As the Rowan brand continues to go from strength to strength, we are delighted to announce that Rowan and our www.knitrowan.com website have become part of The DMC Group under the legal entity ‘Sirdar Holdings Ltd’. The DMC Group is the controller for personal data, and we are committed to protecting the privacy and security of our customers, subscribers, and visitors to our website. All of our staff shop online just like you, so we understand just how important this is.
Rowan joins The DMC Group family of brands which include Wool and the Gang, Sirdar and DMC.
1. IMPORTANT INFORMATION AND WHO WE ARE
This website is not intended for children and we do not knowingly collect data relating to children.
You can contact us in the following ways:
Email address: firstname.lastname@example.org
Postal address: Rowan, Sirdar Holdings Ltd, Flanshaw Lane, Alverthorpe, Wakefield, WF2 9ND
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 (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
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 Data includes first name, last name, username or similar identifier, title.
- Contact Data includes billing address, delivery address, email address and telephone numbers and social media account names.
- Financial Data includes bank account and payment card details. Payment details are processed by our payments processor, Adyen – regarding your payment card, we only see the last three digits of your CVV number.
- Transaction Data includes details about payments to and from you and other details of products you have purchased from us.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and (with your permission) 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 and password, purchases or orders made by you, your interests, preferences, feedback, requests for support and survey responses.
- Usage Data includes information about how you use our website (including our craft tutorials and blog) and incomplete purchases you start but don’t complete on our site.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
- Social Data includes any mentions you make of Wool and the Gang in your social media accounts.
We do not collect any Special Categories of Personal Data about you (this means details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data).
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, to provide you with the products you order). In this case, we may have to cancel a product order 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, Contact and Financial Data by filling in forms or by contacting us. This includes personal data you provide when you:
- order our products;
- create an account on our website;
- subscribe to our newsletter;
- request information about our products;
- enter a competition, promotion or survey; or
- give us feedback or contact us by email or through our website.
Cookies and similar technologies
We may obtain Technical Data from analytics providers such as advertising networks such as AdRoll and Facebook; and Contact, Financial and Transaction Data from providers of technical, payment services such as Adyen (based inside and outside the UK and EU), and delivery service providers. Social Data from service providers we engage to notify us of mentions of our brand names and our products in social media networks. You may opt-out of this processing at any time.
4. HOW DO 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 (that is, the contract for delivery of our products to 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 obligation.
Click here to find out more about the types of lawful basis that we will rely on to process your personal data.
Purposes for which we will use your personal data
We have set out in a table at the end of this document, a description of all the ways we plan to use your personal data, and the legal basis we rely on to do so. In brief, we use your data:
- to register you as a new customer
- to process and deliver your order
- to manage our relationship with you
- to enable you to enter in a prize draw, competition or complete a survey
- to run and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
- to deliver relevant website content and advertisements to you and measure or understand the effectiveness of our advertising
- to use data analytics to find out what products you like, improve our website, products, marketing, customer relationships and experiences
- to make suggestions and recommendations to you about products that may be of interest to you
- to run our ‘refer-a-friend’ programme
- to communicate with you regarding the use of any of your social media content in our marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We may use data we process about you 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.
If you buy or enquire about our products or sign up for our newsletter, then (unless you opt out), we may send you promotional info about our products by post, SMS and email. You can opt-out at any time.
You can ask us to stop sending you marketing messages at any time by following the Unsubscribe links on any marketing message sent to you or by contacting us at any time.
Like many companies, we may serve you with banners and ads when you are on other websites and apps. We try to serve you with ads you’ll be interested in. We do this using a variety of digital marketing networks and ad exchanges, and we use a range of advertising technologies like web beacons, pixels, ad tags, cookies, and mobile identifiers, as well as specific services offered by some sites and social networks, such as AdRoll and Facebook’s Custom Audience service.
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.
5. DISCLOSURE OF YOUR PERSONAL DATA
We may share your personal data with the parties set out below for the purposes set out in the table at the end of this policy.
- Other companies in the DMC Group (which Rowan is a part of) who provide, IT and system administration services and undertake group-wide business admin and reporting.
- Service Providers who help us with delivery and order processing and fulfilment.
- Digital agencies and service providers acting as processors who provide us with marketing, IT, website optimisation and system administration services – including Heroku, Amazon Web Services, Spark Solutions.
- Service providers acting as processors who help us refine and target our ads and marketing communications, and our engagement with social media users – for example, Optimove, MentionMe and Pixlee.
- Email service providers acting as processors who help us distribute and analyse responses to our email communications – including MailChimp and Optimove.
- We use AdRoll and Facebook services to show advertising on third party websites to previous visitors to our site. You can opt-out of remarketing by AdRoll by visiting this link: https://help.adroll.com/hc/en-us/articles/216599538-Opting-Out-of-Personalized-Advertising. You can opt out of remarketing by Facebook here: https://www.facebook.com/help/146952742043748.
- Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.
6. INTENATIONAL TRANSFERS
Some of our external service providers are based outside the UK and EEA (including our fulfilment centre in the USA) - their processing of your personal data will involve a transfer of data outside the UK and EEA. Whenever we transfer your personal data out of the UK and 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 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 here.
- 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 here.
- 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 Europe and the US.
7. 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.
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect of our relationship with you.
In some circumstances you can ask us to delete your data: see [your legal rights] below for further information.
In some circumstances we will 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.
9. LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
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. If you would like to make a request for access please see our contact details in section 1 above. 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 could refuse to comply with your request in these circumstances.
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. 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.
Where we are processing your personal data for direct marketing purposes, you have the right to object at any time, e.g. opt-out or unsubscribe.
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:
- If you want us to establish the data's accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- 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.
- 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.
Responding to requests. If you make one of the requests above 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. We try to respond to all legitimate requests within one month. Occasionally it could 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.
Table of Purposes for which we process your data, and the legal basis on which we do so
About Lawful Basis for Processing
In the third column of the table above, various ‘lawful bases’ for processing data are specified. The following is a guide to each.
Legitimate Interest means 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.
Our legitimate interests include:
- to receive payment for our products and ensure a smooth ordering process for our customers;
- to keep our records updated, to help us and customers complete unfinished transactions, and to study how customers use our products/services;
- to study how customers use our products and services, to develop them and grow our business;
- for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business re-organisation or group restructuring exercise;
- 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; and
- to promote our products and services, develop our products and services, and grow our business.
Performance of Contract means 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 obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
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