Privacy Policy

CONTENTS

  1. INTRODUCTION AND TERMS 
  2. WHO WE ARE AND HOW TO CONTACT US 
  3. YOUR RIGHTS 
  4. THE DATA WE COLLECT ABOUT YOU 
  5. HOW YOUR DATA WILL BE USED 
  6. LAWFUL BASIS FOR PROCESSING 
  7. LEGITIMATE INTEREST & MARKETING 
  8. WHERE YOUR DATA IS HELD 
  9. APPLICATIONS TO WORK FOR US 
  10. DATA RETENTION 
  11. DATA DELETION 
  12. DATA CORRECTION 
  13. INTERNATIONAL DATA TRANSFERS 
  14. DATA INSPECTION 
  15. CHANGES 
  16. COMPLAINTS
  17. THIRD PARTIES 

1. INTRODUCTION AND TERMS

Cut4Cloth Limited (“We “or “us”) are committed to protecting and respecting your personal data and privacy.

This privacy policy relates to how we use and collect personal data from you through your use of this website, our mobile application or when you purchase a product or service from us. It also relates to our use of any personal information you provide to us by telephone, in written correspondence (including letter and email), by SMS and in person. Please note that this website and our services are not intended for children under the age of 18 and we do not knowingly collect data relating to children.

Whenever you provide personal data, we are legally obliged to use your information in line with all applicable laws concerning the protection of such information; including the Data Protection Act 1998 and 2018 (DPA), and The General Data Protection Regulation 2016 (GDPR) together, and with other subsequent laws “Data Protection Laws”.

This privacy policy also forms part of our terms of business and is not intended to override them. This policy may be amended or updated from time to time and any revisions will be posted to this page.

2. WHO WE ARE AND HOW TO CONTACT US

2.1 For the purpose of the Data Protection Laws, the data controller is Cut4Cloth Limited, registered company number 05011885. If you want to request more information about our privacy policy or information regarding data protection you should contact us using the details provided below:

FAO: Privacy Officer
Cut4Cloth Limited t/a Frugi
Hornsby House
Wheal Vrose Business Park
Helston
Cornwall
TR13 0FG

Email: privacy@welovefrugi.com

Telephone: 01326 572828 and ask to speak to the Privacy Officer.

3. YOUR RIGHTS

Under the Data Protection Laws your rights are:

3.1 To be informed – We must make available this privacy notice with the emphasis on transparency over how we process your data.

3.2 Access – You are entitled to find out what details we may hold about you and why.

3.3 Rectification – We are obliged to correct or update your details.

3.4 Erasure – This is also known as the request to be forgotten.

3.5 Restrict processing – You have the right to ‘block’ or suppress the processing by us of your personal data.

3.6 Data portability – You have the right to obtain and reuse your personal data that you have provided to us.

3.7 Object – You have the right to object to us processing your data in relation to direct marketing and or profiling.

3.8 Rights in relation to automated decision making and profiling – We do not use automatic decision making or processing.

4. THE DATA WE COLLECT ABOUT YOU

4.1 We process Personal data. Personal data we process may include name, address and email address. It also may include IP address and cookies (Website).

4.2 Our collection methods are:

4.2.1 Through our website

4.2.2 Through engagement of our services (e.g. registering with us);

4.2.3 Purchase of products from us;

4.2.4 Submitting and enquiry to us or contacting us generally; and

4.2.5 By other communications;

5. HOW YOUR DATA WILL BE USED

5.1 We use information held about you to:

5.1.1 ensure that content from our site is presented in the most effective manner for you and for your devices;

5.1.2 provide you with information, products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes or by Legitimate Interests;

5.1.3 carry out our obligations arising from any contracts entered into between you and us;

5.1.4 allow you to participate in interactive features of our service when you choose to do so, e.g. asking a question through our website.

