Privacy policy
1. Introduction
This is the privacy policy of The Shoe Consultant Ltd (referred to in this policy as “The Shoe Consultant”, “we”, “us” or “our”).
This privacy policy will inform you about how we look after your personal data when you visit our website and about your privacy rights and how the law protects you.
The Shoe Consultant respects your privacy and is committed to protecting your personal data.
2. Purpose of this privacy policy
The purpose of this privacy policy is to tell you how we collect and processes your personal data through your use of this website, for example when you sign up to our email list, purchase a service from us or take part in a webinar or other activity that we organise through this website.
3. What is “personal data”?
“Personal data”, or “personal information”, means any information about an individual from which that person can be identified. It does not include data from which identifying information has been removed (anonymous/anonymised data).
4. What sort of personal data might we collect about you?
We might collect, use, store and transfer different kinds of personal data about you as follows:
- Identity Data – this includes your name, username or similar identifier, title, date of birth and gender.
- Contact Data – including your billing address, delivery address, email address and telephone numbers.
- Financial Data – including your bank account and payment card details.
- Transaction Data – including details about payments to and from you and other details of services you have purchased from us.
- Technical Data – including 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 – including your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data – including information about how you use our website and our services.
- Marketing and Communications Data – this includes your preferences about receiving marketing from us and from third parties and your communication preferences.
(We use these terms throughout this policy).
We do not collect any details about an individual’s race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about their health, and genetic and biometric data. Nor do we collect any information about criminal convictions and offences. (The legal term for these sorts of data is special categories of personal data.)
5. What non-personal data might we collect about you?
We may also collect, use and share data such as statistical or demographic data (“Aggregated Data”). Aggregated Data may be derived from your personal data but it will not directly or indirectly reveal your identity. It is therefore not considered personal data in law.
For example, we may aggregate your Usage Data (see above) to help us calculate the number/percentage of users accessing a specific website feature.
If we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we will treat the combined data as personal data which will be used in accordance with this privacy policy.
6. How might we collect your personal data?
We might collect data from and about you in a number of ways, including through:
- Direct interactions. You might give us your Identity Data, Contact Data and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
– enquire about our services;
– create an account on our website;
– subscribe to our services, email list or publications;
– enter into a contract with us;
– request marketing to be sent to you;
– enter a competition, promotion or survey; or
– give us feedback or contact us.
- Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.
- Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources such as:
– Technical Data from parties such as Google (eg Analytics)
– Contact Data, Financial Data and Transaction Data from providers of technical, payment and delivery services.
– Identity Data and Contact Data from publicly available sources such as Companies House and the Electoral Register in the UK.
7. How do we use your personal data?
We collect your personal data for the purposes set out below:
- to allow us to provide services to you or your organisation;
- to engage in marketing and business development activity in relation to our services. This might include sending you marketing communications, newsletters, updates and other information that we think would be of interest to you;
- where you have applied for a position with us, to review and process your job application;
- to comply with any legal or regulatory obligations applicable to us;
- to establish, exercise or defend our legal rights for the purposes of legal proceedings;
- to record and monitor your use of our website of other online services for our business purposes, including analysis of usage, measurement of site performance and generation of marketing reports;
- to use for our legitimate business interests, such as undertaking business research and analysis, including understanding our relationships with the users of our services, managing the operation of our website and the administration of our business;
- to look into any complaint or query you may have; and to prevent and respond to actual or potential fraud or illegal activities.
The sort of marketing and business activities we refer to above include, for example:
- Promotional offers: We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you.
- Marketing communications: You will receive these from us if you have signed up to our email list, or otherwise requested information from us, or purchased services from us (and you have not opted out of receiving these sorts of communications from us).
- Testimonials: Where you have kindly provided a written testimonial about any of our services, we may quote you on our website and other social media platform.
Note that
- You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time at the address set out in paragraph 13 below.
- We will obtain your express opt-in consent before we share your personal data with any third party for marketing purposes
- We will only use your personal data as the law allows us to. As a schedule to this privacy policy, we have attached a table that sets out more particular examples of the purposes for which we might collect and use your personal data and the lawful bases that we rely on to do so.
- Where you decline to provide personal data that we need to collect under the terms of a contract we have with you, or because we are required to by law, we may be unable to provide services to you. If this is the case, we will notify you.
8. Disclosures of your personal data
We will allow access to your personal data only to those employees, agents, contractors and other third parties who have a business need to access it. They will be required to process your personal data on our instructions and subject to a duty of confidentiality.
