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Introduction

Welcome to the Inside Out Living’s privacy policy.

Inside Out Living respects your privacy and we are committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

This privacy policy is divided into the following sections:

  1. Important Information And Who We Are
  2. The Data We Collect About You
  3. How Is Your Personal Data Collected?
  4. How We Use Your Personal Data
  5. Disclosures Of Your Personal Data
  6. Transfers Outside The UK And EEA
  7. Data Security
  8. Data Retention
  9. Your Legal Rights

1. Important information and who we are

Eden Retail Group Ltd, trading as Inside Out Living, is registered in England and Wales under company number (14497092) with our registered office at 71-75 Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ (collectively referred to as “Inside Out Living”, “we”, “us” or “our” in this privacy policy).

We specialise in the design, manufacture and supply of home and garden lifestyle products, including patio tables and chairs, barbecues, soft furnishings, ornaments and dining accessories to name a few.

We collect, use and are responsible for certain personal data about you. When we do so, we are regulated by the UK GDPR and the EU GDPR. We are responsible as ‘controller’ of that personal data for the purposes of those laws. Personal data is any information that can be used to identify someone.

Purpose of this privacy policy

This privacy policy aims to give you information on how Inside Out Living collects and processes your personal data through your use of this website, including any data you may provide through this website when you purchase a product or sign up to our newsletter.

This website is not intended for children and we do not knowingly collect personal data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Our Website

This privacy policy relates to your use of our website, (https://www.ioliving.co.uk/) (the “Website”) and how we collect personal data about you during the provision and the sale of our goods to you.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This Website privacy policy was published on [insert date] and last updated on [insert date]. We may change this privacy policy from time to time – when we do, we will take appropriate measures to inform you of the relevant changes, consistent with the significance of the changes we make.

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.

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. When you leave our website, we encourage you to read the privacy policy of every website you visit.

2. 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 together as follows:

  • Identity Data includes your full name, username or similar identifier, marital status, title, date of birth, gender, User ID and Social Media profiles.
  • Contact Data includes billing address, delivery address, email address and telephone numbers.
  • Financial Data includes bank account, payment card details and third party payment account details i.e. PayPal.
  • Transaction Data includes details about payments to and from you and other details of products you have purchased from us.
  • 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, data collected by third parties e.g. Google analytics 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, product reviews, feedback and survey responses.
  • Usage Data includes information about how you use our website and products.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for our direct use. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will 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, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

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 offences.

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). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

3. 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 by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
    • browse through our Website;
    • purchase, or attempt to purchase our products through our Website;
    • create an account on our Website;
    • subscribe to our newsletter;
    • request marketing to be sent to you by us; or
    • give us feedback or contact us regarding our products.
  • Automated technologies or interactions. As you interact with our Website, we will automatically collect Technical and Profile Data about your equipment, browsing actions and patterns. We capture how you use and interact with our website through behavioral metrics, heatmaps, and session replay to improve and market our products/services. We collect this data using first and third-party cookies and other tracking technologies to determine the popularity of products/services and online activity. Additionally, we use this information for site optimization, fraud/security purposes, and advertising. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy here for further details.
  • Third parties or publicly available sources. We will receive personal data about you from various third parties as set out below:

Technical Data from the following parties:

  • social media providers such as Facebook, Pinterest and Tik Tok;
  • analytics providers such as Google, Google Analytics and Google Tag Manager, Microsoft Clarity and Quantcast based outside the UK;
  • ad management providers such as SA360;
  • advertising networks including Facebook ‘pixel’, Google Ads, DV360, Adtraction, Microsoft Ads, Flashtalking, Spaceback and Criteo based outside the UK; and
  • any other marketing agencies engaged by us from time to time.

4. How we use your personal data

We will only use your personal data when the law allows us to. The table below explains what we use (process) your personal data for and our reasons for doing so:

What we use your personal data for What information we ask for Our reasons
To provide our goods to you. As set out in “the data we collect about you” section.

 

To provide our goods to you in accordance with the terms and conditions between us.
Account Creation
  • Full name;
  • E-mail address;
  • Address;
  • ID/username, and password;
  • Order details; and
  • Personal interests.
To:

  • manage your order;
  • send you marketing communications; and
  • offer a personalised service.

We rely on our legitimate interests when you create your account as the lawful basis for collecting and using your personal data.

