CCPA Compliance
CORRECT AS OF Monday 31st October 2022
At Raith Ltd., we are 100% committed to protecting your privacy and security.
For all Raith Ltd. services, the data controller — the company that’s responsible for protecting your privacy— is Raith Ltd.
This Privacy Notice helps you to understand how we use your personal information, who we share it with and the rights that you have. For more information on your rights and how to exercise them, head straight to the Your Rights section later in this document.
We change the terms of this Privacy Notice from time to time and you should check it regularly. If we make any material changes we will take steps to bring it to your attention.
YOUR RIGHTS
You have a number of ‘Data Subject Rights’. Below is some information on what they are and how you can exercise them. There is more information on the Information Commissioner’s website www.ico.org.uk
- Right of access - You have the right to request a free copy of the personal information that we hold about you.
- Right to rectification –If you think any of your personal information that we hold is inaccurate, you have the right to request it is updated. We may ask you for evidence to show it is inaccurate.
- Right to erasure (also known as the Right to be Forgotten) and the Right to restriction of processing – You have the right to request that we stop processing, or delete, all of your personal information that we hold. If you exercise this right we will keep a note of your name linked to your request and it won’t prevent us from processing any information provided subsequent to your request.
- Right to data portability – You have the right to ask us to electronically move, copy or transfer your personal information in a machine readable format.
- Rights with regards to automated decision making, including profiling –We sometimes use your personal information to make decisions by automated means. This involves us analysing your account activity including applications, orders, payments etc. We do this to confirm your identity, prevent and detect crime. This automated decision making is necessary if you would like to continue to shop with us online.
- Right to withdraw Consent – Where we are relying on your consent for processing you can withdraw or change your consent at any time.
The above rights may be limited in some circumstances, for example, if fulfilling your request would reveal personal information about another person, if you ask us to delete information which we are required to have by law, or if we have compelling legitimate interests to keep it. We will let you know if that is the case and will then only use your information for these purposes. You may also be unable to continue using our services if you want us to stop processing your personal information.
If you have any general questions or want to exercise any of your rights please contact customerservices@raith-clo.com . Our security procedures mean that we may need to request proof of identity before we disclose personal information to you in response to any request.
We encourage you to get in touch if you have any concerns with how we collect or use your personal information. You do however also have the right to lodge a complaint directly with the Information Commissioners Office, the data protection regulator in the UK, their contact details can be found on their website www.ico.org.uk
THE LAWFUL BASES WE USE TO PROCESS DATA
We will only ever process your information if we have a lawful basis to do so. The lawful bases we rely on are:
- Contract –This is where we process your information to fulfil a contractual arrangement we have made with you.
- Consent –This is where we have asked you to provide explicit permission to process your data for a particular purpose.
- Legitimate Interests -This is where we rely on our interests as a reason for processing, generally this is to provide you with the best products and service in the most secure and appropriate way.
- Legal Obligation –This is where we have a statutory or other legal obligation to process the information, such as for the investigation of crime.
THE INFORMATION WE COLLECT AND HOW WE USE IT
In summary, we collect and use the information that you provide to us directly, for example when you register for an account; we may also use cookies and other similar technologies to collect information from your devices when you interact with our advertising or use our website; we keep records when you speak to our customer service teams; take email addresses to allow us to generate e-receipts and we take personal information from a number of third parties to help us manage your account and improve your shopping experience.
For more detailed information you can read the below which outlines how we use your personal information:
To process any orders that you place with us and to facilitate any returns (Contract and Consent)
- We take payment details to process payment for any credit or debit card orders you place with us. We share these details with our chosen payment processors (for example Worldpay or Paypal)
- We use your account information plus your chosen delivery address details to deliver your purchases and keep you informed of their status, and to process any returns including (where appropriate) collecting the item from you.
- Our chosen payment processors store your payment card details at your request to speed up your checkout in the future.
- We collect your email address to allow us to send you an e-receipt.
To provide you with access to an account (Contract)
- To register an account with us we capture information such as your name, date of birth, contact and delivery information, and a password to protect your account (account information). We use the same information on an ongoing basis to manage and provide secure access to your account, and provide you with the services you request.
To provide customer service to you (Contract and Legitimate Interest)
- We keep correspondence (customer service records) when you contact our customer service teams or interact with us on social media. We use these customer service records to manage your queries or complaints effectively, for quality monitoring and to continually improve our services.
To personalise and improve your experience when you shop (Consent and Legitimate Interest)
- We keep a record of how you interact with our website and any marketing you are exposed to. We use this data, along with purchase history, demographics, account information and third party information, to show you products and offers from across our brands that we think you will be most interested in and to tailor your experience.
- We use your account information, information on the devices you use to access our sites, and your interactions with us to operate personalised features across our website and communications.
To inform you about products and services that may interest you (Consent)
- We use technologies such as cookies within digital marketing networks, ad exchanges and social media networks such as Facebook’s Custom Audience to get relevant marketing messages across to you and other customers. We share aggregated and anonymised information about the customer segments we are interested in reaching with advertising partners, so they can focus on showing adverts to those who are most likely to be interested in our products, services and offers, and to prevent them showing you irrelevant or repetitive advertisements.