5.1.5 carry out necessary maintenance to our infrastructure; and

5.1.6 notify you about changes to our services

5.2 We also embrace the use of social media and may wish to process any comments made public by you

5.3 We share your data with third parties where there is a legal obligation for us to do so or we have identified a valid lawful basis as set out in the table below (please also see clause 7 below, lawful basis). We may process your personal data without your knowledge or consent where this is required or permitted by law.

5.4 You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you.

5.5 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.

Purpose/ActivityType of dataLawful basis for processing including basis of legitimate interest

To register you as a new user and 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
Profile
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 enable you to partake in a prize draw, competition or complete a survey

Identity
Contact
Profile
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, this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) and our mobile application.

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 deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

Identity
Contact
Profile
Usage
Marketing and Communications
Technical

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

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)

To make suggestions and recommendations to you about goods or services that may be of interest to you

Identity
Contact
Technical
Usage
Profile
Marketing and Communications

Necessary for our legitimate interests (to develop our products/services and grow our business)

6. LAWFUL BASIS FOR PROCESSING

6.1 We only process your data (which may include providing it to a third party) where we have identified a valid lawful basis to do so. These are as follows:

6.1.1 Contractual obligation - Where processing is necessary to comply with our obligations arising out of a contract, for example, where you have bought products from us we will use the personal data you provide to fulfil our contractual obligations e.g. taking payment /shipping.

6.1.2 Legitimate Interest - Where we use legitimate interests we will record our decision on making this decision. We rely on legitimate interest where processing of the data we hold on you does not, in our opinion, affect your rights or freedoms and is proportionate to our interests e.g. keeping you up to date with our latest products or obtaining your feedback on our service.

6.1.3 Consent - We will seek to obtain your consent to process your data outside our contractual obligations (see above) unless we have identified a Legitimate Interest (see above).

7. LEGITIMATE INTEREST & MARKETING

7.1 Where we use Legitimate Interests we will record our decision and our method on making this decision. This can be requested by you at any time.

7.2 If you are an existing contact or customer we will only contact you by postal and electronic means (e-mail) with information about services or goods which you have previously purchased from us or enquired about. If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by post or electronic means only if you have consented to this. You can choose to not receive these types of communication by contacting us.

8. WHERE YOUR DATA IS HELD

Your data is stored by us and our processors in the UK, EEA or in a country where an adequacy decision has been made by the European Data Protection Board (EDPB).

9. APPLICATIONS TO WORK FOR US

If you apply to work for us (directly or indirectly) in any role (including volunteers) we may receive data about you from third parties. In addition, we will keep the details of your application and any additional information provided to us by you or others during your application so that we can keep you informed of future opportunities that you may be interested in. If you do not wish for us to keep your details for this reason, please let us know by contacting us using the details provided in this policy.

10. DATA RETENTION

Our data retention policy is dictated by the Data Protection Laws and is available for inspection by submitting a written request using the contact details provided in this policy.

11. DATA DELETION

Under GDPR you have the right to erasure under specific circumstances. A request for your personal data to be deleted will be decided on a case by case basis and must be submitted in writing to the contact details provided in this policy.

12. DATA CORRECTION

We will correct or update your data without delay provided you make the request in writing to the contact details provided in this policy, clearly specifying which data is incorrect or out of date.

13. INTERNATIONAL DATA TRANSFERS

13.1 We may, from time to time, use services provided by companies who are based outside the EEA. Where transfers of personal data to such companies occur, we ensure that the same degree of protection is afforded to your personal data by ensuring that at least one of the following is implemented:

13.1.1 We will only transfer your data to countries deemed to provide an adequate level of protection for personal data by the European Commission through the use of an Adequacy Decision; and/or

13.1.2 We will ensure that, where certain providers are used, the necessary Standard Contractual Clauses, as verified by the European Commission, are in place to provide the same level of protection to the personal data as it would be given in the EEA.

14. DATA INSPECTION

14.1 We strive to be as open as we can be in terms of giving people access to their personal data. Individuals can find out if we hold any of their personal data by making a formal request under the Data Protection Laws. Such requests must be in writing to the contact details provided in this policy. If we do hold your personal data we will respond in writing within one calendar month of your request (where that request was submitted in accordance with this policy).