9. International transfers
We do not transfer your personal data outside the European Economic Area. We will make an exception to this only on a case by case basis and after appropriate case-specific measures have been taken in consultation with you and with your express agreement.
10. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
We will 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.
11. Data retention
For how long will we retain your personal data?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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 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 any applicable legal, regulatory, tax, accounting or other requirements.
Where we anonymise 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.
12. Your legal rights
Under data protection laws, you have the right to:
- Request access to your personal data (this is known as a “data subject access request”). This entitles you to receive a copy of the personal data we hold about you and to check that we are processing it lawfully.
- Request correction of the personal data that we hold about you. This entitles you to have any incomplete or inaccurate data we hold about you corrected. We may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This entitles you to ask us to delete or remove personal data where there is no good reason for our 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 applicable law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons. If such specific legal reasons apply, we will notify you of this 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 you object to processing on this ground because you feel it has a negative impact on your fundamental rights and freedoms. You also have the right to object 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 override your rights and freedoms.
- Request restriction of processing of your personal data. This entitles you to ask us to suspend the processing of your personal data where:
- you require us to establish the accuracy of the data;
- our use of the data is unlawful but you do not want us to erase it;
- you need us to hold the data, even if we no longer require it, because you need it to establish, exercise or defend legal claims; or
- you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. If you make such a request, we will provide your personal data in a structured, commonly used, machine-readable format to you, or a third party nominated by you. Note that this right only applies to automated information which you provided consent for us to use or which we used to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. If you withdraw your consent, the lawfulness of any processing carried out before that will not be affected. If your withdrawal of consent means that we are no longer able to provide certain services to you, we will advise you of this when you withdraw your consent.
No fee (usually)
There is generally no fee to access your personal data or to exercise any of the other rights. However, if your request is clearly unfounded, repetitive or excessive, we are entitled to charge a reasonable fee or to refuse to comply with your request.
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). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit for response
We try to respond to all legitimate requests within one month. We may take longer than a month if your request is particularly complex or you have made a number of requests. In such cases, we will notify you and let you know when we expect to be able to provide our response.
13. Contact details
If you have any questions about this privacy policy or our privacy practices, you can contact us in either of the following ways:
By email to: susannah@shoeconsultant.co.uk
By post to: The Shoe Consultant Ltd, 107 Nightingale Lane, Bromley BR1 2SG
14. Complaints
Please contact us if you have any complaint in relation to this policy or our processing of your personal information.
You also have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (https://ico.org.uk).
15. Changes to this privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review and update it from time to time.
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.
16. 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 data about you. We do not control these third-party websites and are not responsible for their privacy statements or their actions. When you leave our website, we encourage you to read the privacy policy of other websites you visit.
SCHEDULE: More information about legal bases for use of your personal data
The table below sets out some examples of ways in which we might use your personal data, and in each case, the legal bases we rely on to do so.
One legal basis is “legitimate interest”. Where appropriate, we have identified what those legitimate interests are.
Generally, we do not rely on consent as a legal basis for processing your personal data, but we will obtain your consent before sending you our email updates or third party direct marketing communications. You have the right to withdraw consent to marketing at any time by contacting us.
Note that we may process your personal data based on more than one lawful ground depending on the specific purpose for which we are using it.
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
| To register you as a new customer | a) Identity
b) Contact |
Performance of a contract with you |
| To process and deliver your order including:
a) Manage payments, fees and charges b) Collect and recover money owed to us |
a) Identity
b) Contact c) Financial d) Transaction e) Marketing and Communications |
a) Performance of a contract with you
b) Necessary for our legitimate interests (to recover debts due to us) |
| To manage our relationship with you which will include:
a) Notifying you about changes to our terms or privacy policy b) Asking you to leave a review or take a survey |
a) Identity
b) Contact c) Profile d) Marketing and Communications |
a) Performance of a contract with you
b) Necessary to comply with a legal obligation c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) |
| To enable you to partake in a prize draw, competition or complete a survey | a) Identity
b) Contact c) Profile d) Usage e) Marketing and Communications |
a) Performance of a contract with you
b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) |
| 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 |
a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or restructuring)
b) Necessary to comply with a legal obligation |
| To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you | a) Identity
b) Contact c) Profile d) Usage e) Marketing and Communications f) Technical |
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) |
| To use data analytics to improve our website, products/services, marketing, customer relationships and experiences | a) Technical
b) Usage |
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
| To make suggestions and recommendations to you about goods or services that may be of interest to you | a) Identity
b) Contact c) Technical d) Usage e) Profile g) Marketing and Communications |
Necessary for our legitimate interests (to develop our products/services and grow our business) |