SHAKERA DESIGN LTD
Last Updated 10/06/2020
This Privacy Notice (“Privacy Notice”) applies to the processing of personal data in connection with the provision of the Shakera Design Ltd t/a Shaku website at www.shaku.co.uk (the “Site”), and all of the goods and services offered on the Site (“Services”). We respect the privacy of every person who visits our Site and/or uses our Services and we are committed to ensuring a safe online experience for all.1. Purpose of this privacy notice
This Privacy Notice explains our approach to any personal data that we might collect from you or which we have obtained about you from a third party and the purposes for which we process your personal data. This Privacy Notice also sets out your rights in respect of our processing of your personal data. For more information see below.
When we talk about “personal data”, we mean any information which relates to an identified or identifiable living individual. Individuals might be identified by reference to a name, an identification number, location data, an online identifier (such as an IP address) or to other factors that are specific to them, such as their physical appearance.
This Privacy Notice informs you of the nature of the personal data about you that is processed by us and how you can request that we delete it, update it, transfer it and/or provide you with access to it.
This Privacy Notice only applies to the use of your personal data obtained by us, whether from you directly or from a third party. It does not apply to personal data collected by third parties during your communications with those third parties or your use of their products or services (for example, where you follow links to third party websites over which we have no control, or you purchase goods or services from those third parties).
2. About us
The Site and our Services are made available by Shakera Design Ltd t/a Shaku (“SDL”, “we”, “us, “our”). SDL is the data controller responsible for your personal data. For more information see below.
Shakera Design Ltd t/a Shaku (company no: 12040318) is an English company with its registered office at Castle House, 75-76 Wells Street London, W1T 3QH, England.
3. How to contact us
If you have any questions about this Privacy Notice or want to exercise your rights set out in this Privacy Notice, you can contact us by:
- sending an email to email@example.com.
- writing to Castle House, 75-76 Wells Street London, W1T 3QH.
4. How we collect and receive personal data
We collect and receive personal data using different methods:
5. Who we collect personal data about
6. Personal data we collect and how we use it
- an IP address to monitor Site traffic and volume;
- a session ID to track usage statistics on our Site; and
- information regarding your personal or professional interests, demographics, experiences with our Services and contact preferences.
- information that we observe about you from your interactions with our Sites, [with our email communications to you] and/or with our Services (see the “Insight and Analysis” section above for more details of the information collected and how it is collected); and
- the information Facebook (including Instagram), Snapchat and/or Google hold about you.
7. If you fail to provide your personal data
Where we are required by law to collect your personal data, or we need to collect your personal data under the terms of a contract we have with you, and you fail to provide that personal data when we request it, we may not be able to perform the contract we have or are trying to enter into with you. This may apply where you do not provide the personal data we need in order to provide the Services you have requested from us or to process an application for employment with us. In this case, we may have to cancel your application or the provision of the relevant Services to you, in which case we will notify you.
8. How we obtain your consent
Where our use of your personal data requires consent, you can provide such consent:
- at the time we collect your personal data following the instructions provided; or
- by informing us using the contact details set out in the “How to Contact Us” section above.
10. Third party links and services
This Privacy Notice does not apply to your interaction with services provided by third parties.
Our Site may contain links to third party websites and services
When you use a link to go from our Site to another website (even if you don’t leave our Site) or you request a service from a third party, this Privacy Notice shall not apply to the processing of your personal data carried out by the relevant third party provider.
Your browsing and interactions on any other websites, or your dealings with any other third party service provider, is subject to that website’s or third party service provider’s own rules and policies. For example, our website invites you to connect with us on social media platforms such as Facebook and Instagram. When you click on the links we provide to such platforms, you will be transferred from our website to the relevant platform and the privacy notice (and other terms and conditions) of that platform will apply to you.
We do not monitor, control or endorse the privacy practices of any third parties.
