BOING Privacy Policy


These Policy Terms describe the categories of personal data we process and for what purposes. We are committed to collecting and using such data fairly and in accordance with the requirements of the General Data Protection Regulations (GDPR).

These GDPR Policy Terms will become effective from 25th May 2018.

1. Introduction

1.1 We take your privacy seriously and you can find out more here about your privacy rights and how we gather, use and share your personal information – that includes the personal information we already hold about you now. How we use your personal information will depend on the products and services we provide to you.

1.2 Our Data Protection Officer (DPO) provides help and guidance to make sure we apply the best standards to protecting your personal information. Our DPO can be reached by email atsarah@boingjewellery.comor by post to: BOING Data Protection Officer, BOING Jewellery Ltd, Unit 4, Woodhurst Road, Maidenhead, SL6 8TF if you have any questions about how we use your personal information.

See section 3 for more information about your rights and how our DPO can help you.

1.3 This Privacy Notice provides up to date information about how we use your personal information and will update any previous information we have given you about using your personal information (also referred to as personal data). We will update these Terms if we make any significant changes affecting how we use your personal information, and if so we will contact you to let you know about the change.

2. About us

We are what is known as the 'Controller' of personal information we gather and use. When we say 'we' or 'us' in this document, we mean BOING Jewellery Ltd, company number 07777652.

3. Your privacy rights

3.1 You have the right to object to how we use your personal information. You also have the right to see what personal information we hold about you. In addition, you can ask us to correct inaccuracies, delete or restrict personal information or to ask for some of your personal information to be provided to someone else. You can make a complaint to us by finding the best way to be in touch via the details on our websites:

www.boingjewellery.com

You can also make a complaint to the data protection supervisory authority, the Information Commissioner's Office, at https://ico.org.uk

Read more about your Privacy Rights

You can contact us via the website details supplied above to exercise any of the following privacy rights:

3.2 Right to object:

You can object to our processing of your personal information. Please contact us as noted above, providing details of your objection.

3.3 Access to your personal information

You can request access to a copy of your personal information that we hold, along with information on what personal information we use, why we use it, who we share it with, how long we keep it for and whether it has been used for any automated decision making. You can make a request for access free of charge by emailing our DPO in 1.2 above. Please make all requests for access in writing., and provide your full name, address and email address so we have proof of who you are to safeguard your data.

3.4 Right to withdraw consent

If you have given us your consent to use personal information, you can withdraw your consent at any time and, update your marketing preferences by calling us directly or unsubscribing from any mail out sent to you.

3.5 Rectification

You can ask us to change or complete any inaccurate or incomplete personal information held about you.

3.6 Erasure

You can ask us to delete your personal information where it is no longer necessary for us to use it, you have withdrawn consent, or where we have no lawful basis for keeping it.

3.7 Portability

You can ask us to provide you or a third party with some of the personal information that we hold about you in a structured, commonly used, electronic form, so it can be easily transferred.

3.8 Restriction

You can ask us to restrict the personal information we use about you where you have asked for it to be erased or where you have objected to our use of it.

3.9 Make a complaint:

You can make a complaint about how we have used your personal information to us, by emailing us as in 1.2 or calling us through the website in 3.1 above or to a supervisory authority - for the UK this is the Information Commissioner's Office at ico.org.uk (Link opens in a new window).

We will not make any charge for responding to any request from you to exercise your privacy rights, and we will respond to your requests in accordance with our obligations under data protection law.

4. What kinds of personal information we use

4.1 We use a variety of personal information depending on the products and services we deliver to you. For most services, we need to use your name, address and your email address and occasionally your telephone number and a history of products previously ordered by you.

5. How we gather your personal information

We obtain personal information:

  • directly from you, for example when you place an order on our website or respond to social media campaigns on line.
  • All transactional details are conducted by either WorldPay or Paypal and BOING Jewellery Ltd has no access to any card details and fully complies with the PCIDSS requirements to safeguard all payment data.
  • To make a refund to you by BACS however, we will require the name your bank account is in, your sort code and account number.These details are held only for the purposes of making your refund and all data here is destroyed and not retained.

6. How we use your personal information

To process an on-line customer order we clearly need to know your name, email address, delivery address and ideally your telephone number in the case of an issue that we feel is in your interests to be aware of or to re-confirm some order aspect (for example a very unusual product size or a bespoke request).

6.1 To deal with any complaints and fixing our mistakes, we will use:

  1. your contact details, principally your name, telephone number and email address;

6.2 To administer payments to and from you, we will use:

  1. your contact details and the payment details that you have provided to us; and

This information will be used by third party payment providers (in our case WorldPay linking to Barclays bank or Paypal) to process the payment to / from you.

