) Lastly, we may be required to use your data to meet a legal obligation or to protect your interests e.g. we may exchange information with other specialist organisations for the purposes of fraud detection and credit risk reduction and we will retain financial data long term to meet our statutory obligations.

5) Who will process your data?

Your personal data will be processed by the internal staff of MACHIAVELLI LIMITED who have been specifically trained and authorised for this processing. In carrying out the processing, the data may also be transmitted to companies belonging to MACHIAVELLI LIMITED.

Your personal data will also be transmitted to third parties that we use to provide our services; these parties have been rigorously assessed and offer a guarantee of compliance with the legislation on the processing of personal data. These parties have been designated as data processors and carry out their activities according to the instructions given by MACHIAVELLI LIMITED and under its control.

The third parties in question belong to the following categories: banking operators, internet providers, companies specialising in IT and telematics services; couriers; companies that carry out marketing activities, including social media organisations; companies specialising in market research and data processing; companies offering contact centre services; companies providing publishing and distribution services.

When we share your personal data with Royal Mail Group Limited for the purposes of international and domestic shipments, on demand delivery and the security screening associated with these services, Royal Mail Group Limited and MACHIAVELLI LIMITED are both controllers of your personal data. MACHIAVELLI LIMITED is the controller of the personal data of its customers and Royal Mail is the controller of personal data provided to Royal Mail to perform these services. Here is a link to Royal Mail’s Privacy Policy: https://www.royalmail.com/privacy-notice)

Under some circumstances we may be required to disclose or share your data without your consent, for example if we are required by the police, the courts or for other legal reasons. Your data may be transmitted to the police, judicial and administrative authorities, in accordance with the law, for the investigation and prosecution of crimes, the prevention of and protection from threats to public security, to allow MACHIAVELLI LIMITED to ascertain, exercise or defend a right in court, as well as for other reasons related to the protection of the rights and freedoms of others.

We may also transfer your personal data to a buyer or potential buyer in the event that our assets are acquired by another organisation. The purchaser will be required by law to use your personal data only as described in this Privacy Policy.

6) Data transfer outside the European Union

Some of the third parties listed in the previous paragraph ‘Who will process your data?’ may be located in countries outside the European Union that nevertheless offer an adequate level of data protection, as established by specific decisions of the European Commission (https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en)

The transfer of your personal data to countries that do not belong to the European Union and that have not been assessed as offering adequate levels of protection will be performed only:

  1. after the completion between MACHIAVELLI LIMITED and said parties of specific agreements containing safeguard clauses and appropriate guarantees for the protection of your personal data (known as “standard contractual clauses” and approved by the European Commission), or
  2. if the transfer is necessary for the completion and execution of a contract between you and MACHIAVELLI LIMITED (for the purchase of goods offered on our website, for registration on the website or use of services on the website), or for the management of your requests.

7) How long do we keep your data?

We keep your personal data for a limited period of time in line with our data retention policy. The specific retention period will vary according to the reason for processing your personal data. After this period, your data will be permanently erased or otherwise irreversibly rendered anonymous.

Your personal data are retained in accordance with the following criteria:

When you have purchased goods from www.sanbeet.com, we will retain the billing data until the end of the relevant accounting period, normally seven years from the billing date;

When you make a payment, we will retain your payment details up to the certification of the payment and the completion of the relevant administrative-accounting formalities regarding your right of withdrawal and the terms applied for the disputing of the payment;

When you provide us with personal data in order to use the services of www.sanbeet.com, such as marketing communications subscription, we will keep your data for this purpose until the termination of the service or until you cancel your subscription to the service;

When you give us your consent to send you marketing communications, you can withdraw your consent at any time. We will consider your consent to be current for five years from your last interaction with any email that we send you, with our App or with www.sanbeet.com. In any case, we will reduce the number of marketing contacts after six months if you don’t interact with us;

When we use your personal data and browsing history to analyse your behaviour in order to customise the website and to show you personalised sales offers, we will keep the data for analytical purposes until you ask us to delete it;

When we use personal data for market research and satisfaction surveys, we will keep the data until you ask us to stop.

When you contact our Customer Care team, we will keep any additional personal data you provide that is specific to your enquiry for as long as you remain an active customer of www.sanbeet.com.

When you contact our Customer Care team, we will keep the call recording for 6 months. Credit card details are not recorded as part of the call.

8) Your rights

You have the right to request a copy of the data that we hold about you (and we will provide this to you free of charge once we have confirmed your identity).

