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PRIVACY AND COOKIE POLICY
(last updated April 2018)

This privacy policy (“Policy”) describes the personal data collected or generated (“processed”) when you use Amandawakeley.com (the “Site”).

This Policy describes the types of personal data collected and how your personal data is used, shared and protected. It also explains the choices you have relating to your personal data and how you can contact us.

It is important that you read this Policy together with any other privacy notice or fair processing notice that we may provide at or around the time that we collect or process personal data about you so that you are fully aware of how and why we are using that data. This

Policy supplements the other notices and is not intended to override or replace them.

Please note that the Site is not intended for children (those aged 13 and under) and we do not knowingly collect data relating to children.

For ease of reading, we have divided this Policy into several sections:

1. WHO is Responsible for the Processing of Your Personal Data?
2. CONTACT Details
3. WHAT Personal Data We Collect and WHEN
4. WHY and HOW We Use (Process) Your Personal Data
5. SHARING of Your Personal Data
6. PROTECTION and MANAGEMENT of your Personal Data
7. YOUR RIGHTS related to your personal data
8. COOKIES and Pixel Tags
9. CHANGES to our Privacy Policy

1. WHO is Responsible for the Processing of Your Personal Data?

Your personal data is processed by Amandawakeley.com and the controller responsible for your personal data is AW Retail Limited.

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this Policy, or if you think it has not been followed, please contact the data privacy manager using the details set out below.

2. CONTACT Details

The Data Privacy Manager
AW Retail Limited
3 Logan Place
London
W8 6QN

Alternatively, you can contact us at privacy@amandawakeley.com

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

3. WHAT Personal Data We Collect and WHEN

What is personal data?

Where this Policy refers to ‘personal data’ it is referring to data about you (or other living people) from which you could be identified – such as your name, your date of birth, your contact details and even your IP address.

By law all organisations in the UK are obliged to process your personal data in certain ways and to ensure that you are given an appropriate amount of information about how they use it. You also have various rights to seek information from those organisations about how they are using your data, and to prevent them from processing it unlawfully. For more information about these rights, please see the ‘Your Rights’ section of this Policy.

Data we collect from you when you use the Site

We collect and ask you for certain personal data to provide you with the services offered on the Site. For example, when you make purchases, contact our customer service team, request to receive communications, create an account, participate in our events or contests, or interact with the Site.

This personal data includes your:
• Contact details including name, email, telephone number and shipping and billing address
• Login and account information, including account holder name, password and unique user ID
• Personal details including gender, hometown, date of birth and purchase history
• Payment or credit card information
• Data on physical characteristics, including weight, height, and body measurements (such as dress size)
• Personal preferences including your wish list as well as marketing and cookie preferences

We use additional personal data in order to enable particular features on the Site. For example, we may request access to your phone’s geo-location data in order to direct you to a local boutique.

When interacting with the Site data is automatically collected and shared with Amandawakeley.com by the technology platforms providing the experience. This data includes:

• Device IDs, call state, network access, storage information and battery information
• Cookies, IP addresses, referrer headers, data identifying your web browser and version, and web beacons and tags

For more information on Cookies please see the see the section of this Policy which deals with the same.

Updating your information

If you want to update the information you have previously given to us, you can contact AW Retail Limited’s Data Privacy Manager at any time by writing to us using contact details set out here.

4. WHY and HOW We Use (Process) Your Personal Data

We use the personal data we collect from you in the following ways:

To Provide the Features of the Site, Apps, and Services You Request

When you use the Site we will use your data to provide the product you have selected. For example, if you make a purchase on Amandwakeley.com, or participate in an event or promotion, we will use the contact information you give us to communicate with you about the purchase, event or promotion. If you reach out to our customer service team, we will use information about you, such as delivery or payment information, or the product you have purchased to help you resolve a problem or question. To Communicate Information about our Products, Services, Events and for Other Promotional Purposes

For the avoidance of doubt, we will not contact you for promotional purposes, such as notifying you of new services unless you specifically agree to be contacted for such purposes at the time you submit your information on the site, or at a later time if you sign up specifically to receive such promotional information.

To modify your email subscriptions or to opt-out of receiving Amanda Wakeley communication, please contact us at privacy@amandawakeley.com. Should you ever ask us to stop sending those kinds of communications we will hold your details on file to ensure that we respect that request – we justify that retention on the basis that we have a legitimate interest in holding your data in that way.

