Privacy Policy

MALLET LONDON

PRIVACY POLICY

Last updated: May 2022

  1. INTRODUCTION
    • Mallet Footwear Ltd is a company registered in England under company number 09495730 whose registered office is at M25 Business Centre, 121 Brooker Road, Waltham Abbey, Essex, England, EN9 1JH (“Mallet London”, “us”, “we”, “our”).
    • We are the data controller of your personal information for the purposes of all applicable data protection laws, including the General Data Protection Regulation 2016/679 and the UK GDPR (together, the “GDPR”). However, our Website is powered by Shopify who will also have access to certain of your personal information. Please refer to Shopify’s privacy notice for further information: https://www.shopify.com/legal/privacy/customers.
    • We respect your privacy and we are committed to protecting your personal data, which includes information from which we can identify you, as more specifically defined in the GDPR (“Information”). We comply with the principles of the GDPR and aim to maintain consistently high levels of best practice in our processing of your Information.
    • This Privacy Policy (“Policy”) explains how we collect, use and disclose your Information. This Policy is intended to assist you in making informed decisions about your Information when using our website which is available at https://mallet.com/ (the “Website”) and the services available through the Website which include the ability to:
      • purchase our shoes, clothing and other goods;
      • sign up to receive our newsletter; and
      • contact us through the contact form,

(together, the “Services”).

If you have any questions or comments about this privacy policy, please contact us at team@mallet.com

 

  • The Services may contain hyperlinks to services owned and operated by third parties. These third party services may have their own privacy policies and we recommend that you review them. They will govern the use of Information that you submit or which is collected by cookies and other tracking technologies whilst using these services. We do not accept any responsibility or liability for the privacy practices of such third party services and your use of these is at your own risk.
  • If we change our Policy and/or procedures, we will post those changes on our Website to keep you aware of what Information we collect, how we use it and under what circumstances we may disclose it. We encourage you to review this Policy regularly.
  1. Definitions

Information

has the meaning given in paragraph 1.3.

Services

has the meaning given in paragraph 1.4.

GDPR

has the meaning given in paragraph 1.1.

Policy

Analytics Data

Payment Information

Website

has the meaning given in paragraph 1.4.

has the meaning given in paragraph 3.

has the meaning given in paragraph 3.

has the meaning given in paragraph 1.4.

Mallet London”, “us”, “we” and “our

have the meanings given in paragraph 1.1.

  1. Information We May Collect About You
    • We collect and process the following Information which may include your Information.

When you register for an account

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When you register for an account on our Website, we will require some Information about you. This may include:

·                   first name and last name;

·                   email address; and

·                   password.

If you are logged in to your account when you make purchases through the Website, we will also store the details of such purchases and link them to your account. 

 

When you contact us or use our support services

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We provide our support services via our website and by email. You may contact us through the following email addresses:

·                   team@mallet.com;

·                   press@mallet.com; and

·                   sales@mallet.com.

Alternatively, you may contact us using the form on the Website.

The Information we may process in connection with responding to you may include:

·                   first and last name;

·                   email address;

·                   phone number (optional); and

·                   a description of the issue you are experiencing or the matter you are contacting us about.

You are under no obligation to provide us with any details, but if you don’t provide all relevant Information, we may not be able to help. Please do not make reference to other people’s Information within your description or sensitive information about yourself.

 

Information collected for the purposes of making an order

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When you make an order, you may provide us with certain Information including:

·                   first and last name;

·                   items ordered, including sizes;

·                   payment service used (see below);

·                   email address; and

·                   shipping address.

Our Services’ financial transactions are handled through our payment services provider Shopify as standard. Shopify will therefore have access to your Payment Information, and Mallet will not process your Payment Information. Please refer to Shopify’s privacy policy for information regarding how it will process your Payment Information: https://www.shopify.co.uk/legal/privacy/customers

 

 

 

 

When you select the ‘remember me’ option

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When you make an order, you may select the ‘remember me’ option. Where you do so, we will securely store your Payment Information to make it easier for you to place future orders by avoiding you having to re-enter your details. The Information collected includes:

·                   first and last name;

·                   email address;

·                   shipping address; and

·                   mobile phone number.

 

 

Information collected for the purpose of processing your returns

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If you are not fully satisfied with an order you have made, we may process your Information in order to process your return, in accordance with our terms of service available [. If you choose to create a returns label from our Website, the Information collected may include:

·                   order number; and

·                   email address.

