To help us provide the best possible service, we capture personal information about you but we respect and protect your privacy and do all we can to honor the trust you place in us by being transparent about what personal information we collect and how we use it, vowing to handle your data fairly and lawfully at all times.
This notice is to inform you about how we collect and protect any personal information you provide to us and how you can control what personal information we collect from you and what we do with it. It sets out how we intend to use your information, who we will share it with and what rights you have about use of your information.
This notice applies to all our activities under the above brands and however, you provide personal information to us, whether you visit us online or visit our stores or contact us via social media or whether you telephone, email, write to or text us.
Here we provide you with details about:
- What personal information we collect
- How we use your personal information
- Information about cookies
- Who we share your personal information with
- The legal basis for using personal information provided to us
- How we aim to protect your privacy
- How long we will keep your personal information
- International transfers of your information
- Your legal rights relating to your personal information
WHAT PERSONAL DATA DO WE COLLECT?
We may collect the following information about you:
- Your name, age/date of birth and gender;
- Your contact details: postal address including billing and delivery addresses, telephone numbers (including mobile numbers) and e-mail address;
- Purchases and orders made by you;
- Your social media handles;
- Your online browsing activities on any of our websites including what items you store in your shopping bag;
- Your password(s);
- Information about the device you use to browse our websites including the IP address and the device type;
- When you make a purchase or place an order with us, your payment card details;
- Your communication and marketing preferences;
- Your interests, preferences, feedback and competition and survey responses;
- Your location;
- Your correspondence and communications with us; and
- Other publicly available personal data, including any which you have shared via a public platform (such as Instagram, YouTube, Twitter or public Facebook page.
This list is not exhaustive and, in specific instances, we may need to collect additional data for the purposes set out in this Notice. Some personal data are collected directly, for example when you set up an online account on our websites, or send an email to our Customer Services team. Other personal data are collected indirectly, for example, when you browse our websites or undertake online shopping activity. We may also collect personal data from third parties who have your consent to pass your details to us, or from publicly available sources.
We may anonymous and aggregate personal data for insight and research but this will not identify anyone.
Our website is not intended for children and we do not knowingly collect data relating to children.
HOW WE USE YOUR DATA
The Smooshop LLC use your personal data:
- To provide goods and services to you;
- To make a tailored website available to you;
- To manage any account(s) you hold with us;
- To verify your identity;
- For crime and fraud prevention, detection and related purposes;
- To contact you electronically about promotional offers, events, products and services which we think may interest you;
- For analysis, insight and market research purposes to better understand your needs and ensure we are giving you what you like;
- To administer competitions and identify and contact competition winners;
- To enable us to manage customer service interactions with you; and
- Where we have a legal right or duty to use or disclose your information (for example in relation to an investigation by a public authority or in a legal dispute).
The Smooshop LLC use your personal data for marketing purposes and may send you postal mail, texts and/or emails to update you on our latest offers and events.
We aim to update you about products and services of interest and relevance to you as an individual.
You have the right to opt out of receiving promotional communications at any time, by:
- 1: Contacting our Customer Services team via email firstname.lastname@example.org
- 2: Making use of the simple “unsubscribe” link in our emails;
This may not stop service messages such as order updates.
- Personalization and Automated Decision Making
In order to improve your shopping experience with us, when you visit our website, you may receive personalized banner advertisements whilst browsing websites of other companies. Any banner advertisements you see will relate to your browsing activity on our websites from your computer or other devices.
We may do this to decide what marketing communications are suitable for you and this activity is based on our legitimate interests to develop and improve our products and services for you.
You have the right to opt out of any automated decision-making processes including profiling at any time by Contacting our Customer Services team via email email@example.com
In order to provide more personalized services and experiences, we may also ask your permission to review third party data about you, for example, your Twitter or Facebook feeds, to get to know you better and to provide more effective personalization. Some of our services enable you to sign-in via a third party service, such as Facebook. If you choose to sign-in via a third party app, you will be presented with a dialog box which will ask your permission to allow us to access your personal information (e.g. your full name, date of birth, email address and any other information you have made publicly accessible).
