Your data is controlled by ASSEENONTHEHIGHSTREET LTD, a company located at 5 Canon Drive, Bowdon, Altrincham, England WA14 3FD with company registration number 12591182 (herein as “ASOTHS” or “we” or “us” or “our”).
Personal Data: This is any data about an identifiable person, which can be directly used to identify such a person, e.g. name, email, location, email address, etc.
Processing: This means any activities carried out on your data by ASOTHS, such as the collection, use, disclosure, transfer and security of your data.
Non-Personal Data: This is any data that cannot be used to directly identify a person unless combined with other data. This data is automatically collected and are mostly used to track users behaviours for Service or Site improvement.
3. The Site is Powered by Shopify
4. The Data ASOTHS collects from users and how we use them.
When you use the Site, we may collect two categories of data from you, which are Personal Data and Non-Personal Data. These pieces of data are submitted by you willingly and collected by us automatically through cookies and other tracking technologies.
- Data that you submit willingly: The data you submit to us when you use our Services is mostly categorised as Personal Data. This data may include your name, email address, phone number, payment data and shipping address. You may submit this data when you (i) request a user account on the Site; (ii) subscribe to our newsletter; (iii) submit your payment details for your purchases; (iv) take part in our promos, sweepstakes, surveys and offers; (v) submit your shipping details for order delivery; and (vi) other means as may be established now or later.
- Data about analytics, which includes the numbers of users on the Site at a time, the pages users are on, the source of the traffic to the Site, how users browse through different pages on the Site, etc. Analytics data is collected through cookies set by Shopify and cookies set by Google Analytics. Meanwhile, analytical data does not contain any Personal Data about users.
- Transactional data about the purchase you made on any store or vendor on the Site, which includes details of the order, time of order, the item in the order and other data. Transactional data is collected for record purposes – to serve as evidence of your purchase and as required by applicable law.
5. Cookies and Other Tracking Tools
6. Our Legal Bases for Processing your data
Our legal bases for collecting and processing your data includes (i) to fulfil a contract between you and sellers, (ii) we have obtained your consent to processing such data (for example sending newsletters), (iii) to comply with the law, and (iv) for our legitimate business interest through marketing.
7. Does ASOTHS share Users’ data?
Yes – we may share the data about you with affiliates, subsidiaries, employees and the law. However, we will not share data unless it is in relation to providing the Services to you (except for the event of bankruptcy or request by law enforcement). If the sharing of your data is to locations outside the EU, EEA or the UK, such sharing will be in accordance with the regulations of the GDPR.
- Third Party Service Providers: We may work with certain companies to assist in providing the Services to you (“Service Providers”). For example, Shopify provides some of the features on the Site, including web hosting and payment gateway. Likewise, another Service Provider helps us with the delivery of your orders. When ASOTHS work with Service Providers, we are obligated to share relevant data with them to carry out their services. For example, our courier company will need your name and shipping address in order to deliver the items you order from the stores under ASOTHS. However, these Service Providers are under an obligation (through contract) to keep the data we share with them for the purpose of the Services only. They are obligated not to use our users’ data for any other agenda.
- Store Owners or Sellers: By purchasing an item from a store on the Site, you agree that the owner of the applicable store (the seller) will be provided with certain information about you, such as your name and the item you are purchasing.
- The Law: We may disclose any data if such disclosure is to comply with applicable law; to enforce our Terms and Conditions and other agreements; to protect our rights and properties and those of other Site users or third parties. This includes sharing data with law enforcement with respect to court orders, subpoena and other legal summonses and also sharing data with other organisations for fraud protection and credit risk.
- Business Transfers: ASOTHS may engage in any business transfer activity, such as a sale of an asset, merger, acquisition or consolidation of ASOTHS with another company – as well as bankruptcy. If any business transfer activity occurs, we will have to transfer or share users’ Personal Data with the concerned companies.
8. How Secure is your Personal Data?
ASOTHS cares about your privacy. We take every necessary step that is meant to keep your data safe and confidential. Any data collected from you when you use the Site is stored on Shopify’s server and is protected from unauthorised access and use. For your payments, Shopify uses the PCI Security Standards Council to maintain the secure processing of credit card transactions. Shopify also brings in third party audit team to provide Service Organization Control (SOC) reports, which has earned Shopify SOC 2 Type II and SOC 3 reports for the services it provides. However, you are aware that no measure employed to safeguard data is 100% secure. Due to this, ASOTHS cannot guarantee you that your data will at all times be secure or safe from unauthorised access or use.
9. Marketing Communications
When you tick the ”keep me up to date on news and exclusive offers” box on the order page during checkout, you are automatically subscribing to receiving newsletters from ASOTHS to your submitted email address. Newsletters may contain messages about deals, bonuses, offers and promotions that ASOTHS believes will benefit you or match your interest. Once you subscribe to our newsletters, we will continue to send you unless you opt-out. You may opt-out of receiving newsletters by using the “unsubscribe” link at the bottom of any newsletter we send to your email address.
10. Do you have any rights over your Personal Data?
Yes – you have certain rights and choices regarding the data you share with us. Under the GDPR, you have the following rights:
- The right to request for the data ASOTHS processes about you, including the access to rectify any inaccurate data. You can make this request by signing in to “My Account” and modify your address data.
- The right to erase your data when you make a request. You can contact ASOTHS to have your data deleted from our server by sending us a message directly to email@example.com or Contact Us.
11. When do we delete your data?
ASOTHS does not retain any data about you for longer than is necessary. The retention period of any data we hold about you depends on the type of data and the method of collection. If you open an account on the Site, your data will remain with us until your account is closed – either by you or us. Likewise, your email address will remain with us until you opt-out of newsletters. Your payment data and shipping details will be deleted upon the fulfilment of the order. However, we may retain certain Non-Personal Data, such as transactional data for longer periods for the sake of compliance with the law or as evidence of your purchases in the event of disputes.
12. Do we transfer your data outside the UK?
Yes – we may transfer data to Service Providers outside the UK. For example, the Site is hosted on Shopify, an e-commerce software service that provides services such as payment processing and data storage on our behalf. Shopify is based in Canada – a country with “adequate” data protection laws – where it processes your data from. Also, the other Service Providers we use, which are not based in Canada, comply with the GDPR law; therefore, the transfer of your data will be in accordance with the laws of the GDPR.
13. Third Party Links
The Site may contain links, adverts or contents that lead to third party sites (“Third Party Links”). Any Third Party Links available on the Site are not linked to the Services – neither are they endorsed by us for accuracy or completeness. By accessing any Third Party Links through the Site, you hereby release ASOTHS from any loss you may suffer, including loss of data or revenue. We strongly advise that you read the policies of the relevant websites before accessing their links.
14. Children Policy
The Site and our Services are available to people who are at least 18 years of age and can enter into an agreement. We do not welcome minors submitting data to us. If we find out you are a minor and is using the Site without being supervised by at least a parent or legal guardian, we will have your use of the Services terminated without refunds or liability.
15. Contact Us
For any complaints, questions, feedback, enquiries and suggestions regarding this Policy, the Site and our Services, reach out to ASOTHS via the following contact information:
5 Canon Drive,
England WA14 3FD
Company Registration #12591182