Version: November 2022
This notice contains important information about how we collect and process your personal data:
• through your use of our website or our digital applications (Apps);
• by signing up for newsletters, competitions and other marketing activities either in-store or online;
• as an individual customer; or
• as a staff member or other representative of one of our business customers or suppliers.
It also contains information about your rights as a person whose information we process, and how you can complain if you have any concerns about what we are doing with your information. Any changes we make to this notice in the future will be posted on this page and, if appropriate, notified to you by email so please check this page regularly.
Information About Us
Paul Smith Limited is the controller responsible for your personal data (referred to as "we", “us” or “our” in this privacy notice). We are registered with the UK Information Commissioner’s Office with number Z6563397. Our registered office is at The Poplars, Lenton Lane, Nottingham, NG7 2PW, England. If you have any questions about this privacy notice, the use of your personal information, or your dealings with our website or our Apps, you can contact us at email@example.com
Your Personal Data
Information provided to us by you or about you
You will provide some or all of the following information to us when you contact us, purchase goods from our shops or our website, request services offered by us in our shops, register a customer account online with us, use one of our Apps and/or sign up for newsletters and other marketing activities, either when speaking to staff in one of our shops or online:
• Your Identity and Contact Details -includes your name, email address, home postal address/billing address, delivery address (if different), and your contact telephone number;
• Your Payment Details - your bank details and payment card details, however your payment transactions will be encrypted by the acquiring bank so we will not retain any payment card details submitted by you;
•Your Profile Data - if you register a customer account online, this includes the profile you create to identify yourself when connecting to our website and Apps (including your username and password) and other data about purchases and your personal preferences; and
• Additional Personal Details - At your option, you can also provide additional personal information to us such as your date of birth, gender, passport number, product preferences and interests. This additional information would only be collected and stored by us for the purpose of analysing sales to help us understand and improve our business, for the purpose of any service requested by you, and for the purpose of any direct marketing which you may have expressly given your consent to. For information on direct marketing click here.
Please Note: We will combine and use the information we hold about you with the aim of delivering the best service we can, and that you receive products and information from us in the way that you want. As such, it is important that the personal data we hold about you is accurate and up to date. Please keep us informed if your personal data changes during your relationship with us.
In the case that you are an employee or other representative of any of our business customers or suppliers, the same categories of information might be provided to us by you or about you by the business you represent. This notice applies to our processing of that information in the same way that it applies to the processing of information supplied to us directly.
We do not collect any categories of sensitive personal data (except in relation to employees). This website and our store policies assume that the customers we are interacting with are adults, so we do not knowingly collect data relating to children.
Information We Collect When You Interact With Us
As you interact with our website, our communications (including our emails and mobile messages) and Apps, we also automatically collect usage and technical data (described below) about your equipment, browsing actions and patterns. We collect this data by using cookies, server logs and other similar technologies. Click here for more information about cookies. We may also collect preference and other data that you choose to share with us via these platforms.
Usage Data - includes details of products and services you have purchased from us in store and/or online, and information about how you use our website and our Apps and how you interact with our communications (including our emails and mobile messages);
Technical Data - includes:
• your Internet protocol (IP) address, 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 or read our emails;
• information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our website (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page, mobile applications traffic data, weblogs and other communication data ;
•if you use a mobile device to access our website, emails, mobile messages, or one of our Apps, the type of mobile device you use, a unique device identifier (for example, your device’s IMEI number, the MAC address of the device’s wireless network interface, or the mobile phone number used by the device), mobile network information, your mobile operating system, the type of mobile browser you use, time zone settings);
Preference Data – includes information about your preferred methods of communication, what topics you want to hear about, preferred stores or particular lines or items that you are interested in and other information you share with us for the purpose of improving and individualising your shopping experience with us;
Other - We may also receive information from third parties we work closely with such as online fashion retail platforms, delivery services, credit reference agencies and fraud prevention agencies.
When you opt in to marketing communications directly from our stores in United Kingdom, Europe and/or United States of America, and/or if you interact with us in one to one electronic communications, we will add information to a unique customer record which contains details of your transactional history with us, any complaints or special requests you may make electronically, and other related information. Our staff may also add notes of their verbal interactions with you to this record. This will be usage and preference data (as explained further above). Generally speaking, this record will only include information that you choose to share with us in connection with one of those activities.
What We Use Your Personal Data For
Data protection law in the UK allows us to collect, use, store and transfer personal information if we have one or more of the following grounds for doing so:
• To fulfil a contract with you; or
• Where necessary to comply with a legal or regulatory obligation; or
• Where necessary for our legitimate interests (or those of a third party) provided your interests and fundamental rights do not override these interests); or
• For other reasons where you have expressly consented to those purposes.