What are Cookies?
Some cookies collect information about browsing and purchasing behavior when you access our websites via the same computer or device. This includes information about pages viewed, products purchased and your journey around a website. All data passed by cookies is anonymous and will never contain individual detail such as your name, address, telephone number or payment details. For more detailed information about how cookies work, please visit www.allaboutcookies.org
How Are Cookies Managed?
The cookies stored on your computer or other device when you access our websites are designed by
- The Smooshop LLC or on our behalf, and are necessary to enable you to make purchases on our website;
- Third parties who participate with us in marketing programs; and
- Third parties who publish web banner advertisements for us.
What Are Cookies Used For ?
Cookies are used with our marketing partners to present you with appropriate offers and advertising as you browse other sites on the internet, based on your browsing activity while on our sites. Cookies also allow us to work alongside our web analytics partners to see how you like to use our website, which pages or special functions you prefer and help us to promote them and make them better. This helps us to continually improve the relevance of our promotional communications, your shopping experience and our products and services.
The main purposes for which cookies are used are:
- 1: For technical purposes essential to the effective operation of our websites, particularly in relation to online transactions and site navigation.
- 2: For us to market to you, particularly web banner advertisements and targeted updates.
- 3: To enable us to collect information about your browsing and shopping patterns, including to monitor the success of campaigns, competitions etc.
- 4: To enable us to meet our contractual obligations to make payments to third parties when a product is purchased by someone who has visited our website from a site operated by those parties.
What Cookies Do We Use?
There are two types of cookie that may be used during your visit to our site:
Session cookies are deleted after each visit to our site. For example, when you are browsing our site, it will remember you for the duration of your visit, but the cookie will be removed from your computer as soon as you close down your internet browser. Session cookies allow you to add an item to the basket and then move through the checkout. Disallowing these cookies via your web browser will mean you are unable to place an order on the site.
Persistent cookies remember you for a set period of time allowing wish list products and/or previously viewed products to be displayed the next time you visit our site and whether you logged into or out of your account while browsing.
The Smooshop LLC works with several partners who serve advertisements or present online offers on our behalf. Most of these marketing partners use both session and persistent cookies. These cookies are used to deliver adverts more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. All data collected by third party cookies is anonymous and will never contain your name, address, telephone number, email address or payment details.
Turning Off And Deleting Cookies
Most web browsers will provide the option to turn off, or disallow cookies. How you do this depends on the web browser you’re using. Instructions for disallowing cookies can usually be found in the browser’s ‘Help’ menu. Note that in common with most other transactional websites, if you only disable third party cookies, you will not be prevented from making purchases on our websites but refusing the cookies we have used via your web browser will mean that you are unable to make a transactional purchase on our website. You may also find that the functionality of many other websites and services will be affected. Cookies can be deleted using your web browser. However, unless they are disallowed they will be re-applied the next time you visit a website.
If you want to disable cookies, you need to change your website browser settings to reject cookies. How you can do this will depend on the browser you use.
For Microsoft Internet Explorer:
- 1: Choose the menu “Tools” then “Internet Options”.
- 2: Click on the “Privacy” tab.
- 3: Select the appropriate setting.
For Google Chrome:
- 1: Choose Settings > Advanced.
- 2: Under “Privacy and Security,” click “Content Settings”.
- 3: Click “Cookies”.
- 1: Choose Preferences > Privacy.
- 2: Click on “Remove all Website Data”.
For Mozilla Firefox:
- 1: Choose the menu “Tools” then “Options”.
- 2: Click on the icon “Privacy”.
- 3: Find the menu “Cookie” and select the relevant options.
SHARING DATA WITH THIRD PARTIES
We will never sell or rent your personal information to other organizations for marketing purposes.
We will not disclose your personal information to any third party, except for those referred to below.