If you would like a copy of some or all of your personal data, please email or write to us using the contact details in this policy.

If we do hold data about you we will:

  • give you a description of it
  • tell you why we are holding it
  • tell you who it could be shared with
  • tell you how long we will keep the data
  • if the data was not provided by you, we will give you any available information such as the source of the data
  • tell you if the data has been used for automated decision making
  • tell you if the data is stored outside of the European Economic Area, and if so what safeguards are in place to protect your personal data
  • let you have a concise and clear copy of the data

You have the right to ask us to correct any inaccuracies in the personal data we hold about you and to stop us using your data until it has been corrected. We want to make sure that your personal data is accurate and up to date and we will be happy to correct or remove data you think is inaccurate. You can also update your own information at any time by logging into My Account at www.sanbeet.com

You have the right to withdraw your consent to marketing at any time by calling our Customer Care team, clicking “unsubscribe” on a marketing email or replying STOP to a text message. Alternatively, you can sign in to your account on www.sanbeet.com and update your requirements in our Email Preference Centre. You may receive a small number of further communications immediately after unsubscribing but we will implement your request as quickly as possible.

You have the right at any time to oppose our processing of your personal data on the basis of our legitimate interest. You will need to explain the reasons behind your request and allow us to consider your request and respond.

You have the right to request the deletion of your personal data. After receiving and reviewing your request, if legitimate it will be our responsibility to cease processing promptly and to delete your personal data.

You have the right to receive a copy of your data that we process based on your consent or on the basis of a contract with you in a standard format. If you wish, where technically possible, we can transfer your data directly to a third party indicated by you.

To exercise any of these rights, you can sign in to your account, contact our Customer Care team at customercare@sanbeet.com. To ensure that the data of our users are not subject to breaches or illegitimate use by third parties, we will ask you to confirm your identity before carrying out your request.

9) Security

We protect your personal data with specific technical and organisational security measures aimed at preventing your personal data from being used illegitimately or fraudulently.

In particular, we use security measures that guarantee: encryption of your data; the confidentiality, integrity, and availability of your data as well as the resilience of the systems and services that process them; the ability to restore data in the event of a data breach. Furthermore, MACHIAVELLI LIMITED undertakes to test, verify and regularly evaluate the effectiveness of technical and organizational measures in order to guarantee continuous improvement in the safety of processing.

10) Complaints

If you believe that MACHIAVELLI LIMITED is processing your personal data in contravention of the Law, you can file a complaint with the supervisory authority responsible for compliance with the rules on personal data protection.

In the UK, the complaint can be presented to the ICO. More information on how to complain is available on the ICO’s website at https://ico.org.uk/.

11) Changes to this notice

We keep our Privacy Policy under regular review in order to reflect changes in our services and in privacy regulation. This Privacy Policy was last updated on November 25, 2018

12) Legislative references and useful links.

The processing of your personal data is carried out by MACHIAVELLI LIMITED in compliance with the Regulation (EU) 2016/679 general regulation on data protection, UK Data Protection Act 2018 and rules on the processing of personal data (https://ico.org.uk/).

 

  • WHAT PERSONAL INFORMATION DO WE COLLECT FROM YOU AND HOW?

We collect personal information about you when you register or subscribe for one of our services, place an order, buy a gift voucher, use our online services, interact with us in any other way, such as via social media, click on an advert that we put on our or someone else’s website, use our Personal Shopping services, ask for information or assistance, give us a testimonial or other feedback, comment on any blogs or articles featured in our services, attend an event that we run or sponsor, enter competitions or special promotions, sign up for our special offers or other updates, participate in research panels or fill in surveys. By registering, subscribing or using our services, you consent to the use of your personal data in line with this policy. We may also receive information about you from our Group and from third parties, with whom we have a business relationship.

The information we collect and hold about you may include your name, email address, phone and mobile phone numbers, home address, shipping and payment card billing address, payment card details, IP address, search criteria, shopping history, shopping preferences, sizings, responses to research panels and surveys, the type of browser you use (a browser is the program you use to look at websites, such as Internet Explorer, Firefox or Safari), the times when you access the site and for how long, your referring URL (the site you come from to reach our website), cell IDs (these are the unique identifiers of the telecommunications towers being used by your mobile phone when you use our location-based services on your mobile phone or tablet) and other location information (for example, GPS measurements), photographs and other content you share with us when you use our services, date of birth, password details, answers to security questions and any other information you may give us.