If you are an existing customer of Amanda Wakeley (for example, if you have placed an order with us), we may use the email address provided to send you marketing communications about similar products or services, unless you have opted-out. We may use the information that you provide online as well as information from purchases made in store.

To Operate, Improve and Maintain our Business

We may use the data you provide to us to operate our business. For example, when you make a purchase, we may use that information for accounting, auditing and other internal functions.

To enhance your user experience and For Research and Analysis Purposes

We use data about how our visitors use the Site to understand customer behaviour or preferences and to enhance the user experience of the Site. For example, we may use information about how visitors to Amandawakeley.com search for and find products, in order to understand the best ways to organise and present product offerings in our online store.

Why is AW Retail Limited allowed to use your information in this way?

AW Retail Limited will only use your personal data in the following circumstances:
• Where you have asked us to do so, or consented to us doing so.
• Where we need to do so in order to perform a contract we have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

5. SHARING of Your Personal Data

Depending on how and why you provide us with your personal data we may share it in the following ways:
• We may disclose your data to our agents or third party service providers to undertake processing operations on our behalf (see ‘third party suppliers’ detailed below).
• We may disclose personal data if required to do so by law or if we believe that such action is necessary to protect and defend the rights, property or personal safety of the Site or its visitors.

Service Providers

We may share your personal data with third party service providers who provide us with a variety of administrative, statistical, and technical services. For example to process credit cards and payments, shipping and deliveries, manage and service our data, distribute emails, research and analysis, manage brand and product promotions as well as administering certain services and features.

We will only provide service providers with the minimum amount of personal data they need to fulfil the services we request, and we stipulate that they protect this information and do not use it for any other purpose. We take these relationships seriously and oblige all of our data processors to sign contracts with us that clearly set out their commitment to respecting individual rights, and their commitments to assisting us to help you exercise your rights as a data subject.

Please note that some of our service providers may be based outside of the European Economic Area (the “EEA”). Where we transfer your data to a service provider that is outside of the EEA we seek to ensure that appropriate safeguards are in place to make sure that your personal data is held securely and that your rights as a data subject are upheld.

Our current third party suppliers are:

For Payments and Loyalty:

• Adyen (https://www.adyen.com/)
• Givex (http://web.givex.com/)

For Shipments, delivery and collections:

• A J Worldwide Services (ajww.co.uk)
• DHL International (http://www.dhl.co.uk)
• DPD Group (http://www.dpd.co.uk/)
• Dropit Shopping (https://www.dropit.shop/)
• Harper Concierge (harperconcierge.com)
• SCS Worldwide (http://scsworldwide.co.uk/)
• TNT Express (https://www.tnt.com)

For Warehousing and Logistics:

• Exclusive Logistics Limited, Unit B Dewar House, Central Road, Harlow CM20 2ST

• Freight Brokers Limited (http://freightbrokersuk.com/)

Digitial Partners:

• Diligent Commerce (www.diligentcommerce.com)
• Dotmailer Limited (https://www.dotmailer.com)
• Hero Towers Limited (https://www.usehero.com/)

Links to third party websites

Please note that where we provide links to third party websites, plug-ins and applications that are not affiliated with AW Retail Limited such websites are out of our control and are not covered by this Policy. If you access third party websites using the links provided, the operators of these websites may collect information from you that could be used by them, in accordance with their own privacy policies. Please check these policies before you submit any personal data to these websites.

6. PROTECTION and MANAGEMENT of your Personal Data

• Encryption & Security: AW Retail Limited takes the protection of your information very seriously. We use a variety of technical and organisational security measures, including encryption and authentication tools, to maintain the safety of your personal data and to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Your personal data is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to these systems.

AW Retail Limited may store your personal data on secure servers either on our premises or in secure third party data centres. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

• Retention of your data: Except if required otherwise by law, we retain your personal data for as long as necessary to fulfil the purposes for which we collect it and where we have a legitimate interest in doing so, such as:
• To enable us to respond effectively to grievances that may arise after you cease to engage with us; or
• Where you sign up to receive e-mail marketing from us we will retain your e-mail address after you ‘opt-out’ of receiving e-mails in order to ensure that we continue to honour and respect that request.

In some circumstances you can ask us to delete your data: see ‘Your Rights’ below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

7. YOUR RIGHTS related to your personal data

As a data subject you have a number of rights in relation to your personal data. Below, we have described the various rights that you have, as well as how you can exercise them.

Right of Access

You may, at any time, request access to the personal data that we hold which relates to you (you may have heard of this right being described as a "subject access request").

