PLEASE READ THIS POLICY CAREFULLY BEFORE USING PAPIER LTD SERVICES
Protecting your data, privacy and personal information is very important to Papier LTD(" us", " our" or " we"). It is vitally important to us that our customers feel secure when using the Services.
When visiting Papier LTD's website at https://www.papier.com/ (our " Website"), using our application (our " App") or using any of the services offered via the Website or the App (the " Services"), you will be asked to indicate your acknowledgment of, and where applicable your consent to, the practices described in this policy.
Our Website contain links to third party websites. If you follow a link to any of those third party websites, please note that they have their own privacy policies and that we do not accept any responsibility or liability for their policies or processing of your personal information. Please check these policies before you submit any personal information to such third party websites.
We may collect and process the following data about you:
Information that you provide to us. You will be asked to provide us with your information when you:
The information you will be asked to provide to us for these purposes will include your first name, surname, email address, phone number, delivery address, or further information required to verify your identity.
Information we collect about you. With regard to each of your visits to our Website or our App we may automatically collect the following information; however, this information cannot be used to identify you:
Information we receive from other sources. When using our Services, we will be in contact with third parties who may provide us with certain information about you in order to enable your use of the Services.
Use of personal information under EU data protection laws must be justified under one of a number of legal "grounds" and we are required to set out the ground in respect of each use of your personal data in this policy. These are the principal grounds that justify our use of your information:
Consent : where you have consented to our use of your information (you are providing explicit, informed, freely given consent, in relation to any such use and may withdraw your consent in the circumstance detailed below by notifying us);
Contract performance : where your information is necessary to enter into or perform our contract with you;
Legal obligation : where we need to use your information to comply with our legal obligations;
Legitimate interests : where we use your information to achieve a legitimate interest and our reasons for using it outweigh any prejudice to your data protection rights; and
Legal claims : where your information if necessary for us to defend, prosecute or make a claim against you or a third party.
We use information held about you (and information about others that you have provided us with) in the following ways:
|Types of Information Collected||Uses of that Information||Use Justification|
|Email address, first name, surname, home address||To provide you with access to our Website, App and any other information which you request from us, and to use our Services.||Contract performance.|
|Email address, first name, surname, home address, product choices and customization, phone call recordings and Website chat history||To provide you with the Services.||Contract performance.|
|Email address, first name, surname||For marketing our own products and services that we believe will be of interest to you.||Legitimate interest (for marketing our own similar products and services and any re-engagement campaigns).|
|Email address, first name, surname, home address, product choices and customization, phone call recordings and Website chat history||To identify more appropriate products and services to market to you.||Legitimate interest (to tailor our services appropriately). No marketing of third party products or services will be conducted without your consent.|
|Email address, first name, surname, home address, product choices and customization, phone call recordings and Website chat history||To administer our Services and for internal operations, including research, data analysis and data statistics, and to create derived, anonymised and aggregated data to improve our Services.||Legitimate interest (to administer and improve our Services).|
|Email address||To notify you about changes to our Services.||Contract performance, legitimate interests (to update our Services from time to time).|
We will not sell your personal data (or any other data you provide us with) to third-parties, however, we reserve the right to share any data, which has been anonymised and/or aggregated. You acknowledge and accept that we own all right, title and interest in and to any derived data or aggregated and/or anonymised data collected or created by us.
In accordance with legitimate interests, we may share customer name, address and purchase information (but never email or phone number) with Epsilon Abacus so they can analyse what products may interest you and contact you accordingly via post. We work with Epsilon Abacus (registered as Epsilon International UK Ltd), a company that manages the Abacus Alliance on behalf of UK retailers. The participating retailers are active in the clothing, collectables, food & wine, gardening, gadgets & entertainment, health & beauty, household goods, and home interiors categories. This group of retailers share information on what their customers buy. Epsilon Abacus analyses this pooled information to help the retailers understand consumers’ wider buying patterns. From this information, retailers can tailor their communications, sending people suitable offers that should be of interest to them, based on what they like to buy. You can opt out at any time of this profiling by emailing firstname.lastname@example.org or by contacting our Customer Support team on +44(0)20 7770 6477.
We may use information for marketing products and services to you in the following ways:
|Type of marketing activity||Use Justification|
|Newsletters and marketing emails relating to our own similar services and products. Where required by law, we will ask for your consent at the time we collect your data to conduct any of these types of marketing.||Legitimate interest (to market our products and services - you have the right to unsubscribe at any time).|
We will provide an option to unsubscribe or opt-out of further communication on any electronic marketing communication sent to you or you may opt out by contacting us.
The personal data that we collect from you (including email addresses that form part of our prospective marketing database) is processed in the European Economic Area ("EEA") and stored on Heroku and Amazon Web Services (Europe) Cloud Servers This data may however be processed by staff operating outside of the EEA who work for us or for one of our business partners or service providers. A full list of our third party sub-processors and details of their privacy policies can be found [here]. Countries outside the EEA may not provide the same level of adequate protection for the rights and freedoms of data subjects in relation to the processing of personal data. In countries which do not provide appropriate safeguards, we shall transfer your data subject only to your consent except for transfers to and from: (i) any country with a valid adequacy decision from the European Commission; (ii) any country with which we have ensured similar levels of safeguards have contractually been put in place (this may include entering into standard contractual clauses); or (ii) any organization, including any of our sub-processors, which ensures an adequate level of protection in accordance with applicable data protection laws.
