Privacy policy

Last updated: April 2023

This section summarises how we obtain, store and use information about you. It is intended to provide a very general overview only. It is not complete in and of itself and it must be read in conjunction with the corresponding full sections of this Privacy Policy.

  • Data controller: Design Arc Brands Limited registered with the Information Commissioner’s Office (ICO) under number ZB537607
  • What is ‘Personal Data’: ‘Personal Data’ has been defined under the GDPR (EU and UK) as ‘any information relating to an identified or identifiable natural person (‘data subject’). An identifiable natural person is one who can be identified, directly or indirectly, in particular, by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

Any references to ‘Personal Data’ in this policy therefore means information about living individuals, which, alone or in conjunction with other information held by us, is capable of identifying them.

  • Applicable Data Protection Law - The GDPR 2016/679, the UK GDPR, The Data Protection Act 2018, and any other national implementing legislation relating to data protection in the UK, regulate our use of your Personal Data (collectively ‘Applicable Data Protection Law’)
  • How we collect or obtain information about you:
    • when you provide it to us (for example, by contacting us, placing an order on our website, by subscribing for our newsletter and through creating an account)
    • from your use of our website, using cookies and similar technologies, and 
    • occasionally, from third parties.
  • Information we collect:name, contact details, date of birth, IP address, information from cookies, information about your computer or device (for example, device and browser type), information about how you use our website (for example, which pages you have viewed, the time when you view them and what you clicked on, the geographical location from which you accessed our website (based on your IP address) and the company name or business name (if applicable).
  • How we use your information:for administrative and business purposes (particularly to contact you and process orders you place on our website), to improve our business and website, to fulfil our contractual obligations, to advertise our goods and services and/or to send you promotional material if you have opted in, to analyse your use of our website, and in connection with our legal rights and obligations.
  • Disclosure of your information to third parties:only to the extent necessary to run our business, to our service providers, to fulfil any contracts we enter into with you, if there is a legitimate interest to do so, and where required by law, or to enforce our legal rights.
  • Do we sell your information to third parties (other than in the course of a business sale or purchase or similar event):No
  • How long we retain your information:for no longer than necessary, taking into account any legal obligations we have (for example, to maintain records for tax purposes), any other legal basis we have for using your information (for example, your consent, performance of a contract with you or our legitimate interests as a business) and certain additional factors described in the main section below titled ‘How long we retain your information’. For specific retention periods in relation to certain information which we collect from you, please see the main section below titled ‘How long we retain your information’.
  • How we secure your information:using appropriate technical and organisational measures such as storing your information on secure servers, encrypting transfers of data to or from our servers using Secure Sockets Layer (SSL) technology, only granting access to your information where necessary.
  • Use of cookies and similar technologies:we use cookies and similar information gathering technologies including essential, functional, analytical and targeting cookies. For more information, please visit our cookies policy here: https://www.raffya.com/pages/cookie-policy
  • Transfers of your information outside the European Economic Area:In certain circumstances, we will transfer your information outside of the United Kingdom and/or the European Economic Area, including to the United States of America. Where we do so, we will ensure appropriate safeguards are in place, including, for example, undertaking a transfer risk assessment and executing data protection clauses by way of an International Data Transfer Agreement (IDTA), an International Data Transfer Addendum to the EU Standard Contractual Clauses or the UK Binding Corporate Rules (UK BCRs) as applicable.
  1. Your rights in relation to your information
    • to access your information being processed and to receive information about its use
    • to have your information corrected and/or completed
    • to have your information deleted
    • to restrict the use of your information
    • to receive your information in a portable format
    • to object to the use of your information
    • to withdraw your consent to the use of your information
    • not to have significant decisions made about you based solely on automated processing of your information, including profiling
    • to complain to a supervisory authority, including to the Information Commissioner’s Office (ICO)
  • Sensitive personal information or special categories of Personal Date: we do not knowingly or intentionally collect what is commonly referred to as ‘sensitive personal information’ or ‘special categories of Personal Data’. Please do not submit sensitive personal information about you to us. For more information, please see the main section below titled ‘Sensitive Personal Information’.

Our details

The data controller in respect of our website is Design Arc Brands Limited, a limited liability company registered in England and Wales (company registration number 14681943), the registered address of which is at Quadrant House, Floor 6, 4 Thomas More Square, London E1W 1YW. 

You can contact the data controller by writing to Design Arc Brands Limited at the address above or sending an email to info@raffya.com.

If you have any questions about this Privacy Policy, please contact the data controller.

Klarna

In order to be able to offer you Klarna’s payment options, we will pass to Klarna certain aspects of your personal information, such as contact and order details, in order for Klarna to assess whether you qualify for their payment options and to tailor the payment options for you.

General information on Klarna can be found here. Your personal data is handled in accordance with Applicable Data Protection Law and in accordance with the information in Klarna’s privacy policy.

Information we collect when you visit our website

We collect and use information from website visitors in accordance with this section and the section titled ‘Disclosure and Additional uses of your information’.

Web server log information

We use a third party server to host our website. Our website server automatically logs the IP address you use to access our website as well as other information about your visit such as the pages accessed, information requested, the date and time of the request, the source of your access to our website (for example, the website or URL (link) which referred you to our website), and your browser version and operating system.

Our server is located in the United Kingdom.

