1. Important information and who we are
This website is not intended for children and we do not knowingly collect data relating to children.
You have the right to make a complaint at any time to the Information Commissioner's Office(ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
2. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
· Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
· Contact Data includes billing address, delivery address, email address and telephone numbers.
· Financial Data includes bank account and payment card details and or data collected by third party financial facilitators for example only – WorldPay, Stripe, PayPal.
· Transaction Data includes detailsabout payments to and from you and other details of Skarper and other productsand services you have purchased from us.
· Technical Data includesinternet protocol (IP) address, your login data, browser type and version, timezone setting and location, browser plug-in types and versions, operating systemand platform, and other technology on the devices you use to access thiswebsite.
· Profile Data includes your username and password, purchasesor orders made by you, your interests, preferences, feedback and surveyresponses.
· Usage Data includesinformation about how you use our website, products and services.
· Marketing andCommunications Data includes your preferences in receivingmarketing from us and our third parties and your communication preferences.
We do not collectany Special Categories of Personal Data about you(this includes details about your race or ethnicity, religious or philosophicalbeliefs, sex life, sexual orientation, political opinions, trade unionmembership, information about your health, and genetic and biometric data). Nordo we collect any information about criminal convictions and offences.
If you fail toprovide personal data
Where we need tocollect personal data by law, or under the terms of a contract we have withyou, and you fail to provide that data when requested, we may not be able toperform the contract we have or are trying to enter into with you (for example,to provide you with Skarper or other goods or services). In this case, we mayhave to cancel a product or service you have with us but we will notify you ifthis is the case at the time.
3. Howis your personal data collected?
We use differentmethods to collect data from and about you including through:
· Directinteractions. You may give usyour Identity, Contact and Financial Data by filling in forms or bycorresponding with us by post, phone, email or otherwise. This includespersonal data you provide when you:
· apply to join ourLaunch Club
· apply to buySkarper or our other products or services;
· create an accounton our website;
· request marketingto be sent to you;
· enter acompetition, promotion or survey; or
· give us feedbackor contact us.
· Third parties or publicly available sources. We will receivepersonal data about you from various third parties and public sources as setout below:
Ø Technical Datafrom the following parties:
§ analytics providers such as Google based outside the UK;
§ advertising networks based inside OR outside the UK; and
§ search information providers based inside OR outside the UK.
Ø Contact, Financial and Transaction Data from providers oftechnical, payment and delivery services based inside OR outside the UK.
Ø Identity and Contact Data from data brokers or aggregators based insideOR outside the UK.
Ø Any data or images collected at any Skarper events.
4. Howwe use your personal data
We will only useyour personal data when the law allows us to. Most commonly, we will use yourpersonal data in the following circumstances:
· Where we need toperform the contract we are about to enter into or have entered into with you.
· Where it isnecessary for our legitimate interests (or those of a third party) and yourinterests and fundamental rights do not override those interests. Legitimate Interest means the interestof our business in conducting and managing our business to enable us to giveyou the best service/product and the best and most secure experience. We makesure we consider and balance any potential impact on you (both positive and negative)and your rights before we process your personal data for our legitimateinterests. We do not use your personal data for activities where our interestsare overridden by the impact on you (unless we have your consent or areotherwise required or permitted to by law). You can obtain further informationabout how we assess our legitimate interests against any potential impact onyou in respect of specific activities by contacting us.
· Where we need tocomply with a legal obligation that we are subject to.
Generally, we donot rely on consent as a legal basis for processing your personal data althoughwe will get your consent before sending third party direct marketingcommunications to you via email or text message. You have the right to withdrawconsent to marketing at any time by contacting us.
Purposes forwhich we will use your personal data
We have set outbelow, in a table format, a description of all the ways we plan to use yourpersonal data, and which of the legal bases we rely on to do so. We have alsoidentified what our legitimate interests are where appropriate.
Note that we mayprocess your personal data for more than one lawful ground depending on thespecific purpose for which we are using your data. Please contact us if youneed details about the specific legal ground we are relying on to process yourpersonal data where more than one ground has been set out in the table below.