 

Information collected for the purposes of analytics

(“Analytics Data”)

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When you visit our Website we collect technical information about your use of the Website, including the number of visitors we receive, where visitors have come to the Website from and the webpages they visited while on the Website.

We collect the following data points from visitors: average pages per Website session, where our visitors come from, visitors’ device and operating system, time of day that the Website is used, general location, average time on a Website page, button clicks, number of views on a Website page, depth of scroll down a Website page, and whether a visitor is a new or returning visitor. This data is collected via cookies and similar technologies. Please see more details on this in our Cookie Policy [here]

 

 

 

Information collected when you sign up to receive direct marketing communications such as a newsletter

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If you sign up to receive direct marketing communications such as our newsletter or access to restocks, we will process your email address. You may sign up for our direct marketing communications via our Website, or when you provide your email address to one of our sales representatives in store, and in each case indicate you wish to join our mailing list.

 

Information collected when you use our store locator function on the Website

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If you use the store locator function of our Website in order to find a Mallet London store, we may process your location to let you know where the nearest Mallet London store is to you when you choose to access this function on our Website.

 

  1. Why We Collect Information About You

To provide our Services to you

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We may use and retain your Information where necessary to perform the contract we are about to enter into or have entered into with you, and / or on the basis of our legitimate interests in providing our Services and providing an optimal experience for you, such as to:

·       provide our Website;

·       deliver our Services to you;

·       register your account;

·       manage and administer accounts; and

·       ensure that the Services function properly and deliver the features promised.

 

Handling and fulfilling your purchases, returns and refunds

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We will use Information about you (including Payment Information) in order to handle and fulfil your purchases on the Website, as well as your refunds when you make a return. We process this information in accordance with the terms of our contract with you (where we need this information to provide our Services to you) or to take steps at your request prior to entering into a contract. We also use this Information to pursue our legitimate interests in fulfilling your orders and returns, and to comply with our legal obligation to retain records of customer purchases and transactions.

Please note that when you make a purchase on the Website, your Information may be provided to those third parties necessary to process your transactions with us, such as credit card companies, banks and the companies that handle shipping on our behalf. This includes exchanging Information with other companies and organisations for fraud protection and credit risk reduction. Our Services’ financial transactions are handled through our payment services provider Shopify, who will have access to your Payment Information. You may also choose to process your payment through one of our third-party payment providers ShopPay, PayPal, AmazonPay instead of through Shopify, in which case such payment provider will have access to your Payment Information.

 

To send you email marketing 

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We may process your name and email address for our mailing list in the following way:

·       Consent-based mailing lists: We may process your Information to keep you updated with information on news, offers, and updates about us. We rely upon your consent in order for us to undertake this data processing activity. You can revoke your consent at any time. Please let us know by clicking unsubscribe at the bottom of any marketing email that you receive.

·       ‘Soft opt-in’ mailing lists: In some instances (such as with our existing UK customers) the law may permit us to process your Information in order to send information to you by email that we think is of interest to you on the basis of our legitimate interests, being our legitimate interest to promote our business. If you would like to be removed from this list, please let us know by clicking unsubscribe at the bottom of any marketing email that you receive.

 

Online Advertising

We may process data for online advertisements. While we do not permit third party advertising on our website, we undertake:

o   Remarketing, which allows us to show display ads to people who've previously visited our website;

o   Advertising on social networks, which means that if you link to one of our social media platforms you may be subject to targeted marketing via that platform (including in your newsfeed);

o   Ad performance monitoring, meaning that your information may be used to understand how advertisements have performed or how many people have viewed/interacted certain advertisements;

o   Serving personalised ads, meaning that your information may be used to service you more relevant online advertising on third party services.

We work with third party advertising networks and social media platforms as set out in our Cookie Policy [here]. If you would like to find out more about the way these third parties collect and process your information, please refer to their respective privacy policies and/or terms and conditions.

By interacting with the consent tool on our website, you are able to consent to our use of cookies or similar technologies. You are able to withdraw your consent at any time by emailing us at: team@mallet.com.

