PRIVACY POLICY
1. Privacy Policy
1.1 This Privacy Policy covers the following:
- Who we are
- What information do we collect
- Applying to work with us
- What information do we collect
- Applying to work with us
- How do we use your information
- Who may use your information
- Third party links and services
- How do we protect your information
- Where is your information processed
- Marketing communications - How long do we keep your information
- Your rights
- How do you contact us
1.2 This Privacy Policy applies to all of the personal data we collect about you, including information collected on our websites (including mobile access or apps) where this policy is linked to; all of which are referred to as the “Site” in this policy, and information collected at events, in stores or via telephone with one of our people.
1.3 Your privacy matters to us, so please do take the time to get to know our practices and, if you have any questions, contact us using our contact details below . This Privacy Policy was last updated on June 15 2018 and applies from that date.
1.4 We may occasionally amend this Privacy Policy. Any new policy will automatically be effective when it is published on the Site. You should therefore return here regularly to view our most up to date Privacy Policy. You should also print a copy for your records.
1.5 We do not knowingly collect or process data from anyone under the age of thirteen (13) years old.
2. Who we are
2.1 Extraless is a global organisation. By the use of “we” in this Privacy Policy we are referring to the EXTRALESS Group whose members include the following: EXTRALESS LTD (Company Number 10489323), a company incorporated in England & Wales whose registered office is at 7-11 Woodcote Road, Wallington, Surrey, SM6 0LH.
2.2 We refer to Extraless together with its group companies as “Extraless”, “extraless.com”, “we”, “us” or “our” in this Privacy Policy.
2.3 Please check the Site or the store to see which member of the Extraless you are dealing with. If you are unsure please get in touch with us using the contact details below.
2.4 Our main website is operated by Extraless LTD. (“EXTRALESS”). EXTRALESS LTD has its registered office in The United Kingdwom at 7-11 Woodcote Road, Wallington, Surrey, SM6 0LH, Company Reg. Number 10489323. They operate our main website on our behalf. You can find out more about EXTRALESS LTD, its service providers and see its privacy policy by visiting http://www.extraless.co.
3. What information do we collect?
3.1 Most of the information we collect is information provided directly by you, which is set out on the web page on which we collect it - for example in our enquiry form - at events, in store or by our people by phone. This may include: contact information – information such as name, email address, physical mailing address, device identifier and telephone number ; personal information – such as your birthday, gender and clothes and shoe size; professional information – such as your employment background, job description and related information; social media – such as your Facebook, Instagram, twitter, WeChat or Google account details. In some cases we may use your Facebook, WeChat or Google credentials to allow access to your account with EXTRALESS; transaction information – your contact information, the products you are interested in, your purchasing requirements, financial or other payment information including your card details and billing address, your PayPal account (if any) and any identification numbers needed; and responses to surveys – information you provide in responding to a survey on the Site, via an app or email, on the telephone or otherwise.
3.2 We may also collect and process other information obtained through the Site or the device you are using, including: information through ‘My Account’ – information for registration of ‘My Account’ such as your contact information, password and email preferences.
If you are a registered user, we collect information about your access to the reserved area of the Site such as information on the date and time of access and with your consent, information on your interests and preferences in relation to our products and services.
We also collect information relating to your orders; including order number, list of products you have ordered and information on their delivery status as well as information on your wish list, which includes your personal collection of favourite items; location information (including GPS signals sent by a mobile device, location information gathered from social media networks or sensor or IP address data from your device); information from cookies, web beacons or from the internet, including your IP address, browser type, operating system, domain name, access times, which pages you visit within our Site and referring website addresses.
Cookies are small pieces of information that are stored by your browser on your computer’s hard drive. You can find out more about how we deal with cookies in our Cookies Policy; if you ask us to connect with other sites (for example if you ask us to connect with your Facebook account) we may get information that way too; and we may record telephone calls.
4. Applying to work with us
4.1 If you use the Site to apply to work with us, we will use the information you supply to process your application and to monitor recruitment statistics. Please do not send us any sensitive personal data with your application unless we specifically ask you for it. As a global business we may transfer your details outside of your home country and to other companies in our group. We will ask you to sign up to additional confidentiality and privacy terms if you apply for a job with us. Once a person has taken up employment with us, we will compile a file relating to their employment. At that stage we will give more details about how we hold employee data and we will expect the employee to sign up to additional confidentiality and privacy terms as part of their employment.
