CLIK EMPIRE LTD – trading as CLARA-OLIVIA
This Notice explains the types of personal information we may collect about you when you interact with us. It also explains how we store and process that data and how we keep it safe.
If you have any questions after reading this, please contact us.
2. Who is Clik Empire Ltd?
- Clik Empire Ltd is a privately-owned business based in the UK, ref no 08806995 – we’ll refer to it as ‘the company’ in the rest of this document.
- We currently own the website Clara-Olivia.com and Clara-Olivia is a trading name under which we operate.
- Our address is The Post House, Kitsmead Lane, Chertsey KT16 0EG, United Kingdom.
For simplicity throughout this notice, ‘we’ and ‘us’ means the company and its trading name.
3. The legal bases we rely on
The law on data protection sets out a number of different reasons for which a company may collect and process your personal data, including:
In specific situations, we can collect and process your data with your consent, such as when you ask us to send you newsletters
When collecting your personal data, we’ll always make clear to you which data is necessary in connection with a particular service.
We might need your personal details to meet our contractual obligations, such as delivering your order to you.
If the law requires us to, we may need to collect and process your data. This might be if we need to pass information to the authorities to combat fraud or other criminal activity.
In specific situations, 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.
This might be to help us send you personalised offers or to combine your information with others to understand trends and make changes to what we offer or decide on new products to sell.
4. When do we collect your personal information?
- When you visit any of our websites, and buy products from us.
- When you make an online purchase and check out as a guest (in which case we just collect transaction-based data).
- When you create an account with us.
- When you engage with us on social media.
- When you join a loyalty programme which we operate.
- When you contact us by any means with queries, complaints etc.
- When you enter prize draws or competitions.
- When you choose to complete any surveys, we send you.
- When you comment on or review our products and services.
5. What sort of personal data do we collect?
- If you have an online account with us, we might collect your name, gender, date of birth, billing/delivery address, orders and receipts, email and telephone number. For your security, we’ll also keep an encrypted record of your login password.
- Details of your interactions with us through contact forms on the website, via email or if you phone us.
- Details of your shopping preferences.
- Details of your visits to our websites and which site you came from to ours.
- Personal details such as size information from previous orders, which help us to recommend items of interest.
We’ll only ask for and use your personal data collected in order to recommend items of interest and to tailor your shopping experience with us. Of course, it’s always your choice whether you share such details with us.
- Payment card information.
- Your comments and product reviews.
- To deliver the best possible web experience, we collect technical information about your internet connection and browser as well as the country where your computer is located, the web pages viewed during your visit, and any search terms you entered.
- Your social media username, if you interact with us through those channels, to help us respond to your comments, questions or feedback.
6. How and why do we use your personal data?
We want to give you the best possible customer experience.
We use this to offer you promotions, products and services that are most likely to interest you. The data privacy law allows this as part of our legitimate interest in understanding our customers and providing the highest levels of service.
Here’s how we’ll use your personal data and why:
- To process any orders that you make by using our website. If we don’t collect your personal data during checkout, we won’t be able to process your order and comply with our legal obligations.
- We might need to pass your details to a courier to deliver what you ordered.
- To respond to your queries, refund requests and complaints. We may also keep a record of these to help in your future communication with us and to demonstrate how we communicated with you throughout. We do this on the basis of our contractual obligations to you, our legal obligations and our legitimate interests in providing you with the best service.
- To protect our business and your account from fraud and other illegal activities. This includes using your personal data to maintain, update and safeguard your account.
- To process payments and to prevent fraudulent transactions. We do this on the basis of our legitimate business interests. This also helps to protect our customers from fraud.
- If we discover any criminal activity or alleged criminal activity through our use of fraud monitoring and suspicious transaction monitoring, we will process this data for the purposes of preventing or detecting unlawful acts.
- With your consent, we will use your personal data, preferences and details of your transactions to keep you informed by email or social media about relevant products and services including tailored special offers, discounts, promotions, events, competitions and so on.
Of course, you are free to opt out of hearing from us by any of these channels at any time.
- To send you communications required by law or which are necessary to inform you about our changes to the services we provide you. For example, updates to this Privacy Notice, product recall notices, and legally required information relating to your orders. These service messages will not include any promotional content and do not require prior consent when sent by email or text message. If we do not use your personal data for these purposes, we would be unable to comply with our legal obligations.
- To display the most interesting content to you on our websites or apps, we’ll use data we hold about your favourite brands or products and so on. We do so on the basis of your consent to receive notifications and/or for our website to place cookies or similar technology on your device.
- To administer any of our prize draws or competitions which you enter, based on your consent given at the time of entering.
- To develop, test and improve the systems, services and products we provide to you. We’ll do this on the basis of our legitimate business interests.
- To comply with our legal obligations to share data with law enforcement.