Your passwords are stored on Papier LTD's servers in encrypted form. We do not disclose your account details. It is your responsibility to keep your password secure. Unfortunately, the transmission of information via the internet is not completely secure. Although Papier LTD will do its best to protect your personal data, we cannot guarantee the security of your data transmitted to our Website, any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent any unauthorised access.
Please contact us if you would like further details on the specific safeguards applied to the export of your personal information outside EEA.
We may also disclose your personal information to third parties in the following circumstances:
|Purpose of disclosure and third party(s) to which disclosure might be made||Use Justification|
|We may disclose your personal information to our service providers and business partners, including our manufacturers (to assist us in performing any contract we enter into with them or you, including providing the Website and the Services it enables), analytics providers, (to assist us in the improvement and optimisation of the Website) and/or a member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006. A list of such third parties can be reviewed at [LINK].||Contract performance, legitimate interest, (to allow our service providers to provide the necessary services).|
|If we sell or buy any business or assets, we may disclose your personal information to the prospective seller or buyer of such business or assets.||Legitimate interest (to sell our business or assets); and where required by applicable law, consent (for sensitive personal data).|
|If Papier LTD or substantially all of its assets are acquired by a third party, personal information about our customers will be one of the transferred assets.||Legitimate interest (to sell our Company or assets); and where required by applicable law, consent (for sensitive personal data).|
|If we are under a duty to disclose or share your personal data in order to comply with any legal obligation or to protect the rights, property, or safety of Papier LTD, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection.||Legal obligation, vital interest.|
|Fraud Prevention and other checks. We and other organisations may also access and use your personal information to conduct credit checks and checks to prevent fraud. If false or accurate information is provided and fraud is identified or suspected, details may be passed to fraud prevent agencies.||Legitimate interest (to assist with the prevention of fraud and to assess your risk profile).|
|We may disclose your personal information to third parties, the court service and/or regulators or law enforcement agencies in connection with proceedings or investigations anywhere in the world where compelled to do so. Where permitted, we will direct any such request to you or notify you before responding unless to do so would prejudice the prevention or detection of a crime.||Legal obligation (to cooperate with law enforcement and regulatory authorities).|
We will hold the above information for as long as is necessary in order to provide you with the Services, deal with any specific issues that may raise, or otherwise as is required by law or any relevant regulatory body. Once your account is terminated or deactivated, we shall delete the personal data relating to your account within 30 days. If your account is inactive for 18 months, we may contact you to assess whether you want to continue to use the Services. Some personal data may need to be retained for longer than this to ensure Papier LTD can comply with applicable laws and internal compliance procedures, including retaining your email address for marketing communication suppression if you have opted not to receive any further marketing.
We restrict access to your personal information to those persons who need to use it for the relevant purpose(s). Our retention periods are based on business needs and your information that is no longer needed is either irreversibly anonymized (and the anonymized information may be retained) or securely destroyed.
Under the General Data Protection Regulation (EU) 2017/676, you have various rights in relation to your personal data. All of these rights can be exercised by contacting us at email@example.com
You have the following rights in relation to your personal data:
|Right of Access||The data subject shall have the right to obtain from the controller confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, a copy of the personal data undergoing processing.|
|Right to Rectification||We will use reasonable endeavors to ensure that your personal information is accurate. In order to assist us with this, you should notify us of any changes to the personal information that you have provided to us by sending us a request to rectify your personal data where you believe the personal data we have is inaccurate or incomplete.|
|Right to erasure / 'Right to be forgotten'||Asking us to delete all of your personal data will result in Papier LTD deleting your personal data without undue delay (unless there is a legitimate and legal reason why Papier LTD is unable to delete certain of your personal data, in which case we will inform you of this in writing).|
|Right to restriction of processing||You have the right to ask us to stop processing your personal data at any time.|
|Right to data portability||You have the right to request that Papier LTDprovides you with a copy of all of your personal data and to transmit your personal data to another data controller in a structured, commonly used and machine-readable format, where it is technically feasible for us to do so.|
|Right to complain||You have the right to lodge a complaint to a supervisory authority such as the Information Commissioner's Office in the UK (see [www.ico.org.uk](http://www.ico.org.uk)). Although we encourage our customers to engage with us in the event they have any concerns or complaints.|
Papier LTD will not ordinarily charge you in respect of any requests we receive to exercise any of your rights detailed above; however, if you make excessive, repetitive or manifestly unfounded requests, we may charge you an administration fee in order to process such requests or refuse to act on such requests. Where we are required to provide a copy of the personal data undergoing processing this will be free of charge; however, any further copies requested may be subject to reasonable fees based on administrative costs.
Asking us to stop processing your personal data or deleting your personal data will likely mean that you are no longer able to use Papier LTD's Services, or at least those aspects of the Services which require the processing of the types of personal data you have asked us to delete, which may result in you no longer being able to use the Services.
Where you request Papier LTD to rectify or erase your personal data or restrict any processing of such personal data, Papier LTD may notify third parties to whom such personal data has been disclosed of such request.
For the purpose of the relevant data protection legislation, the data controller is Papier LTD (company no. 09534860) with registered address at C/O Withers LLP, 20 Old Bailey, London EC4M 7AN.
Our data compliance officer is Joseph Robertson (firstname.lastname@example.org)