Type of data
Lawful basis for processing including basis of legitimate interest
To register you to join our Skarper Launch Crew or as a new customer
Performance of a contract with you
To process and deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey
(d) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to partake in a prize draw, competition or complete a survey
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
(e) Marketing and Communications
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you
(f) Marketing and Communications
Necessary for our legitimate interests (to develop our products/services and grow our business)
We strive toprovide you with choices regarding certain personal data uses, particularlyaround marketing and advertising.
Promotionaloffers from us
We may use yourIdentity, Contact, Technical, Usage and Profile Data to form a view on what wethink you may want or need, or what may be of interest to you. This is how wedecide which products, services and offers may be relevant for you (we callthis marketing).
You will receivemarketing communications from us if you have said you want to be informed whenwe launch Skarper or have requested information from us about or purchased Skarperor other goods or services from us and you have not opted out of receiving thatmarketing.
We will get yourexpress opt-in consent before we share your personal data with any third partyfor marketing purposes.
Opting out of marketing
You can ask us orthird parties to stop sending you marketing messages at any time by followingthe unsubscribe or opt-out links on any marketing message sent to you or bycontacting us at any time at the details shown above.
You can unsubscribe from marketingcommunications at any time by clicking on the link in any email you receivefrom us
Where you opt outof receiving these marketing messages, this will not apply to personal dataprovided to us as a result of a product/service purchase, warrantyregistration, product/service experience or other transactions.
Change of purpose
We will only useyour personal data for the purposes for which we collected it, unless wereasonably consider that we need to use it for another reason and that reasonis compatible with the original purpose. If you wish to get an explanation asto how the processing for the new purpose is compatible with the originalpurpose, please contact us.
If we need to useyour personal data for an unrelated purpose, we will notify you and we willexplain the legal basis which allows us to do so.
Please note thatwe may process your personal data without your knowledge or consent, incompliance with the above rules, where this is required or permitted by law.
5. Disclosuresof your personal data
We may share yourpersonal data with the parties set out below for the purposes set out in thetable above.
· Other companiesin the Skarper group acting as joint controllers or processors and who arebased inside or outside the UK and provide IT and system administrationservices and undertake leadership reporting.
· Service providersacting as processors based inside or outside the UK who provide IT and systemadministration services.
· Professionaladvisers acting as processors or joint controllers including lawyers, bankers,auditors and insurers based in the UK and other countries who provideconsultancy, banking, legal, insurance and accounting services.
· HM Revenue &Customs, regulators and other authorities acting as processors or jointcontrollers based [in the United Kingdom who require reporting of processingactivities in certain circumstances.
We require allthird parties to respect the security of your personal data and to treat it inaccordance with the law. We do not allow our third-party service providers touse your personal data for their own purposes and only permit them to processyour personal data for specified purposes and in accordance with ourinstructions.
It is possiblethat from time to time some of our external third parties are based outside theUK so their processing of your personal data will involve a transfer of dataoutside the UK.
Whenever wetransfer your personal data out of the UK, we ensure a similar degree ofprotection is afforded to it by ensuring at least one of the followingsafeguards is implemented:
· We will onlytransfer your personal data to countries that have been deemed to provide anadequate level of protection for personal data.
· Where we usecertain service providers, we may use specific contracts approved for use inthe UK which give personal data the same protection it has in the UK.
Please contact usif you want further information on the specific mechanism used by us whentransferring your personal data out of the UK.
We have put inplace appropriate security measures to prevent your personal data from beingaccidentally lost, used or accessed in an unauthorised way, altered ordisclosed. In addition, we limit access to your personal data to thoseemployees, agents, contractors and other third parties who have a business needto know. They will only process your personal data on our instructions and theyare subject to a duty of confidentiality.
We have put inplace procedures to deal with any suspected personal data breach and willnotify you and any applicable regulator of a breach where we are legallyrequired to do so.
How long will youuse my personal data for?