- To send you survey and feedback requests to help improve our services. These messages will not include any promotional content and do not require prior consent when sent by email or text message. We have a legitimate interest to do so as this helps make our products or services more relevant to you.
- For example, we might display a list of items you’ve recently looked at, or email you to remind you what you’ve left in your shopping cart.
Of course, you are free to opt out of receiving these requests from us at any time by updating your preferences in your online account.
- To build a picture of who you are and what you like, and to inform our business decisions, we’ll combine data from our website, third parties and data from publicly-available lists as we have described in the section 'What Sort of Personal Data do we collect?' We’ll do this on the basis of our legitimate business interest.
7. Protecting your personal data
We will always treat your data with the utmost care and take all appropriate steps to protect it.
We secure access to all transactional areas of our websites and apps using ‘https’ technology and regularly changed passwords.
Access to your personal data is password-protected, and sensitive data such as payment card information) is secured and tokenised to ensure it is protected.
We regularly monitor our system for possible vulnerabilities and attacks, and we carry out penetration testing to identify ways to further strengthen security.
8. How long will we keep your personal data?
We will only keep your data for as long as is necessary for the purpose for which it was collected.
At the end of that period, your data will either be deleted completely or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning.
For example; when you place an order, we’ll keep the personal data you give us for six years so we can comply with our legal and contractual obligations..
9. Who do we share your personal data with?
We sometimes share your personal data with trusted third parties, such as delivery couriers, payment processors, for fraud management, to handle complaints and to help us personalise our service and messages to you.
Here’s the policy we apply to those organisations to keep your data safe and protect your privacy:
- 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.
- We work closely with them to ensure that your privacy is respected and protected at all times.
- If we stop using their services, any of your data held by them will either be deleted or rendered anonymous.
Sharing your data with third parties for their own purposes:
Examples of the kind of third parties we work with are:
- IT companies who support our website and other business systems.
- Delivery couriers.
- Direct marketing companies who help us manage our communications with you.
- Google/Facebook to show you products that might interest you while you’re browsing the internet. This is based on either your marketing consent or your acceptance of cookies on our websites.
- Data insight companies to ensure your details are up to date and accurate.
We will only do this in very specific circumstances, for example:
- For fraud management, we may share information about fraudulent or potentially fraudulent activity in our systems. This may include sharing data about individuals with law enforcement bodies.
- We may also be required to disclose your personal data to the police or other enforcement, regulatory or Government body, in your country of origin or elsewhere, upon a valid request to do so. These requests are assessed on a case-by-case basis and take the privacy of our customers into consideration.
- We may, from time to time, expand, reduce or sell the company and this may involve the transfer of parts or the whole business to new owners. If this happens, your personal data will, where relevant, be transferred to the new owner or controlling party, under the terms of this Privacy Notice.
- For further information please contact our Data Protection Officer.
We currently work with the following companies, who help us manage and process your personal data as part of their contracts with us:
- PayPal – for payment processing
- Braintree – for payment processing
- Springbot – for email and social media marketing
- Linnworks – for order processing and shipping
- xSellco – for customer service management
- Mailchimp – for email marketing and list management
- Google – for marketing and data management
- Twitter – for marketing and communication
- Instagram – for marketing
- Pinterest – for marketing
- Facebook – for marketing and communication
10. Where your personal data may be processed
Sometimes we will need to share your personal data with third parties and suppliers outside the European Economic Area (EEA), such as Australia or the USA.
If you are based outside the UK and place an order with us, we will transfer the personal data that we collect from you to our servers in the UK.
Protecting your data outside the EEA
The EEA includes all EU Member countries as well as Iceland, Liechtenstein and Norway. We may transfer personal data that we collect from you to third-party data processors in countries that are outside the EEA.
This might be to fulfil your order or process your payment.
If we do this, we have procedures in place to ensure your data receives the same protection as if it were being processed inside the EEA. For example, our contracts with third parties stipulate the standards they must follow at all times.
Any transfer of your personal data will follow applicable laws and we will treat the information under the guiding principles of this Privacy Notice.
11. What are your rights over your personal data?
An overview of your different rights
You have the right to request:
- Access to the personal data we hold about you, free of charge.
- The correction of your personal data when incorrect, out of date or incomplete.
- For example, when you withdraw consent, or object and we have no legitimate overriding interest, or once the purpose for which we hold the data has come to an end.
- That we stop using your personal data for direct marketing (either through specific channels, or all channels).
- That we stop any consent-based processing of your personal data after you withdraw that consent.
You have the right to request a copy of any information about you that we hold at any time, and also to have that information corrected if it is inaccurate.
To ask for your information, please contact:
Data Protection Officer, Clik Empire Ltd, The Post House, Kitsmead Lane, Chertsey, KT16 0EG, or email: firstname.lastname@example.org
To ask for your information to be amended, please update your online account, or contact us on email@example.com .