Please note that this right entitles you to receive a copy of the personal data that we hold about you in order to enable you to check that it is correct and to ensure that we are processing that personal data lawfully. It is not a right that allows you to request personal data about other people, or a right to request specific documents from us that do not relate to your personal data.

You can exercise this right at any time by writing to us using contact details set out here and telling us that you are making a subject access request. You do not have to fill in a specific form to make this kind of request.

Your Right to Rectification and Erasure

You may, at any time, request that we correct personal data that we hold about you which you believe is incorrect or inaccurate. You may also ask us to erase personal data if you do not believe that we need to continue retaining it (you may have heard of this right described as the “right to be forgotten”).

Please note that we may ask you to verify any new data that you provide to us and may take our own steps to check that the new data you have supplied us with is right. Furthermore, we are not always obliged to erase personal data when asked to do so; if for any reason we believe that we have a good legal reason to continue processing personal data that you ask us to erase we will tell you what that reason is at the time we respond to your request.

You can exercise this right at any time by writing to us using the contact details set out here and telling us that you are making a request to have your personal data rectified or erased and on what basis you are making that request. If you want us to replace inaccurate data with new data, you should tell us what that new data is. You do not have to fill in a specific form to make this kind of request.

Your Right to Restrict Processing

Where we process your personal data on the basis of a legitimate interest (see the section of this Policy which explains why we use your personal) you are entitled to ask us to stop processing it in that way if you feel that our continuing to do so impacts on your fundamental rights and freedoms or if you feel that those legitimate interests are not valid.

You may also ask us to stop processing your personal data (a) if you dispute the accuracy of that personal data and want us verify that data's accuracy; (b) where it has been established that our use of the data is unlawful but you do not want us to erase it; (c) where we no longer need to process your personal data (and would otherwise dispose of it) but you wish for us to continue storing it in order to enable you to establish, exercise or defend legal claims.

Please note that if for any reason we believe that we have a good legal reason to continue processing personal data that you ask us to stop processing, we will tell you what that reason is, either at the time we first respond to your request or after we have had the opportunity to consider and investigate it.

You can exercise this right at any time by writing to us using the contact details set out here and telling us that you are making a request to have us stop processing the relevant aspect of your personal data and describing which of the above conditions you believe is relevant to that request. You do not have to fill in a specific form to make this kind of request.

Your Right to Portability

Where you wish to transfer certain personal data that we hold about you, which is processed by automated means, to a third party you may write to us and ask us to provide it to you in a commonly used machine-readable format.
Because of the kind of work that we do and the systems that we use, we do not envisage this right being particularly relevant to the majority of individuals with whom we interact. However, if you wish to transfer your data from us to a third party we are happy to consider such requests.

Your Right to stop receiving communications

For details on your rights to ask us to stop sending you various kinds of communications, please contact us.

Your Right to object to automated decision making and profiling

You have the right to be informed about the existence of any automated decision making and profiling of your personal data, and where appropriate, be provided with meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing that affects you.

Exercising your rights

When you write to us making a request to exercise your rights we are entitled to ask you to prove that you are who you say you are. We may ask you to provide copies of relevant ID documents to help us to verify your identity.
It will help us to process your request if you clearly state which right you wish to exercise and, where relevant, why it is that you are exercising it. The clearer and more specific you can be the faster and more efficiently we can deal with your request. If you do not provide us with sufficient information then we may delay actioning your request until you have provided us with additional information (and where this is the case we will tell you).

8. COOKIES and Pixel Tags

What is a Cookie?

A cookie is a small amount of data, which often includes an anonymous unique identifier that is sent to your browser from a website’s computer and stored on your computer’s hard drive. Each website can send its own cookie to your browser if your browser’s preferences allow it, but (to protect your privacy) your browser only permits a website to access the cookies it has already sent to you, not the cookies sent to you by other websites.

Many websites do this whenever a user visits their website in order to track online traffic flows.

Cookies record information about your online preferences. Users have the opportunity to set their computers to accept all cookies, to notify them when a cookie is issued, or not to receive cookies at any time. The last of these, of course, means that certain personalised services cannot then be provided to that user and accordingly you may not be able to take full advantage of all the Site’s features. Each browser is different, so check the “Help” menu of your browser to learn how to change your cookie preferences.
If you have set your computer to reject cookies you can still browse the Site anonymously until such time as you wish to register for the services we provide. For further information on cookies please visit http://www.aboutcookies.org.
What is a Pixel Tag?

