Harpenne Privacy Notice
Dated: 1 September 2019
1. Harpenne as a data controller of Your personal data
Harpenne (‘We’, ‘Us’, ‘Our’) is a fashion and accessories brand operated by Adventures in Retail Limited registered in England and Wales with company number 10926262 and head office located in Chelsea House, Westgate, London, W5 1DR.
We are the data controller of the information submitted by You when You visit Our website, shop with Us, subscribe to receive news and updates about Us and any other information exchanged in any communications with Us.
As a data controller, we are registered with the Information Commissioner’s Office. Our registration number is ZA527335.
If you have any questions regarding how Harpenne use Your personal data, You can contact Our data protection officer by email on firstname.lastname@example.org
2. What categories of personal data do We collect about You
We may collect the following personal data about You:
- Contact details, including Your title, gender, name and surname, email address, phone number;
- Date of Birth;
- Order details, including clothing and shoes size;
- Billing address and delivery address;
- Product and style preferences,
- IP address;
- Communications and interactions with Us whether online (on Our website and social media channels), on the phone or emails;
- Social media posts and other content that You make publicly available online;
- Information You provide in Your reviews of Us, including survey responses;
- Information from cookies, including information on the devices You may use to visit Our website - please see our separate Cookies Policy.
Harpenne never access, process or store Your payment details. When You submit Your payment details to complete Your order or save Your debit or credit card details for future purchases (this option is only available when You create an account with Us), these information will be collected and safeguarded by Shopify, the company that supports Our website. Shopify privacy notice is accessible here.
3. How do We collect personal data about You
We collect personal data about You in the following circumstances:
- When You visit Our website;
- When You create an account on Our website;
- When You buy products from Us;
- When You contact Us, via phone, email or instant messaging services;
- When You subscribe to receive communications from Us;
- When You allow social media sites to provide Your data to Us;
- When you enter any competitions run by Us;
- When completing any of Our surveys or leaving Us a review;
- When You have given permission to a third party to share with Us the information that they hold about You.
4. How do we use Your personal data and what is the legal basis for processing Your data
We have listed below the ways in which We use Your personal data and the associated legal basis we rely on for the processing:
- To manage Your order, deliver the products to You, process a return and issue a refund. In these circumstances, We will process Your personal data in performance of Our contract with You;
- To respond to your queries, claims and complaints regarding Your order or Your shopping experience with Us.
In these circumstances, We will process Your personal data in performance of Our contract with You.
- For statistical, analytical or survey purposes and to personalise Your shopping experience on Our website.
In these circumstances, We have a legitimate interest to improve Our services and products that We provide;
- Where You shop with Us and have not opted out from receiving news about Us.
In these circumstances, We have a legitimate interest to send You information about similar products or services;
- Where You have given Us specific consent, We use Your data to send you information about Harpenne and Our products that We think You might like and to notify You of products or special offers that may be of interest to You.
In these circumstances, We ask for Your consent to process Your data for this purpose and You may revoke Your consent at any point.
- To process Your application when You enter a competition promotion or prize draw.
In these circumstances, We will process Your personal data in performance of Our contract with You.
We only keep Your personal data for as long as is necessary for the purpose for which it was collected (subject to any legal requirements). Once it is no longer necessary, We will either delete the data, or anonymise it.
5. Who do We share Your personal data with
We may share Your personal data with third parties We work with, including in the following circumstances:
- to process Your order and deliver Our products to You, for example with Our warehouse and logistic providers;
- to send You information about Our products, offers and updates that We think might be relevant to You;
- to personalise Your shopping experience on Our website.
When personal data are shared with business partners based outside of the European Economic Area, We will only do so in compliance with applicable law and on the basis of appropriate and suitable safeguards.
6. How we protect Your personal data
We use our best efforts to ensure that whenever You interact and shop with Us Your experience with Harpenne is safe. We protect the security and confidentiality of Your personal data and employ internal processes and security technologies to verify that the suppliers and business partners We work with have adequate measures and controls in place.
You should keep secret the password chosen by You when You create an account with Us. You are responsible for restricting access to Your device and/or email address to prevent unauthorised access to Your account.
7. Your data protection rights
Data protection laws give You the following rights which You may exercise during Your relationship with Us as controller of Your personal data.
Right to be informed
We will update this Privacy Notice as needed and bring such changes to Your attention.
Right of access
You have the right to request a copy of the personal data that We hold about You by emailing email@example.com.