Use of website server log information for IT security purposes

Our third party hosting provider collects and stores server logs to ensure network and IT security and so that the server and website remain uncompromised. This includes analysing log files to help identify and prevent unauthorised access to our network, the distribution of malicious code, denial of services attacks and other cyber attacks, by detecting unusual or suspicious activity.

Unless we are investigating suspicious or potential criminal activity, we do not make, nor do we allow our hosting provider to make any attempt to identify you from the information collected via server logs.

Legal basis for processing:

  1. Legal obligation: compliance with a legal obligation to which we are subject (Article 6(1)(c) of the General Data Protection Regulation).we have a legal obligation to implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk of our processing of information about individuals. Recording access to our website using server log files is such a measure.
  2. Legitimate interests: Our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
    We have a legitimate interest in using your information for the purposes of ensuring network and information security.

Cookies and similar technologies

Cookies are data files which are sent from a website to a browser to record information about users for various purposes.

We use cookies on our website, including essential, functional, analytical and targeting cookies. For further information on how we use cookies, please see our cookies policy which is available here: https://www.raffya.com/pages/cookie-policy

All devices have the ability to decline cookies. Our website will display a pop up to remind you that when you access our website, we will place cookies on your device to improve your experience of our website. We will also give you the option to consent to or opt-out of cookies. You can reject some or all of the cookies we use on or via our website by changing your browser settings but doing so can impair your ability to use our website or some or all of its features. For further information about cookies, including how to change your browser settings, please visit www.allaboutcookies.org or see our cookies policy. For more information on cookie consent you may also want to visit the UK Information Commissioner's webpage on cookies: https://ico.org.uk/for-organisations/guide-to-pecr/guidance-on-the-use-of-cookies-and-similar-technologies/

We have presence on social media, such as (without limitation) Facebook, Twitter, Instagram, TikTok and Google. Your access of our profile via these social media platforms may result in you and your activities being tracked by the cookies placed by these social medial platforms.

Google Analytics: In order to optimise our service, we may apply Google Analytics and our own statistical analyses.

Google Analytics is a web analysis service provided by Google, which is used for the purposes of market research and ensuring that the service meets user requirements. Google Analytics uses cookies which are placed on your device to make it possible to analyse how you make use of our service. The information generated by the cookies about your use of our service (including your pseudonymised IP address) is as a rule transmitted to and stored by Google on servers in the United States. Google uses this information in order to evaluate your use of our service and to create reports on activities for the operator of the service. Google may also transmit this information to third parties if this is prescribed by law, or if third parties process the data on behalf of Google. On no account will Google connect your IP address with other Google data. At https://tools.google.com/dlpage/gaoptout?hl=en-GB  you can, with effect for the future, opt out of the recording and saving of your Data at any time. The saving of cookies makes it possible to analyse user behaviour and activate interest-based advertising.

Third Party Links

You might find links to third party websites on our website. Please note that third party websites should have their own respective privacy policies which you should check. We do not accept any responsibility or liability for third party policies whatsoever as we have no control over them.

Information we collect when you contact us

We collect and use information from individuals who contact us in accordance with this section and the section titled ‘Disclosure and Additional uses of your information’.

Email

When you send an email to the email address displayed on our website we collect your email address and any other information you provide in that email (such as your name, telephone number and the information contained in any signature block in your email).

Legal basis for processing:

  1. Legitimate interest(s):our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation), which is responding to enquiries and messages we receive and keeping records of correspondence.
  2. Contractual Necessity:necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
    Where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).

Transfer and storage of your information

We use a third party email provider to store emails you send us. Our third party email provider is Microsoft.

Emails you send us will be transferred and stored outside the European Economic Area on our third party email provider’s servers in the United States of America. For further information please see the section of this privacy policy titled ‘Transfers of your information outside the European Economic Area’.

Phone

When you contact us by phone, we collect your phone number and any information provided to us during your conversation with us.

Legal basis for processing:

  1. Legitimate interest(s): Our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation), which is responding to enquiries and messages we receive and keeping records of telephonic conversations.
  2. Contractual Necessity: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
    Where your call to us relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).

Post

If you contact us by post, we will collect any information you provide to us in any postal communications you send us.

Legal basis for processing:

  1. Legitimate interest(s):our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation), which is responding to enquiries and messages we receive and keeping records of correspondence.
  2. Contractual Necessity:necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
    Where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).

Transfer and storage of your information

Information you submit to us by post will be stored in the United Kingdom.

Information we collect when you interact with our website

We collect and use information from individuals who interact with particular features of our website in accordance with this section and the section titled ‘Disclosure and Additional uses of your information’.

E-Newsletter

When you sign up for our e-newsletter on our website and/or opt-in to receive information, news and offers about our products, services and promotions from us, by either signing up when you create an account, signing up in your account dashboard, signing up at the bottom of the homepage, clicking ‘newsletter’ at the top of the homepage or signing up to hear when at item is back in stock, we collect your first name, last name and email address.

Legal basis for processing:

  1. Consent: Your consent (Article 6(1)(a) of the General Data Protection Regulation).You give your consent to us for sending you our e-newsletter by signing up to receive it using the steps described above.

In compliance with Applicable Data Protection Law, all emails sent by us will clearly state who the email is from and will provide clear information on how to contact the sender. In addition, all marketing email messages will also contain concise information on how to remove yourself from our mailing list should you wish to, so that you receive no further email communication from us.

