Last updated: May 25, 2018
Trouva respects your privacy and is committed to protecting your Personal Data. We want to be transparent with you about how we collect and use your Personal Data in making available this website (“Site”) and providing our services.
We want to make sure you know what happens to your Personal Data, what your rights are and how the law protects you.
Who we are and how to contact us
Who we are.
Our address is: 60 Worship Street, London, EC2A 2EZ, United Kingdom.
How to contact us.
You can contact us directly with any privacy-related queries or complaints at: firstname.lastname@example.org.
Your rights relating to your Personal Data.
Your rights in connection with your Personal Data
Under certain circumstances, by law you have the right to:
Request access to your Personal Data. This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.
Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have exercised your right to object to processing (see below).
Object to processing of your Personal Data. This right exists where we are relying on a Legitimate Interest as the legal basis for our processing and there is something about your particular situation, which makes you want to object to processing on this ground. You also have the right to object where we are processing your Personal Data for direct marketing purposes.
Request the restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of Personal Data about you, for example if you want us to establish its accuracy or the reason for processing it.
Request the transfer of your Personal Data. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
How to exercise your rights
If you want to exercise any of the rights described above, please contact us by emailing: email@example.com.
Typically, you will not have to pay a fee to access your Personal Data (or to exercise any of the other rights outlined above). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive, or, we may simply refuse to comply with your request in these circumstances.
What do we need from you?
We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights).
This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it.
We may also contact you to ask you for further information in relation to your request to speed up our response.
How long do we typically take to resolve requests?
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
We will reply to your complaint as soon as we can.
If you feel that your complaint has not been adequately resolved, please note that the GDPR gives you the right to contact your local data protection supervisory authority, which for the UK, is the Information Commissioner’s Office.
Marketing communications preferences.
You can ask us to stop sending you marketing messages at any time by:
following the “Unsubscribe” links on any marketing message sent to you (including emails relating to Boutiques you have chosen to ‘Follow’ on the Trouva platform); and/or • contacting us at any time by emailing: firstname.lastname@example.org.
Where you opt out of receiving these marketing messages, this opt-out will not apply to service-related communications (and any processing of your Personal Data involved in sending such communications). As a non-exhaustive list of what these service-related communications may include, they might be emails or notifications:
What Personal Data we collect.
All the Personal Data we collect, both from you and from third parties about you, is outlined in the table below.
Before you read that table, it might be useful to explain what “Personal Data” is. The GDPR definition of Personal Data can be found here. Essentially, it means: information about an individual, from which that individual is either directly identified or can be identified.
It does not include ‘anonymous data’ (i.e., information where the identity of individual has been permanently removed).
However, it does include ‘indirect identifiers’ or ‘pseudonymous data’ (i.e., information which alone doesn’t identify an individual but, when combined with certain additional and reasonably accessible information, could be attributed to a particular person).
|Category of Personal Data collected||What this means|
|Identity Data||Your full name, your signature (when you sign for an order or to confirm collection of a return)|
|Contact Data||Your home address, shipping address, billing address, email address and telephone numbers.|
|Financial Data||Your bank account and payment card details, including your bank account number, sort code, IBAN, BIC, and bank address. Payment card details will be collected directly by our Payment Processor and we won’t receive them. However, in certain limited cases, we may receive bank account details in the context of administering refunds.|
|Social Media Data||The profile picture, email address and first and last name associated with your social media profile.|
|Marketing and Communications Data||Your preferences concerning receiving marketing from us and your communication preferences.|
|Behavioural Data||Inferred or assumed information relating to your behaviour and interests, based on your online activity. This is typically aggregated and grouped into “segments” (e.g., there may be a segment for men, living in London and aged under 25, who like sports).|
|Technical Data||Internet protocol (IP) address, data about log-ins (e.g., the time when a log-in occurs), browser type and version, time zone setting and city-level location (inferred from your IP address), browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website or use our services.|
No Special Categories of Personal Data
We do not collect any “Special Categories of Personal Data” about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
How we use your Personal Data and why.
We will only use your Personal Data for the purposes for which we collected it as listed below, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
What is our “legal basis” for processing your Personal Data?
In respect of each of the purposes for which we use your Personal Data, the GDPR requires us to ensure that we have a “legal basis” for that use. Most commonly, we will rely on one of the following legal bases:
Where we need to perform a contract we are about to enter into or have entered into with you (“Contractual Necessity”).
Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests (“Legitimate Interests”). More detail about the specific legitimate interests pursued in respect of each Purpose we use your Personal Data for is set out in the table below.
Where we need to comply with a legal or regulatory obligation (“Compliance with Law”).
We have set out below, in a table format, the legal bases we rely on in respect of the relevant Purposes for which we use your Personal Data.
|Processing Purpose||Why do we do this||Our legal basis for this use of data|
To provide the Services
This processing is necessary to perform the contract governing our provision of the Trouva services. This includes:
* Managing orders and returns (including processing payments and refunds through our payment processor).
* Passing your information to Boutiques for them to process your order.
* Providing customer support.
*Setting up and managing your account on the Site.
*Providing any other elements of the Trouva services to you.
Legitimate interests (where you make an order for someone else) – we have a legitimate interest in processing the Personal Data of the recipient of your order for the purposes of performing the agreement we made with you.
If something goes wrong with an order or a product is out of stock, we may want to use one of our partners to send you a cookie to say ‘sorry’.
We have a legitimate interest in trying to maintain a good relationship with you in the event that something goes wrong with your order.
We record a small percentage of Users’ sessions on the Site to identify issues with the user journeys to ensure the quality of service.
It is in our legitimate interests that we are able to monitor certain user journeys to ensure that we can develop and improve the features and functionalities of our Site.
We use a third party called Hotjar to perform this processing purpose on our behalf.
If you want to opt-out from Hotjar collecting this insight information at any time, you can do so by following the instructions on this Hotjar opt-out page.
Aggregated Data creation
We have a legitimate interests in creating Aggregated Data to use and share for our own business purposes.
Compliance, fraud prevention and safety
We use your Personal Data as we believe necessary or appropriate to:
* Enforce the terms and conditions that govern the use of the Trouva platform;
* Protect our rights, privacy, safety or property, and/or that of you or others;
*Protect, investigate and deter against fraudulent, harmful, unauthorised, unethical or illegal activity
Compliance with Law – this will be the case where we have to carry out any of these processing activities in order to comply with a legal or regulatory obligation.
Legitimate Interests – it is in our legitimate interests to be able to take appropriate steps to ensure that our services are legally compliant, free of fraud and safe for you, us and our Boutiques to use.
To track technical issues that might be occurring on our Site or relating to our services.
It is in our legitimate interests that we are able to monitor and ensure the proper operation of our Site and associated systems and services.
To keep our Site, together with associated services and systems, operational and secure.
We have a legitimate interest in ensuring the ongoing security and proper operation of our Site, together with associated IT services and networks. This may include ensuring that we are protected from automated spamming, crawling, scraping, denial-of-service attacks and similar operations.
We use this information to prepare and send you marketing communications relating to products and boutiques that we think you might be interested in.
We have a legitimate interest in providing you with updates on our Site and related offers where you have purchased or shown interest in similar services from us
What happens when you do not provide necessary Personal Data?
Where you fail to provide Personal Data that we need to process based on Contractual Necessity or for the purposes of Compliance with Law, we may not be able to perform the contract we have or are trying to enter into with you (for example, we may not be able to open your account, we may have to close your account, we may not be able to procure the fulfilment of your order or process a return etc).
Personal Data from Third Party Sources
In addition to the Personal Data that we collect directly from you (as described in the section immediately above this one), we also collect certain of your Personal Data from third party sources. These sources are broken down in the table below, together with a description of whether they are publicly available or not.
|Third party data source||Publicly available?||Category(ies) or other types of personal data received|
|Social Media sites||Yes||Social Media Data|
|Analytics Providers||No||Behavioural Data and Technical Data|
|Advertising technology providers||No||Behavioural Data and Technical Data|
What are cookies?
We may collect information using “cookies”. Cookies are small data files stored on the hard drive of your computer or mobile device by a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience on our Site.
We use two broad categories of cookies:
first party cookies, served directly by us to your computer or mobile device; and
third party cookies, which are served by our partners or service providers on our Site.
Cookies we use
Our Site uses the following types of cookies for the purposes set out below:
|Type of cookie||Purpose|
|Essential Cookies||These cookies are essential to provide you with services available through our Site and to enable you to use some of its features. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.|
|Functionality Cookies||These cookies allow our Site to remember choices you make when you use our Site. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-select your preferences every time you visit our Site.|
|Analytics and Performance Cookies||
These cookies are used to collect information about traffic to our Site and how users use our Site. The information gathered may include the number of visitors to our Site, the websites that referred them to our Site, the pages they visited on our Site, what time of day they visited our Site, whether they have visited our Site before, and other similar information. We use this information to help operate our Site more efficiently, to gather broad demographic information, monitor the level of activity on our Site, and improve the Site.
We use Google Analytics for this purpose. Google Analytics uses its own cookies. You can find out more information about Google Analytics cookies here and about how Google protects your data here.
|Targeted and advertising cookies||These cookies track your browsing habits to enable us to show advertising which is more likely to be of interest to you. These cookies use information about your browsing history to group you with other users who have similar interests. Based on that information, third party advertisers can place cookies to enable them to show advertisements which we think will be relevant to your interests while you are on third party websites.|
|Social Media Cookies||These cookies are used when you share information using a social media sharing button or “like” button on our Site or you link your account or engage with our content on or through a social networking website such as Facebook or Twitter. The social network will record that you have done this|
You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings”, “help” “tools” or “edit” facility). Many browsers are set to accept cookies until you change your settings.
If you do not accept our cookies, you may experience some inconvenience in your use of our Site. For example, we may not be able to recognise your computer or mobile device and you may need to log in every time you visit our Site.
Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.com.uk.
In particular, you can disable cookies which remember your browsing habits and target advertising at you by visiting http://www.youronlinechoices.com/uk/your-ad-choices. If you choose to remove targeted or advertising cookies, you will still see adverts but they may not be relevant to you. Even if you do choose to remove cookies by the companies listed at the above link, not all companies that serve online behavioral advertising are included in this list, and so you may still receive some cookies and tailored adverts from companies that are not listed.
You can prevent the use of Google Analytics relating to your use of our Site by downloading and installing the browser plugin available here.
We may use Flash cookies (which are also known as Flash Local Shared Object (“LSOs”)) on our Site to collect and store information about your use of our Site. Unlike other cookies, Flash cookies cannot be removed or rejected via your browser settings. If you do not want Flash cookies stored on your computer or mobile device, you can adjust the settings of your Flash player to block Flash LSO storage using the tools contained in the Website Storage Settings Panel at this website. You can also control Flash LSOs by going to the Global Storage Settings Panel at this website and following the instructions. Please note that setting the Flash Player to restrict or limit acceptance of Flash LSOs may reduce or impede the functionality of some Flash applications, including, potentially, Flash applications used in connection with our Site
We may also use pixel tags (which are also known as web beacons and clear GIFs) on our Site to track the actions of users on our Site. Unlike cookies, which are stored on the hard drive of your computer or mobile device by a website, pixel tags are embedded invisibly on webpages. Pixel tags measure the success of our marketing campaigns and compile statistics about usage of the Site, so that we can manage our content more effectively.
Do Not Track Signals
Some Internet browsers may be configured to send "Do Not Track" signals to the online services that you visit. We currently do not currently respond to do not track signals. To find out more about "Do Not Track," please visit http://www.allaboutdnt.com.