- We share limited information with selected suppliers to enable them to identify new prospective customers on our behalf and to prevent us repeatedly advertising products or services you have already bought.
- We receive information on how you interact with our adverts and content on third-party websites and social media platforms (such as Google or Facebook) which we use to tailor the information that is displayed to you.
To keep in touch with you (Legitimate Interest and Consent)
- Unless you tell us you don’t want us to, when you register for an account and shop with us we start to keep you up to date with news of products and services, offers, promotions and Sale information. You can change your preferences at any time by accessing your online account or by using the link in every email that we send to you.
- When we send you communications we use records of how you interact with our website and any other marketing we’ve sent to you, along with purchase history, to tailor the messages to include information you are most likely to be interested in.
- We use your account information to notify you about important service messages, such as material changes to this policy or information about your account.
To ensure the Website and the services we offer you operate properly (Legitimate Interest)
- We use cookies and similar technologies to keep track of your preferences when using our site.
- We use other cookies and similar technologies to help us understand how you use the site, this allows us to optimise your shopping experience and continually improve our site.
- We gather information about the devices you use to access our sites (desktop and mobile) for example your IP address and device type, to ensure the site is secure and works across multiple platforms.
- We use information for Logistics planning, demand forecasting, management information, dealing with errors on our site, and general research and development.
To develop and improve our products, range and services (Legitimate Interest & Consent)
- We may contact you to take part in customer satisfaction surveys. If you respond we collect your feedback and contributions (customer feedback). We use this information to develop the services we offer.
- We use information about how you browse and engage with our website to improve our websites.
- We use all information, including third party data in the development of new products, services and systems to ensure they work as expected and will be useful to our customers.
To enable you to partake in an event, prize draw or competition (Consent)
- Where you interact directly with the promotion of an event, prize draw or competition, and you provide your consent, we will use the details you provide, specific in that instance, to send invites, identify entrants and winners, or to enter you into the competition, online with the terms and conditions.
To prevent and detect crime (Legitimate interest/Legal obligation)
- We use your account information, order history and payment history to assist in monitoring for fraudulent transactions or suspected money laundering.
- When you register an account or contact our call centres we use your account, application and purchase history information to confirm your identity.
- We use device identifiers and IP addresses in fraud prevention and investigation, and to maintain network and data security.
To fulfil our legal obligations (Legal obligation)
- We use your data to ensure we comply with any requirements imposed on us by law or court order, including disclosure to law or tax enforcement agencies and authorities or pursuant to legal proceedings.
- We will share data with regulatory and other official bodies if they make formal requests.
- We will maintain records to meet regulatory and tax requirements.
- We will use your account information to contact you in connection with product recalls or other similar product quality issues and to comply with our legal obligations in connection with the sale of age restricted products.
HOW LONG WE KEEP IT FOR
When you place an order through the Site, we will maintain your Order Information for our records unless and until you ask us to delete this information.
If you no longer wish to be a customer you can contact our customer services and request we remove information. However, we have a legal requirement to keep some of your personal data even after you have asked us to delete it. We will only keep what we absolutely need to, and only make sure we can meet our legal or regulatory requirements, resolve disputes, prevent fraud and abuse or enforce our terms & conditions.
THIRD PARTIES WE SHARE DATA WITH AND RECEIVE DATA FROM
We work with a number of trusted third parties to provide you high quality goods and services.
We always make efforts to anonymise data and only pass over personal information that is absolutely necessary for the purposes it is being processed. We always do so securely.
We have contracts in place with all suppliers that help us to ensure security and privacy of your personal information, these are reviewed and updated regularly and always in line with data protection laws.
- Delivery Partners –Helping us to deliver the goods you order to you.
- IT Companies –Supporting us in maintaining our website, provide our in store shopping services, and other business systems including; Shopify apps, data storage facilities, and providing and supporting Cloud based infrastructure used in providing our products and services.
- Marketing Companies and Online Advertising -Helping us to manage our electronic communications to you and to help us show you the advertising you are most likely to be interested in. Companies that provide marketing and advertising assistance (including management of email marketing operations, mobile messaging services such as SMS, and services that deploy advertising on the internet or social media platforms, such as Facebook and Google) as well as analysis of the effectiveness of our advertising and communications campaigns.
- We use technologies such as cookies, pixels, and device ID’s within digital marketing networks, ad exchanges and social media networks such as Facebook’s Custom Audience to get relevant marketing messages across to you.
- Payment processors -Payment card processors to process credit and debit card payments and store payment information; for example Worldpay and Paypal.
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Fraud prevention services -Before we provide goods and services to you, we use third parties to undertake fraud and money laundering checks and verify your identity. These organisations will report to us on industry fraud indicators and if they have reason to believe an identity is fraudulent.
If we have reason to suspect fraud or other criminal offences we will pass your personal information law enforcement for the detection, investigation and prevention of crime. If we think there is a risk of fraud, we may suspend activity on your account or refuse access to your account and/or cancel an order. If we do this we will inform you by email or SMS and ask you to contact us.