14.2 The information we supply will:

14.2.1 Confirm that your data is being processed;

14.2.2 Verify the lawfulness and the purpose of the processing;

14.2.3 Confirm the categories of personal data being processed;

14.2.4 Confirm the type of recipient to whom the personal data have been or will be disclosed, and

14.2.5 Let you have a copy of the data in an intelligible form.

14.3 Please note that you may need to provide identification in order to prove who you are to access your data.

14.4 If you agree, we will try to deal with your request informally, for example by providing you with the specific information you need over the telephone.

14.5 In the instance that we do not hold information about you we will also confirm this in writing at the earliest opportunity.

15. CHANGES

We keep our privacy notice under regular review and you should check back regularly to ensure you are aware of changes to it. We may display this notice to you from time to time to help ensure you are aware of its contents.

16. COMPLAINTS

You have the right to complain about the processing of your personal data. Please contact us using the details provided above. If you are still unsatisfied you have the right to complain to the Information Commissioners Office.

17. THIRD PARTIES

17.1 We will keep your information within the ‘organisation’ except where disclosure is required or permitted by law or when we use third party service providers (data processors) to supply and support our services to you. We have contracts in place with our data processors. This means that they cannot do anything with your personal data unless we have instructed them to do so. They will not share your personal data with any organisation apart from us. They will hold it securely and retain it for the period we instruct.

17.2 Please see below the list of services where we use third party data processors which sets out the categories of recipients of personal data.

SERVICE PROVIDED
IT Provider – Cloud Service – IT Support
Email Provider
Secure document disposal service
Referral Scheme Partner
Internal HR systems provider
Storage Facility
Cleaning service (Offices)

Accountants

Contests, poll and giveaways platform

Survey provider

User generated content provider

Online purchase fulfillment service

17.3 KLARNA

In order to be able to offer you Klarna’s payment options, we will pass to Klarna certain of your personal information, such as contact and order details, in order for Klarna to assess whether you qualify for their payment options and to tailor the payment options for you.

General information on Klarna you can find here. Your personal data is handled in accordance with applicable data protection law and in accordance with the information in Klarna’s privacy policy.

17.4 DUEL

In order to be able to offer you the Frugi Fun program, we will pass to our platform provider, Duel, certain aspects of your Duel coupon usage in order for them to monitor coupon usage. By using the Duel platform via our micro-site https://family.welovefrugi.com/ you agree to engage with Frugi and Duel for the platform services. Access and use of the Services is subject to the relevant terms set out as found in Duel's Terms of Use

General information on Duel you can find here. Your personal data is handled in accordance with applicable data protection law and in accordance with the information in Duel's Privacy Policy.

17.5 FACEBOOK

If you fill in the lead extension form within a Facebook paid ad, Facebook will hold your data outside of the European Economic Area (EEA) for a 90-day period before it is deleted. We will use this information to send you information about the Autumn/Winter 2020 Collection.

17.6 YOTPO

In order to be able to offer our customers Yotpo’s independent customer reviews, we will pass to Yotpo certain aspects of your personal information, such as name, email address, IP address and Shipping address. This is in order for Yotpo to send, receive and process customer’s product reviews. In compliance with the principle of data minimization, Yotpo only collect, store, and process data that is absolutely necessary for carrying out the purpose for which the data is processed.

General information on Yotpo you can find here. Your personal data is handled in accordance with applicable data protection law and in accordance with the information outlined in Yotpo’s privacy guide. More information can be found here.

17.7 TOTS BOTS

Where you have communicated to us that you consent, we will share your personal data with our sister company, Tots Bots Limited. The data shared will include your name, email address, IP address and any other relevant information to allow Tots Bots Limited to contact you with product information and offers which it considers relevant. Please contact us if you wish to amend your preferences regarding this sharing of your personal data.

General information on Tots Bots can be found here. Your personal data is handled in accordance with applicable data protection law and in accordance with the information outlined in Tots Bots’ privacy policy. More information can be found here