We encourage you to become familiar with the privacy practices of every website you visit or third party service provider that you use in connection with your interaction with us and to contact them if you have any questions about their respective privacy notices and practices.
This Privacy Notice applies solely to personal data processed by us through your use of our Site, your receipt of our Services and/or in connection with our business operations. It does not apply to the processing of your personal data by these third party websites and third party service providers.
11. Sharing personal data
We will only share personal data with others when we are legally permitted to do so. When we share personal data with others, we put contractual arrangements and security mechanisms in place to protect the personal data shared and to comply with our data protection, confidentiality and security standards and obligations.
When processing your personal data, we may need to share it with third parties as follows:
Backend fulfilment partners: We share personal data with third parties that assist us with backend fulfilment, such as Shopify Inc.
Payment providers and banks: We share personal data with third parties who assist us with the processing of payments and refunds, such as Stripe Inc.
Third-party email marketing and CRM specialists: We share personal data with specialist suppliers who assist us in managing our marketing database and sending out our email marketing communications and user-related communications.
Suppliers of postal and courier services: We share personal data with suppliers who assist us in sending out our postal marketing communications and membership-related communications.
Auditors, lawyers, accountants and other professional advisers: We share personal data with professional services firms who advise and assist us in relation to the lawful and effective management of our organisation and in relation to any disputes we may become involved in.
Law enforcement or other government and regulatory agencies and bodies: We share personal data with law enforcement or other government and regulatory agencies or other third parties as required by, and in accordance with, applicable law or regulation.
Sharing with other third parties: Occasionally, we may receive requests from third parties with authority to obtain disclosure of personal data, such as to check that we are complying with applicable law and regulation, to investigate an alleged crime, or to establish, exercise or defend legal rights. We will only fulfil requests for personal data where we are permitted to do so in accordance with applicable law or regulation.
This list is non-exhaustive and there may be circumstances where we need to share personal data with other third parties in order to operate our Site and to provide our Services.
12. Transfers outside the european economic area (“eea”)
Where necessary in order to operate our Site and to otherwise deliver our Services, we will transfer personal data to countries outside the EEA.
Non-EEA countries do not have the same data protection laws as the EEA. In particular, non-EEA countries may not provide the same degree of protection for your personal data, may not give you the same rights in relation to your personal data and may not have a data protection supervisory authority to help you if you have any concerns about the processing of your personal data. However, when transferring your personal data outside the EEA, we will comply with our legal and regulatory obligations in relation to your personal data, including having a lawful basis for transferring personal data and putting appropriate safeguards in place to ensure an adequate level of protection for the personal data.
We will take reasonable steps to ensure the security of your personal data in accordance with applicable data protection laws.
When transferring your personal data outside the EEA, we will ensure that, where required by applicable law, at least one of the following safeguards is implemented:
Adequacy decisions: We will only 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 https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en.
Model clauses: Where we use certain service providers, 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 https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.
EU-U.S. Privacy Shield: Where we have partners or suppliers based in the US, 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 US. For further details, see https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/eu-us-privacy-shield_en.
Please contact us if you would like further information on the specific mechanisms used by us when transferring your personal data outside the EEA.
13. How long we keep your personal data
In respect of personal data that we process in connection with the supply of our Services, we may retain your personal data for up to six years from the date of supply of the relevant Services and in compliance with our data protection obligations. We may then destroy such files without further notice or liability.
In respect of any other personal data that we process, we will retain relevant personal data for up to three years from the date of our last interaction with you and in compliance with our data protect obligations. We may then destroy such files without further notice or liability.
If any personal data is only useful for a short period (e.g. for a specific event or marketing campaign), we will not retain it for longer than the period for which it is used by us.
If you have opted out of receiving marketing communications from us, we will need to retain certain personal data on a suppression list indefinitely so that we know not to send you further marketing communications in the future.
14. Confidentiality and security of your personal data
We are committed to keeping the personal data you provide to us secure and we will take reasonable precautions to protect your personal data from loss, misuse or alteration.
