PRIVACY NOTICE

1. Who we are and what we do

Startsmart is a children’s clothing retailer producing high quality clothes that are smart, classic and good value for money. We can be contacted  at Startsmart, 3 Manor Close, Ditcheat BA4 6QT or on 01749 860938.

2. the first point of contact for data protection

If you have any concerns or queries about our data protection procedures, please contact Lucy Barber on 01749 860938 or sales@startsmart.co.uk.

3. Why we process data

We sell directly to customers at events in the UK and Europe alongside sales through our website and directly to customers who telephone our office.

If you are one of the suppliers we work with to make our clothes or supply us with services, then we process your data and finance details as part of our ongoing working relationship.

4. Legal bases for processing your data including any explanation of legitimate interests

The law on data protection sets out a number of different reasons for which a company may collect and process your personal data. Some of these reasons, set out below, are the bases we have for processing your personal data:

Consent
In specific situations, we can collect and process your data with your consent. For example, when you opt in to receive our newsletter or exclusive email offers.

When collecting your personal data, we always make it clear to you which data is necessary in connection with a particular service.

Contractual obligations
In certain circumstances, we need your personal data to comply with our contractual obligations.

We need to collect and retain your contact details, so we can, for example:

• Supply you with goods or;
• Enter into a contract with you to supply us with goods or services

Legal obligations
If the law requires us to, we may need to collect and process your data.  

For example, we are obliged to retain certain information for HMRC tax and accounting purposes or to comply with other legislative provisions.

Legitimate interest
In particular circumstances, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests.

For example, we retain customer and supplier information for six years beyond the contract period, in order to maintain a good working relationship with these individuals.

If you are a customer or supplier we may also use your address details to send you direct marketing information by post or email, telling you about our latest products and promotions that we think might interest you, based on our previous dealings.

5. When we collect data

Via our website
When you order via our website, your name, addresses and phone number are collected to enable us to deliver your order to your address. We also collect this information if you use the form to contact us online with an enquiry about your order, or a general question about Startsmart.

At exhibitions
We have the facility to process payments taken for purchases at our exhibitions and events. We will only collect other data from you (name, addresses and contact number) if the item you wish to purchase is out of stock and needs to be ordered from our Head Office and delivered to you.

Alternatively, if we’re at an event without any coverage for our mobile card terminals then we will use a manual imprinter to obtain an imprint of your card on a paper voucher and complete all card details on the voucher. The imprint of the card on the paper voucher proves that the card was present when the transaction took place. We will also collect your name, phone number and postcode in order to submit the transaction as per the applicable merchant instructions.

Phone or email
If you make an enquiry or order over the phone or by email, we will use the details you give us to process your payment and confirm your order. These details will be your name, addresses, phone number and payment details.

6. What data we collect

• Contact information including: name, address, phone number and email address
• We collect your payment details when you place an order with us via our website, over the phone or at an exhibition
• New online customers will be given the option to create an account when you first order from us
• If you are a supplier, we also collect your data as part of our ongoing contract and to process invoices and payments.

Our website uses cookies. A cookie is a small file of letters and numbers that we put on your computer if you agree. These cookies allow us to distinguish you from other users of the website which helps us to provide you with a good experience when you browse our website and also allows us to improve our site.

For example, the cookies we use are ‘analytical’ cookies. They allow us to recognise and count the number of visitors and to see how visitors move around the site when they’re using it. This helps us to improve the way our website works, for example by making sure users are finding what they need easily and by helping you enter our site without having to re-login.

7. How we use your personal data

• We process data to enable us to process customer orders and deliver these to the correct addresses
• Customer bank details will only be used when placing and processing an order
• We hold your telephone number and addresses so that we can contact you via phone, post or email regarding the products and promotions that we think you might be interested in, based on our dealings with you

8. How long we keep your personal data

Whenever we collect or process your personal data, we only keep it for as long as is necessary for the purpose for which it was collected.

At the end of that retention period, your data will be deleted completely. Some examples of our data retention periods:

Purchases and Services
When you place an order, we keep the personal data you give us for 6 years so that we can retain a good relationship with you should you place any more orders or have any queries about an order.