We may record or monitor calls that you receive from us or make to us. We do this for security and training purposes, and to improve the services we provide to you.

  • HOW THIS INFORMATION MAY BE USED

Whenever you give us your personal information we will use it in accordance with applicable privacy laws and for the purposes set out in this policy, on the data entry forms you complete, in any relevant terms and conditions and on pages or emails which link to the data entry forms.

When you use our services: If you use any of our services, register for or attend one of our events, set up, look at or change your account details or contact your personal shopper or a member of our Customer Care team, we will record your personal details. Your information will be used in the first place to provide the products, services or information you have asked for and to provide you with a personalized shopping experience. We keep the information you provide and may use it for several purposes, including: (i) accounting, billing, reporting and audit; (ii) credit checking or screening; (iii) authentication and identity checks; (iv) credit, debit or other payment card verification and screening; (v) debt collection; (vi) safety, security, health, training, administrative and legal purposes; (vii) data matching and dedupe, statistical and market analysis, and marketing information; (viii) advertising and marketing for us, our Group and third parties; (ix) developing, testing and maintaining systems; (x) studies, research and development; (xi) customer surveys; (xii) customer care and to help us in any future dealings with you, for example by identifying your requirements and preferences; (xiii) where required by law or in connection with legal proceeding or disputes; and (iv) any other uses set out in the terms and conditions for use of our services. For these purposes, we may disclose your information to one or more of the other organisations listed in the section called “who we will share your personal information with”.

Saved payment card details will only be shared with our payment partner and not with any other third parties and will only be used to process your order, using our payment partner’s systems.

We may also use your personal information to send you marketing updates, as detailed in the next section.

Tracking how our online services are used: We collect, and use third parties to collect and share with us, information from lots of visitors to our online services and analyse it to build up a picture of how people use our websites. This helps us improve the services we offer. We may also give anonymous statistics about visitors to other, reputable organisations, but the information we provide will not include details that would allow these organisations to identify you.

Customization of our online services and advert targeting: We may use the information you give us about yourself and the information we collect via cookies when you use our online services to build up a picture of your interests. We may then use this information to try to make sure that when we send you marketing communications and when you visit our websites or use our online services, you don’t miss offers and information that might interest you. This information may also be used by our third-party advertising agencies and networks, to advertise our own or third-party products and services to you when you visit third-party websites and online services. This is called advert targeting or interest-based advertising.

Testimonials: If you give us feedback, we may use it to improve our services and we may publish it online or offline to promote our business and our services. We will ask for your permission before we publish it.

Comments and reviews submitted to our online services: If you wish to submit a comment or feedback on a blog or article featured on our services, we may (but are not obliged to) publish your comment online or offline to promote our business and our services. We will collect your name or username which will be displayed next to your comment and e-mail address, which will not be published, but which we may use to contact you in relation to your comment.

Mobile services: When you request our mobile services, we may keep your mobile phone number, the make and model of your phone, the operating system used by your phone and details of your network operator, and we will link a unique identifier to your mobile phone number. We’ll store your device language, app language, country, We need this information in order to provide the features and services enabled through our mobile services and to administer our mobile service. Our Givenchy mobile services use your location to show your closest Givenchy store. We may also use it for SMS or voice marketing and market research.

Social networks: If you follow us or interact with us on any of our pages on third-party social media platforms, such as Instagram, Facebook, Twitter, Pinterest and Google+, the information you provide will be subject to the third party’s privacy policy, as well as this privacy policy.

Direct marketing: For information on how we may market to you, please read the section called “marketing opt-in and opt-out provisions”.

Customer surveys: Every now and again, we may ask you for your opinion on our services and the products you have purchased through our services. When we do research or surveys, we may use cookies and may combine the information collected by those cookies with your answers.

  • WHO WE WILL SHARE YOUR PERSONAL INFORMATION WITH

We will share your information with other companies in our company, who may use it for their own business purposes, as set out in their privacy policy. These purposes may include financial reporting and analysis, strategic planning, the development of customer segmentation and metrics to provide a consistent view of our customer base, research and analytics, to help us source the right products in future and make better product recommendations, more effective targeting of our marketing campaigns, the creation of inspiring content and editorial features, the development of new products and collaboration opportunities with designer brands. It will also be used to provide more tailored marketing by phone, post, email, SMS or any other means (electronic or otherwise) and you expressly agree to such use.