We have implemented information security policies, rules and technical measures to protect the personal data that we have under our control from:
- unauthorised access;
- improper use or disclosure;
- unauthorised modification; and
- unlawful destruction or accidental loss.
All our employees and data processors (i.e. those who process your personal data on our behalf, for the purposes listed above) who have access to and are associated with the processing of personal data are obliged to respect the confidentiality of the personal data of all users of our Site and our Services.
15. Personal data of children
We do not specifically target our Sites or our Services at children. However, due to the nature of our organisation and the Services we provide, we may from time to time collect and process personal data relating to individuals under the age of 18. Where we do so, we will comply with all applicable laws and regulations relating to the processing of personal data of minors. However, if you are under the age of 18, you must ask a parent or guardian for permission before using our Site and our products and services. If you are a parent or guardian, please supervise your child’s use of our Site and our Services.
16. How to access your information and your other rights
You have the following rights in relation to the personal data we hold about you. If you would like to exercise any of these rights, please contact us using the details set out in How to contact us.
Your right of access
If you ask us, we will confirm whether we are processing your personal data and, if so, provide you with a copy of that personal data (along with certain other details). If you require additional copies, we may charge a reasonable fee for producing those additional copies.
Your right to rectification
If the personal data we hold about you is inaccurate or incomplete, you are entitled to have it rectified. If we have shared your personal data with others, we’ll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we will also tell you who we’ve shared your personal data with so that you can contact them directly.
Your right to erasure
You can ask us to delete or remove your personal data in some circumstances, such as where we no longer need it or where you withdraw your consent (where applicable). If we have shared your personal data with others, we will let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we will also tell you who we have shared your personal data with so that you can contact them directly.
Your right to restrict processing
You can ask us to ‘block’ or suppress the processing of your personal data in certain circumstances such as where you contest the accuracy of that personal data or you object to us processing it for a particular purpose. This may not mean that we will stop storing your personal data but, where we do keep it, we will tell you if we remove any restriction that we have placed on your personal data to stop us processing it further. If we’ve shared your personal data with others, we’ll let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal data with so that you can contact them directly.
Your right to data portability
You have the right, in certain circumstances, to obtain personal data you have provided to us (in a structured, commonly used and machine readable format) and to reuse it elsewhere or to ask us to transfer it to a third party of your choice.
Your right to object
You can ask us to stop processing your personal data, and we will do so, if we are:
- relying on our own or someone else’s legitimate interest to process your personal data, except if we can demonstrate compelling legal grounds for the processing; or
- processing your personal data for the purposes of direct marketing.
Your rights in relation to automated decision-making and profiling
You have the right not to be subject to a decision when it is based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for the entering into, or the performance of, a contract between you and us.
Your right to withdraw consent
If we rely on your consent (or explicit consent) as our legal basis for processing your personal data, you have the right to withdraw that consent at any time. You can exercise your right of withdrawal by contacting us using our contact details in the “How to Contact Us ” section above or by using any other opt-out mechanism we may provide, such as an unsubscribe link in an email.
Your right to lodge a complaint with the supervisory authority
If you have a concern about any aspect of our privacy practices, including the way we have handled your personal data, please contact us using the contact details provided in the “How to Contact Us” section above. You can also report any issues or concerns to a national supervisory authority in the Member State of your residence or the place of the alleged infringement. You can find a list of contact details for all EU supervisory authorities at: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm. As we are incorporated in the UK, our regulatory authority is https://ico.org.uk.
17.Changes to this privacy notice
We may make changes to this Privacy Notice from time to time
To ensure that you are always aware of how we use your personal data, we will update this Privacy Notice from time to time to reflect any changes or proposed changes to our use of your personal data. We may also make changes to comply with changes in applicable law or regulatory requirements.
We will notify you by e-mail of any significant changes to this Privacy Notice. However, we encourage you to review this Privacy Notice periodically to be informed of how we use your personal data.