PRIVACY POLICY
Retromixer 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 and tell you about your privacy rights and how the law protects you.
This website is not intended for children and we do not knowingly collect data relating to children.
We do not sell your data.
PROTECTING YOUR PRIVACY
This privacy notice aims to give you information on how Retromixer collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter, purchase a product or service or take part in a competition.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice 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 notice supplements the other notices and is not intended to override them.
If you have any questions about how we Protect Your Privacy, we have appointed a Data Protection Officer (DPO), Denny Schenk, who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO via the contact form or by using the company’s address at
Denny Schenk (DPO)
Retromixer Ltd
11-15 Thistle Street
EH2 1DF Edinburgh
United Kingdom
you can also send an email at:
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). 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.
THIRD-PARTY LINKS
This privacy policy only applies to Retromixer’s use of data, our website, services or products, which may from time to time, 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 notice of every website you visit. Similarly, if you are directed to our website from a third party we are not responsible for the privacy policy or practices of the third party. We strongly recommend you read their policy.
THE DATA WE COLLECT ABOUT YOU
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Contact Data includes billing address, delivery address, email address and telephone numbers.
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments to and from you and other details of products and services 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 and other technology on the devices you use to access this website.
- Usage Data includes information about how you use our website, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We do not collect any Special Categories of Personal Data about you, including 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.
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 we would need your name and address. 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.
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 data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- apply for our products or services;
- create an account on our website;
- subscribe to our service or publications;
- request marketing to be sent to you;
- enter a competition, promotion or survey; or
- give us feedback.
Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies. For details, refer to our Cookie Policy.
Third parties or publicly available sources. We may exchange some data about you with some third parties as set out below
Technical Data from the following parties:
- analytics and search information providers such as Google
- advertising and social networks such as Facebook
Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as:
HOW WE USE YOUR PERSONAL DATA
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.
- 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.
- Where we need to comply with a legal or regulatory obligation.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to 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, 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.
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.
|
Purpose/Activity |
Type of data |
Lawful basis for processing |
|
To register you as a new customer |
· Identity · Contact |
· Performance of a contract with you |
|
To process and deliver your order including: · Manage payments, fees and charges · Collect and recover money owed to us |
· Identity · Contact · Financial · Transaction · Marketing and Communications |
· Performance of a contract with you · Necessary for our legitimate interests (to recover debts due to us) |
|
To manage our relationship with you which will include: · Notifying you about changes to our terms or privacy policy · Asking you to leave a review or take a survey |
· Identity · Contact · Marketing and Communications |
· Performance of a contract with you · Necessary to comply with a legal obligation · Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) |
|
To enable you to partake in a prize draw, competition or complete a survey |
· Identity · Contact · Usage · Marketing and Communications |
· Performance of a contract with you · Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) |
|
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
· Identity · Contact · Technical |
· Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) · Necessary to comply with a legal obligation |
|
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences |
· Technical · Usage |
· Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
INFORMATION ABOUT MARKETING
We may use your Identity, Contact, Technical and Usage 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).
Retromixer will not send individuals these communications unless you opt in. At any point you can ask us to stop direct marketing. Where we collect contact information from you, which may be used for marketing purposes, we will provide you with an opportunity to object to marketing.
Organizations can process personal data for direct marketing purposes where it is necessary for their legitimate interests. Retromixer has a legitimate interest in promoting its products and services but will always comply with privacy regulations and individuals’ right to object to marketing.
You will receive marketing communications from us if you have requested information from us or purchased goods from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have opted in for receiving that marketing.
We may use your personal data to enable us to provide you with targeted marketing content through social media and online. You have a choice whether you wish to receive these communications and may object at any time.
Third-party marketing
We will get your express opt-in consent before we share your personal data with any company outside Retromixer for marketing purposes. At present, we do not do any third-party marketing
Opting out
You can ask us to stop sending you marketing messages at any time 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
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 our cookie policy.
DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with external third parties set out below for the purposes set out in the table above. This includes things like performing a contract (i.e. processing payments, shipping products), for our legitimate interests and for running our business (i.e. operating our website) and complying with legal obligations.
- James & James for shipping parcels.
- Shopify; for providing a website, IT and system administration support.
- Shopify Payments & Paypal; for securing payments.
- HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
TRANSFERS OF PERSONAL DATA OUTSIDE OF THE UK
Our website is powered by Shopify Inc. and their processing of your personal data may involve transferring your data outside the European Economic Area (EEA). By using our products and services you acknowledge and agree to your personal information being transferred in this way, including to jurisdictions outside the EEA. Shopify has ensured us that whenever they transfer your personal data out of the EEA, that suitable safeguards are in place to protect the information with relevant Data Protection Legislation. For example, these safeguards might include:
- The European Commission will decide that the country or international organization has an adequate level of personal data protection
- The information will be handled by an organization that is providing a level of protection that’s approved by the European Commission. For example, the EU-US Privacy Shield Framework for organizations based in the USA
For further information on how Shopify protects your information across borders you can view their privacy policy, specifically Section 12 (https://www.shopify.com/legal/privacy), or visit their Data Processing Addendum (https://www.shopify.com/legal/dpa)
Please contact us if you want further information on the specific mechanism used when transferring your personal data out of the EEA.
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.
DATA RETENTION
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
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 requirements.
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 for tax purposes.
In some circumstances we may anonymize 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.
KEEPING YOUR INFORMATION
We’ll hold on to your information for as long as you have your account, or as long as is needed to be able to provide the services to you, or (in the case of any contact you may have with our Customer Care team) for as long as is necessary to provide support-related reporting and trend analysis only.
If reasonably necessary or required to meet legal or regulatory requirements, resolve disputes, prevent fraud and abuse, or enforce our terms and conditions, we may also keep hold of some of your information as required, even after you have closed your account or it is no longer needed to provide the services to you.
INDIVIDUALS UNDER 16
Retromixer does not intentionally, or knowingly, process personal information from individuals under the age of 16. When necessary, users under the age of 16 will be told not to submit any personal details. We will make every effort to delete any details of such users where a parent or guardian has informed us that these details have been collected.
YOUR LEGAL RIGHTS
Under data protection laws in relation to your personal data, 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.
- 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. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of 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. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to 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; (c) 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. 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 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. Where you receive direct marketing messages from Retromixer, you can withdraw your consent directly via ‘the ‘Unsubscribe’ link in the email or by emailing us.
If you wish to exercise any of the rights set out above, please contact our DPO via the contact form.
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 may 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 TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally it may 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.
CHANGES TO OUR PRIVACY POLICY
We will keep our privacy policy under regular review and will place any updates on this webpage. This privacy policy was last updated on 15 October 2018.