Privacy and Cookie Policy

London: 24 May 2018

1. ANATOMIE Londons's APPROACH TO PRIVACY

1.1 www.anatomie.london is a website (herein referred to as the “platform”) owned and operated by Anatomie Ltd at Unit 26, 27 Blue Anchor Lane, London SE16 3UL (the “we”, “our”, “us”). We are committed to protecting and respecting your privacy in accordance with the applicable data protection legislation (GDPR). This privacy policy (“Privacy and Cookie Policy”) sets out how we collect, use and share information that identifies you or is associated with you (“personal data”).

1.2 For the purposes of the Data Protection Legislation, we are the data controller of the personal data we collect and process about you. If you have any questions related to this Privacy Policy, please use the contact details provided in section 11 below to get in touch. Also, just drop us a line at buyer@anatomie.london and we'll sort it.

1.3 Like most other websites we also use cookies to store and access information whilst providing access to our platform. Find out more about cookies below!

2. PERSONAL DATA WE COLLECT ABOUT YOU

2.1 We collect personal data from you when you voluntarily submit information directly to us or via our platform. This can include information you provide when you register to use the platform, create an account on our platform, set up a profile, provide feedback or reviews on our products or platform, enter competitions through our platform, correspond with us, purchase products from the platform, subscribe to our email lists or respond to surveys or promotions.

2.2 The categories of personal data we collect include the following:

• (a) Contact details: Such as your name, your email address, your telephone number and addresses associated with your account.
• (b) Profile information: Such as your contact details (as above) and other any information you share when creating a profile on Services.
• (c) Comments and opinions: Such as, comments and opinions you share on ANATOMIE London’s services, when you provide feedback or reviews on our products or platform, or when you respond to our surveys, competitions and promotions.
• (d) Payment and transaction information: Records of the products and services you purchase from us and the payment method, and credit/ debit card details, you use for the transaction.
• (e) Your preferences: Choices you make such as notification and messaging preferences or choices about how the platform is displayed.
• (f) Information about products you have looked at: We collect information about the products that you have looked at on the platform or in one of our showrooms, or that you have added to your cart.
• (g) Information about how you use and connect to the online service:
• (i) We automatically collect information about how you use the platform such as the pages and links you access, the time you access the platform and duration you are on it, the platform you come to the platform from or go to after leaving the platform and selections and choices you make when using the platform.
• (ii) We also automatically collect information about the computer or other electronic devices you use to connect to the platform such as details about the type of device (which can include unique device identifying numbers), its operating system, browser and applications connected to the platform through the device, your Internet service provider or mobile network, your IP address and your device’s telephone number (if it has one).
• (iii) Typically, the information we collect about how you use or connect to the platform is associated with your device.
• (h) Information about your location: Other than information you choose to provide to us, we do not collect information about your precise location. Your device’s IP address may help us determine an approximate location but this will be no more precise than the city, state or country you are using your device in.
• (i) Information provided by other users: Sometimes, other visitors to our platform provide your personal data. For example, other visitors may provide your personal data to us when they invite you to use the platform or through ANATOMIE London’s services.
• (j) Information from fraud prevention organisations: Where permitted by law, if fraudulent activity is suspected relating to your account, we may be provided with information by credit reference, fraud and crime prevention organisations.

2.3 We also automatically collect personal data indirectly from you such as information about the pages you look at on the platform or the device you connect to the platform with.

3. HOW WE USE YOUR INFORMATION

3.1 We will also use your personal data for the purposes specifically described below:

• (a) Contact details: we will use your contact details so that we can communicate with you directly via phone, SMS messaging, or email, in particular, about queries, issues, problems we have detected or concerns you or other users have. We may also use your contact details to send you information about similar products and services that we think may be of interest to you (such communications will be in accordance with your marketing preferences as explained in more detail in section 5 below).
• (b) Profile information: we use your profile information to provide ANATOMIE London’s services to you.
• (c) Comments and opinions: we will use your comments and opinions to determine similar products and services that may be of interest to you.
• (d) Payment and transaction information: we will use payment and transaction information you provide to process payment for any product or service you purchase from us.
• (e) Messages to us: we will use messages you send to us to help us respond to any query, issue or concern you raise and to provide ANATOMIE London’s services to you and ensure that you are able to interact with our users as permitted by the functionality of the service and your preferences which you can set by using the ‘my preference’ functionality on your profile page.
• (f) Your preferences: we will use your preference settings which you set for the purpose of providing notifications, messages, displaying the platform and following other choices you are able to make about how the platform is displayed to you.
• (g) Information about products you have looked at: we use this information to determine similar products and services that may be of interest to you.
• (h) Information about how you use and connect to the online service: we use this information to present the platform to you on your device of choice. We will also use this information to determine similar topics, products and services that may be of interest to you.
• (i) Information about your location: we may use an approximate location to ensure content on the platform is relevant to the city, state or country you are using your device in. We will not collect or track your precise location.
• (j) Information about fraudulent activity relating to your account: we will use information about fraudulent activity relating to your account for the purposes of preventing fraud or crime in accordance wit the law.
• (k) All personal data on an aggregated basis: we will use all the personal data we collect to continuously monitor and improve the platform and our procedures and processes; and to help us develop new products and services.

