1. DATA CONTROLLER

The data controller who is responsible for Your personal data is Clive Christian Perfume Limited, with registered office at 3rd Floor, 32 Brook Street, Mayfair, London, W1K 5DH, United Kingdom, registration number in the Companies House of England and Wales 03538453, VAT number GB189079161 (the Controller, we, us or our in this Policy). The Controller has also appointed Nichebox S.r.l. as its representative for the processing of User’s personal data in the European Union, under Article 27 of the Regulation (EU) 2016/679. To be able to contact him and ask for possible assistance write to the e-mail address of the Controller.

CONTACT US. If You have any queries about the processing of personal data by the Controller and, in particular, to exercise Your rights (summarized in paragraph 10 below), Users may contact the Controller at its registered office or by writing via e-mail to the following address: customercare@clivechristian.com. 

2. ABOUT US AND THE CLIVE CHRISTIAN GROUP

Clive Christian Perfume Limited is a UK based independent luxury perfume house and owns/manages several brands.

Clive Christian Perfume Limited is part of a group of companies (each a ‘member’) operating under the same holding company, Nichebox UK Limited (company number 01384942), with is registered office address at 32 Brook Street, London, United Kingdom, W1K 5DH (together, the Group).

3. COLLECTION OF YOUR PERSONAL INFORMATION

Personal data 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, process and transfer the following personal data about You:

• Information You give us: You may give us information about You by filling in forms on the Site or by corresponding with us by phone, e-mail, or otherwise. This includes information You provide when You register to use the Site, search for a product, place an order on the Site, enter a competition, promotion or survey and when You report a problem with the Site. The information You give us may include Your name, address, e-mail address and phone number, financial and credit card information and personal description/title.

• Information we collect about You: With regard to each of Your visits to the Site we may automatically collect the following information:

  • Technical information, including the Internet protocol (IP) address used to connect Your computer to the Internet, Your login information, browser type and version, time zone setting, browser plug-in types and versions.

  • operating system and platform.

  • Information about Your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from the Site (including date and time); products You viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction.

  • Information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.

  • When You visit the Site, view or click on our online advertisements (including our advertisements on third party websites), visit our social media pages, we also collect certain information about Your usage or device by automated means by using technologies such as cookies, web server logs. The data collected could be some or all of: Name, Host, rawhost, urldomain, path, issecure, ishttponly, issession, expires, isnew, sessionid, timestamp, browserid.

We collect the types of personal data by using cookies and other similar technologies. We also receive such technical data about You if You visit other websites employing our cookies. Please see our cookies policy at https://www.clivechristian.com/pages/cookie-policy for further details.

Retail Partners / Dealerships

This Policy does not address any data collection at our retail partners. When You visit this Site, our social media pages, click on our advertisements, or use services or features of one of our mobile applications, we may also collect certain information about Your device or usage by automated means, including using technologies such as cookies, web server logs and web beacons. You will need to review the privacy policies of department stores or online retailers to see how they look after Your personal data.

Aggregated and anonymous data

We may also collect, use and share 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 technical data to calculate the percentage of users accessing a specific feature on our Site. 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 Policy.

Special categories of personal data and criminal offence data

We do not actively collect any special categories of personal data about You (this includes 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). Nor do we actively collect any criminal offence data about criminal convictions and offences.

4. PURPOSE AND LEGAL BASIS OF PROCESSING

4.1. We use different methods to collect data from and about You.

How we use the information: The information above that You may provide us with or that we collect from You may be used to provide the following services to You, to:

• Send You promotional materials or other communications after You provide Your consent by positively opting in to receive such materials and communications (consent to the processing of Your personal data for one or more specific purposes).

• Provide our products to You, including processing Your payment when You choose to purchase our products on the Site and delivery of the products to You (processing is necessary for the performance of a contract to which You are a party or in order to take steps at the request of You prior to entering into a contract).

• Provide services to You and operational features on the Site (processing is necessary for the performance of a contract to which You are a party or in order to take steps at the request of You prior to entering into a contract).

• Create and manage Your online account (processing is necessary for the pursuing of a legitimate interest of the Controller).

• Chat with You or respond to Your enquiries via our customer service team (processing is necessary for the performance of a contract to which You are a party or in order to take steps at the request of You prior to entering into a contract).

• Communicate special events, sweepstakes, surveys and offers through our positively opted in newsletter/email marketing (consent to the processing of Your personal data for one or more specific purposes).

• Personalised adverts displayed to You on the Site and elsewhere to Your interests and online history with us (consent to the processing of Your personal data for one or more specific purposes).

• Automated decision-making and profiling (consent to the processing of Your personal data for one or more specific purposes).

• Manage and take care of the security of the Site and registered accounts (pursuing a legitimate interest of the Controller).

• Assert or defend a right in or out of court (pursuing a legitimate interest of the Controller).

• To meet our professional, legal and regulatory obligations and to meet our insurance and audit requirements (necessary to comply with a legal obligation).

• To administer, monitor and manage our relationship with You, including ongoing monitoring, and to maintain our records, which includes legal advice, legal proceedings, such as relating to any investigations and litigation (pursuing a legitimate interest of the Controller).

In the event that we use personal data for the purposes of automated decision-making and those decisions have a legal (or similarly significant effect) on You, You have the right to challenge to such decisions under the Data Protection Laws, requesting human intervention, expressing their own point of view, and obtaining an explanation of the decision from us. Such right does not apply in the following circumstances: (i) the decision is necessary for the entry into, or performance of, a contract between the You and us; (ii) the decision is authorised by law; or (iii) You have given Your explicit consent.

Where we use Your personal data for profiling purposes, the following shall apply:

• Clear information explaining the profiling will be provided, including its significance and the likely consequences.