Our legitimate interests are to improve our services, to better communicate with you and to prevent criminal activity.

Purchases and order management
  • Full name;
  • E-mail address;
  • Address;
  • Contact information;
  • Personal description or preferences;
  • Transaction information including purchased products;
  • Payment information; and
  • Purchase history.
To:

  • contact you to finalise your order where you have saved your shopping cart or placed products in your cart without completing the checkout process;
  • provide product updates;
  • process your order including delivering the products to your chose address;
  • manage payment;
  • manage any communications you have with us regarding your order;
  • secure your transactions against any fraud;
  • manage any complaint relating to an order placed by you; and
  • run analytics and statistics.

If you place a purchase using a registered account, we will add this transaction to your profile so we can understand your interests and preferences. You will see a record of your transactions with us within your account.

We rely on the performance of a contract when you make an order for goods and we manage your order as the lawful basis for collecting and using your personal information.

Our legitimate interests are to improve our products and how we deliver them, to better communicate with you and to prevent fraud or criminal activity.

Newsletter and marketing subscription
  • Full name;
  • E-mail address;
  • Contact information;
  • Personal description or preferences;
  • Order details;
  • User generated content; and
  • Other information you have shared with us e.g. by contacting us.

 

 

To:

  • provide new customers with a discount on their first order (subject to Ts&Cs);
  • keep our customers up to date with latest news and offers for the brand;
  • send you marketing communications;
  • maintain an up to date list if you have opted out of marketing communications and have asked not to be contacted by us; and
  • run analytics or collect statistics.

We rely on our legitimate interests as the lawful basis for collecting and using your personal data when you sign up to our newsletter.

Our legitimate interests are to improve our services, to better communicate with you and to prevent criminal activity.

Responding to enquiries
  • Full name;
  • E-mail address;
  • Contact information;
  • Order information; and
  • Other information that may be shared by contacting us.
To respond to enquiries communicated to us via telephone or sent to us via e-mail, post or through our ‘Chat with us’ chat box or ‘message us’ form on our Website.

We rely on our legitimate interests as the lawful basis for collecting and using your personal data when you submit information to us in order respond to your enquiries.

User generated content (e.g. through our “Get in Touch” online submission form on our Website) – We do not add such content to any form of database, however we would use such information to follow up any queries you might have.
  • Full name;
  • E-mail address;
  • Contact information;
  • Personal description or preferences; and
  • Other information you have shared with us e.g. by contacting us.
To deal with any queries or complaints you might have.

We rely on our legitimate interests as the lawful basis for collecting and using your personal data when you submit information to us in order to respond to your queries and communicate with you.

Returns/refunds
  • Full name;
  • E-mail address;
  • Bank details (to process the refund); and
  • Contact information.
To perform our duties under the contract, to process your return and provide you with a refund.

We rely on the performance of a contract when you return goods to us as the lawful basis for collecting and using your personal data.

Our legitimate interests are to improve the sale of our goods to you.

Legal and regulatory requirements – e.g. accounting and tax purposes.
  • Full name;
  • Contact information; and
  • Order history.

 

To comply with our legal or regulatory obligations, when we believe in good faith that it is required by law or at the request of authorised authorities who may conduct investigations.

We rely on our legal obligations as the lawful basis for collecting and using your personal data in this circumstance.

Our legitimate interests are to comply with our legal obligations.

Social media channels – You can engage with us via social media services such as Facebook and Instagram. When you engage with our content posted or if you contact us, you may provide personal data to us. You may provide us with certain personal data available in your profile such as:

  • Full name;
  • E-mail address;
  • Photos;
  • Gender;
  • Age;
  • Location; and
  • ID related to the social media platform.
To communicate with you by replying to any of your comments or dealing with a message sent to us.

We rely on our legitimate interests as the lawful basis for collecting and using your personal data, to improve the sale of our goods to you.

Survey responses and/or user feedback You may provide us with:

·       Your name;

·       E-mail address; and

·       Contact details.

To improve the user experience of our Website and to improve our products and business departments.

We rely on our legitimate interests as the lawful basis for processing your data in this way.

Profiling

Profiling enables us to determine aspects of our customers behaviour, interests and habits to be analysed and predicted.

We may collect any personal information as set out in the table above.

We collect this information from various sources which include:

·        Internet and browsing history;

·       Location data; and

·       Buying habits.

 

 

To send and display personalised communications.