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Research and analytics companies -We may share personal details to allow research companies and feedback providers to contact you directly on our behalf in order to capture your opinions on our products, services, websites and apps. We may ask these research companies to analyse the results so that we can better understand your online experience, which will help us to improve our services. We only provide them with the information they need to perform their function. This may take the form of a survey, where you may be asked to review a product or service you’ve bought or provide general feedback on our products and services. You will always have the choice about whether to take part in our market research or surveys. We may share information with specialist companies to analyse customer information to help us better understand how you use our services and to tailor products, services and offers that may be relevant for you.
We utilise companies that help us track and record the way you navigate our website, so that we can understand your online experience and use it to improve our services and offer a more personalised experience.
- General service companies -Such as printers and mailing houses that assist us in providing our products and services.
- Regulators and the Police -We will share data with regulators and other official bodies (including law enforcement) if they make formal requests or pursuant to legal proceedings.
- Future mergers and acquisitions -In the future your data may be transferred to another data controller as part of a merger or acquisition.
SENDING INFORMATION OUTSIDE THE EUROPEAN ECONOMIC AREA
Our main operations are based in the UK and your personal information is generally processed, stored and used within the UK and countries in the European Economic Area (EEA). In some instances your personal information may be processed outside the European Economic Area. We also work with suppliers and partners who may make use of Cloud and /or hosted technologies across multiple geographies.
If and when this is the case we take steps to ensure there is an appropriate level of security so your personal information is protected in the same way as if it was being used within the EEA.
Where we need to transfer your data outside the UK or EEA we will use one of the following safeguards:
- The use of European Commission approved standard contractual clauses in contracts for the transfer of personal data to third countries.
- Transfers to a non-EEA country with privacy laws that give the same protection as the EEA.
COOKIES
We use cookies and similar technologies (“Cookies”) on www.raith-clo.com for identification, analysis and advertising purposes. By using our Site you consent to the storing and accessing of Cookies on your device.
This cookie policy (“Cookie Policy“) is intended to inform you how we use Cookies to assist you in making informed decisions when using the Sites. Please take a moment to read and understand this Cookie Policy. This Cookie Policy should also be read in conjunction with our Privacy Policy and our Terms and Conditions.
Cookies are very small text documents or pieces of software code, which often include an anonymous unique identifier. When you visit a website or use a mobile application, a computer asks your PC or mobile device for permission to store this file on your computer or mobile device and access information from it. Information gathered through Cookies include the date and time of visits and how you are using the website or mobile application.
Our use of cookies generally requires your consent - When you first access our Site you will be asked to consent to our use of the Cookies described in this Cookie Policy – this will give you a full break down and allow you to choose specifically which Cookies you allow or block.
Our Sites also uses Cookies for which we do not require your consent. This Cookie Policy refers to these Cookies as “Strictly Necessary Cookies” and without them the services that you have asked for cannot be provided.
What happens when you do not consent to cookies and or you choose to block cookies that you have previously accepted?
In order to use some parts of our Sites you will need to consent to Cookies. If you choose to withhold consent, or subsequently block cookies, some aspects of our Sites may not work properly and you may not be able to access all or part of Sites.
What cookies do we use?
The list below sets out more information about the individual Cookies used on our Sites and the purposes for which they are used:
Essential Cookies
Essential cookies are those that are required for raith-clo.com to function correctly. If you choose to block these cookies you may finds elements of site functionality do not work, or that you are unable to place an order.
Analytics Cookies
Analytics Cookies are used by us to understand how customers use our site, this allows us to understand where we can improve the site and how quickly the site is loading.
Internet Advertising Cookies
We use Internet advertising cookies to measure the effectiveness of our advertising, understanding which advertising you click on and interact with. We then may use this to tailor more relevant advertising.
Social Cookies
Social cookies allow us to include social sharing functionality on our website (e.g. the Facebook Like button), social cookies are also used to measure the effectiveness of any advertising we do across social networks.
We hope this explains things clearly – and please be aware you can set your browser to reject cookies or you can delete them yourself if you wish. For full information on how to delete cookies please visit aboutcookies.org (this will open in a new window – please note that we can't be responsible for the content of external websites).
THIRD-PARTY APPS, WEBSITES AND SERVICES
If you use any third-party apps, websites or services to access our services, your usage is subject to the relevant third party's terms and conditions, cookies policy, and privacy notice. For example, if you interact with us on social media, your use is subject to the terms and conditions and privacy notices of the relevant social media platform (Facebook, Twitter etc.). The same stands if you use third-party services, like Amazon's Alexa, as your use of the service is subject to their applicable terms and conditions. We may be required to share customer information relating to transactions and use of such third party services with that third party.
Minors
Customers need to be over 16 years old to create an account with us and to sign up to receive our newsletter. We do not knowingly collect Personal Data from children under the age of sixteen (16). If you are under the age of sixteen (16), please do not submit any Personal Data through the Services. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide Personal Data through the Sites and Services without their permission. If you have reason to believe that a child under the age of 16 has provided Personal Data to us through the Services, please email us at, info@raith-clo.com; and we will endeavour to delete that information from our databases.
HOW YOU CAN GET IN TOUCH
Should you need to contact us please write to: