Privacy Policy | Bella + Frank

BELLA+FRANK | Privacy Policy

This Privacy and Cookies Policy establishes the terms and conditions under which BELLA+FRANK Ltd (registered at Spaces, Mocatta House, Trafalgar Place, Brighton, BN1 4DU) processes the personal data that you provide us with in person or when using the website www.bellaandfrank.co.uk

Data Protection Officer: studio@bellaandfrank.co.uk

Postal Mail: Spaces, Mocatta House, Trafalgar Place, Brighton, BN1 4DU

BELLA+FRANK is committed to ensuring that your privacy is protected. Should we ask you to provide certain details, you can be confident that it will only be used according to the information in this privacy statement. This privacy policy sets out how BELLA+FRANK Ltd uses and processes any information that you give BELLA+FRANK when you use this website or in person. BELLA+FRANK may change this policy from time to time by updating this page. We will make sure to notify you of such changes via the website (for example using banner or pop-up notifications), or we may even send you a notice to your e-mail address when the change in question is relevant to your privacy, for you to be able to review the changes or object or unsubscribe from any service or functionality should you wish to. We recommend that you also review this Privacy Policy from time to time in case minor changes are made or we make any interactive improvement. This policy is effective from April 1^st 2019.

Contents

WHAT DATA WE COLLECT AND WHAT WE DO WITH IT 2
DATA PROTECTION RIGHTS 6
DATA SECURITY 7
INFORMATION ON COOKIES 8

WHAT DATA WE COLLECT AND WHAT WE DO WITH IT

We receive, collect and store any information you enter on our website or provide us in any other way. In addition, we collect the Internet Protocol (IP) address used to connect your computer to the Internet; login; e-mail address; password; computer and connection information and purchase history. We may use software tools to measure and collect session information, including page response times, length of visits to certain pages, page interaction information, and methods used to browse away from the page. We also collect personally identifiable information (including name, email, password, communications), feedback and comments.

What we collect:

your identity data (such as, your name, surname, language and country from which you interact with us, contact data, etc.);

economic and transactions information (such as, your payment or card data, information on your purchases, orders, returns, etc.);

connection, geolocation and/or browsing data (such as, if you interact with us from your mobile phone,);

commercial information (such as, if you have subscribed to our newsletter),

information about your tastes and preferences.

Please remember that when we ask you to fill in your personal data to give you access to any functionality or service of the BELLA+FRANK website, certain fields are compulsory as this is information that we need to be able to provide the service. Please take into account that, if you decide not to make such data available to us, you may be unable to access those services or functionalities.

What we do with it:

BELLA+FRANK Ltd shall use Personal Data for the following purposes:

Why

More information

Legal Standing

How Long Do We Keep It

To manage your registration as a user of the Website. (only applicable to wholesale customers)

The BELLA+FRANK website requires site membership to access the wholesale portal. The data you provide us with shall be used to identify you as a Wholesale user, and to give you access to its different functionalities, products and services that are available to you such.

We process your data because this is necessary on the terms regulating the use of the Wholesale Platform. In other words, for you to be able to register as a user on the Platform, we need to process your personal data, since we would otherwise be unable to manage your registration.

We will process your data for the time during which you remain a registered user.

Development, performance and making of the purchase or services contract

This purpose includes processing your data, mainly:

i. To contact you for updates or informative notices related to the products or services, including quality surveys and to be able to establish the degree of customer satisfaction with the provided service;

ii. To manage payment of the products that you purchase, regardless of the payment procedure used.

Activate the necessary arrangements in order to control and prevent potential fraud against you and against us during the purchase process. If we consider that the transaction can be fraudulent, this processing may cause the blocking of the transaction.
To manage potential returns after you have purchased and manage requests of availability information for articles, reservations of products through the Platform, depending on the availability of such options from time to time.
For invoicing purposes and to make available to you the tickets and invoices of the purchases you have made through the Platform.
To ensure that you are able to use other available functionalities or services, such as the purchase, management and use of the Gift Card or of the Gift Voucher.