3.2 We may anonymise and aggregate any of the information we collect (so that it does not identify you). We may use anonymised information for purposes that include testing our IT systems, research, data analysis, improving the platform, developing new products and features or displaying information about the purchases made via our platform such as the most popular purchases or purchases based on an approximate location.

3.3. We process your personal data (i) with your consent, (ii) when we need to do this to fulfil a contract with you (for example, the contract of sale), (iii) where we are required to do this by law (for example, where it is necessary to retain it in connection with potential litigation), and/or (iv) when it is in our legitimate interests to do this and when these interests are not overridden by your data protection rights. For example to deter fraud and carry out direct marketing.

4. INFORMATION WE SHARE WITH THIRD PARTIES

4.1 We may share your personal data with the following parties:

• (c) Service providers, partners and advisors: third parties who provide a service to us, partner with us on certain business activities, advise us or that we work within other business capacities. For example, we use a third party delivery service to deliver any products you buy to your postal address. We may also pass your personal data to our marketing and other business partners and other carefully selected third parties who may wish to offer you other goods or services that we or they have identified as likely to be of interest to you. These third parties will only be allowed to use your personal data in accordance with our instructions or your marketing preferences (where applicable) and will be required to keep your information secure.
• (e) Law enforcement, regulators and other parties for legal reasons: third parties who we are under a legal obligation to disclose your personal data to or who we need to disclose your personal data to protect our rights, property or safety or the rights, property or safety of others, detect and investigate illegal activities and breaches of any agreement we have with you.

4.2 We do not disclose personal data to anyone else except as set out above, where permitted by law and/or with your consent. We may provide third parties with aggregate statistical information and analytics about users of the platform but we will make sure that no one can be identified from this information before we disclose it.

5. MARKETING AND ADVERTISING

5.1 Email Marketing - From time to time we may contact you by email with information about our similar products and services which we think you may be interested in if you agree [at the point of registration / sale]. Thereafter, if you do not want us to send you email marketing, please use the contact details provided in section 11 below . You can also unsubscribe from our marketing emails by clicking on the unsubscribe link in the emails we send to you.

5.2 Email Notifications About Your Order or Changes to the Services We Provide - We may send you email notifications in relation to your order or changes to the way we provide our services to you.

6. STORING AND TRANSFERRING YOUR PERSONAL DATA

6.1 International Transfers of your Personal data: the personal data we collect may be transferred to and stored in countries outside of the jurisdiction you are in, including, in particular, outside the European Union. Some of these jurisdictions offer differing levels of protection in respect of personal data and may, in certain instances, be less protective than the jurisdiction you are resident in. We ensure that your personal data is treated securely and in accordance with this Privacy Policy.

6.2 We put in place European Commission approved standard contractual clauses or rely on alternative transfer mechanisms to protect this data. A copy of these clauses is available for your review upon request to us using the contact details provided in section 11 below.

7. YOUR RIGHTS IN RESPECT OF YOUR PERSONAL DATA

7.1 You may have various rights with respect to our use of your personal data:

• Marketing: As stated above in section 5, you may opt-out of receiving such emails from us by using the contact details provided in section 11 below, or by clicking on the unsubscribe link in the emails we send to you.
• Cookies: Please see our Cookies Policy for more information about your rights as regards our use of cookies.
• Access, rectify, port, block, complete, delete and update: You have the right to access, rectify, block, port, complete, delete and update your personal data, and to restrict its use. You also have the right to request further information about the processing of your personal data.
• Object: In certain circumstances, you also have the right to object to the processing of your personal data by us.

7.2 You can exercise the above rights by contacting us using the details provided in section 11 below at any time. All requests will be dealt with at the earliest opportunity and any delay will be kept to a minimum.

7.3 There are exceptions to these rights; for example, access may be refused if it would reveal personal data about another person or if we are prevented from disclosing such information by law.

7.4 We hope that we can satisfy queries you may have about the way we process your data. However, if you have unresolved concerns you also have the right to complain to the competent data protection authority.

7.5 When we ask you to supply us with your personal data we will make it clear whether the data we are asking for must be supplied so that we can provide the products and services to you, or whether the supply of any information we ask for is optional.

8. HOW LONG DO WE KEEP YOUR INFORMATION?

8.1 We will retain your information, whether or not your account is active, for as long as we believe it is necessary to fulfill our business purposes or to comply with applicable law, audit requirements, regulatory requests or orders from competent courts.

9. CHANGES TO THIS POLICY

9.1 We may update this Privacy Policy from time to time, and when we do so we will update the “last modified” date at the top of this Privacy Policy. Regularly reviewing this page ensures that you are always aware of what information we collect, how we use it and under what circumstances, if any, we will share it with other parties.

10. NOTICE TO YOU

10.1 If we need to provide you with information about something, whether for legal, or business related purposes, we will select what we believe is the best way to get in contact with you. We will usually do this through email or by placing a notice on the platform. The fact that we may send notices to you will not stop you from being able to opt out of certain types of contact as described in this Privacy Policy.

11. CONTACTING US

11.1 Questions, comments and requests regarding this Privacy Policy are welcome and should be addressed to buyer@anatomie.london or ANATOMIE Ltd Unit 26, 27 Blue Anchor Lane, London SE16 3UL

12. COOKIE POLICY

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