6.3 To make credit decisions about new stockists (including new applications for credit or requests to increase credit limits) we will use:

  1. information you give to us about your credit history or other information in the public domain or our own knowledge of your credit pattern;

6.4 To comply with any legal obligations from a government office, to prevent financial crime including fraud and money laundering we will use:

  1. any information you have given us, that we have obtained from a third party, or that we have obtained by looking at how you use our services, only where it is necessary for us to use that information to comply with a legal obligation; and

6.5 For financial management and debt recovery purposes, we will use:

  1. Any of your contact details;
  2. information we obtain from looking at how you have used our services, including information about the pattern of your purchases;

We will give information to and receive information from third parties where that is necessary to recover debts due by you to us, for example, debt recovery agents, credit reference agencies and sheriff officer or bailiff services. This might include passing personal information about you to a third party who we have transferred your debt to, and who will then contact you directly to collect that debt. If your debt is transferred to a third party you will be advised of the identity of that third party. This is usually only in respect of stockist who have been granted credit terms as on line payments for web purchases are taken up front.

We use your information in this way because it is necessary to perform our contract with you, to exercise our legal rights, and because it is fair and reasonable for us to do so.

6.6 To enable payments to third parties (such as sales agents or distributors dealing with our network of stockists in the UK or EEA) who may have introduced you to us, we will use:

  1. information about the general nature of the products and services; and
  2. information about the value of those products and services.

We use your information in this way because it is in our interests to do so to provide you with the products and services that best suit you.

We will give information to and receive information from our agents or distributors who have introduced you to us.

6.7 To carry out market research and analysis to develop and improve our products and services we will use:

  1. information about how you have used our website and your product order history

We may pass your personal information to market research companies and other service providers as required.

6.8 To market products and services to you from us or our partners, we will use:

  1. the contact details you have provided to us; and
  2. information we have gathered from your use of our other products and services to form a profile of you which we will use to assess what other products and services would be most beneficial for you.

We will pass your personal information to our digital media and social media service companies who help us with these marketing activities.

We might also receive personal information about you from a third party and use it to market our products and services to you, where you have given that third party your consent to share the personal information with us. We may collect your name and address from other service providers for the purpose of providing suitable marketing to you.

7. Automated decision making

Profiling for marketing

We want you to get the most relevant information about products and services at the right time. The most effective way for us to do this is to use automated processes with digital and social media marketing to create a profile of you.

To carry out marketing profiling we use information you give to us, details about what other products you have with us and any feedback you have given us.

We use processes to analyse this information to decide what products to offer to you and to prioritise the marketing messages you receive by; assessing your eligibility for those products and services; assessing how likely they are to be of interest for you; and deciding how likely you are to respond.

We use data that you have provided or that we have collected from you from use of your account. We use this information to create models based on the performance of previous promotional initiatives, so that we can predict the likely success of future promotions generally, but this information is not used to make any specific decisions about you as an individual.

The partners we pass your personal information to for marketing might also carry out marketing profiling using your personal information for these purposes

8. Our legal basis for using your personal information

8.1 We only use your personal information where that is permitted by the laws that protect your privacy rights. We only use personal information where:

  1. we have your consent (if consent is needed);
  2. we need to use the information to comply with our legal obligations;
  3. we need to use the information to perform a contract with you; and/or
  4. it is fair to use the personal information either in our interests or someone else's interests, where there is no disadvantage to you – this can include where it is in our interests to contact you about products or services, market to you, or collaborate with others to improve our services.

Where we have your consent, you have the right to withdraw it.

9. Sharing your personal information with or getting your personal information from others

9.1 We will share personal information within our company only and with BOING’s sales agents and distributors only (if you are a stockist or potential stockist) in cases where we need to do that to make products and services available to you, market products and services to you, meet or enforce a legal obligation or where it is fair and reasonable for us to do so. We will only share your personal information to the extent needed for those purposes.

9.2 Most of the time the personal information we have about you is information you have given to us,or gathered by us in the course of providing products and services to you. We also sometimes gather personal information from and send personal information to third parties where necessary for credit checking or marketing purposes, for example so you can receive the best offers from us and our partners.

10. Transfers outside the UK

10.1 We may need to transfer your information outside the UK to; service providers, agents, subcontractors and regulatory authorities in countries where data protection laws may not provide the same level of protection as those in the European Economic Area, such as the USA.

