Formehri respects your privacy and is committed to protecting your personal data. This privacy notice will inform you how we look after your personal data when you visit our website (regardless of where you see it from) and tell you about your privacy rights and how the law protects you.
This privacy notice is in a layered format so you can click through to the specific areas below. Also use the Glossary at the back of the notice to understand the meaning of some of the terms used in this privacy notice.
- CRITICAL INFORMATION AND WHO WE ARE
PURPOSE OF THIS PRIVACY NOTICE
This privacy notice aims to provide information on how Formehri collects and processes your personal data through your use of our website, or when you purchase a product.
This website is not intended for children, and we do not knowingly collect data relating to children.
CONTROLLER
Formehri Ltd. is the controller and responsible for your personal data (referred to as Formehri, “we,” “us” or “our” in this privacy notice).
If you have queries about this privacy notice, including any requests to exercise your legal rights, don’t hesitate to contact us using the details below.
CONTACT DETAILS
You can contact us at:
Email: dataprivacy@formehri.com
You have the right to complain to the Commission Nationale de l’Informatique et des Libertés – CNIL, the French supervisory authority for data protection issues (http://www.cnil.fr/). However, we would appreciate the chance to deal with your concerns before you approach the CNIL, so don’t hesitate to contact us in the first instance.
CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
This version was last updated on April 20th, 2022, and historic versions can be obtained by contacting us.
The personal data we hold about you needs to be accurate and current. Please keep us informed if your personal data changes during your relationship with us.
THIRD-PARTY LINKS
This website may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share your data. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
- THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store, and transfer different kinds of personal data about you, which we have grouped as follows:
- Identity Data includes first name, last name, title, date of birth, and gender.
- Contact Data includes billing address, delivery address, email address, and telephone numbers.
- Financial Data includes bank account details, card number details, and PayPal details.
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us and from which of our stores.
- Technical Data includes internet protocol (IP) address, your login data, browser type, and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
- Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, clothing sizes, feedback, and survey responses.
- Usage Data includes information about how you use our website, products, and services.
- Marketing and Communications Data includes your preferences in receiving communications from us.
We also collect, use, and share Aggregated Data, such as statistical or demographic data, for any purpose. Aggregated Data may be derived from your data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, suppose we combine or connect Aggregated Data with your personal data so it can directly or indirectly identify you. In that case, we treat the combined data as personal data, which this privacy notice will use.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offenses.
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product you have with us, but we will notify you if this is the case at that time.
- HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Contact, and Financial Data by filling in forms or corresponding with us by post, phone, email, or otherwise. It includes personal data you provide when you:
- Buy or express an interest in our products or services in-store or on our website.
- Create an account on our website.
- Subscribe to our communications updates.
- Request that we send new product information to you.
- Enter or survey.
- Take part in a Formehri event.
- Submit a product review.
- Contact customer services.
We have automated technologies or interactions. As you interact with our website and the emails we send you, we may automatically collect Technical Data about your equipment, browsing actions, and patterns. We collect this personal data using cookies, server logs, and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
- HOW WE USE COOKIES
A cookie is a small file that asks permission to be placed on your computer’s hard drive. Once you agree, the file is added, and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes, and dislikes by gathering and remembering information about your preferences.
We use traffic log cookies to identify which pages are being used. It helps us analyse data about web page traffic and improve our website to tailor it to customer needs. We only use this information for statistical analysis, and the data is removed from the system.
Overall, cookies help us provide a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you other than the data you choose to share with us. You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. It may prevent you from taking full advantage of the website.
- HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- We must fulfill the contract we are about to enter or have entered with you.
- Where we have your consent.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights, do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
You have the right to withdraw consent to communications at any time by unsubscribing via the link provided with each email we send to you or by contacting us on dataprivacy@formehri.com
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
In a table format, we have described below all the ways we plan to use your personal data and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we use your data. Don’t hesitate to contact us if you need details about the specific legal ground we rely on to process your personal data where more than one ground has been set out in the table below.
PURPOSE/ACTIVITY
TYPE OF DATA
To register you as a new customer
(a) Identity
(b) Contact
To process and deliver your order, including managing payments and fees.
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications
To manage our relationship with you, which will include:
(a) Notifying you about changes to our terms or privacy notice
(b) Asking you to complete a survey
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications
To manage our relationship with you, which will include:
(a) Notifying you about changes to our terms or privacy notice
(b) Asking you to complete a survey
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications
To manage our relationship with you, which will include:
(a) Notifying you about changes to our terms or privacy notice
(b) Asking you to complete a survey
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting, and hosting of data)
(a) Identity
(b) Contact
(c) Technical
To deliver relevant website content to you.
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical
To manage our after-sales relationship with you, including:
(a) Assisting you with warranty issues
(b) Contacting you about a product recall
(a) Identity
(b) Contact
(c) Profile
(d) Transaction
To use data analytics to improve our website, products/services, communications, customer relationships, and experiences.
(a) Technical
(b) Usage
To make suggestions and recommendations about goods or services that may interest you.
(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
MARKETING
We strive to provide you with choices regarding specific personal data uses, particularly around new product communications. Our policy regarding ongoing communications about the Formehri brand or further product information is strictly on an opt-in basis.
OPTING OUT
You can ask us to stop sending you Formehri brand or new product communications messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your preferences by following the opt-out links on any communications message sent to you, or by contacting us directly.
