1. INTRODUCTION

1.1    We are committed to safeguarding the privacy of our website visitors and customers; in this policy we explain how we will handle your personal data.

1.2    This policy applies where we are acting as a data controller with respect to your personal data; in other words, where we determine the purposes and means of the processing of that personal data.

1.3    We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website and services, we will ask you to consent to our use of cookies when you first visit our website.

1.4    Our website incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can specify whether you would like to receive direct marketing communications and limit the publication of your information.

2. HOW WE USE YOUR PERSONAL DATA

2.1    In this Section 2 we have set out:

(a)    the general categories of personal data that we may process;
(b)    in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
(c)    the purposes for which we may process personal data; and
(d)    the legal bases of the processing.

2.2    We may process data about your use of our website and services (usage data). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.

2.3    We may process your account data (account data). The account data may include your name and email address. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is consent, namely the proper administration of our website and business.

2.5    We may process information contained in any enquiry you submit to us regarding goods and/or services (enquiry data). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you]. The legal basis for this processing is consent.

2.6    We may process information relating to our customer relationships, including customer contact information (customer relationship data). The customer relationship data may include your name, your contact details, and information contained in communications between us. The source of the customer relationship data is you. The customer relationship data may be processed for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications and promoting our products and services to customers. The legal basis for this processing is our legitimate interests, namely the proper management of our customer relationships.

2.7    We may process information relating to transactions, including purchases of goods and services that you enter into with us and through our website (transaction data). The transaction data may include your contact details, your card details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us or taking steps, at your request, to enter into such a contract and our legitimate interests, namely the proper administration of our website and business.

2.8    We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (notification data). The notification data may be processed for the purposes of sending you the relevant notifications and newsletters. The legal basis for this processing is consent.

3. AMENDMENTS

3.1    We may update this policy from time to time by publishing a new version on our website.

3.2    You should check this page occasionally to ensure you are happy with any changes to this policy.

3.3    We may notify you of significant changes to this policy by email.

4. YOUR RIGHTS

4.1    In this Section 8, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

4.2    Your principal rights under data protection law are:

(a)    the right to access;
(b)    the right to rectification;
(c)    the right to erasure;
(d)    the right to restrict processing;
(e)    the right to object to processing;
(f)    the right to data portability;
(g)    the right to complain to a supervisory authority; and
(h)    the right to withdraw consent.

4.3    You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.

4.4    You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

4.5    In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.

4.6    In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

4.7    You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

4.8    You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.

4.9    To the extent that the legal basis for our processing of your personal data is:

(a)    consent; or
(b)    that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,

        and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

4.10  If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.

4.11  To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

5. THIRD PARTY WEBSITES

5.1    Our website may include hyperlinks to, and details of, third party websites.

5.2    We have no control over, and are not responsible for, the privacy policies and practices of third parties.

6. PERSONAL DATA OF CHILDREN

6.1    Our website and services are targeted at persons over the age of 18.

6.2    If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.

7. UPDATING INFORMATION

7.1    Please let us know if the personal information that we hold about you needs to be corrected or updated.

8. ABOUT COOKIES

8.1    A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

8.2    Cookies may be either 'persistent' cookies or 'session' cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

8.3    Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

9. COOKIES THAT WE USE

9.1    We use cookies for the following purposes:

(a)    authentication - we use cookies to identify you when you visit our website and as you navigate our website;
(b)    status - we use cookies to help us to determine if you are logged into our website;
(c)    shopping cart - we use cookies to maintain the state of your shopping cart as you navigate our website;
(d)    security - we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally;
(e)    analysis - we use cookies to help us to analyse the use and performance of our website and services; and

10. COOKIES USED BY OUR SERVICE PROVIDERS

10.1  Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

10.2  We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google's privacy policy is available at: https://www.google.com/policies/privacy/.

10.3  We publish Google AdSense interest-based advertisements on our website. These are tailored by Google to reflect your interests. To determine your interests, Google will track your behaviour on our website and on other websites across the web using cookies. You can view, delete or add interest categories associated with your browser by visiting: https://adssettings.google.com. You can also opt out of the AdSense partner network cookie using those settings or using the Network Advertising Initiative's multi-cookie opt-out mechanism at: http://optout.networkadvertising.org. However, these opt-out mechanisms themselves use cookies, and if you clear the cookies from your browser your opt-out will not be maintained. To ensure that an opt-out is maintained in respect of a particular browser, you may wish to consider using the Google browser plug-ins available at: https://support.google.com/ads/answer/7395996.

11. MANAGING COOKIES

11.1  Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

(a)    https://support.google.com/chrome/answer/95647?hl=en (Chrome);
(b)    https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
(c)    http://www.opera.com/help/tutorials/security/cookies/ (Opera);
(d)    https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(e)    https://support.apple.com/kb/PH21411 (Safari); and
(f)    https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).

11.2  Blocking all cookies will have a negative impact upon the usability of many websites.

11.3  If you block cookies, you will not be able to use all the features on our website.

12. OUR DETAILS

12.1  This website is owned and operated by Vaultskin, part of Creative Ideas UN Ltd.

12.2  We are registered in England under registration number 07991840, and our registered office is at 235 EARLS COURT ROAD, SUITE 93, LONDON, SW5 9FE.

12.3  You can contact us:

(a)    Preferable by email, using info@vaultskin.com;
(b)    using our website contact form;
(c)    by post, using the postal address given above.