We may share your data with:
- Other companies within our group;
- Purchasers, investors, funders and advisers if we sell our business or assets or restructure whether by merger, re-organization or otherwise;
- Our legal and other professional advisers, including our auditors;
- Credit reference agencies where necessary for card payments;
- Governmental bodies, regulators, law enforcement agencies, courts/tribunals and insurers where we are required to do so:
- To comply with our legal obligations and/or the administration of justice;
- To exercise our legal rights (for example in court cases);
- For the prevention, detection, investigation of crime or prosecution of offenders; and
- For the protection of our employees and customers.
|Type of External Service Provider||Reason for Sharing Your Information|
|Database Administrators||Administration of our marketing databases|
|Mailing Houses||Delivery of postal|
|Electronic Mail Administrators||Delivery of email campaigns including electronic newsletters and administration of on-line competitions|
|Couriers and Logistics Service Providers||Goods delivery|
|Software Providers||Administration of sales and returns|
|Marketing Consultancies and Advertising Services Providers||Analysis of marketing data and customer insight for the development and administration of marketing campaigns. Delivery of offers, promotions and other marketing campaigns. Website tracking to assist with personalising your on-line buying experience. Facilitate customer product and service reviews|
|Insurers||Provision of insurance cover on products purchased from us|
|Finance Companies||Provision of interest free and interest bearing credit for our customers|
|Watch Manufacturers||Administration of guarantees and repairs|
|Call Recording Providers||Call recording to facilitate: customer care, administration of enquiries and complaints and facilitate telephone orders and order fulfilment for the Smooshop website|
|Insurance Claims and Repair Handlers||Facilitate certain types of insurance claim administration|
|Electronic Platform Providers||To create on-line accounts, to fulfil website orders and electronic newsletter distribution|
|Email Administrators||Provision of email system|
|Live Engagement Platform Providers||Delivery of live chat environment|
|App Developer||Delivery of customer chat app called Akin|
|Payment Service Providers||Website payment services|
|Website Hosting Service Providers||Administration of our websites, fulfilment of on-line orders and electronic marketing campaigns|
|Order Fulfilment Providers||Facilitate fulfilment of orders on websites and customer care|
|Electronic Repair Administrators||Repair processing and workshop administration: facilitating watch repairs by post, facilitating communications with our repair services|
|Document Disposal Managers||Document disposal|
Our service providers and suppliers.
In order to make certain services available to you, we have partnered with certain trusted third parties including IT, mailing, payment services, delivery and marketing service providers. We may need to share your personal information with some of our service partners. We only allow our service providers to handle your personal information when they have confirmed that they apply appropriate data protection and security controls. We also impose contractual obligations on service providers relating to data protection and security, which mean they can only use your information to provide services to us and to you, and for no other purposes.
LEGAL BASIS FOR USING DATA
We are required to set out the legal basis for our ‘processing’ of your personal data.
We collect and use customers’ personal data
- 1: As necessary to perform our contract with you
- For the purposes of complying with our duties and exercising our rights under contracts for the sale of goods or services to customers; or
- 2: As necessary for the pursuit of our legitimate interests including:
- Selling and supplying goods and services to our customers;
- Promoting, marketing and advertising our products and services;
- Sending promotional communications which are relevant and tailored to individual customers (including administering loyalty schemes);
- To administer competitions and promotions and identify and contact competition winners;
- Understanding our customers’ behavior, activities, preferences, and needs;
- Improving existing products and services and developing new products and services;
- Protecting customers, employees and other individuals and maintaining their safety, health and welfare;
- Good governance, accounting and managing and our operations and complying with our legal obligations;
- Preventing, investigating and detecting crime, fraud or anti-social behavior and prosecuting offenders, including working with law enforcement agencies;
- Handling customer contacts, queries, complaints or disputes;
- Managing insurance claims by customers;
- Protecting our company, its employees and customers, by taking appropriate legal action against third parties who have committed criminal acts or are in breach of legal obligations to us;
- Handling any legal claims or regulatory enforcement actions taken against us; and
- Fulfilling our duties to our customers, colleagues, shareholders and other stakeholders or
- 3: As necessary for complying with our legal obligations including:
- Where you exercise your rights under data protection laws;
- For compliance with legal and regulatory requirements; or
- To establish or defend our legal rights; or
- 4: Based on your consent
You have the right to withdraw consent at any time. Where consent is the only legal basis for processing your personal data, we will cease to process your personal data for that purpose after consent is withdrawn.
