BRYDON BROTHERS PRIVACY POLICY



Effective date: May 25th, 2018

1. INTRODUCTION

Brydon Brothers Limited a company registered in England under number 09282241 whose registered office address is located at Northside House, Cockfosters Parade, Barnet, England, EN4 9EB (“Brydon Brothers”, “us”, “we”, or “our”) operates the brydonbrothers.com website (the “Site”) and provides customers with an online retail experience (“Services”).

This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Site and Services and the choices you have associated with that data.

We use your data to provide and improve the Site and our Services. By using the site, you agree to the collection and use of information from our Site in accordance with this policy.

If you have any questions about this Privacy Policy, including any requests to exercise your legal rights please contact us using the details set out below: Email address: hello@brydonbrothers.com

Postal address: Brydon Brothers Ltd, 29-31 Oxford St, London, W1D 2DR, UK 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.

In this Privacy Policy we use the term “Personal Data” to mean data which identifies you (or which can be used to identify you when combined with other information in our possession or likely to come into our possession).

2. TYPES OF DATA COLLECTED BY US

Direct Interactions With You

You may give us your identity and contact details (such as your first name and last name, email address, phone number and address) when you fill in forms, or by corresponding with us by post, phone, email or otherwise. This may include, but is not limited to data you provide when you:

• Subscribe to our publications;

• Request marketing to be sent to you;

• Enter a competition, promotion or survey; or

• Give us some feedback.

We will also collect data from you regarding your preferences in receiving marketing from us and your communication preferences.

Data Collected automatically

We use cookies and similar tracking technologies to automatically collect certain technical information regarding how you access and use the Site (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Site that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data. For more detail about how we use cookies see the section 3 below “Tracking & Cookies Data”.

3. TRACKING & COOKIES DATA

We use cookies and similar tracking technologies to track the activity on our Site and hold certain information.

Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our site.

Examples of cookies we use:

• Session Cookies. We use Session Cookies to operate our Site. These cookies are essential to enable you to move around the Site and use its features.

• Preference Cookies. We use Preference Cookies to remember your preferences and various settings on our Site.

• Security Cookies. We use Security Cookies for security purposes.

• Analytics Cookies. These cookies collect information about how people are using our Site. For example, the pages visited most often, how people are moving from one link to another, and if they get error messages from certain pages. We use these cookies to improve our Site.

• Targeting or Advertising Cookies. These cookies are used to deliver advertisements that are more relevant to you and your interests. They remember that you have visited a website and the pages you visited.

Whilst the exact names of cookies utilised on this Site may fluctuate over time we have set out below some specific examples of the cookies and similar tracking technologies currently used on our Site. Please note that we have no control over the third party cookies used on our Site.

ANALYTICS COOKIES

Google Analytics

Google Analytics is a web analytics service offered by Google that uses Analytics Cookies to track and report website traffic. Google uses the data collected to track and monitor the use of our Site. This data is shared with other Google services. Google may use the collected data to contextualise and personalise the ads of its own advertising network.

You can opt-out of having your activity on the Site made available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity.

For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: http://www.google.com/intl/en/policies/privacy/

TARGETING OR ADVERTISING COOKIES

Google AdWords

Google AdWords uses Targeting or Advertising Cookies to serve adverts to you on third party websites after you have visited our Site. This remarketing service is provided by Google Inc.

You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads

Google also recommends installing the Google Analytics Opt-out Browser Add-on – https://tools.google.com/dlpage/gaoptout – for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.

For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: http://www.google.com/intl/en/policies/privacy/

Facebook

Facebook uses Targeting or Advertising Cookies to serve adverts to you on third party websites after you have visited our Site. This remarketing service is provided by Facebook Inc. You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/164968693837950. To opt-out from Facebook’s interest-based ads follow these instructions from Facebook: https://www.facebook.com/help/568137493302217. Facebook adheres to the Self-Regulatory Principles for Online Behavioral Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings. For more information on the privacy practices of Facebook, please visit Facebook’s Data Policy: https://www.facebook.com/privacy/explanation

4. HOW WE USE YOUR 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:

• Where we need to perform a contract with you;

• Where we need to comply with a legal or regulatory obligation;

• Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests; and/or with your explicit consent.