We are committed to keeping your information confidential. We do not sell, rent or lease our subscription lists to third parties, and we will not provide your personal information to any third party individual, government agency and/or company at any time unless compelled to do so by law. We will use your email address solely to provide information about our products and services, and for sending marketing and promotional material as consented to by you. We will maintain the information you send via email in accordance with Applicable Data Protection Law.

If you prefer not to receive any direct marketing communications from us, you can opt out by unsubscribing at any time or by emailing us at info@lilyandlionel.com.

Transfer and storage of your information

Information you submit to us when you sign up for our mailing list is transferred outside the EEA and stored on our third party mailing list provider’s servers. Our third party mailing list provider is: Klaviyo, a Klaviyo Inc. company. You can access their privacy policy here: https://www.klaviyo.com/legal/privacy

For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below titled ‘Transfers of your information outside the European Economic Area’.

Country of storage: United States of America. This country is not subject to an adequacy decision by the European Commission.

Safeguard(s) used: Klaviyo provides GDPR compliant forms with multiple checkboxes, which enables Personal Data to be collected and processed only with your consent, and in accordance with the General Data protection Regulations (GDPR). Following the invalidation of the EU-US Privacy Shield framework, Klaviyo has also incorporated the European commission’s Standard Contractual Clauses into its Data Protection Addedndum, which in turn has been incorporated into Klaviyo’s Terms of Service.

Registering on our website

When you register and create an account on our website, we collect the following information: your name, email address and password.

If you do not provide the mandatory information required by the registration form, you will not be able to register or create an account on our website.

Legal basis for processing:

  1. Legitimate interest: Our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
    Registering and administering accounts on our website to provide you the ability to complete your purchase quickly, upload feedback, and to facilitate the running and operation of our business.

Transfer and storage of your information

Information you submit to us in order for us to create a members account, will be stored within the European Economic Area on our third party hosting provider’s servers in the United Kingdom. 

Information we collect when you place an order on our website

We collect and use information from individuals who place an order on our website in accordance with this section and the section titled ‘Disclosure and Additional uses of your information’

Information collected when you place an order

Mandatory information

When you place an order for goods or services on our website, we collect your name, email address, telephone number, billing address, shipping address and IP address.

If you do not provide this information, you will not be able to purchase goods or services from us on our website or enter into a contract with us.

Legal basis for processing:

  1. Contractual Necessity- necessary to perform a contract (Article 6(1)(b) of the General Data Protection Regulation).We need the mandatory information collected by our checkout form to establish who the contract is with and to contact you to fulfil our obligations under the contract, including sending you receipts and order confirmations. 
  1. Legal obligation: compliance with a legal obligation (Article 6(1)(c) of the General Data Protection Regulation).
    We have a legal obligation to issue you with an invoice for the goods and services you purchase from us, particularly where you are VAT registered and we require the mandatory information collected by our checkout form for this purpose. We also have a legal obligation to keep accounting records, including records of transactions.
  1. Legitimate interest(s): we collect your phone number and email address for our legitimate interest of contacting you more easily in relation to your order and your account.

Transfer and storage of your information

Information you submit to us when you place an order is transferred outside the European Economic Area and stored on our third party email provider’s (Microsoft’s) servers in the United States of America as well as on our website’s servers in the United Kingdom. For further information on the safeguards used, please see the section below titled ‘Transfers of your information outside the European Economic Area’.

Processing your payment

After you place an order on our website you will need to make payment for the goods or services you have ordered. In order to process your payment we use third party payment processors, including PayPal and Stripe. Your payment will be processed by the third party payment processor you choose to process your payment. 

Please note that we use third party payment processors as service providers only, and are not responsible for the Personal Data collected by them. The third party payment processor you choose to process your payment collects, uses and processes your information, including payment information, in accordance with their respective privacy policy. You can access their privacy policies via the following link(s):

Transfer and storage of your information

Stripe is based in the United States of America. Information relating to Stripe’s processing of your payment may be transferred outside the European Economic Area to the United States of America.

PayPal may transfer information relating to your transaction and the processing of your transaction outside the European Economic Area.

Where Stripe and Paypal do so, they will put appropriate safeguards in place.

For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below titled ‘Transfers of your information outside the European Economic Area’.

Legal basis for processing:

  1. Contractual Necessity: necessary to perform a contract (Article 6(1)(b) of the General Data Protection Regulation).
    For the purposes of enabling you to fulfil your contractual obligation to pay for the goods or services you have ordered from us, following which we may be able to deliver the goods and services to you.

Information collected or obtained from third parties

This section sets out how we obtain or collect information about you from third parties.

Information received from third parties

Generally, we do not receive information about you from third parties. The third parties from which we receive information about you will generally include other businesses and clients we work with from time to time who may recommend our services to you. These could be businesses in any industry, sector, sub-sector or location.

It is also possible that third parties with whom we have had no prior contact may provide us with information about you.

Information we obtain from third parties will generally be your name and contact details, but will include any additional information about you which they provide to us.