If you opt in to our mailing list, then we keep your email address securely on our system until you unsubscribe.

Suppliers
For companies who are supplying us with our clothes, we retain your personal information for a period of 6 years so that we can, if necessary, contact you again and continue our business relationship with you.

We also need to comply with our legal contractual obligations and therefore we need to retain certain transactional information from the order for 7 years to satisfy accounting rules.
 

9. HOW WE KEEP YOUR DATA SAFE

We are aware of the need to maintain the correct and highest-level security when processing your personal information. We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorised way.

We take the following steps to maintain the security of your personal information:

• We keep all your information in systems that are secure, using Microsoft Office 365 and CyberTech Digital Ltd
• Access to customer information is limited to those who need access for the performance of their job.
• We maintain firewalls and anti-virus software
• Our systems are password protected
• Any data which is accessed off site or on a mobile device is kept locked when not in use and never left unattended

Data collected at exhibitions or events including Terminal receipts, paper vouchers and other transaction records are kept and transported securely in a locked container. 

All documentation retained in paper form is kept locked in our offices and the premises is monitored with an intruder alarm which is monitored remotely.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

10. Who we share your data with

We sometimes share your personal data with trusted third parties which act only on our instruction (known as “data processors”). 

Data processors might be, for example, 3rd party accounting apps or subcontractors or delivery drivers or those companies who store data for us:

Where we share information with these companies or individuals we make sure that they also keep your data secure and that they also protect your rights. To this end, we make sure that:

• We provide only the information they need to perform their specific services.
• They may only use your data for the exact purposes we specify in our contract with them or where their terms and conditions of processing contain the correct data processor clauses under GDPR
• If we stop using their services, any of your data held by them will either be deleted or rendered anonymous.

We sometimes also share your data with third parties for their own purposes (“joint controllers”) e.g. HMRC, accountants, legal advisors.

We will only do this in very specific circumstances, for example:

• With your consent
• Where we have a data sharing agreement in place with the other party
• Where we are obliged to share the information for legal reasons

11. Where your data is processed

We do not transfer data outside of the EEA.

From time to time we may pass personal data such as your name and email address to other services that we use to send out communications (both electronic and print).

However, your personal data will remain in the EU or countries considered by the EU to have equivalent policies such as Jersey, Guernsey, Switzerland, New Zealand and Canada. Companies based in the USA that have certified with the EU-US Privacy Shield programme are also considered to be permitted destinations by the EU (this includes popular US products like Gmail, DropBox and MailChimp).

12. Your rights and who to contact

You have the following rights, which you can exercise free of charge:

If you would like to exercise any of those rights, please contact Lucy Barber on 01749 860938 or via sales@startsmart.co.uk.

OTHER RIGHTS

Your right to withdraw consent
Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent. You can do this by contacting sales@startsmart.co.uk.

Where we rely on our legitimate interest
In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. 

We will then stop processing your information unless we believe we have a legitimate overriding reason to continue processing.

Direct marketing
You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We will always comply with your request. To ask us to stop direct marketing please email us at sales@startsmart.co.uk.

Checking your identity
To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Notice. 

For us to check your identity, please:

• Let us have enough information to identify you (e.g. your full name, address and customer/supplier number or order number, if applicable);
• Let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
• Let us know what right you want to exercise and the information to which your request relates.

If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act on your behalf.

If we choose not to action your request, we will explain to you the reasons for our refusal.

Your right to contact the ICO
We would hope that you will always raise any issues with us first, and that we will be able to resolve them to your satisfaction. However, if this isn’t possible then you always have a right to complain directly to the Information Commissioner’s Office (ICO) If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data.

You can contact them by calling 0303 123 1113 (local rate) or go online to www.ico.org.uk/concerns (this opens in a new window; please note we can't be responsible for the content of external websites).

If you are based outside the UK, you have the right to lodge your complaint with the relevant data protection regulator in your country of residence.

You also have the right to take to seek a judicial remedy.

Updates to this privacy notice
From time to time we will make changes to this Privacy Notice, for example, as the result of government regulation, new technologies, or other developments in data protection laws or privacy generally. You should check our website periodically to view the most up-to-date Privacy Notice. This privacy notice was last updated on 24 August 2018.