A pixel tag is another method of collecting information akin to a cookie but are contained graphically on a website. Like cookies they collect information about your online preferences. They can also work alongside cookies specifically to read and trigger them.

You can set your computer to reject pixel tags and if you do so you can still browse the Site anonymously until such time as you wish to register for the services we provide.

How to find and control your cookies and pixel tags

Some websites use technology which includes cookies and pixel tags. You may adjust your device’s web browser settings to refuse these however, please note that because these, cookies especially, are widely used, disabling the use of them in your web browser may interfere with full use of various websites.

Please note, that if you use multiple browsers you will need to opt out of receiving cookies and pixel tags on each device and for each browser. Also, if you change devices or delete cookies from your device you will need to repeat this opt-out process.
AW Retail Limited’s cookies and pixel tags

AmandaWakeley.com receives and records information, which may include personal data, from your browser when you use the Site. We use a variety of methods, such as cookies and pixel tags to collect this information, which may include your
(i) IP-address;
(ii) unique cookie identifier, cookie information and information on whether your device has software to access certain features;
(iii) unique device identifier and device type;
(iv) domain, browser type and language,
(v) operating system and system settings;
(vi) country and time zone;
(vii) previously visited websites;
(viii) information about your interaction with the Site such as click behaviour, purchases and indicated preferences; and
(ix) access times and referring URLs.

Third parties may also collect information via the Site through cookies, third party plug-ins and widgets. These third parties collect data directly from your web browser and the processing of this data is subject to their own privacy policies.

We use cookies and pixel tags to track our customers’ usage of the Site and to understand our customers’ preferences (such as country and language choices). This enables us to provide services to our customers and improve their online experience. We also use cookies and pixel tags to obtain aggregate data about site traffic and site interaction, to identify trends and obtain statistics so that we can improve the Site. There are generally three categories of cookies used on the Site:

Functional: These cookies are required for basic site functionality and are therefore always enabled. These include cookies that allow you to be remembered as you explore the Site within a single session or, if you request, from session to session. They help make the shopping cart and checkout process possible as well as assist in security issues and conforming to regulations.
Performance: These cookies allow us to improve the Site’s functionality by tracking usage. In some cases, these cookies improve the speed with which we can process your request and allow us to remember Site preferences you have selected. Refusing these cookies may result in poorly tailored recommendations and slow the Site’s performance.
Social media and Advertising: Social media cookies offer the possibility to connect you to your social networks and share content from the Site through social media. Advertising cookies (of third parties) collect information to help better tailor advertising to your interests, both within and beyond the Site. In some cases, these cookies involve the processing of your personal data. Refusing these cookies may result in seeing advertising that is not as relevant to you or you not being able to link effectively with Facebook, Twitter, or other social networks and/or not allowing you to share content on social media.

The Site also uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”) (https://policies.google.com/privacy). Google Analytics uses cookies, which are text files placed on your computer, to help us analyse how users use the Site. The information generated by the cookie about your use of the Site (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the Site, compiling reports on website activity for AW Retail Limited and providing other services relating to website activity. Google may also transfer this information to third parties when required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google and no personally identifiable information will be stored. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of the Site. By using the Site, you consent to the processing of anonymous data about you by Google in the manner and for the purposes set out above.

As a business we use a number of Google services which enable us to understand you better which in turn means we deliver a more appropriate and relevant service to you. We may from time to time use remarketing tools within Google Analytics and implement the Google Display Network to advertise online which means third-party vendors, including Google, may show our adverts across the Internet. We, and third-party vendors, including Google use first-party cookies (such as Google Analytics cookies) and third-party cookies (such as DoubleClick cookie) together to report how your ad impression and other uses and interactions relate to visits on the Site. We also utilise the Google Analytics Demographic and Interest reporting tool from which we may gather information such as age, gender and interests that are already held by Google to understand who is visiting the Site and the best way to serve you relevant content. No personally identifiable information will be collected and all demographic information is anonymous.
You can always change your preferences by visiting the "Cookie Settings" at the bottom of each page of the Site.

9. CHANGES to our Privacy Policy
Applicable law and our practices change over time. If we decide to update this Policy, we will post the changes on the Site and Apps. If we materially change the way in which we process personal data, we will provide you with prior notice, or where legally required, request your consent prior to implementing such changes. We strongly encourage you to read this Policy and keep yourself informed of our practices.

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