We process your data because their processing is necessary for us to make the purchase or services contract with you.

We consider that we have a legitimate interest to carry out the necessary verifications to detect and prevent potential fraud when you make a purchase. We understand that the processing of these data is positive for all the participating parties when a purchase is paid and in particular for you, since this allows us to establish measures to protect you from fraud attempts by third parties.

We will process your data for the time necessary to manage the purchase of the products or services that you buy, including potential returns, complaints or claims related to the purchase of the product or service in question.

To meet requests or applications that you make through the Customer Support channels

Attend and manage your requests made using the available customer service channels in relation to the Platform or the Physical Stores, as well as monitoring the quality of our service.

We only process the personal data that are strictly necessary to manage or resolve your request or application.

We consider that we have legitimate interest in answering the requests or queries raised by you through the existing different contact channels. We understand that the processing of these data is also beneficial to you to the extent that it enables us to assist you adequately and answer to the queries raised.

The processing of your data in the case of orders and generally in relation to products and services offered by BELLA+FRANK is necessary to perform the purchase contract.

The processing of your data in relation to any requests by you in which you exercise your rights as explained below or to claims on products and services is legally permitted as part of our compliance with our legal obligations

We will process your data for the time necessary to meet your request or application.

For marketing purposes.

If you authorize your subscription to the BELLA+FRANK Newsletter, we will provide you with information regarding our products and services, through different means as, among others, by email, any other equivalent electronic means of communication (such as SMS, etc.). Subscription to the BELLA+FRANK Newsletter may entail using Personal Data to make personalized advertising related to our products and services available to you via email, SMS or any other of our own electronic media or those of third parties. You can also unsubscribe at any time by following the information we provide in each communication.

To disseminate in the website or through our channels in the social networks photographs or pictures that you shared publicly, provided that you expressly give us your consent for the purpose.

In order to show you customised information. we consider that we have a legitimate interest to conduct a profiling with the information that we have about you (such as your browsing, preferences or purchase history) and the personal data that you have provided us, such as the age range or language, since we understand that the data processing of these data is also beneficial to you because it allows you to improve your user experience and access the information in accordance with your preferences.

We are legally permitted to process your data for marketing purposes due to the consent that you give us, for example, when accepting the legal terms and conditions to participate in a promotional action or to publish your pictures on the Platform or on our social networks’ channels.

We will process your data until you unsubscribe or cancel your subscription to the newsletter.

If you participate in promotional actions, we will keep the data during a six (6) months period from the end of the action.

Analysis of usability and quality to improve our services

If you access our Platform, we inform you that we will treat your browsing data for analytic and statistic purposes, i.e., to understand the manner in which users interact with our Platform and thus be capable of introducing improvements in the Platform.

In addition, we occasionally perform quality surveys and actions to

know the degree of satisfaction of our customers and users and detect those areas in which we may improve.

We consider that we have a legitimate interest in analysing the Platform usability and the user’s satisfaction degree, since we understand that that the processing of these data is also beneficial for your because the purpose is to improve the user experience and provide a higher quality service.

We will process your data occasionally for the time during which we proceed to carry out a specific quality action or survey or until we anonymise your browsing data.

No card details are held on our site or seen by anyone at BELLA+FRANK. BELLA+FRANK does not have access to nor will we save any card or payment details provided by you at purchase. Financial transactions on this Websites are handled through our payment services providers: PayPal and/or Wirecard. You should only provide your personal information to PayPal and/or Wirecard after also reviewing the PayPal privacy policy (available at https://www.paypal.com/uk/webapps/mpp/ua/privacy-full) and/or the Wirecard privacy policy (available at https://www.wirecard.com/privacy-protection/). We will share information with these Data Processors only to the extent necessary for the purposes of processing payments you make via our website. Our direct payment gateways adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of credit card information by our store and its service providers.