4.2 If you apply to work with us through a third party, such as a recruitment consultant, please also check their privacy policy before proceeding. We do not encourage unsolicited approaches either directly or from third parties – please do not send personal data to us unless the data subject has read and agrees to this privacy policy.
4.3 We may retain details of candidates who may be of interest to us, either now or in the future, for up to one year. If you would not like us to do that please let us know. Additionally, if your circumstances change – for example you no longer wish to be considered by us for employment – please let us know that too.
5. How do we use your information?
5.1 We use information collected about you as outlined in this Privacy Policy.
5.2 Our primary purpose in collecting your personal data is to conclude an order which you have made for the purchase of our goods and to provide you with services which we believe will optimize your use of the Site. We may use your personal data for the following purposes: to complete and execute your order for the purchase of our goods on the Site, in stores or via telephone; to register on ‘My Account’ and use the services offered to registered users; to provide the information, services or support and to manage your Customer Service requests and related after-sales services; to identify you, and to contact you from time to time with product or service updates; to send other messages that are useful to the service we provide; to manage our relationship with you and to carry out any related administration; to provide personalised, targeted, or location-based content, services, and advertising from us and third parties; to promote our services, or the services of our suppliers or partners like Extraless.com, including by email and via social media platforms (subject to the relevant marketing permissions)*; to compare information for accuracy, and verify it with third parties*; to detect, investigate and prevent activity we think may be potentially illegal, unlawful or harmful and to enforce our Privacy Policy and/or other legal terms found on the Site or any other purpose referenced herein or therein*; to carry out surveys, research, including market research, statistical research on site traffic, sales and other commercial information to assist us in improving the services we provide to you and tailor the Site*; and to enable the call recording feature to work and in order to troubleshoot the service.
5.3 We process your personal data where we have your consent to do so, which you may withdraw at any time, or otherwise where this is necessary for: the performance of our contract with you for the provision of Extraless or to take preliminary steps at your request; us to fulfil our legal obligations; or, the purposes of the legitimate interests pursued by us or by a third party.
5.4 A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. Our legitimate interests are those indicated with a “*” above, and we consider that we have implemented sufficient checks and protections to ensure that your rights and interests are not unreasonably intruded on. *However, you can object to processing on any of these bases at any time and, if you do so, we will stop processing the personal data unless we can show compelling legitimate grounds which override your rights and interests, or we need the data to establish, exercise or defend legal claims – see the paragraph “Your rights” below.
6. Who may use your information?
6.1 We may disclose your personal data to enforce our policies, to comply with our legal obligations or in the interests of security, public interest or law enforcement in any country where we have entities or affiliates. For example, we may respond to a request by a law enforcement agency or regulatory or governmental authority. We may also disclose data in connection with actual or proposed litigation, or to protect our property, security, people and other rights or interests.
6.2 We share your information with third parties who help deliver our products and services to you. Examples include hosting our web servers, analysing data, providing marketing assistance, and providing Customer Service. These companies will have access to your personal information as necessary to perform their functions, but they may not use that data for any other purpose.
6.3 We may also share your personal data: with companies in our group (see paragraph 2.1 of this Privacy Policy for more details); or, with any third party you have asked us to share your personal data with – such as Facebook or any other social media site if you have asked us to connect with your account.
6.4 You may have accessed our Site through a hyperlink from a third party website. If so, you consent to your personal details and purchase information, including behavioural patterns, being shared with that third party in accordance with our contractual relationship with them.
6.5 If extraless.com or Extraless is sold, or some of its assets transferred to a third party, your personal information, as a valuable asset, may also be transferred to the acquirer, even if they are not in the same line of business as us. Our customer database could be sold separately from the rest of the business, in whole or in a number of parts. Potential purchasers and their advisors may have limited access to data as part of the sale process. However, use of your personal information will remain subject to this Privacy Policy. Likewise, your personal information may be passed on to a successor in interest in the unlikely event of a liquidation, bankruptcy or administration.
6.6 Please remember that when you share information publicly on the Site, for example a comment on a blog post, it may be indexable by search engines, including Google, which may mean that the information is made public.
7. Third party links and services
7.1 The Site may contain links to third parties’ websites. We are not responsible for the privacy practices or the content of those websites. Therefore, please read carefully any privacy policies on those links or websites before either agreeing to their terms or using those websites.