 

To facilitate your use of the ‘remember me’ function

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When you select the ‘remember me’ function, we will securely store your Payment Information to make it easier for you to place future orders by avoiding you having to re-enter your details. We do this on the basis of our legitimate interest in facilitating an optimal experience for users of our Services.

 

To help us improve the Services and fix any problems

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We may process Information about you (including Analytics Data) so that we can analyse and improve our Services. Where this processing uses Analytics Data, we do so on the basis of your consent. Otherwise, this processing is necessary for us to pursue our legitimate interests of (i) ensuring that our Services function properly so that you and other users have the best experience when using the other Services; (ii) improving the quality of our Services, and providing a better experience to our users; (iii) identifying and correcting any bugs in the Services and (iv) understanding the effectiveness of our marketing to attract new customers and re-engage our current customers.

 

To respond to your enquiries and requests for support

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We may process your Information so that we are able to properly respond to your enquiries. 

We process this Information in accordance with the terms of our contract with you (where we need this Information to provide our Services to you) or to take steps at your request prior to entering into a contract.

We also use this Information to pursue our legitimate interests in responding to your enquiries and requests for support, and to understand our customers and improve our Services.

You are under no obligation to provide us with any details, but if you don’t provide all relevant Information, we may not be able to help.

 

To help you to find a Mallet London store nearby

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We may process your location Information to suggest a nearby store when you are using the store locator function on our Website.

We process this Information on the basis of our legitimate interests in offering this service and assisting you with your search for one of our physical stores.  

 

To prevent fraud and illegal activity

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We process your Information for our legitimate interests of ensuring that any use of the Services is lawful and non-fraudulent, does not disrupt the operation of our Services, does not harass our staff or other individuals, to enforce our legal rights and to comply with our legal obligations.

Where we reasonably believe that you are or may be in breach of any applicable laws or our terms of use, we may use your Information to inform relevant third parties such as your law enforcement agencies about the content.

 

  1. WHAT RIGHTS DO I HAVE IN RESPECT OF THE INFORMATION YOU PROCESS?  
    • You have the following rights over the way we process Information relating to you, as set out in the table below.
    • To make a request, please send an email to team@mallet.com If you submit a request, we aim to comply without undue delay, and within one month at the latest.

Ask for a copy of Information we are processing about you and have inaccuracies corrected

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You have the right to request a copy of the Information we hold about you and to have any inaccuracies corrected.

We will use reasonable efforts to the extent required by law to supply, correct or delete Information held about you on our files (and with any third parties to whom it has been disclosed to).

 

Object to us processing Information about you

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You can ask us to restrict, stop processing, or to delete your Information if:

·                   you consented to our processing the Information, and would now like to withdraw that consent;

·                   we no longer need to process that Information for the reason it was collected;

·                   we are processing that Information because it is in the public interest or it is in order to pursue a legitimate interest of ours or of a third party, you don’t agree with that processing, and there is no overriding legitimate interest for us to continue processing it;

·                   the Information was unlawfully processed;

·                   you need the Information to be deleted in order to comply with legal obligations; or

·                   the Information is processed in relation to the offer of a service to a child.

 

Obtain a machine-readable copy of your Information, which you can use with another service provider

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If we are processing Information in order to perform our obligations to you, or because you consented, or if that processing is carried out by automated means, we will help you to move, copy or transfer your Information to other IT systems.

If you request, we will supply you with the relevant Information in a commonly used, machine-readable and interoperable format. Where it is technically feasible, you can ask us to send this Information directly to another IT system provider if you prefer.

 

Make a complaint to a supervisory authority

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If you are unhappy with the way we are processing your Information, please let us know by contacting us via our support services.

If you do not agree with the way we have processed your Information or responded to your concerns, an alternative is to submit a complaint to a data protection supervisory authority. In the UK, this is the Information Commissioner’s Office whom we are registered: https://ico.org.uk/concerns, or you can submit a complaint to the supervisory authority in your country.

  1. How We Disclose Your Information To Third Parties

We will share your Information with third parties only in the ways that are described in this privacy policy

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We may share your Information with third parties as specifically approved by you or under the circumstances described below.

Group members, personnel, suppliers or subcontractors: We keep your Information confidential, but may disclose it to any member or future member of our group (which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006), our personnel, suppliers or subcontractors insofar as it is reasonably necessary for the purposes set out in this Policy. The categories of suppliers we use includes: IT service providers, payment processors, data hosting providers and professional advisors. However, this is on the basis that they do not make independent use of the Information, and have agreed to safeguard it.