Below are the ways we will use your personal data for our legitimate interests and/or to fulfil a contract with you or the business you represent (it being in our legitimate interests to process the personal data of employees and other representatives of our corporate customers and suppliers, to the minimum extent necessary to facilitate performance of that business contract):
• processing your order, including taking payment, supplying products and any after sales services such as cancellations and returns;
• identity verification and credit checking;
• keeping you updated on the progress of your order, we will usually communicate with you about your order by email, but we or our couriers may also contact you by phone;
• where you have registered with us, processing and administering your account;
• making sure that whatever information we hold about you is accurate and up to date;
• where you are an eligible overseas visitor under an applicable retail export scheme and have elected to receive a tax free shopping form where offered in any of our shops, processing personal information related to such service (including sharing your information with the third party provider of such tax free shopping services);
• processing information required for competition, promotion or survey entries by you;
• allowing you to participate in interactive features of our service if you choose to do so;
• analysing sales to help us understand and improve our business;
• combining personal data gathered across the Paul Smith Group as described in this privacy notice (including to create consolidated customer records and insights of your interactions with us to create a profile on how you interact with the Paul Smith Group). Our profile of you can affect what offers and rewards you might receive form us;
• administration, analysis and assessment of our website, communications (including emails and mobile messages) and Apps and their performance, to understand and develop our business and for the improvement and optimisation of our website, communications (including emails and mobile message) and any Apps; and
• as part of our efforts to keep our website and our Apps safe and secure.
We need your consent for direct marketing communications. If you have expressly given your consent to receive direct marketing from us, whether via our website, Apps or in store, we may use the information you have given us and which we collect when you interact with us for;
• providing individualised personal communications via agreed channels, to inform you about offers, in store activities, and any other information which you have expressed a particular interest in learning more about;
• delivering direct marketing, advertising and updates from us to you, such as telling you about forthcoming events, products, services and offers and updates and information about us;
• measuring and understanding the effectiveness of advertising we serve to you and others;
• helping us decide which direct marketing emails and other communications we send to you; and
• making suggestions and recommendations to you and other users of our website and our Apps and in-store customers about goods or services that may interest you or them.
At any time you can opt out of direct marketing or change your preferences. Links will be provided (where possible within or alongside any direct marketing communication) for you to indicate any change to your preferences. If you need further information on how to do this, please contact us at firstname.lastname@example.org.
Who We Share Your Personal Data With
We may share your information within the Paul Smith Group and with our selected third parties for the purposes referred to above. For example:
• Payment Acquiring Services to process your payment;
• Delivery and Courier Companies to supply your order;
• Credit Reference & Fraud Prevention Agencies for credit checking and identity verification;
• Tax Free Shopping Service providers where you qualify for this service and have elected to receive this service (and please be aware that after we share your data with such third party provider they shall be an independent data controller and data processor for the purpose of them providing the tax free shopping services to you in accordance with the third party’s privacy notice);
• third party providers of services which we use to support our business in our interactions with customers and staff, where the providers require access to our systems and the personal data they contain in order to deliver those services, or for essential maintenance or technical support purposes;
• Analytics and search engine providers that assist us in the improvement and optimisation of our website and Apps;
• Build and hosting service providers that help us to maintain the software that runs our website and our Apps. They provide us with reporting statistics, and serve cookies on our behalf to enable any website or Apps personalisation and sign-in functionality. Click here for more information on cookies
• Where you opted in to direct marketing, third party advertisers, affiliate marketing agencies and advertising networks engaged by us to select and serve relevant communications to you on our behalf, and the providers of third party communications platforms which we use for our direct communications with you.
We require all third parties engaged by us to respect the security of your personal data and to treat it in accordance with the law. Such third parties are only allowed to process your personal data in accordance with our instructions, and not for their own purposes.
From time to time, we may ask you if you would like to be contacted by other selected third parties, such as part of a joint promotion or a collaboration. If we do this, we will also provide you with a link to that third party’s privacy notice to help you decide whether or not you wish to be contacted by them. If you do consent to this (by an express opt in), that third party would be the data controller in respect of any activity by them that you have consented to.
Links to Other Organisations
Our website, emails and/or our Apps may, from time to time, contain links to and from websites of our partner networks, advertisers and affiliates. If you follow a link these websites have their own privacy policies and we do not accept any responsibility or liability for the terms of these policies. Please check these policies before you submit any personal data to those websites.