• Appropriate mathematical or statistical procedures will be used.

• All personal data processed for profiling purposes shall be secured in order to prevent discriminatory effects arising out of profiling.

We currently make the following automated decisions: When You visit this Site or our online advertisements or use one of our social networking or mobile applications, we collect certain information by automated means, using technologies such as cookies, web server logs and web beacons. Information may include (i) technical information, such as the Internet protocol (IP) address used to connect Your computer to the Internet, Your login information, browser type and version, time zone settings, language settings, domain, operating system, platform or other system settings, and (ii) information about Your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from the Site, products You viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information, and methods used to browse away from the page and any phone number used to call our customer service number.

We may use the information collected on this Site to deliver personalized content for market research, data analytics and system administration purposes, such as to determine whether You've visited us before or are new to the Site, and for compliance with our legal obligations, policies and procedures, including compliance with relevant industry standards and the enforcement of our general terms and conditions. We may also use the information in other ways for which specific notice is provided at the time of collection.

5.  SHARING OF YOUR PERSONAL INFORMATION

We do not sell or rent personal data, or otherwise disclose personal information we collect about You, except to the following parties (but only to the extent necessary):

• A member of our Group who provide us with services and/or to fulfil any order with You. 

• Professional advisers including bankers, solicitors, auditors and insurers who provide us with banking, legal, insurance and accounting services.

• Employees and/or collaborators of the Controller, as well as external companies and professionals with whom the Controller collaborates.

• Third party service providers who perform services on our behalf based on our instructions. We do not authorise these services providers to use or disclose Your information except as necessary to perform services on our behalf or comply with legal requirements. Examples of these service providers include entities that process credit card payments, fulfil orders, fulfil deliver/shipping services, provide web hosting and marketing activities, provide data cleansing and analytics services.

• Third-party company offering customer service.

• In addition, we may disclose information about You if we are required to do so by HM Revenue & Customs, regulators, law or legal process, to law enforcement authorities or other government officials, or when we believe disclosure is necessary to appropriate to prevent physical harm or financial loss.

• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use Your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of Your personal data and to treat it in accordance with the law. We do not allow our third parties to use Your personal data for their own purposes and only permit them to process Your personal data for specified purposes and in accordance with our instructions. 

6. DATA TRANSFERS 

As a rule, the Controller does not make transfers of users' personal data outside the European Economic Area. In any case, each company in the Group, as an independent data controller, is obliged to respect the data protection of the Users of the Site, and any transfers abroad of data that were to take place on a group-wide basis, for the sole purposes envisaged in paragraph 4, would take place on the basis of adequate protection measures. In any case, it is understood that sales relating to Users from Canada, Mexico and the United States are handled directly by Clive Christian Perfume LLC according to the US Data Protection Laws. Users may still contact the Controller at the e-mail address given in paragraph 1 for further information regarding the processing of their personal data by the Group companies.

7. INFORMATION STORAGE PERIOD

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 unauthorized 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. As a general rule we hold data for 6 years. If You would like more information on our retention periods, please let us know.

With reference to the consent given, the Controller retains the personal data of Users for a period not exceeding 4 years after collection, and then applies methods of anonymization, deletion, and/or reapplication of consent, without prejudice in any case to the possibility for Users to revoke their consent at any time, the data processing carried out before revocation remains valid.

8. PROTECTION OF YOUR PERSONAL INFORMATION

We have put in place the appropriate technical and organizational measures, e.g. data segregation systems and computerized archives, to protect personal data You provide us via our Site against accidental or unlawful destruction or accidental loss, alternation, unauthorized disclosure or access or use. 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.

9.  SOCIAL MEDIA AND USER GENERATED CONTENT

Our Site allows users to submit their own content. Please note that any content submitted to one of our social platforms can be viewed by the public, and You should be cautious about providing certain personal information e.g. financial information, address details or health issues via these platforms. We are not responsible for any content You submit, and any actions taken by other individuals if You post any content, including personal information, on one of our social media platforms whether via our Site or not. To remove or delete our apps from Your social networking account, follow the instructions from the relevant social network customer support page.

10. YOUR RIGHTS

You have the right to ask us not to process Your personal data for marketing purposes. We will usually inform You (before collecting Your data) if we intend to use Your data for such purposes or if we intend to disclose Your information to any third party for such purposes. You can exercise Your right to prevent such processing by checking certain boxes on the forms we use to collect Your data. You can also exercise the right at any time by contacting us at customercare@clivechristian.com to remove Your data from our records. 

You also 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. 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. In some cases, we may demonstrate that we have compelling legitimate grounds to process Your information which override Your rights and freedoms.

• Request the restriction of the 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 (otherwise known as ‘data portability’). 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 withdraw Your consent, we may not be able to provide certain products or services to You. We will advise You if this is the case at the time You withdraw Your consent.

• Lodge a complaint with the Data Protection Authority.

If You wish to exercise any of the rights set out above, please contact us via the details set out in the Contact Us section in paragraph 1 above.

11. THIRD PARTY WEBSITE AND LINKS

Our Site may contain links to sites, plug-ins and applications owned and operated by third parties, such as social networking sites. Clicking on those links or enabling those connections may allow third parties to collect or share data about You. Please be aware that we do not endorse, do not control and are not responsible for the privacy practices of third-party sites, even if we provide a link to those sites. The Policy presented here does not apply to such sites. These third parties may have their own privacy policies, which we strongly suggest You read and review. Our products and services may also be made available to You through third party platforms or through other third-party channels. We are not responsible for the privacy practices of any sites or apps which are not operated by companies within the Group.

12. CHANGES TO THE POLICY

Our Policy may change from time to time to reflect changes in our processing of Your personal information. Any changes to this Policy will be posted on the Site.