Who we share your Personal Data with.
The table below describes who we share your Personal Data with, what we share and why we share it.
We may share your Personal Data with other Controllers (i.e., people who can use the relevant data for their own purposes), as well as Processors (i.e., people who use the relevant data only on our behalf and under our instruction).
|Recipients||Why we share it|
|Boutiques (as our Processors)||So that they can fulfil your order, we need to give your delivery information to boutiques whose products you purchase.|
|Advertising technology providers (as independent Controllers)||Advertising technology and analytics providers collect this Personal Data via this Site so that they can make sure that you see the most relevant content based on how you browse the Site and other pages on the internet.|
|Our payment processors (as independent Controllers)|
We engage third parties to process your payments for products purchased via the Site.
|Our delivery management platforms (as our Processors)||These third parties prepare the labelling and packaging information that we get our boutiques to use to send you your orders|
|Our other Service Providers (as our Processor)||
We engage certain other third parties to provide elements of the Trouva services or to improve your experience on the Site. Here are a few examples of the types of things these third parties might be engaged to help us with:
* Providing customer support services.
* Helping confirm your delivery address.
* Helping us send out marketing messages.
|Our Hosting Provider (as our Processor)||We outsource the hosting of the Site. This means that all categories of Personal Data that we process will be held and stored on the servers of our hosted service provider|
|HM Revenue & Customs, regulators and other authorities (as independent Controllers)||Authorities may require reporting of processing activities in certain circumstances.|
We share your Personal Data with certain external third parties who are based outside the European Economic Area (“Europe”). Any processing of your Personal Data by these parties will involve an export of your Personal Data outside of Europe.
We endeavour to ensure that people to whom we provide Personal Data hold it subject to appropriate safeguards and controls. Whenever we transfer your Personal Data out of Europe, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
We may transfer your Personal Data to countries that have been deemed to provide an adequate level of protection for Personal Data by the European Commission. For further details, see European Commission: Adequacy of the protection of Personal Data in non-EU countries.
Where we use service providers outside Europe, we may use specific contracts approved by the European Commission, which give Personal Data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of Personal Data to third countries.
Where we use service providers based in the U.S., we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to Personal Data shared between Europe and the U.S. For further details, see European Commission: EU-U.S. Privacy Shield.
How we keep your Personal Data secure.
We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. The efficacy of these security measures is evidenced by the fact that we have attained the following certifications and accreditations:
Attestation of PCI DSS compliance by an independent certified party
Cyber Essentials Scheme
We limit access to your Personal Data to those employees and other staff who have a business need to have such access. All such people are subject to a contractual duty of confidentiality.
We have put in place procedures to deal with any actual or suspected Personal Data breach. In the event of any such breach, we have systems in place to work with applicable regulators. In addition, in certain circumstances (e.g., where we are legally required to do so) we may notify you of breaches affecting your Personal Data.
How long we store your Personal Data.
We are committed to only keeping your Personal Data for so long as we reasonably need to use it for the purposes set out above. This general rule applies unless a longer retention period is required by law (for example for regulatory purposes).
In respect of the Personal Data we process to provide you with the Trouva platform and associated services, we will only keep this Personal Data for so long as you have an open account on the Site. When you close your account, we will delete or irreversibly anonymise your Personal Data within thirty (30) days.
As noted above:
in respect of any Personal Data we process based on our, or a third party’s, legitimate interests, you have the right to object to processing of your Personal Data for this purpose at any time; and
you also have a general right to request erasure of your Personal Data where there is no good reason for us continuing to process it.
If you want to exercise either of these rights, please email us at: email@example.com.
Please note that this data retention framework does not apply to Aggregated Data, which we may store for a longer period of time.
Our policy on children.
This Site is not intended for children below 16 and we do not knowingly collect data relating to such children.
Third party links.
StreetHub Ltd t/a Trouva, 2018