PERSONAL INFORMATION OF THIRD PARTIES PROVIDED BY YOU. We offer functionalities or services that require us to process the personal data of a third party that you must provide, such as the purchase and activation of a BELLA+FRANK gift card or shipping address for third parties. If you provide us with personal data of third parties, you confirm that you informed them of the purposes and of the manner in which we need to process their personal data. Additionally, if you have a Gift Receipt and you wish to return goods associated with it, we will use the Personal Data provided in the return form for (a) managing the request and processing the collection of the goods from your home address, (b) attending to requests related to the Gift Receipt or the return that you wish to make, and for (c) confirming the approval of the return and sending, by email or other equivalent electronic means, the Voucher with the refund amount.

DATA PROTECTION RIGHTS

BELLA+FRANK Ltd undertakes to respect the confidentiality of your Personal Data and to guarantee you can exercise your rights. You may exercise your rights of access, rectification, cancellation and opposition by sending an email to our Data Protection officer oyin@Bella+Frank.com by postal mail to Bella+Frank, Spaces, Mocatto House, Trafalgar Place, Brighton, BN1 4DU indicating the reason for your request. If we consider this necessary to be able to identify you, we may request you to provide a copy of a document evidencing your identity. This will be provided to you free of charge.

To elaborate on the above, you should be aware that you have the following rights:

To request access to your personal data that we hold. We remind you that where you are a Platform registered user you may also consult this information in the relevant section of your online account.
To request that we rectify the personal data that we hold. In any case, please take into account that, on actively making your personal data available to us through any procedure, you guarantee that they are true and accurate and you undertake to notify to us any change or modification of your data. You will be liable for any loss or damage caused to the website or to the person responsible for the Platform or to any third party by reporting erroneous, inaccurate or incomplete information in the registration forms. Please remember that, as a general rule, you must provide us only with your own data, not with those of third parties, other than to the extent otherwise permitted in this Privacy Policy.

To request that we erase your personal data to the extent that they are no longer necessary for the purpose for which we need to keep processing them, as we have explained above, or when we are no longer legally permitted to process them.

To request that we cancel or limit the processing of your personal data, which entails that in certain cases you can request us to temporally suspend the processing of the data or that we keep them longer than necessary.
If you have given us your consent to process your data for any purpose, you also have the right to withdraw such consent at any time.
When we are legally permitted to process your data due to your consent or to for the purposes of a contract, you will also have the right to request the portability of your personal data. This means that you will have the right to receive the personal data that you made available to us in a structured, commonly used and machine-legible format, to be able to transmit them to another entity directly without impediments on our part.

In addition, where the processing of your data is based on our legitimate interest, you will also have the right to object to the processing of your data.
Finally, we inform you that you have the right to file a claim before the responsible data protection regulatory authority, in particular, before the UK Data Protection Authority (http://ec.europa.eu/justice/article-29/structure/data- protection-authorities/index_en.htm)

It may also be necessary to transfer your Personal Data to companies belonging to the BELLA+FRANK Ltd or to third parties who provide us with support services such as:

financial institutions
anti-fraud detection and prevention entities,
technological service providers,
logistic, transport and delivery partners and service providers,
providers of customer support related services,
advertising and marketing related partners and service providers.
Klarna – In order to be able to offer you Klarna’s payment options, we will pass to Klarna certain aspects of your personal information, such as contact and order details, in order for Klarna to assess whether you qualify for their payment options and to tailor the payment options for you.
General information on Klarna you can find here. Your personal data is handled in accordance with applicable data protection law and in accordance with the information in Klarna’s privacy policy.

By providing us with your Personal Data on this Platform, you are authorizing us to process and share your information with said collaborators. Our collaborators or data processors will always be chosen to be in line with and to respect the data privacy laws as outline here and as required by EU Data Protection Law.

DATA SECURITY

We are committed to ensuring that your information is secure. User information registered in BELLA+FRANK Ltd servers are always protected by a login and password. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online. Although BELLA+FRANK Ltd makes every effort, cannot guarantee the security of information that is transmitted, namely intrusion by third parties (hackers).

We will not sell, distribute or lease your personal information to third parties unless we have your permission or are required by law to do so.

Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information, which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.

INFORMATION ON COOKIES

We use cookies in this Platform, which are small text files with information on your navigation in this Platform, whose principal objective is to improve your experience in the Platform. Please, continue reading, to find further information on the cookies that we use, their purpose and other information of interest.

What is a Cookie?

A Cookie is a small text file that a website stores on your PC, telephone or any other device, with information about your navigation on that website. Cookies are necessary to facilitate browsing and to make it more user-friendly, and they do not damage your computer.

While this Policy uses the general term “Cookies”, as they are the main method for storing information used by this website, the browser’s “Local Storage” space is also used for the same purposes as the Cookies. All the information included in this section is also applicable to this “Local Storage”.

Who uses the information stored in Cookies?

The information stored in the Cookies from our website is used exclusively by us, except for those identified below as “third-party cookies”, which are used and managed by external entities to provide services requested by us to improve our services and the experience of the user when browsing our website. The main services for which these “third-party cookies” are used are to obtain access statistics and to guarantee the payment transactions that are carried out.

How can I avoid using Cookies on this website?

If you prefer to avoid the use of Cookies on this page, taking into account the above-described limitations, first you must disable the use of Cookies in your browser and then delete the Cookies saved in your browser associated with this website. You may use this option for preventing the use of Cookies at any time.

How do I disable and prevent the use of Cookies?

You may restrict, block or delete the Cookies from this website at any time by changing the configuration of your browser following the steps indicated below. While settings are different in each browser, Cookies are normally configured in the “Preferences” or “Tools” menu. For further details on configuring Cookies in your browser, see the “Help” menu in the browser itself. Which particular Cookies does this website use and for what purpose? The chart below shows the Cookies, tags and other similar devices used by this website, together with information on the purpose, duration and management (proprietary and by third parties) of each one of them

What are Cookies used for on this website?

Cookies are an essential part of how our website works. The main purpose of our Cookies is to improve your browsing experience. For example, they are used to remember your preferences (language, country, etc.) while browsing and on future visits. The information collected by the Cookies also enables us to improve the site by estimating numbers and patterns of use, the suitability of the website to the individual interests of the users, quicker searches, etc. On occasions, if we have obtained your informed consent in advance, we may use Cookies, tags or other similar devices to obtain information that enables us to show you, either from our own website or from third-party websites or any other means, advertising based on the analysis of your browsing habits.

The chart below shows the Cookies, tags and other similar devices used by this website, together with information on the purpose, duration and management (proprietary and by third parties) of each one of them.

Cookie Name	Life Span	Purpose	Management
svSession	Permanent	Creates activities and BI	Own Cookies
hs	Session	Security	Own Cookies
Incap_ses_${Proxy-ID}_${Site-ID}	Session	Security	Own Cookies
Incap_visid_${Proxy-ID}_${Site-ID}	Session	Security	Own Cookies
nlbi_{ID}	Persistent	Security	Own Cookies
XSRF-TOKEN	Persistent	Security	Own Cookies
smSession	Two weeks	Identify logged in site members	Own Cookies
JSESSIONID	Session	Session Tracking	Own Cookies
test_cookie	Session	Tracking for Adverts	Google Adwords
_ga	2 years	Used to distinguish users	Google Analytics
_gat	24 hours	Used to distinguish users	Google Analytics
_gid	1 minute	Used to throttle request rate	Google Analytics
PHPSESSID	Session	Enables website to store serialised state data	Own Cookies

This information chart will be updated as quickly as possible as the services offered on this website change. We will notify you of any changes via the website through banner or pop-up notifications or we may send you a notice to your e-mail address when the change in question is relevant to your privacy. However, the information chart may temporarily fail to include a cookie, tag or other similar device as a result of the update, though they will always be devices with identical purposes to those included in this chart. We recommend that you also review this Privacy Policy from time to time in case minor changes are made or we make any interactive improvement.

What are Cookies NOT used for on this website?

We do not store sensitive personal information, such as your address, your password, your credit or debit card data, etc., in the Cookies we use.

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