7.2 We may also use Google Analytics to gather statistics on site usage. This may involve the use of cookies. There are more details in Google’s own privacy policy. Google may aggregate data they collect from their various services including Google Analytics, Google Translate, Google Maps and YouTube. You acknowledge and accept that we have no control over Google’s data collection. You should look at Google’s privacy policy for details of their data collection practices.
7.3 If you have asked us to share data with third party sites (such as social media sites), their servers may not be secure.
7.4 Note that, despite the measures taken by us and the third parties we engage, the internet is not secure. As a result others may nevertheless unlawfully intercept or access private transmissions or data.
8. How do we protect your information?
8.1 We take what we consider to be appropriate technical and organisational measures designed to reduce the risk of unauthorised or unlawful processing of your personal data and accidental loss or destruction of, or damage to, your personal data. While no system is completely secure, we believe the measures implemented by the Site reduce our vulnerability to security problems to a level appropriate to the type of data involved. However, it remains your responsibility: where you are a registered user with ‘My Account’ for the Site: to log off or exit from the Site when not using it; to ensure no-one else uses the Site while your device is logged on to the Site (including by logging on to your device through a mobile, Wi-Fi or shared access connection you are using); to keep your password or other access information secret. Your password and log in details are personal to you and should not be given to anyone else or used to provide shared access for example over a network. You should use a password which is unique to your use of the Site – do not use the same password as you use for another site or email account; and, to maintain good internet security. For example, if your email account or Facebook account is compromised this could allow access to your account with us if you have given us those details and/or permitted access through those accounts. If your email account is compromised it could be used to ask us to reset a password and gain access to your account with us. You should keep all of your account details secure. If you think that any of your accounts has been compromised you should change your account credentials with us, and in particular make sure any compromised account does not allow access to your account with us. You should also tell us as soon as you can so that we can try to help you keep your account secure and if necessary warn anyone else who could be affected.
9. Where is your information processed?
9.1 Extraless is a global retailer. As a result we might transfer your personal information to places outside of your home country, for example to companies in our group that are based outside the EEA such as the USA and Hong Kong for the purposes outlined in this Privacy Policy. If you are in the European Economic Area (EEA) this means that your data may be transferred from the EEA to another country and stored there, where we (or our suppliers) might process it.
9.2 If we transfer your personal data outside your country we will try to take steps to ensure that your privacy rights continue to be protected in compliance with applicable data protection law and this Privacy Policy.
10. Marketing communications
10.1 If you have given permission, we may contact you by mail, telephone, SMS, text/picture/video message, social media and email about products, services, promotions and special offers that may be of interest to you. If you prefer not to receive any direct marketing communications from us, you can opt out at any time. See further 'Your rights', below.
11. How long do we keep your information?
11.1 We will retain your personal data only as long as is necessary for the purposes set out in this Privacy Policy, or as is required by applicable law, and then we will delete it.
12. Your rights
12.1 In some countries you may have the right to gain access, correct, update, restrict, delete, be forgotten, or object to the processing of, or request data portability of the personal data collected about you subject to some exceptions and conditions. You can find out more about these rights in the EU by reading the General Data Protection Regulation.
12.2 If you wish to inquire about any of those rights or would like to submit a request then please send us your request by any of the following ways: write to our Customer Service; or, write a letter to us and post it to 7-11 Woodcote Road, Wallington, Surrey, SM6 0LH, UK or contact us through dpo@extraless.com
12.3 We may charge a small fee depending on your request where that is permitted by law. We will take all reasonable steps to delete your personal data from our system(s) on receiving a valid request, unless restricted by law. We may keep a copy for as long as is necessary in our opinion, in compliance with applicable laws and regulations. We will respond to any of your above-mentioned requests within one month but we reserve the right to verify your identity before dealing with your request.
12.4 You may also have the right to lodge a complaint with a data protection regulator, which you may lodge with the Information Commissioner’s Office (ICO), as the EU lead supervisory authority for Badé. The ICO’s contact details are as follows: 7-11 Woodcote Road, Wallington, Surrey, SM6 0LH
12.5 If your complaint is about the processing activities of Extraless, then their lead supervisory authority is the Italian Data Protection Authority and you can contact them as follow: Postal Address 7-11 Woodcote Road, Wallington, Surrey, SM6 0LH
13. How do you contact us? If you have any questions about this Privacy Policy, the practices of this Site, or your dealings with this Site, we encourage you to contact us at dpo@extraless.com This Privacy Policy was updated in September 2020