Opting out of these messages will not prevent you non-marketing messages from us, for example relating to products ordered, responses to customer service queries, etc.
CHANGE OF PURPOSE
We will only use your data for the purposes we collected it unless we reasonably consider that we need to use it for another reason. That reason is compatible with the original purpose. If you wish to explain how the new purpose’s processing is consistent with the original purpose, please get in touch with us.
If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis which allows or requires us to do so.
Please note that we may process your personal data without your knowledge or consent in compliance with the above rules where this is required or permitted by law.
- DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties below for the purposes set out in the table above.
External Third Parties as set out in the Glossary.
Third parties to whom we may choose to sell, transfer, or merge parts of our business or assets. Alternatively, we may seek to acquire other companies or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and treat it according to the law. We do not allow our third-party service providers to use your personal data for their purposes and only permit them to process your personal data for specified purposes and by our instructions.
- INTERNATIONAL TRANSFERS
Some of our external third parties are based outside the European Economic Area (EEA), so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
We will only transfer your personal data to countries deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en
Where we use certain service providers, we may use specific contracts approved by the European Commission, which give personal data the same protection it has in Europe. For further details, see https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en
Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield, which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/eu-us-privacy-shield_en
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
- DATA SECURITY
We have established appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed unauthorizedly, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions and are subject to a duty of confidentiality.
We have established procedures to deal with any suspected personal data breach. We will notify you and any applicable regulator of a breach where we are legally required to do so.
- DATA RETENTION
FOR HOW LONG WILL YOU USE MY PERSONAL DATA?
We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including to satisfy any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data, and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law, we must keep basic information about our customers (including Contact, Identity, Financial, and Transaction Data) for six years after they cease being customers for tax purposes. We also keep this basic information about our customers for a maximum of seven years following your most recent purchase from us to deal efficiently with any after-sales queries that you may have. We keep customer profile information that you have indicated you are happy for us to have to keep you up to date regarding our products, services, and events and will keep this information until you indicate you no longer wish us to keep this data, or for seven years following your most recent active interaction with us (e.g., opening or clicking on an email we send you), whichever of these two is shorter.
In some circumstances, you can ask us to delete your data: see [Request erasure] below for further information.
In some circumstances, we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes. We may use this information indefinitely without further notice to you.
- YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws concerning your personal data:
- Request access to your personal data.
- Request correction of your personal data.
- Request the erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Right to opt-out of automated profiling of your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
To learn more about these rights, please see the “Your Legal Rights” section in paragraph 11 below.
If you wish to exercise any of the rights set out above, please get in touch with us at dataprivacy@formehri.com.
NO FEE IS USUALLY REQUIRED
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
WHAT WE MAY NEED FROM YOU
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). It is a security measure to ensure that personal data is not disclosed to anyone with no right to receive it. We may also contact you to ask you for further information about your request to speed up our response.
TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within ten business days. Occasionally it may take us longer than this if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.
- GLOSSARY
LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you regarding specific activities by contacting us.
Performance of Contract means processing your data where it is necessary to fulfill a contract to which you are a party or to take steps at your request before entering into such a contract.
Complying with a legal or regulatory obligation means processing your personal data where it is necessary to comply with a legal or regulatory obligation that we are subject to.
Consent means you have explicitly permitted us to process your personal data. In such circumstances, we will have asked you a specific question, and you will have entered information or ticked a tick box to indicate your consent.
EXTERNAL THIRD PARTIES
Service providers are acting as processors based in the EU who provide IT and system administration services.
Professional advisers acting as processors or joint controllers, including lawyers, bankers, auditors, and insurers based in the EU, provide consultancy, banking, legal, insurance, and accounting services.
EU Customs, regulators, and other authorities acting as processors or joint controllers based in the EU require reporting of processing activities in certain circumstances.
Customer service call, email, web chat, and website behavioural service providers, acting as processors, based in the UK, EU, or USA.
YOUR LEGAL RIGHTS
You have the right to:
- Request access to your personal data (commonly known as a “data subject access request”). It enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. It enables you to have any incomplete or inaccurate data we hold about you corrected. However, we may need to verify the accuracy of the new data you provide.
- Request the erasure of your personal data. It enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully, or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons, which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party), and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts your fundamental rights and freedoms. You also have the right to object to where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which overrides your rights and freedoms.
- Request restriction of processing of your personal data. It enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful, but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it. In such circumstances, we may reserve the right to delete your personal data rather than hold it but restrict processing where our processes are not set up to enable a restriction.
- Request the transfer of your personal data to you or to a third party. We will provide you, or a third party you have chosen, with your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information you initially provided with your consent for us to use or where we used the information to carry out a contract with you.
- Request to opt out of automated profiling of your personal data. You have the legal right to of any automated profiling of your personal data that could have a legal consequence for you and have a human involved in the processing decision rather than it being automated. The only profiling of this type that we undertake is in our marketing activities, in which we tailor our marketing communications to your transactional history and product preferences. Don’t hesitate to get in touch with us if you wish to opt out of this automated profiling. However, please be aware that our systems are not configured to send un-tailored marketing communications to you, so in practice opting out of automated profiling will result in you being opted out of receiving marketing communications from us.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any process before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case you withdraw your consent.