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Welcome to Secret Sales' privacy and cookies notice.
Secret Sales (owned and operated by LRG Online) respects your privacy and is committed to protecting your personal data. This privacy notice 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 opt-in to email updates; we'll tell you about your privacy rights and how the law protects you.
This privacy notice is provided in a layered format so you can click through to the specific areas set out below.
Last reviewed: May 2021
Important information about who we are
Our services, whether through the Secret Sales website or otherwise, are not intended for children and we do not knowingly collect data relating to children.
Full name of legal entity: LRG Online Ltd
Email address: [email protected]
Postal address: 22 Charterhouse Square, London, EC1M 6DX
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.
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 by either updating the information on your customer account on the website or by contacting us at the email set out above, giving us the details of the changes.
Personal data means any information about a living 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:
We do not collect any financial or payment data from you, as all financial transactions take place using a third party payment provider [Sagepay], who collect and process all financial and payment related data securely on their own terms and on their own IT systems.
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 (to provide you with goods or services). In this case, we may have to cancel a product or service you have ordered from us, but we will notify you if this is the case at the time.
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity and Contact by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
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. [We may also receive Technical Data about you if you visit other websites employing our cookies.]
Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
Technical Data from the following parties:
Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Sage Pay.
Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the UK.
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Where we need to perform the contract, we are about to enter into or have entered into with you. Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
We will share your personal data with the supplier or brand you have ordered a product from (if you order any); we share your personal data in this way as it is necessary for the performance of the contract.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Where we need to comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
PROMOTIONAL OFFERS FROM US
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 products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased goods or services over the Secret Sales website and you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
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 and 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 other transactions.
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, only where this is required or permitted by law.
We may share your personal data with the parties set out below for the purposes set out in the table above.
Third Parties, such as service providers (who provide IT and system administration services) or professional advisers (including lawyers, bankers, auditors and insurers), where this is in our legitimate interests and sharing your personal data as we propose will not prejudice your fundamental rights to privacy nor your interests.
HM Revenue & Customs, regulators and other authorities acting as joint controllers, based in the United Kingdom, and who require reporting of processing activities in certain circumstances.
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.
In order to offer you Klarna’s payment methods, we might in the checkout pass your personal data in the form of contact and order details to Klarna, in order for Klarna to assess whether you qualify for their payment methods and to tailor those payment methods for you. Your personal data transferred is processed in line with Klarna’s own privacy notice here: https://www.klarna.com/international/privacy-policy/
We collect your personal data on behalf of the suppliers of the goods you may contract to buy using the Secret Sales website, as processors of your personal data on behalf of the suppliers, who are the controllers of such personal data. In some instances, the suppliers are outside the UK or EEA, and therefore your personal data may will be sent out of the UK or the EEA where it may not be as securely kept as it would be under the data privacy laws in the UK and the EEA. You should read the supplier’s privacy notices, which govern the security of your personal data, carefully.
Whenever we transfer your personal data out of the UK, we endeavour to ensure a similar degree of protection is afforded to it by ensuring we use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.
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, in relation to the personal data you provide to us as controllers, 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.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers.
In some circumstances you can ask us to delete your data: see 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.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
YOUR LEGAL RIGHTS
You have the right to:
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. Send your request to [email protected]
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. You can send your updated information to [email protected]
Request erasure of your personal data. This enables you to ask us to delete or remove personal data, including social media login information for Facebook, Instagram and Twitter. This can be executed either where there is no good reason for us continuing to process your data, or where you no longer wish for us to use it. To request the erasure of your data, please email [email protected]
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. You also have the right to object where we are processing your personal data for direct marketing purposes and request erasure of your personal data from the marketing database. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. To request the erasure of your data, please email [email protected]
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data where you do not want to end it finally. Please send your request to [email protected]
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. 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. If you need any more information, please email [email protected]
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. To withdraw your consent, please email [email protected]
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 28 days, but we will always endeavor to complete your request sooner. Occasionally it could take us longer than 28 days 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.