Find out more about how we transfer your data outside of the UK

We may need to transfer your personal information to territories that are outside the EEA. We will only transfer your personal information outside the EEA where either the transfer is to a country which the EU Commission has decided ensures an adequate level of protection for your personal information, or we have put in place our own measures to ensure adequate security as required by data protection law. These measures include ensuring that your personal information is kept safe by carrying out strict security checks on our overseas partners and suppliers, backed by strong contractual undertakings approved by the relevant regulators such as the EU style model clauses. You can find out more information about standard contractual clauses as detailed by the ICO. Visit their website at ico.org.uk (Link opens in a new window) and search for ‘International transfers’.

11. How long we keep your personal information for

11.1 How long we keep your personal information for depends on the products and services we deliver to you. We will never retain your personal information for any longer than is necessary for the purposes we need to use it for.

We will not use your personal information for marketing purposes once you tell us not to or choose to unsubscribe to any marketing initiative from BOING. We will keep the other personal information until you opt out or advise us you no longer wish to subscribe to any newsletters or information on new products.

12. Keeping you up to date

12.1 We will communicate with you about products and services we are delivering using any contact details you have given us - for example by post, email, social media, or website.

12.2 By purchasing a BOING product from our website you will be added automatically to our marketing database unless you opt out as part of the checkout process on our website by clicking on the marketing opt out box.Where you have given us consent to receive marketing, you can withdraw consent, and update your marketing preferences by calling us directly, writing to us or simply unsubscribing from automated mailshots.

You can also update your contact preferences by emailing or calling us directly. For contact details, visit our websites on www.boingjewewllery.com

13. Your online activities

13.1 We may use cookies to track your use of our website.We may use cookies to provide tailored marketing messages when you are logged into our website if you have given us consent.

13.2 Find out more about cookies

A cookie is a small file which is sent to your browser and stored on your computer's hard disc and helps us understand and track your use of our websites and where we can improve the information and services provided. We use cookies solely to gather information on IP addresses, to analyse trends, administer the website, track your movements on the website and gather broad demographic information for aggregate use. For information about blocking the use of cookies, please refer to the instructions/help screen on your internet browser. Please note that you may not be able to use or access certain parts of the website or online services if you block the use of all cookies. For further information on our use of cookies visit the Privacy and Cookie section on our website at the footer.

Old Data & Cookie Policies before GDPR - Some of which can be still relevant

INTRODUCTION

Please do not send emails or register on the site if you do not want that information to be processed by us in the ways described by this notice.  By providing us with information on the Site, you consent to the transfer of personal data as described in the following policy.

Your privacy is very important to us.  This Privacy and Cookie Policy explains what information we collect about you and what we do with it.  Please take a few minutes to read it.

BOING Jewellery Ltd., trading as BOING (“we”) run this site www.boingjewellery.com (the “Site”) for visitors who wish to find out more about our business and for visitors who wish to purchase our products (“you”) using this Site.

Your access, use of and submission of an order via the Site constitutes your explicit consent to the collection, use and transfer of your personal data, in the manner described in this Privacy and Cookie Policy (“the Policy”).  If you disagree with the way we process data collected on the Site, we recommend kindly that you do not use the Site.  If you wish to obtain further information about us / or the contents of this Privacy and Cookie Policy, you can contact us by email, post or telephone.

1. WHAT TYPE OF DATA DO WE COLLECT ABOUT YOU?

Personal data relating to Internet users viewing the Site may be collected through the Site on each of the following occasions:

  1. data regarding navigation may be collected by our web servers or by cookies when you are browsing the Site;
  2. data regarding your identity and email address may be collected when you send an email to us through the Site (if you choose to do so), for instance via the ‘Contact Us’ page or where you submit an Order in accordance with our Terms and Conditions;
  3. data regarding your identity may be collected by the Site on online registration; and
  4. Upon collection the personal data will be stored for as long as is reasonably necessary to provide goods and services, in accordance with our Terms and Conditions.
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2. WHAT IS A COOKIE

A cookie is a tiny element of data that is stored on your computer’s hard drive by your web browser when you access a website. The Site makes use of the following types of cookie technology:

  1. A “Session cookie”, which contains a random ID number automatically allocated to your computer by the webserver for the duration of your visit. It is meant to make your use of the Site faster and easier. It will be deactivated after thirty minutes of inactivity on the Site and will be automatically removed from your computer when you close your browser.
  2. A “Script generated cookie” is automatically allocated to your computer when you register to access any restricted areas of the Site and on each subsequent visit. It only contains an identifier which will enable the Site to identify you as a registered user so that you do not have to identify yourself again while you move from one server to another during your visit. It will remain on your computer after your visit until you remove it. It will be placed again at your next visit.
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Third-Party cookies and advertising

We do not use any third-party advertising companies or affiliates to display advertisements or use cookies on our website. We also do not provide personal data about you to any third party advertisers, affiliates or to any other third party.