Opting Out Of Marketing And Preference Updates
If you no longer wish to receive direct marketing and updates from Paul Smith you can unsubscribe at any time by clicking on the link in the emails or following the instructions in mobile messages provided with or in connection with those applicable communications. You can also amend your preferences for Paul Smith Group email newsletters within the email preference centre. Please note that if you have opted in to receive marketing communications directly from our stores, you will not automatically be opted out of receiving those store communications if you unsubscribe to our Paul Smith Group email newsletters, so you would also need to expressly opt out of the applicable store communications if you no longer wish to receive these. Similarly, if you opt out from our store communications you will not automatically be opted out of receiving our Paul Smith Group email newsletters. Alternatively you can speak to a member of staff in store, or contact customer services on +44 (0) 115 968 5821 or email email@example.com. If you are a registered online customer you can also opt out of Paul Smith Group email newsletters and amend your preference settings within your login profile under "My Account".
Cookies (including those which enable banner advertising) require a separate opt out and please Click here for more details.
Security Of Your Personal Data
Our website, Apps and systems have appropriate security measures in place to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. All information you provide to us is stored on secure servers. We have also put in place procedures to deal with any suspected personal data breach.
Where you have chosen a password which enables you to access certain parts of our website or our Apps, you are responsible for keeping this password confidential. We ask you to choose an effective, secure password and not to share your password with anyone or to re-use a password that you have used elsewhere.
We recommend only connecting to secure wireless networks that you trust to reduce the risk of unauthorised people intercepting your online activity. Beware of the risks of using public wifi.
If you receive an email purporting to be from Paul Smith asking for personal data, please do not respond to the email but please let us know that this has happened so we can check whether the email is genuine.
Outside UK - Data Storage & Transfer
Most of the data that we collect from or about you will be processed within, and stored at, locations in the UK or other countries which the UK government has determined to have adequate data protection safeguards in place (including, for example, the European Economic Area (“EEA”)). We may also transfer such personal data to countries outside of those referred to above, but we will only do so to the extent that this is necessary for our work with members of the Paul Smith Group and third parties who we use to help us carry out the purposes referred to above or to comply with a legal duty.
Whenever we transfer your personal data out of the EEA, we will make sure an adequate level of protection is afforded to it by using one of the following safeguards:
• We may use contract clauses with recipients which mean they must protect your personal data with the same level of protection as it has in the EEA;
• We may share data with organisations which have in place Binding Corporate Rules governing the onward sharing of personal data to third country recipients within their group of companies; and
• We may transfer personal data to organisations if they are part of a multilateral or bilateral arrangement which has been determined by the UK government to offer a level of protection equivalent to that offered by the other arrangements above.
How Long We Keep Your Personal Data For
If you visit our website but are not a customer or supplier of ours: we will keep your usage and technical data for as long as we require it for the purposes identified above, but some data will be erased at the end of your visit to the site, and the remainder will be erased as soon as it is no longer required.
If you are a recipient of newsletters or other communications: we will keep your data for as long as we need it to continue to communicate with you, but will delete the data as soon as it is no longer required, which will generally be if you inform us that you no longer wish to receive our communications. We may retain a copy of your contact information to ensure that you are not inadvertently sent further communications in the future.
If you are an individual customer of ours: we will keep your data for as long as you are a customer and thereafter we may keep it for longer in order to respond to any questions or complaints, or to deal with any unresolved issues relating to the customer contract.
If you are an employee or other representative of a business customer or supplier of ours: we will keep your data for as long as that business relationship continues and thereafter we may keep it for longer in order to respond to any questions or complaints, or to deal with any unresolved issues relating to the business contract.
In all cases: we may retain some data after the periods identified above, where that is necessary to satisfy legal, accounting or reporting requirements. We may also keep your data for research or statistical purposes.
You have the right to object to our use of your personal information, or to ask us to delete, remove or stop using it if there is no need for us to keep it. Please let us know if you think we should not be using it, but please be aware that there may be legal or other official reasons why we need to keep or use your information.
Your rights under data protection laws in relation to your personal data are briefly summarised below, and you can exercise these rights by emailing us at firstname.lastname@example.org or by writing to us at Customer Services Dept., Paul Smith Limited, The Poplars, Lenton Lane, Nottingham NG7 2PW, England:
• Request access to your personal data (commonly known as a “data subject access request”). This 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. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. Please note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which we will tell you about, if applicable, after receiving 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 on your fundamental rights and freedoms.
• Request restriction of processing of your personal data. You can 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; © 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.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time if we are relying on your consent to process your personal data (such as direct marketing and cookies). This won’t affect any processing already carried out before you withdraw your consent or processing under other grounds. If you withdraw your consent, we may not be able to provide certain products or services to 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.
You will not have to pay a fee to access your personal data and we try to respond to all requests within one month.
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). However, we would appreciate the chance to deal with any concerns you may have before you approach the ICO so please contact us in the first instance.
If you have any questions or require any more information please contact us at email@example.com.