If we choose not to action your request we will explain to you the reasons for our refusal.
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.
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 must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data, which we will of course explain to you.
You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We must always comply with your request.
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. 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.
12. How can you stop the use of your personal data for direct marketing?
There are several ways you can stop direct marketing communications from us:
- Click the ‘unsubscribe’ link in any email communication that we send you. We will then stop any further emails.
- If you have an account, sign in, visit the ‘Your Account’ area and change your preferences.
- Write to us at:
Clik Empire Ltd, The Post House, Kitsmead Lane, Chertsey, KT16 0EG.
Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated.
13. Contacting the Regulator
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 have the right to lodge a complaint with the Information Commissioner’s Office.
You can contact them by calling 0303 123 1113.
Or go online to www.ico.org.uk/concerns (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. Details can be found in Section 16.
14. If you live outside the UK
For all non-UK customers
By using our services or providing your personal data to us, you expressly consent to the processing of your personal data by us or on our behalf. Of course, you still have the right to ask us not to process your data in certain ways, and if you do so, we will respect your wishes.
Sometimes we’ll need to transfer your personal data between countries to enable us to supply the goods or services you’ve requested. In the ordinary course of business, we may transfer your personal data from your country of residence to ourselves and to third parties located in the UK.
By dealing with us, you are giving your consent to this overseas use, transfer and disclosure of your personal data outside your country of residence for our ordinary business purposes.
This may occur because our information technology storage facilities and servers are located outside your country of residence and could include storage of your personal data on servers in the UK.
We’ll ensure that reasonable steps are taken to prevent third parties outside your country of residence using your personal data in any way that’s not set out in this Privacy Notice. We’ll also make sure we adequately protect the confidentiality and privacy of your personal data.
For the purposes of this Privacy Notice, ‘personal data’ means any information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether or not the information or opinion is true, and whether or not the information or opinion is recorded in a material form.
If you are in Australia you may submit any questions, comments or complaints to our UK-based Data Protection Officer who will come back to you within 30 days.
If you are contacting us to complain about an alleged breach of this Privacy Notice or our legal privacy obligations, please provide us with as much detail as possible in relation to your complaint.
We will take every privacy complaint seriously and assess it with the aim of resolving all issues quickly and efficiently. We’d be grateful for your cooperation with us during this process by providing us with any relevant information that we made need.
If we have not come back to you within 30 days, or you are not happy with the response that you’ve received, you may submit a complaint to the Office of the Australian Information Commissioner. (opens in a new window; please note we can't be responsible for the content of external websites.)
We are committed to keeping your personal information secure and will take all reasonable precautions to protect it from loss, misuse or unauthorised access or alteration. However, except to the extent liability cannot be excluded due to the operation of statute, we exclude all liability (including in negligence) for the consequences of any unauthorised access to, disclosure of, misuse of or loss or corruption of your personal information.
Nothing in this Privacy Notice restricts, excludes or modifies or purports to restrict, exclude or modify any statutory consumer rights under any applicable law including the Competition and Consumer Act 2010 (Cth).
As your data may be transferred to third parties outside Canada, local police or other enforcement, regulatory or Government bodies may have access to that data, with or without our knowledge.
The personal data we process may be accessed by people within the Partnership, or by our third-party service providers, who require access for the purposes indicated in this Privacy Notice, or as may be permitted or required by applicable law. The personal data we collect is largely held in the UK.
If you have any questions, please contact our Data Protection Officer.
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 information, you have the right to lodge a complaint with the Office of the Privacy Commissioner of Canada, (opens in a new window; please note we can't be responsible for the content of external websites) or in some Canadian provinces, your local Privacy Commissioner.
South Korea, Malaysia, Singapore, Qatar
Terms used in this Privacy Notice shall have the meanings assigned to them by the Personal Data Protection Act 2010 (also known as the PDPA).
By placing an order with us, opening an account, browsing our website and/or agreeing to receive digital direct marketing communications, you agree that we may process your personal data as described in this Privacy Notice and our Cookies Notice, including for analytics and research into website use.
When you agree to receive direct marketing emails from us, we’ll send you promotions on products we sell.
If you are in Hong Kong you may submit a complaint to our UK-based Data Protection Officer who will come back to you within 30 days. If we have not come back to you or you are not happy with the response that you receive, you may submit a complaint to the Office of the Privacy Commissioner for Personal Data.
15. Any questions?
We hope this Privacy Notice has been helpful in setting out the way we handle your personal data and your rights to control it.
If you have any questions that haven’t been covered, please contact our Data Protection Officer who will be pleased to help you:
- Email us at firstname.lastname@example.org
- Or write to us at:
Data Protection Officer, Clik Empire Ltd, The Post House, Kitsmead Lane, Chertsey, KT16 0EG
This notice was last updated on 28/05/2018