Legal basis for processing:

  1. Contractual Necessity: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).Where a third party has passed on information about you to us (such as your name and email address) in order for us to provide services to you, we will process your information in order to take steps at your request to enter into a contract with you and perform a contract with you (as the case may be).
  1. Consent: consent (Article 6(1)(a) of the General Data Protection Regulation). Where you have asked a third party to share information about you with us and the purpose of sharing that information is not related to the performance of a contract or services by us to you, we will process your information on the basis of your consent, which you give by asking the third party in question to pass on your information to us.
  1. Legitimate interests:our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
    Where a third party has shared information about you with us and you have not consented to the sharing of that information, we will not process your personal information unless we have a legitimate interest in processing that information in certain circumstances.

For example, we would have a legitimate interest in processing your information to perform our obligations under a sub-contract with the third party, where the third party has the main contract with you. Our legitimate interest is the performance of our obligations under our sub-contract.

Similarly, third parties may pass on information about you to us if you have infringed or potentially infringed any of our legal rights. In this case, we will have a legitimate interest in processing that information to investigate and pursue any such potential infringement.

Where we receive information about you in error

If we receive information about you from a third party in error and/or we do not have a legal basis for processing that information, we will delete your information.

Information obtained by us from third parties

In certain circumstances (for example, to verify the information we hold about you or obtain missing information we require to provide you with a service) we will obtain information about you from certain publicly accessible sources, both EU and non-EU, such as Companies House, online customer databases, business directories, media publications, social media, and websites (including your own website if you have one) and any affiliates.

Legal basis for processing:

  1. Contractual Necessity: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation). Where you have entered into a contract or requested that we enter into a contract with you, in certain circumstances, we will obtain information about you from public sources in order to enable us to understand your business and provide services to you or services to a sufficient standard. 

For example, we would obtain and/or verify your email address from your website or from a directory where you ask us to send you information by email but we do not possess the information or we need to confirm that we have recorded your email address correctly.

  1. Legitimate interests: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
    In certain circumstances, we will have a legitimate interest in obtaining information about you from public and private sources. For example, if you have infringed or we suspect that you have infringed any of our legal rights, we will have a legitimate interest in obtaining and processing information about you from such sources in order to investigate and pursue any suspected or potential infringement.

Our use of profiling

We use profiling on our website. We do not consider that this has any legal effect on you or similarly significantly affects you.

You have the right to object to our use of profiling described in this section. You can do that by opting-out of cookies and similar technologies in accordance with the method described in the relevant section below. If you do not want us to process your actual IP address (usually the IP address assigned to you by your Internet Service Provider) when you visit our website, you can use a Virtual Private Network (VPN).

You can find out more about our use of cookies and similar technologies (including the legal basis on which we use them) and how to opt out from them in our cookies policy, which is available here: https://www.raffya.com/pages/cookie-policy

Profiling

Profiling is any form of automated processing of your information to evaluate personal aspects about you, in particular to analyse or predict things like your performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.

Use of profiling for web analytics

Our web analytics service, Google Analytics collects information such as your location (based on your IP address) and your behaviour (based on cookies) when you access our website (such as the pages you visit and what you click on). We will only process information from cookies if you have consented to us setting cookies on your computer in accordance with our cookies policy (https://www.raffya.com/pages/cookie-policy).

We also use Hotjar to generate ‘heatmaps’ to help us analyse user behaviour on our website by generating a visual representation of where users have spent their time on our website (such as highlighting where users have moved their mouse cursor on a web page, its location on the page and what they have clicked on. You can find out more about how Hotjar works and the information they collect in their privacy policy via the following link: https://www.hotjar.com/privacy

Logic involved: by automatically analysing and categorising information such as the location (based on IP address) as well as the behaviour and devices of visitors to our website (using cookies), we are able to gain a better understanding of what our website visitors want (in terms of the content of our website and our products), how to improve our website and how to advertise and market our services to them.

Significance and envisaged consequences: cookies will be used to track and store information about your behaviour through your device on our website and your location will be analysed based on your IP address. 

Legal basis for processing:

  1. Legitimate interest: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
    Improving our website for our website users and getting to know our website user’s preferences so our website can better meet their needs and desires.

Use of profiling for Facebook advertising

We use profiling to advertise on Facebook. Information collected by Facebook in relation to its advertisements and the Facebook Pixel on our website is transferred by Facebook outside the European Economic Area. For further information and information on the safeguards used, please see the section of this privacy policy titled 'Transfers of your information outside the European Economic Area' 

Logic involved: by targeting individuals based on criteria such as what they have liked on Facebook, we are able to more effectively advertise our services to those who we think are most likely to be interested in purchasing them, making our advertising more cost-effective and relevant. 

Significance and envisaged consequences: advertisements will be displayed to you on Facebook (Meta) if you meet the relevant criteria which form the basis of our advertising campaign. If you click on any relevant advertisements displayed to you on Facebook, your behaviour will be tracked using the code (Facebook Pixel) which we have installed on our website (if you have consented to the use of such technologies on our website) and your actions on our site will be tracked and the information shared with Facebook (you can access Facebook’s (Meta’s) Privacy Policy here: https://www.facebook.com/about/privacy/). 

How to object: If you accepted the use of Facebook Pixel using our cookie tool, you can use our cookie tool to turn it off and stop it processing your information as well. You can also opt-out of Facebook processing your information using Facebook Pixel by changing your ad settings in your Facebook account here: https://www.facebook.com/ads/settings   
You can opt out of Facebook and other companies that participate in the Digital Advertising Alliance in Europe from showing you interest based ads by visiting http://www.youronlinechoices.com, selecting your country, clicking ‘Your Ad Choices’, then locating Facebook (and any other companies you want to block) and selecting the ‘Off’ option. 