You do not have to agree to the use of cookies. For information on how to reject cookies, see below Removing and Disabling Cookies Section. However, in order to use the payment section of the Site, we recommend that you do not block the recording of cookies on your computer.

3. REMOVING AND DISABLING COOKIES

If you don’t want us to place cookies on your computer at all, you can set your browser to disable or reject cookies. This will mean that no websites will be able to place cookies on your computer. You can do this by adjusting the preferences within your browser. This may mean, however, that you will not be able to enjoy full use of all parts of the Site.

If you want to remove previously-stored cookies, you can manually delete the cookies at any time. This will not prevent websites from placing further cookies on your computer.

4. WHAT WE DO WITH THE INFORMATION WE COLLECT ABOUT YOU

DATA COLLECTED BY WEB SERVERS AND COOKIES

The web servers that serve the Site collect the IP address of users who visit the Site, their Site navigation information (page requested, time of request, browser type and server response) as well as the user name if the user has registered to any restricted areas of the site.

This information is regularly aggregated and de-identified so that the number of visits to the Site and its pages, the average time spent on the Site and the pages viewed, etc., can be measured and analysed to improve our product offerings and marketing approach and to improve the Site’s content and functionality. This information will not be used to create individual visitors’ profiles. We will not track the individual navigation of visitors, except in the very limited cases where a visitor faces navigation problems which require a technical intervention to correct the problem or to detect potential intrusions.

DATA COLLECTED ON SENDING AN EMAIL TO THE OWNER

You may want to send an email to us through the Site, for instance via the ‘Contact Us’ page. By doing so, you will provide us with basic information about yourself, such as your email address, telephone numbers, your name and your query.

We will not use the information you provide when sending us emails for purposes other than responding to your message, handling your query or your Order, analysing your feedback and/or suggestions and for improving the Site.

Except if provided to others, as set out below, the supplied data will be kept on the Site’s secured servers and computer systems, protected from outside intrusions.

5. TRANSFER OF THE DATA COLLECTED VIA THE SITE TO THIRD PARTIES

Data collected by web servers and cookies are not transferred to any third parties.

Data collected on sending an email may be provided only to those whose assistance is needed to handle your query.

Data collected through the Site may also be transferred to others from time to time in the following cases as needed to perform the data processing purposes described in this Policy:

  1. at your request, on your order or subject to your prior agreement, to recipients specified by you;
  2. to authorised third parties in compliance with our statutory or regulatory obligations;
  3. to recipients who are operators acting on our behalf in their capacity as agent, authorised proxy, sub-contractor, service provider or in any other capacity, including suppliers in charge of hosting or maintaining the site;
  4. in the case of a change of control or acquisition or the whole or part of the assets or business of BOING Inc Limited, the data collected through this site will be transferred to the acquiring entity.
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6. TRANSFERRING YOUR DATA OUTSIDE THE UK

Currently we do not transfer your data outside UK.

7. SUBJECT ACCESS RIGHTS

At law you have the following rights

  1. A subject access right which enables you to be told whether we hold any personal data about you and to obtain a copy of that information;
  2. A right to get personal data relating to you rectified, completed, updated, blocked or erased when incomplete, unclear, obsolete or processed unlawfully;
  3. A right to object to the processing of data relating to you on legitimate grounds and a right to object free of charge to the use of data for solicitation purposes.
  4. We will comply with such rights as provided under applicable law. If you wish to exercise your subject access right, please contact us in writing at the address set out on the Site with sufficient information to identify yourself and the information you require. We will respond to your request within 30 days. We reserve the right to charge £10 for complying with a subject access request.

8. SECURITY

Except if provided to others in the circumstances set out in this Policy, the data supplied by you will be kept on the Site’s secured servers and computer systems, protected from outside intrusions.

9. PAYMENT SECURITY

In order to serve you most efficiently, reputable third-party banking institutions handle our credit card transactions (currently Cardsave, Streamline and Barclaycard Merchant Services). They receive the information needed to verify and authorise your payment card and for us in turn to process your order. All such organisations are under very strict obligations to keep your personal information private.  If you have any privacy or security questions in relation to Cardsave, Streamline or Barclays Card Services, you should contact them directly.

10. CHANGES TO THIS PRIVACY AND COOKIE POLICY

We reserve the right to make changes to this Policy from time to time and reserve the right to do so. Any changes to the Policy will appear on this page, which you should check from time to time. By continuing to use the site you are deemed to accept changes to this Policy.

11. CONTACTING US

If you have any questions about any aspect of this Policy or want to discuss how we handle your data you can contact us by email, post or telephone by referring to the Contact us section.