We will onlyretain your personal data for as long as reasonably necessary to fulfil thepurposes we collected it for, including for the purposes of satisfying anylegal, regulatory, tax, accounting or reporting requirements. We may retainyour personal data for a longer period in the event of a complaint or if wereasonably believe there is a prospect of litigation in respect to ourrelationship with you.
To determine theappropriate retention period for personal data, we consider the amount, natureand sensitivity of the personal data, the potential risk of harm fromunauthorised use or disclosure of your personal data, the purposes for which weprocess your personal data and whether we can achieve those purposes throughother means, and the applicable legal, regulatory, tax, accounting or otherrequirements.
By law we have tokeep basic information about our customers (including Contact, Identity,Financial and Transaction Data) for six years after they cease being customersfor tax & legal purposes.
In somecircumstances you can ask us to delete your data: see your legal rights below for further information.
In somecircumstances we will anonymise your personal data (so that it can no longer beassociated with you) for research or statistical purposes, in which case we mayuse this information indefinitely without further notice to you.
9. Yourlegal rights
Under certaincircumstances, you have rights under data protection laws in relation to yourpersonal data as follows:
Request access to your personaldata (commonly known as a "data subject access request"). Thisenables you to receive a copy of the personal data we hold about you and tocheck that we are lawfully processing it.
Request correction of the personaldata that we hold about you. This enables you to have any incomplete orinaccurate data we hold about you corrected, though we may need to verify theaccuracy of the new data you provide to us.
Request erasure of your personaldata. This enables you to ask us to delete or remove personal data where thereis no good reason for us continuing to process it. You also have the right toask us to delete or remove your personal data where you have successfullyexercised your right to object to processing (see below), where we may haveprocessed your information unlawfully or where we are required to erase yourpersonal data to comply with local law. Note, however, that we may not alwaysbe able to comply with your request of erasure for specific legal reasons whichwill be notified to you, if applicable, at the time of your request.
Object to processing of your personaldata where we are relying on a legitimate interest (or those of a third party)and there is something about your particular situation which makes you want toobject to processing on this ground as you feel it impacts on your fundamental rightsand freedoms. You also have the right to object where we are processing yourpersonal data for direct marketing purposes. In some cases, we may demonstratethat we have compelling legitimate grounds to process your information whichoverride your rights and freedoms.
Request restriction of processing of your personaldata. This enables you to ask us to suspend the processing of your personaldata in the following scenarios:
· If you want us to establish the data's accuracy.
· Where our use of the data is unlawful but you do not want us toerase it.
· Where you need us to hold the data even if we no longer require itas you need it to establish, exercise or defend legal claims.
· You have objected to our use of your data but we need to verifywhether we have overriding legitimate grounds to use it.
Request the transfer of your personaldata to you or to a third party. We will provide to you, or a third party youhave chosen, your personal data in a structured, commonly used,machine-readable format. Note that this right only applies to automatedinformation which you initially provided consent for us to use or where we usedthe information to perform a contract with you.
Withdraw consent at any time where we arerelying on consent to process your personal data. However, this will not affectthe lawfulness of any processing carried out before you withdraw your consent.If you withdraw your consent, we may not be able to provide certain products orservices to you. We will advise you if this is the case at the time youwithdraw your consent.
If you wish toexercise any of the rights set out above, please contact us at the detailsabove.
No fee usuallyrequired
You will not haveto pay a fee to access your personal data (or to exercise any of the otherrights). However, we may charge a reasonable fee if your request is clearlyunfounded, repetitive or excessive. Alternatively, we could refuse to complywith your request in these circumstances.
What we may needfrom you
We may need torequest specific information from you to help us confirm your identity andensure your right to access your personal data (or to exercise any of yourother rights). This is a security measure to ensure that personal data is notdisclosed to any person who has no right to receive it. We may also contact youto ask you for further information in relation to your request to speed up ourresponse.
Time limit torespond
We try to respondto all legitimate requests within one month. Occasionally it could take uslonger than a month if your request is particularly complex or you have made anumber of requests. In this case, we will notify you and keep you updated.