Legal basis for processing

  1. Legitimate interest: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation). Marketing our goods and services effectively. 

Disclosure and Additional uses of your information

This section sets out the circumstances in which we will disclose information about you to third parties and any additional purposes for which we use your information.

Disclosure of your information to service providers

We use a number of third parties to provide us with services which are necessary to run our business or to assist us with running our business and who process your information for us on our behalf. These include the following:

  • Telephone provider (UK),
  • Email provider (USA),
  • Mailing list provider (USA),
  • IT service provider (UK),
  • Web developer (UK),
  • Hosting provider (for Shopify website) (Canada)
  • Domain (USA), and
  • Delivery Partners such as courier services

Apart from our email provider and our mailing list provider, which are located in the United States of America, our service providers are located in the United Kingdom.

Your information will be shared with these service providers where necessary to provide you with the service you have requested, whether that is accessing our website or ordering goods and services from us.

We do not display the identities of all of our service providers publicly by name for security and competitive reasons. If you would like further information about the identities of our service providers, however, please contact us directly by email and we will provide you with such information where you have a legitimate reason for requesting it (where we have shared your information with such service providers, for example). 

Legal basis for processing:

  1. Legitimate interest relied on: legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
    Where we share your information with these third parties in a context other than where is necessary to perform a contract (or take steps at your request to do so), we will share your information with such third parties in order to allow us to run and manage our business efficiently.
  2. Contractual Necessity: necessary to perform a contract and/or to take steps at your request prior to entering into a contract (Article 6(1)(b) of the General Data Protection Regulation).

We may need to share information with our service providers to enable us to perform our contractual obligations to you or to take the steps you have requested before we enter into a contract with you.

Disclosure of your information to other third parties

We disclose your information to other third parties in specific circumstances, as set out below.

Providing information to Google Inc. and Hotjar

Google collects information through our use of Google Analytics on our website. Google uses this information, including IP addresses and information from cookies, for a number of purposes, such as improving its Google Analytics service. Information is shared with Google on an aggregated and anonymised basis. To find out more about what information Google collects, how it uses this information and how to control the information sent to Google, please see the following page: https://www.google.com/policies/privacy/partners/

We share information with Hotjar in order to enable us to use the Hotjar service. You can find out more information about the information that Hotjar collects by accessing their privacy policy here: https://www.hotjar.com/legal/policies/privacy  

Legal basis for processing:

  1. Legitimate interest(s): our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
    Meeting our contractual obligations to Google under our Google Analytics Terms of Service (https://www.google.com/analytics/terms/us.html). You can opt out of Google Analytics by installing the browser plugin here: https://tools.google.com/dlpage/gaoptout

Transfer and storage of your information

  1. Information collected by Google Analytics and Hotjar is stored outside the European Economic Area on their respective servers in the United States of America. 

For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below titled ‘Transfers of your information outside the European Economic Area’.

  1. Sharing your information with third parties, which are either related to or associated with the running of our business, where it is necessary for us to do so. These third parties include our accountants, advisors, business partners (including our delivery partners), independent contractors, and insurers. 

Further information on each of these third parties is set out below. 

Legal basis for processing:

  1. Legitimate interest: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
    Running and managing our business efficiently.
  1. Accountants

We share information with our accountants for tax purposes. For example, we share with our accountants invoices we issue and receive for the purposes of completing tax returns and our end of year accounts.

Our accountants are located in the United Kingdom.

  1. Advisors

Occasionally, we obtain advice from advisors, such as accountants, financial advisors, lawyers and marketing and public relations professionals. We will share your information with these third parties only where it is necessary to enable these third parties to be able to provide us with the relevant advice.

Our advisors are located in the United Kingdom.

  1. Business partners

Business partners are businesses we work with which provide goods and services which are complementary to our own or which allow us to provide goods or services which we could not provide on our own. We share information with our business partners where you have requested services which they provide whether independently from, or in connection with our own services.

Our business partners also include our delivery partners (such as courier services) with who we share your Personal Data, in accordance with the legal basis outlined in Article 6.1 (b) of the GDPR, i.e. contractual necessity, as our delivery partners will perform the shipment/delivery obligations under our contract with you.

Our business partners are located in the United Kingdom.

  1. Independent contractors

Occasionally, we use independent contractors in our business. Your information will be shared with independent contractors only where it is necessary for them to perform the function we have hired them to perform in relation to our business.

Our independent contractors are located in the United Kingdom.

  1. Insurers

We will share your information with our insurers where it is necessary to do so, for example in relation to a claim or potential claim we receive or make or under our general disclosure obligations under our insurance contract with them.

Our insurers are located in the United Kingdom.

  1. In case of a merger or acquisition

Sharing your information with a prospective or actual purchaser or seller in the context of a business or asset sale or acquisition by us, a merger or similar business combination event, whether actual or potential.

Legal basis for processing:

  1. Legitimate interest(s): legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
    Sharing your information with a prospective purchaser, seller or similar person in order to allow such a transaction to take place.

Disclosure and use of your information for legal reasons

  1. We may share an individual’s Personal Data to report possible criminal acts or threats to public security to a competent authority

If we suspect that criminal or potential criminal conduct has occurred, we will in certain circumstances need to contact an appropriate authority, such as the police. This could be the case, for instance, if we suspect that a fraud or a cyber crime has been committed or if we receive threats or malicious communications towards us or third parties.