We rely on consent as the lawful basis for collecting and using your personal information in order to send you tailored communications specific to your interests.

You may object at any time to the use of your personal data for profiling by contacting us using the contact details below.

 

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows 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.

Marketing

We would like to send you information about products, services, and special offers, which may be of interest to you. We have a legitimate interest in using your personal data for marketing purposes (see above ‘How we use your personal data’). This means we do not usually need your consent to send you marketing information. However, where consent is needed, we will ask for this separately and clearly.

You can opt out of targeted advertising by:

Facebook – https://www.facebook.com/settings/?tab=ads

Google – https://www.google.com/settings/ads/anonymous

Bing – https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads

Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at:  http://optout.aboutads.info/.

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

Cookies

A cookie is a small text file which is placed onto your device (e.g. computer, smartphone or other electronic device) when you use our Website. We use cookies on our Website. These help us recognise you and your device and store some information about your preferences or past actions.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this Website may become inaccessible or not function properly. For more information about the cookies we use, please see here.

5. Disclosures of your personal data

We routinely share your personal data such as your full name and delivery address details with our freight providers in order to ship our goods to you and fulfil your order. In addition, we may share your personal data with our office management tool providers e.g. Microsoft 365 in order to process your orders and deal with them accordingly and our IT service suppliers, as well as our third party marketing agencies that support us with our marketing strategy.

Some of those third party recipients may be based outside the United Kingdom and European Economic Area. For further information see ‘Transferring your information out of the UK and EEA’.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. Transferring your information out of the UK and EEA .

We may transfer your personal data to other organisations located outside the United Kingdom (UK) and European Economic Area (EEA) including to Canada and the United States in the following circumstances:

  • we share information with:
    • our IT service providers, whose servers may be located outside the UK/EEA, for the purposes of running our business effectively (this includes things such as our e-mail and document management systems, our website host and our data storage providers);
    • with one of our freight providers to deliver your goods to you (such providers include but are not limited to Panther, ArrowXL, DPD, Matthew Transport Services and FirstPoint Logistics); or
    • if you are based outside the UK/EEA.

Under data protection law, we can only transfer your personal data to a country or international organisation outside the UK/EEA where:

  • the UK government has decided the particular country or international organisation ensures an adequate level of protection of personal data (known as an ‘adequacy decision’);
  • there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for data subjects; or
  • a specific exception applies under data protection law.

Adequacy decision

We may transfer your personal data to certain countries, on the basis of an adequacy decision. These include:

  • all European Union countries, plus Iceland, Liechtenstein and Norway (collectively known as the ‘EEA’);
  • Gibraltar; and
  • Andorra, Argentina, Canada, Faroe Islands, Guernsey, Israel, Isle of Man, Japan, Jersey, New Zealand, Switzerland and Uruguay.

The list of countries that benefit from adequacy decisions will change from time to time. We will always seek to rely on an adequacy decision, where one exists. Other countries we are likely to transfer personal data to do not have the benefit of an adequacy decision. In these circumstances, we will ensure the transfer complies with data protection law by implementing effective transfer mechanisms (e.g. standard contractual clauses).

7. 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. 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 they are subject to a duty of confidentiality.

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.

8. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, 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 the applicable legal, regulatory, tax, accounting or other requirements.

In some circumstances you can ask us to delete your data: see your legal rights below for further information.

In some circumstances we will 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.

9. Your legal rights

Under certain circumstances, you have the following rights:

  • Right to request access to your personal and to be provided with a copy of your personal data.
  • Right to request correction of your personal data.
  • Right ‘to be forgotten’ and require us to eras your personal data in certain circumstances.
  • Right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations.
  • Right to require us to restrict processing of personal data in certain circumstances.
  • Right to object at any time to your personal data being processed for direct marketing; and in certain other situations to our continued processing of your personal data, e.g. processing carried out for the purpose of our legitimate interests.
  • Right not to be subject to a decision based solely on automated processing that produces legal effects concerning you or similarly significantly affects you.

For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance issued on the UK Information Commissioner’s Office (ICO) Website which can be accessed here.

If you wish to exercise any of the rights set out above, please contact us.

No fee 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 clearly unfounded, repetitive or excessive. Alternatively, we could 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). 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 to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Complaints

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator 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.

Contact details:

Email address: rhys.evans@ioliving.co.uk

Postal address: 71-75 Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ

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