Brydon Brothers uses your data for various purposes:

• To provide and maintain our Site;

• To provide our Site and Services to you and to notify you about changes to our Site and Services;

• To provide customer support;

• To gather analysis or valuable information so that we can improve our Site and Services;

• To monitor the usage of our Site;

• To detect, prevent and address technical issues;

• To provide you with news, special offers and general information about our Services unless you have opted not to receive such information; and to deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

5. RETENTION OF DATA

Brydon Brothers will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. You may opt-out at any time from receiving marketing communications from us in accordance with section 9 below “Your Rights”. We will also retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

Brydon Brothers will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.

To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk from harm form unauthorised 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. You can request details of our retention periods for different aspects of your Personal Data by contacting us.

6. INTERNATIONAL TRANSFER OF DATA

We may use third party service providers located outside the European Economic Area (“EEA”). As such your information, including Personal Data, may be transferred to — and maintained on — computers located outside of the EEA. Brydon Brothers will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy. No transfer of your Personal Data will take place to an organisation or a country unless there are adequate controls in place including the security of your Personal Data in compliance with applicable data protection laws.

7. DISCLOSURE OF YOUR DATA

Service Providers

We may disclose your Personal Data to third party companies and individuals we engage to:

• fulfil all orders purchased through the website

• facilitate our Services;

• provide certain functions on our behalf in connection with the operation of our business such as IT and system administration services;

• perform Site-related services;

• assist us in analysing how our Site is used; and

• advertise products to you on third party websites which are tailored to meet your preferences and likely interests.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Professional Advisers

We may disclose your Personal Data to our professional advisers including lawyers, bankers, auditors and who provide consultancy, banking, legal, insurance and accounting services.

Legal Requirements

Under certain circumstances, Brydon Brothers may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency). Brydon Brothers may also disclose your Personal Data in the good faith belief that such action is necessary to:

• To comply with a legal obligation;

• To protect and defend the rights or property of Brydon Brothers;

• To prevent or investigate possible wrongdoing in connection with the Service;

• To protect the personal safety of users of the Service or the public; or

• To protect against legal liability.

Business Re-Organisations

We may need to disclose your Personal Data to third parties who we choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses 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 Policy.

8. SECURITY OF YOUR DATA

The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

9. YOUR RIGHTS

Brydon Brothers aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.

You have the right to object to the processing of your Personal Data where we are relying on a legitimate interest of ours to carry out the processing. You also have the right to object to us processing your Personal Data for direct marketing purposes and can opt-out of receiving marketing emails from us at any time by following any “unsubscribe” link provided in our emails or by contacting us at hello@brydonbrothers.com

Where we are relying on your consent to process your Personal Data, you can without your consent at any time. This will not affect the lawfulness of any processing carried out before you withdraw your consent. In certain circumstances, you have the right:

• To access and receive a copy of the Personal Data we hold about you

• To rectify any Personal Data held about you that is inaccurate

• To request the restriction of processing of your Personal Data

• To request the deletion of Personal Data held about you

Please note that we may ask you to verify your identity before responding to such requests. If you wish to exercise any of your rights please contact us.

10. LINKS TO OTHER SITES

Our Site may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

11. CHILDREN’S PRIVACY

Our Site and Services are not addressed to anyone under the age of 13 (“Children”). We do not knowingly collect personally identifiable information from anyone under the age of 13. If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

12. CHANGES TO THIS PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page. We will let you know via email and/or a prominent notice on our Site, prior to the change becoming effective and update the “effective date” at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page. It is important that the Personal Data we hold about you is accurate and current. Please keep us informed if your Personal Data changes during your relationship with us.

13. CONTACT US

If you have any questions about this Privacy Policy, please contact us at hello@brydonbrothers.com

 

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