We will generally only need to process your information for this purpose if you were involved or affected by such an incident in some way.

Legal basis for processing:

  1. Legitimate interests: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
    Preventing crime or suspected criminal activity (such as fraud).
  1. Compliance with a legal obligation (Article 6(1) (c) of the General Data Protection Regulation- we may have a legal obligation to disclose your Personal Data to a relevant authority, for the purposes of preventing crime.
  2. 2. In connection with the enforcement or potential enforcement of our legal rights

We will use your information in connection with the enforcement or potential enforcement of our legal rights, including, for example, sharing information with debt collection agencies if you do not pay amounts owed to us when you are contractually obliged to do so. Our legal rights may be contractual (where we have entered into a contract with you) or non-contractual (such as legal rights that we have under copyright law or tort law).

Legal basis for processing:

  1. Legitimate interest: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
    Enforcing our legal rights and taking steps to enforce our legal rights.
  2. In connection with a legal or potential legal dispute or proceedings

We may need to use your information if we are involved in a dispute with you or a third party for example, either to resolve the dispute or as part of any mediation, arbitration or court resolution or similar process. 

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s): resolving disputes and potential disputes.

  1. For ongoing compliance with laws, regulations and other legal requirements

We will use and process your information in order to comply with legal obligations to which we are subject. For example, we may need to disclose your information pursuant to a court order or summons if we receive one.

Legal basis for processing:

  1. Legal obligation(s): compliance with a legal obligation (Article 6(1)(c) of the General Data Protection Regulation).
    Legal obligations to disclose information which are part of the laws of England and Wales, or if they have been integrated into the United Kingdom’s legal framework (for example in the form of an international agreement which the United Kingdom has signed).

      2. Legitimate interest: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Where the legal obligations are part of the laws of another country and have not been integrated into the United Kingdom’s legal framework, we have a legitimate interest in complying with these obligations.

How long do we retain your information

This section sets out how long we retain your information. We have set out specific retention periods where possible. Where that has not been possible, we have set out the criteria we use to determine the retention period.

Retention periods

Server log information: we retain information on our server logs for 1 (one) year.

Correspondence and enquiries: when you make an enquiry, or correspond with us for any reason, whether by email, via post or by phone, we will retain your information for as long as it takes to respond to and resolve your enquiry, and for 1 (one) further year, after which point we will delete your information.

E-Newsletter: we retain the information you used to sign up for our e-newsletter for as long as you remain subscribed (i.e. you do not unsubscribe) or if we decide to cancel our e-newsletter service, whichever comes earlier.

Order information: we store information in relation to orders you place on our website for 7 (seven) years in accordance with our obligations to keep records for tax purposes and to defend against potential legal claims.

Criteria for determining retention periods

In any other circumstances, we will retain your information for no longer than necessary, taking into account the following:

  • the purpose(s) and use of your information both now and in the future (such as whether it is necessary to continue to store that information in order to continue to perform our obligations under a contract with you or to contact you in the future)
  • whether we have any legal obligation to continue to process your information (such as any record-keeping obligations imposed by relevant law or regulation)
  • whether we have any legal basis to continue to process your information (such as your consent)
  • how valuable your information is (both now and in the future)
  • any relevant agreed industry practices on how long information should be retained
  • the levels of risk, cost and liability involved with us continuing to hold the information 
  • how hard it is to ensure that the information can be kept up to date and accurate, and
  • any relevant surrounding circumstances (such as the nature and status of our relationship with you). 

How we secure your information

We take appropriate technical and organisational measures to secure your information and to protect it against unauthorised or unlawful use and accidental loss or destruction, including:

  • only sharing and providing access to your information to the minimum extent necessary, subject to confidentiality restrictions where appropriate, and on an anonymised basis wherever possible
  • using secure servers to store your information
  • verifying the identity of any individual who requests access to information prior to granting them access to information and
  • using Secure Sockets Layer (SSL) software to encrypt any information you submit to us via any forms on our website.

Transmission of information to us by email

Transmission of information over the internet is not entirely secure, and if you submit any information to us over the internet (whether by email, via our website or any other means), you do so entirely at your own risk.

We cannot be responsible for any costs, expenses, loss of profits, harm to reputation, damages, liabilities or any other form of loss or damage suffered by you as a result of your decision to transmit information to us by such means.

Transfers of your information outside the European Economic Area

Your information will be transferred and stored outside the European Economic Area (EEA) in the circumstances set out below. 

  • We will also transfer your information outside the EEA or to an international organisation in order to comply with legal obligations to which we are subject (compliance with a court order, for example). Where we are required to do so, we will ensure appropriate safeguards and protections are in place, including undertaking safeguards required to be implemented by the Information Commissioner’s Office such as undertaking a transfer risk assessment, and executing data protection clauses in the form of the International Data Transfer Agreement (IDTA), an International Data Transfer Addendum to the EU Standard Contractual Clauses or the UK Binding Corporate Rules (UK BCRs) as applicable.

Email

Information you submit to us by email is transferred outside the EEA and stored on our third party email provider’s servers. Our third party email provider is: Microsoft. You can access their privacy policy here: https://privacy.microsoft.com/en-gb/privacystatement 

Country of storage: United States of America. This country is not subject to an adequacy decision by the European Commission.

