Craftypups respects your privacy and is committed to protecting your personal data. This Privacy Policy will tell you how we look after your personal data when you visit our website and inform you of your privacy rights and how the law protects you.

Please use the Glossary at the end of this Privacy Policy to understand the meaning of some of the terms used in it.

If you are using our Facebook craftypups page, then you are also agreeing to the Facebook terms and conditions of use, including where they differ from our policy below. Please review Facebook’s information for more details.

1. IMPORTANT INFORMATION AND WHO WE ARE

Purpose of this Privacy Policy

This Privacy Policy aims to give you information on how craftypups collects and processes your personal data through your use of this website, including any data you may provide through the website when you sign up to receive our marketing material, purchase a product or service or take part in a competition.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this Privacy Policy together with any other privacy notice on our website from time to time so that you are fully aware of how and why we are using your data.

Controller

Craftypups is the controller and responsible for your personal data (collectively referred to as, “we”, “us” or “our” in this Privacy Policy).

We have appointed a data protection lead (DPL) who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact us and state that your query is for the attention of the DPL.

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 (https://ico.org.uk). In the UK, please read: https://ico.org.uk/for-the-public/raising-concerns/for details of how to do this. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the Privacy Policy and your duty to inform us of changes

We may need to update this Policy at any time and without notice and where we do this, we will notify you by including pop up boxes on the website and/or emailing our customers. This Policy was last updated on 04 March 2019.

It is important that the personal data we hold about you is accurate and up to date. Please keep us informed if your personal data changes during your relationship with us and periodically review your account settings on our website.

Third party links

This website may 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 Policy of every website you visit.

2. THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together, as follows:

• Identity Dataincludes first name and last name. It also includes your gender, if you choose to provide it to us.
• Contact Datameans the data we use to contact you including your billing address (if you purchase a product through PayPal), delivery address, email address and telephone number.
• Financial Datameans the payment method and card association used to process your payments for your orders. We do not store or process your card details ourselves, they are processed and stored via one of our contracted third party service providers. We encrypt your payment card details in your browser and securely transfer this data to our relevant third party payment provider to process a payment.
• Transaction Datameans details about transactions you have made on our website including the payments to and from you along with other details of products and services you have purchased from us.
• Technical Datameans details about the device(s) you use to access our website including your internet protocol (IP) address, browser type and version, location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
• Profile Data includes your username (email address), your login data, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Dataincludes information about how you use our website, products and services. This includes your browsing patterns and information such as how long you might spend on one of our webpages and what you look at and for on our website, the page that referred you to our site and the click stream during your visit to our website, page response times and page interaction information (clicks you make on a page).
• Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.

We also collect, use and share aggregated and/or anonymised data (“Aggregated Data”) such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

If you fail to provide personal data

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, where you do not provide suitable delivery instructions to provide you with goods or services). 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.

3. 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 Identity Data, Contact Data, Transaction Data, Profile Data, Financial Data and Marketing and Communications Data by using our website, filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you
• purchase a product through our website;
• create an account on our website;
• request marketing to be sent to you;
• enter a competition; or
• give us some feedback.
• Automated technologies or interactions. As you interact with our website, we may automatically collect Usage Data and Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our Cookies Policyfor further details.

4. THIRD PARTY SOURCES OF DATA/DATA SHARING

We also collect from and share data with the following providers:

• Essential Service Providers:Sometimes, other businesses give us data about you which we may need for our legitimate interests of conducting business with you and on occasion they are necessary to perform our contract with you. It usually comprises Financial Data or Transaction Data. This happens when we link through to third party payment providers. They tell us that you have paid for your products and, where relevant and/or necessary they will provide us with your Contact Data and Transaction Data. We also might engage third party contractors to provide us with technical or delivery services that are related to your account with us.
• Professional Advisers and Investors:We may also share your data with professional advisers such as our lawyers and insurers to manage risks and legal claims, and/or as part of our relationship and obligations to our investor organisations. This is in our legitimate interests.
• Group:It is possible we could sell our business to a third party or re-organise our business or become insolvent. In that scenario, our database of customers is one of the biggest parts of that business and so we would need to share it with the third-party buyer and their advisers. This is in the legitimate interests of selling our business. We may also expand our group of companies and in this scenario we may share your data within our group in order to improve our products and services and because of some of our internal support services may be shared across the group. This is in our legitimate interests of cost efficiency and growing our business. Where this occurs, we will post a link to all group companies and their locations in this Privacy Policy and they will use it in the ways set out in this Policy.
• Law Enforcement/Legal Compliance:We will cooperate with all third parties to enforce their intellectual property or other rights. We will also cooperate with law enforcement requests from within or outside your country of residence. This may include disclosing your personal information to government or law enforcement agencies, or private parties, when we have a good faith belief that disclosure is required by law or when we, in our discretion, believe that disclosure is necessary to protect our legal rights, or those of third parties and/or to comply with a judicial proceeding, court order, fraud reduction or legal process served on us. In such cases, we may raise or waive any legal objection or right available to us. These uses of your data are in our legitimate interests of protecting our business security. We may also use your data and share it with the recipients listed in this Privacy Policy for the purpose of complying with our legal obligations.