From time to time, we may engage third party business partners to provide information about you or to collect personal information on our behalf. We may also share or match your data with third-party business partners to provide you with the products, services or information you ask for or for interest-based advertising. We may pass your information onto one or more of the following organisations: (i) data processing companies, mailing houses and other third party suppliers working on our Group’s behalf; (ii) ad-serving agencies and other advertising intermediaries; (iii) credit reference or fraud prevention agencies, which may keep a record of that information; (iv) research students, universities and other research and development organisations; (v) regulatory bodies, government and enforcement agencies, such as the police.

Every now and again, we receive requests for information from government departments, the police and other enforcement agencies. If this happens, and there is a proper legal basis for providing your personal information, we will provide it to the organisation asking for it.

We collate information about site traffic, sales, wish lists, and other commercial information which we may pass onto third parties, but this information does not include any details which can identify you personally.

  • WHERE WE PROCESS YOUR PERSONAL INFORMATION

When we use your information as described in this policy, this may involve sending your information outside the European Economic Area (EEA). When we do this, we make sure that appropriate steps are taken to protect your personal information and your rights. By providing us with your personal information, you agree that we may transfer, store and process your information outside the EEA. Governments in certain countries such as the USA have broad powers to access data for security, crime prevention and detection and law enforcement purposes.

  • MARKETING OPT-IN AND OPT-OUT PROVISION

We offer you the chance to receive news and fashion updates which, depending on your preferences, we will discuss with you by phone or live chat or send to you via email, SMS and/or direct mail. These include alerts for new products, features, enhancements, special offers, upgrade opportunities, contests, events of interest, and one-off marketing promotions. You can opt-out of receiving these updates if you wish.

We, or our third-party business partners, may also ask you if you want to receive marketing if you enter a promotion or attend an event thrown or sponsored by us.

Marketing communications you subscribe to will only be sent by our company.

You have the right to ask us not to use your personal information for marketing. At all times, we will offer you the opportunity to unsubscribe from any service or update to which you have subscribed, if you change your mind. Whenever you receive direct marketing from us, we will tell you how to unsubscribe. Alternatively, you can change your marketing preferences by logging into My Account. To opt out of direct mail, please contact our Customer Care team: customercare@sanbeet.com

If you tell us that you do not want to receive direct marketing, we will still contact you in order to provide you with the products and services you request and for administration purposes.

  • HOW YOU CAN ACCESS YOUR PERSONAL INFORMATION AND KEEP IT UP TO DATE

You have the right to review and update your personal details. If for any reason you are concerned that the personal information we hold is not correct, please visit our online services and, after logging into the site using the “Sign In” menu on the home page, your personal information will be made available for review and change in the “My Account” dashboard. Only you or, upon your request, our Customer Care team, may access your personal data from our online services using your user ID and password. Information may be changed online within “Account Details”, “Address” and “My Email Preferences”. You can change or delete saved credit/debit card details each time you make a purchase. You will also be able to delete saved credit/debit card details by adding or editing a shipping/billing address. If you change your billing or shipping address while your order is still being processed, the order will be re-processed through security validation checks. If you prefer, you may contact us by email at customercare@sanbeet.com and we will amend your personal details.

  • SAFEGUARDING YOUR PERSONAL INFORMATION

We will take reasonable care to maintain appropriate safeguards to ensure the security, integrity and privacy of the information you have provided to us. We have put in place technology and security policies which are designed to protect the personal information we hold about you. We also follow the security procedures that applicable privacy laws require. These cover storing, using and releasing any information you have provided and, as well as measures designed to prevent unauthorised access or use. When you place an order or access your account information, we use a Secure Socket Layer (SSL) encryption which encrypts your information before it is sent to us to protect it from unauthorised use.

  • WHY WE LINK TO OTHER WEBSITES

Our online services contain hyperlinks to websites that are owned and operated by other organisations. These websites have their own privacy and cookie policies, and we urge you to read them. They control how your personal information is used when you give it to these other organisations or they collect it with cookies. We do not approve any other websites and we are not responsible for any information, material, products or services that are on or accessible through those websites or for the privacy practices of websites run by other organisations. If you use these other websites you do so at your own risk.

  • HOW WE CAN MAKE CHANGES TO THIS POLICY

We may update this privacy policy from time to time so you may want to check it each time you give us personal information or use our websites.

  • WHERE AND HOW TO ASK QUESTIONS OR CONTACT US ABOUT THIS POLICY

If you require further information about our privacy policy, please go to the help section of our websites where frequently asked questions (FAQ’s) are answered. We welcome your questions, comments and requests about this privacy policy.

 

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