Shopify and MaxMind: our Website is powered by Shopify and as such Shopify will have access to some of the Information we process, however, this is on the basis that Shopify does not make independent use of the Information and has agreed to safeguard it. Please refer to Shopify’s privacy notice for further information: https://www.shopify.com/legal/privacy/customers. Further, part of the service offered by Shopify involves obtaining fraud detection services from MaxMind. Where you make a purchase through our Website, your Information may be processed by MaxMind in order to assist us with avoiding fraudulent transactions. Please refer to MaxMind’s privacy notice for further information:

Merger or acquisition: If we are involved in a merger, acquisition, or sale of all or a portion of our assets, we may be required to share your Information with the buyer. You will be notified via account message and/or a prominent notice on our Website of any change in ownership or uses of your Information, as well as any choices you may have regarding your Information.

Required by law: In addition, we may disclose your Information to the extent that we are required to do so by law (which may include to government bodies and law enforcement agencies); in connection with any legal proceedings or prospective legal proceedings; and in order to establish, exercise or defend our legal rights (including providing Information to others for the purposes of fraud prevention).

Enforcement: We may also disclose your Information to third parties in order to enforce or apply the terms of agreements, to investigate potential breaches, or to protect the rights, property or safety of us, our users, or others.

Professional services: We use third party organisations (as set out above) to help provide a professional service to our customers. These organisations act as data processors and are strictly controlled in how they may/may not use your Information and we remain responsible for the protection of your Information. 

 

  1. WHERE WE STORE YOUR INFORMATION
    • Our Website is hosted by Shopify Inc. They provide us with the online e-commerce platform that allows us to sell our products and services to you.
    • Your Information is stored through Shopify’s data storage, databases and the general Shopify application. They store your Information on a secure server behind a firewall and may transfer your Information to Canada and/or the USA to do so. We may also store your Information on our own servers and databases located in the UK.
    • Where we transfer your Information outside of the UK (either to Shopify or to other suppliers delivering services to us), we will have appropriate safeguards in place to protect your Information, an example of which may include standard data protection clauses adopted by a data protection regulator and / or approved by the European Commission to ensure that appropriate safeguards are in place to protect your Information. If you would like to find out more about the safeguards we use for these purposes, please let us know by writing to team@mallet.com.  
  2. How Long Do We Keep Your Information For?

We will only keep your Information for as long as it is reasonably necessary to do so bearing in mind the purpose for which it was collected. At the end of the retention period, we assess whether it is necessary to continue to retain Information to achieve the purposes for which it was collected. To determine appropriate retention periods, we consider the amount, nature, and sensitivity of the Information, the potential risk of unauthorised access, and legal requirements.

  1. SECURITY OF YOUR INFORMATION

We follow appropriate security procedures in the storage and disclosure of your Information so as to prevent unauthorised access by third parties. We also require those parties to whom we transfer Information to comply with the same. However, unfortunately, the transmission of Information via the internet is not completely secure. So, we cannot ensure the security of your Information transmitted by you to us via the internet. Any such transmission is at your own risk and you acknowledge and agree that we shall not be responsible for any unauthorised use, distribution, damage or destruction of your Information, except to the extent we are required to accept such responsibility by the GDPR. Once we have received your Information we will use security procedures and features to prevent unauthorised access to it. We will take all reasonable technical and organisational precautions to prevent the loss misuse or alteration of your Information. Please be aware that, although we endeavour to provide reasonable security for Information we process and maintain, no security system can prevent all potential security breaches.

  1. COOKIES

Our Website uses cookies. Please refer to our Cookie Policy: [insert link]for further information.

  1. HOW TO CONTACT US

Our contact details are as follows: Mallet London, M25 Business Centre, 121 Brooker Road, Waltham Abbey, Essex, England, EN9 1JH, team@mallet.com.

 

 

 

 

 

 

 

 

This section should set out all the purposes of data processing. The current version is based on the existing privacy policy, and we have also made some assumptions. Please let me know if anything here is either incomplete or incorrect.

 

Please also note the GDPR requires a controller of personal data (i.e. Mallet London) to justify its processing of such personal data on the basis of one or more legal grounds (such as Mallet London’s ‘legitimate interests').