Please include the following information with Your request so that We are able to identify You:
- Full name;
- Full address;
- Email address.
We will process Your request within 30 days from the date that we have identified You. In the event that We refuse to fulfil Your request (for example if it is unreasonable), We will give a full explanation as to why.
Right to rectification
You have the right to correct any information We collect about You which might be incorrect, incomplete, or out of date. You can do this yourself by logging into your account, or by contacting our Customer Services Team who will give you step-by-step advice on how to do this. You can contact them by emailing: firstname.lastname@example.org.
Right to erasure
You have the right to obtain from Us the erasure of Your personal data when the processing is based on Your consent and such consent is withdrawn. To exercise Your ‘right to be forgotten’, please contact Us at email@example.com and We will comply with Your request within 30 days from the date that we have identified You. Please note that Your right to erasure does not apply to data related to any of your transactions as we have a legal obligation to keep the same.
Right to restrict processing
You have the right to request Us that we restrict the processing of Your personal data where You have a particular reason for wanting the restriction, such as when You believe that the data is not accurate.
Right to data portability
You have the right to receive a copy of the personal data that We hold about You and/or have such personal data transmitted from Us to another data controller if this is technically doable.
Right to object
Where We are processing Your personal data on the basis of Our legitimate interest, You have the right to object to the processing. We must then do so unless We believe We have a legitimate overriding reason to continue processing Your personal data.
If You want Us to stop sending You marketing material, You can do this in the following ways:
- click the ‘unsubscribe' link in any email communication that We send You;
- contact Our Customer Services Team by emailing:
- If You have an account with Us, log in into your account, visit the ‘My Account' area and change Your preferences;
You can disable targeted online adverts by adjusting Your browser’s or mobile phone settings.
Please note that You may continue to receive communications for a short period after changing Your preferences whilst our systems are fully updated.
Rights related to profiling
We may process Your personal data by profiling and segmenting in order to ensure that the communications and adverts that We send You are tailored to Your online preferences, shopping habits, interests and online activity. As a result, We may exclude You from communications which We feel are irrelevant to You.
If You want Us to stop profiling You, please contact Us at firstname.lastname@example.org.
Finally, if You are unhappy with the manner in which We handle Your personal data, You can contact Us at email@example.com.
If You are unsatisfied with Our response and believe that We are not adequately hanling Your personal data, You are entitled to make a complaint to Your data protection regulator.
If You are based in the United Kingdom, You can contact the Information Commissioner’s Office by calling 0303 123 1113, or online at www.ico.org.uk/concerns (this links through to a third party website over which We have no control).
User Generated Content Policy
By tagging your social media posts and/or social media images (including their captions) with #teamharpenne (the “ Harpenne Hashtags”), or with the following handles @harpenne (the “ Harpenne Handles ”), you agree to the following Harpenne policy.
All posts and content tagged with the Harpenne Hashtags and/or the Harpenne Handles, including without limitation, your name, biographical information and all other names, usernames, pseudonyms, text, likenesses, graphics, logos, marks, images, photographs, code, videos, clips, GIFs, moving images and all other information and material shall be referred to in this policy as " UGC”.
- You grant us a royalty free, perpetual, irrevocable - unless you tell us otherwise - transferable, worldwide licence (including the right to sub-licence) to use, publish, edit and remove UGC in our sole discretion and on any media, for any purpose, including to advertise our products;
- You hereby warrant and represent that:
i) you own all rights in UGC;
ii) you have obtained permission from any person(s) identifiable in UGC to grant the rights specified in this policy, or where those person(s) are aged 18 years or under, you either:
- are the parent or legal guardian or such identified person(s), or
- have obtained the express consent from a parent or legal guardian of such identified person(s) to their appearance in UGC and to you submitting UGC to the Harpenne Handles/Harpenne Hashtags.
iii) your use and our use of UGC will not infringe the rights of any third party or breach any applicable law or regulation.
- You hereby unconditionally and irrevocably waive (or procure the same from any third party where applicable) any and all moral rights and any other similar rights in connection with our usage of UGC.
- You agree that the personal data that we collect from UGC will be treated in accordance with our Privacy Notice and the terms of this policy.
- You shall indemnify and hold us harmless and any person acting our behalf from any and all claims, demands, costs, liabilities, damages and expenses (including reasonable legal fees) which we may incur in connection with the use of UGC.
- We reserve the right to amend this policy at any time, so please check back here when you tag or upload UGC.