 E-Newsletter

Information you submit to us when you sign up for our mailing list is transferred outside the EEA and stored on our third party mailing list provider’s servers. Our third party mailing list provider is: Intuit Mailchimp. You can access their privacy policy here: https://www.mailchimp.com/legal/privacy

Country of storage: United States of America. This country is not subject to an adequacy decision by the European Commission.

Facebook (Meta)

Facebook transfers information it collects from its advertisements and the Facebook Pixel on our website outside the EEA. 

Countries of storage: United States of America and other countries. These countries are not subject to an adequacy decision by the European Commission. 

Safeguard(s) used: where Facebook transfers your information outside the EEA they will ensure EU-approved model contract clauses are in place, obtain your consent for such transfers or adopt other means under European Union law. EU-approved model clauses are standard data protection clauses adopted by the European Commission in accordance with its committee examination procedure under Article 93(2) of the General Data Protection Regulation. Post Brexit, data collectors in the UK can transfer Personal Data outside of the UK and the EEA to countries not given the adequacy decision by executing and implementing the International Data Transfer Addendum to the Standard Contractual Clauses. This is permitted under Article 46(2) of the General Data Protection Regulation. Transfers on the basis of your explicit consent are permitted under Article 49(1)(a) of the General Data Protection Regulation. 

Payment processing

PayPal

When you pay for goods and services in relation to our website, if you use PayPal, information about your order and the processing of your order may be transferred outside the European Economic Area. You can access PayPal’s privacy policy here

Stripe

Information processed by Stripe is transferred outside the EEA and stored on Stripe’s servers. You can access Stripe’s privacy policy here

Country of storage: United States of America. This country is not subject to an adequacy decision by the European Commission.

Apple Pay: Information processed by Apple is transferred outside the EEA and stored on Apple’s servers. You can access Apple’s privacy policy here

Country of storage: United States of America. This country is not subject to an adequacy decision by the European Commission.

Google Pay: Information processed by Google is transferred outside the EEA and stored on Google’s servers. You can access Google’s privacy policy here

Country of storage: United States of America. This country is not subject to an adequacy decision by the European Commission.

Shop Pay: Information processed by Shopify through Shop Pay is transferred outside the EEA and stored on Shopify’s servers. You can access Shopify’s privacy policy here.

The United States has less strict privacy laws, and therefore carries the associated risk of your Personal Data being easily accessible in the United States of America.

Should you not wish your Personal Data to be processed in the United States of America you must not:

  1. Opt-in to receive promotional material from us
  2. Purchase products via our Website, and/or pay using the above-mentioned platforms 

A purchase by you of products using our website and/or using any of the above-mentioned payment platforms shall constitute your consent to your Personal Data being processed in the United States of America.

 Your rights in relation to your information

Subject to certain limitations on certain rights, you have the following rights in relation to your information, which you can exercise by writing to Design Arc Brands Limited, Quadrant House, Floor 6, 4 Thomas More Square, London E1W 1YW or sending an email to info@raffya.com:

  • to request access to your informationand information related to our use and processing of your information
  • to request the correction or deletionof your information
  • to request that we restrict our useof your information
  • to receive information which you have provided to us in a structured, commonly used and machine-readable format(e.g. a CSV file) and the right to have that information transferred to another data controller (including a third party data controller)
  • to object to the processing of your information for certain purposes(for further information, see the section below titled ‘Your right to object to the processing of your information for certain purposes’) and
  • to withdraw your consent to our use of your informationat any time where we rely on your consent to use or process that information. Please note that if you withdraw your consent, this will not affect the lawfulness of our use and processing of your information on the basis of your consent before the point in time when you withdraw your consent.
  • to prevent us using your Data for direct marketing
  • to have (in certain circumstances) inaccurate Personal Data corrected, blocked, or destroyed
  • to access a copy of your Personal Data that is undergoing processing (‘subject access rights’)
  • to object to automated decisions. We do not, however, use automated decision making
  • Data portability, which allows you to get and use your Personal Data for different purposes
  • a right to object to processing that is likely to cause or is causing damage or distress.

If you want to (1) tell us to stop using your Data for direct marketing or withdraw consent from us processing your Personal Data for any of the purposes mentioned in this policy (2) exercise your subject access rights (3) tell us about inaccurate Personal Data you think we hold on you or (4) object to a use you believe we’re making of your Data which is causing, or is likely to cause damage or distress, please contact our Data Protection Manager by writing to us at:

Design Arc Brands Limited

Quadrant House Floor 6

4 Thomas More Square

London E1W 1YW

Or by emailing us at info@raffya.com.

In accordance with Article 77 of the General Data Protection Regulation, you also have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or of an alleged infringement of the General Data Protection Regulation. 

For the purposes of the UK, the supervisory authority is the Information Commissioner’s Office (ICO), the contact details of which are available here: https://ico.org.uk/global/contact-us/

You are entitled to make a complaint at the Information Commissioner’s Office (ICO) https://ico.org.uk/make-a-complaint/

The ICO’s address is:           

Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Helpline number: 0303 123 1113

ICO website: https://www.ico.org.uk 

Further information on your rights in relation to your Personal Data as an individual

The above rights are provided in summary form only and certain limitations apply to many of these rights. For further information about your rights in relation to your information, including any limitations which apply, please visit the following pages on the ICO’s website: 

You can also find out further information about your rights, as well as information on any limitations which apply to those rights, by reading the underlying legislation contained in Articles 12 to 22 and 34 of the General Data Protection Regulation, which is available here: https://gdpr-info.eu  

Verifying your identity where you request access to your information

Where you request access to your information, we are required by law to use all reasonable measures to verify your identity before doing so. 