HOW WE PROTECT YOUR DATA
The Smooshop LLC is committed to keeping your personal data safe and secure.
Our security measures include:
- Encryption of data;
- Regular cybersecurity assessments of all service providers who may handle your personal data;
- Regular planning to ensure we are ready to respond to cybersecurity attacks and data security incidents;
- Daily penetration testing of systems;
- Security controls which protect our IT systems infrastructure and our premises from external attack and unauthorized access; and
- Internal policies setting out our data security rules for our personnel.
- Regular training for our employees.
WHAT YOU CAN DO TO HELP PROTECT YOUR DATA
You should always be cautious when sharing your personal data. No one from our company will ever ask you to confirm any bank account or credit card details via email. If you receive an email claiming to be from The Smooshop LLC asking you to do so, please ignore it and do not respond.
If you are using a computing device in a public location, we recommend that you always log out and close the website browser when you complete an online session.
In addition, we recommend that you take the following security measures to enhance your online safety
- Keep your account passwords private because anyone who knows your password may access your account or be compromised if your account is accessed without authority.
- When creating a password, use a difficult word/number combination of at least 8 characters and something that is not easily guessed by hackers such as dictionary words, your name, email address, or other personal data that can be easily obtained. Also, frequently change your password. You can do this accessing your account, clicking ‘your account’, clicking ‘your data’ and selecting ‘change password’.
- Avoid using the same password for different online accounts.
HOW LONG WE KEEP YOUR DATA
We will not retain your data for longer than necessary for the purposes set out in this Notice. Different retention periods apply for different types of information, and our Data Retention Policy sets out the length of time we will usually retain personal data and where these default periods might be changed.
In summary, various laws, accounting and regulatory requirements applicable to us require us to retain certain records for specific amounts of time. In relation to your personal data, we will hold this only for so long as we require that personal data for legal or regulatory reasons or for legitimate organizational purposes and we will not keep your data for longer than is necessary for the purposes for which we collect them.
To deliver products and services to you, it is sometimes necessary to share your personal information outside of the European Economic Area (the EEA). This will typically occur when service providers are located outside the EEA or if you are based outside the EEA. These transfers are subject to special rules under data protection laws. If we transfer your personal information outside the EEA, we will ensure that the transfer will be compliant with data protection law and all personal data will be secure. Our standard practice is to assess the laws and practices of the destination country and relevant service provider and the security measures that are to be taken as regards the data in the overseas location; Alternatively, we use standard data protection clauses.
You have the following rights:
- The right to be informed about our processing of your personal data which is the aim of this Notice;
- The right to request access to personal data that we hold about you at any time;
- The right to ask us to update and correct any out-of-date or incorrect personal data that we hold about you;
- The right to object to the processing of your personal data and/or to withdraw any consent you have given us and to opt out of any marketing communications that we may send you.
- The right to prevent processing that is likely to cause damage or distress to you or anyone else;
- The certain rights in relation to automated decision-making processes including the right to object to profiling;
- The right to request that we erase or destroy your personal data in certain circumstances (the right to be forgotten) for example when the data are no longer necessary for the purpose for which we collected them;
- The right to have your personal data provided to you by us in a structured, commonly used and machine-readable format and the right to have that data transmitted to another data controller. This is known as the right to data portability.
If you wish to exercise any of the above rights, you can always:
Email us at firstname.lastname@example.org.