The lawful bases for sharing and processing this data is set out in the table belowand please refer to the External Third Partieslisted in the Glossary for further information.

5. 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.

See the Glossary at the end of this Privacy Policy to find out more about the types of lawful basis that we will rely on to process your personal data.

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 to change your preferences.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we may 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.

We do not conduct any automated decision making. We may on occasion profile our customers for the purposes of targeting marketing at them and where this is done, this is undertaken for our legitimate interests of ensuring our marketing is relevant to its audience. For example, we may classify an appropriate audience for a promotion by what products on our website they have previously looked at or expressed an interest in. We do not conduct any online behavioural tracking.

Marketing

We may use your Identity, Contact, Technical, Usage and Profile 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 only use the data you provide to us directly for this purpose along with the Aggregated Data provided to us by our analytics partners and we do not track what other websites you may visit after visiting our site, though in common with most websites, we may register the site which referred you to our site (e.g. a search engine).

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

We generally only send electronic marketing - such as email marketing - to people who have previously bought similar products from us and this is in our legitimate interests. We will always strive to offer a way out of receiving this marketing when you first purchase our products and in every marketing communication afterwards.

Where you have not previously bought from us but have registered your details with us (for example by entering a competition or signing up for a newsletter), we will only send you marketing communications if you opted into receiving marketing at the time and so given us your express consent (which you may withdraw at any time – see Opting out below).

Opting out

You can ask us to stop sending you marketing messages at any time by contacting us at any time and requesting an adjustment to your marketing preferences.

If you opt out of receiving email marketing from us, we will no longer share your email address with social media platforms (see ‘External Third Parties’ below). However, you may continue to see our ads through them, due to their general demographic targeting. Please check the social media platforms for more detail of how to opt out from seeing these ads.

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, or related correspondence, and we will continue to process such data in accordance with this Privacy Policy and only ever as permitted by law.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

6. DISCLOSURES OF YOUR PERSONAL DATA

We require all third parties to respect the security of your personal data and to treat it in accordance with the law and they may only use your data for the purposes we specify in our contract with them. We will always work with them to protect your privacy.

7. INTERNATIONAL TRANSFERS

Some of our External Third Parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact usif you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

8. 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.

You acknowledge that the Internet is not a completely secure medium for communication and, accordingly, we cannot guarantee the security of any information you send to us (or we send to you) via the Internet. We are not responsible for any damages which you, or others, may suffer as a result of the loss of confidentiality of such information.

9. 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. For example, details of your orders will be kept for as long as we need to retain that data to comply with our legal and regulatory requirements. This is generally 7 years unless the law prescribes a longer period.

In some circumstances you can ask us to delete your data: see ‘Your Legal Rights’below for further information.

In some circumstances we may anonymise 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.

10. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under UK 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 for example where you consider that we do not need it any longer for the purposes for which we originally collected it as explained to you in this Privacy Policy, where you have withdrawn your consent to our using it and we had relied on that consent according to this Policy, where you consider that we cannot show a ‘legitimate interest’ in continuing to process it and we have relied on that legitimate interest to process it as explained to you in this Policy . 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 wish to exercise any of these rights, please contact us, marking your query for the attention of the DPL.

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 limit 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.

11. GLOSSARY

Lawful basis

Legitimate Interestmeans the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contractmeans processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligationmeans processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

External third parties

Cloud storage providers- we use cloud computing platforms that securely store all of our data, including customer details.

Email service providers- in order to send you marketing content and transactional emails, we share your details with our email service providers.

Social Media Platforms- We may make your name and email address available to companies in order to advertise and market our services to you through other platforms on the internet (e.g. Facebook). See the ‘Marketing’ section of this Privacy Policy above.

Analytics tools- we use analytics tools to track the way that users interact with our website.

Profiling tools- we use profiling tools to understand how you engage with our website and show you content we think will be most relevant to you, based on our understanding of your interests and preferences.

Payment providers- in order to facilitate any payments made on our site, we facilitate the sharing of your Financial Data with payment providers.

Delivery providers- in order to package and mail your orders to you, it is necessary to share your information with delivery providers.

Marketing and insights providers- marketing and insights tools allow us to understand our customers better so that we may provide you with the best possible website, products and customer service experience. We may share certain information about our customers to facilitate this process.