These measures are designed to protect your information and to reduce the risk of identity fraud, identity theft or general unauthorised access to your information.

How we verify your identity 

Where we possess appropriate information about you on file, we will attempt to verify your identity using that information. 

If it is not possible to identity you from such information, or if we have insufficient information about you, we may require original or certified copies of certain documentation in order to be able to verify your identity before we are able to provide you with access to your information. 

We will be able to confirm the precise information we require to verify your identity in your specific circumstances if and when you make such a request.

Your right to object to the processing of your information for certain purposes

You have the following rights in relation to your information, which you may exercise in the same way as you may exercise your rights described above by writing to Design Arc Brands Limited, Quadrant House, Floor 6, 4 Thomas More Square, London E1W 1YW or sending an email to info@raffya.com:  

  • to object to us using or processing your information where we use or process it in order to carry out a task in the public interest or for our legitimate interests, including ‘profiling’ (i.e. analysing or predicting your behaviour based on your information) based on any of these purposes; and
  • to object to us using or processing your information for direct marketing purposes(including any profiling we engage in that is related to such direct marketing).

You may also exercise your right to object to us using or processing your information for direct marketing purposes by:

  • clicking the unsubscribe link contained at the bottom of any marketing email we send to you and following the instructions which appear in your browser following your clicking on that link or
  • sending an email to infor@raffya.com, asking that we stop sending you marketing communications or by including the words “OPT OUT”.

For more information on how to object to our use of information collected from cookies and similar technologies, please see the section titled ‘How to accept or reject cookies’ in our cookies policy, which is available here: https://www.raffya.com/pages/cookie-policy    

Sensitive Personal Information

‘Sensitive personal information’ or special categories of Personal Data as defined in Article 9(1) of the GDPR and the UK GDPR is information about an individual that reveals their racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic information, biometric information for the purpose of uniquely identifying an individual, information concerning health or information concerning a natural person’s sex life or sexual orientation.

We do not knowingly or intentionally collect sensitive personal information from individuals, and you must not submit sensitive personal information to us.

If, however, you inadvertently or intentionally transmit sensitive personal information to us, you will be considered to have explicitly consented to us processing that sensitive personal information under Article 9(2)(a) of the General Data Protection Regulation. We will use and process your sensitive personal information for the purposes of deleting it.

Changes to our Privacy Policy

We update and amend our Privacy Policy from time to time. 

Minor changes to our Privacy Policy

Where we make minor changes to our Privacy Policy, we will update our Privacy Policy with a new effective date stated at the beginning of it. Our processing of your information will be governed by the practices set out in that new version of the Privacy Policy from its effective date onwards.

Major changes to our Privacy Policy or the purposes for which we process your information

Where we make major changes to our Privacy Policy or intend to use your information for a new purpose or a different purpose than the purposes for which we originally collected it, we will notify you by email (where possible) or by posting a notice on our website. 

We will provide you with the information about the change in question and the purpose and any other relevant information before we use your information for that new purpose.

Wherever required, we will obtain your prior consent before using your information for a purpose that is different from the purposes for which we originally collected it. 

Children’s Privacy

We care about the safety and privacy of children online,  and do not knowingly contact or collect information from persons under the age of 18 (‘child’/ ‘children’). The website is not intended to solicit information of any kind from persons under the age of 18, especially children below the age of 13 (thirteen) years .

It is possible that we could receive information pertaining to persons under the age of 18 by the fraud or deception of a third party. Unless contacted by a parent or legal guardian, we have no way of knowing that Personal Data relating to a child was submitted without parental consent. As a parent/legal guardian you understand that that the onus of controlling your child’s Personal Data lies on you. If we become aware, after notification by a parent/legal guardian or the children themselves, that we have received Personal Data from children without verification of parental consent, we will, where required by law to do so, immediately obtain the appropriate parental consent to use that information or, if we are unable to obtain such parental consent, we will delete the information from our servers. If you would like to notify us of our receipt of information about persons under the age of 18, please do so by sending an email to info@raffya.com.

Do Not Track Disclosures

“Do Not Track” is a privacy preference that users can set in their web browsers. When a user turns on a Do Not Track signal in their browser, the browser sends a message to websites requesting that they do not track the user. For information about Do Not Track, please visit www.allaboutdnt.org

At this time, we do not respond to Do Not Track browser settings or signals. In addition, we use other technology that is standard to the internet, such as pixel tags, web beacons, and other similar technologies, to track visitors to the website. Those tools may be used by us and by third parties to collect information about you and your internet activity, even if you have turned on the Do Not Track signal. For information on how to opt out from tracking technologies used on our website, see our cookies policy which is available here: https://www.raffya.com/pages/cookie-policy.  

Copyright

The copyright in this Privacy Policy is either owned by, or licensed to Design Arc Brands Limited and is protected by copyright laws around the world and copyright protection software. All intellectual property rights in this document are reserved.