What does this policy cover?
This policy describes the processing of your personal data by Liberty Retail Limited (00042342) of 210-220 Regent Street Mayfair, London, England, W1B 5AH ("we", "us" or "our") in relation to:
- your use of our website at www.libertylondon.com (the “website”); and
- your interaction with us at the Liberty London store ("in-store")
For the purposes of applicable data protection law (including, the General Data Protection Regulation 2016/ 679 (the "GDPR"), we are a ‘data controller’ of your personal data.
Where applicable, this policy should be read alongside our terms and conditions, which tell you about the terms on which you may use the website.
What personal data is collected?
1. Personal data collected from you:
The following categories of personal data will be collected about you in connection with your use of the website and your interaction with us in-store, including, but not limited to, when you fill in forms on the website or whilst in-store, when you register to use the website or sign-up to the Liberty Loyalty (and Beauty Loyalty) Programme, when you submit user-generated content, reviews or ratings, engage in any social media functions or 'like'/ 'love' products on the website:
- Personal Identification Information: such as, your name and date of birth;
- Contact Information: such as, your email address, postal address, postcode and telephone number;
- Demographic Information: such as your gender;
- Preference Information: such as, information about the types of products you have purchased on the website, and information about the types of products you like or are interested in;
- Financial information: such as, payment card numbers; and
- Your marketing preferences, including any consents you have given us
In addition, if you contact us by phone, email or otherwise, we may keep a record of that correspondence.
2. Personal data collected about you:
- From Others: Although we generally collect personal data directly from you, we also collect certain categories of personal data about you from other sources. In particular:
- financial and/or transaction details from payment providers in order to process a transaction;
- personal contact information from our in-store wi-fi provider in order to provide you with offers and marketing communications; and
- personal contact and preference information from our events ticketing provider in order to administer in-store events and tailor our services to you
- Automatically Collected Information: such as, web browser type and version, operating system, the website you came from and exit to, your IP (Internet Protocol) address, your Device ID and Mac ID, your browser settings, the date and time of your visits, and details regarding your interaction with the website (including which pages, products or resources on the website you access), our emails and our in-store wifi network; and
- Cookies Information: in accordance with the Cookies section below
How is your personal data used, and what is the legal basis for this use?
We process your personal data for the following purposes:
- Contractual Necessity: As required to establish and fulfil a contract with you, for example: if you make a purchase from us (this will include taking payments, and arranging the delivery or other provision of products, awards or services); communicating with you and providing customer services; and in order to administer the Liberty Loyalty (and Beauty) Programmes
- Legitimate Interests: As required by us to pursue our own legitimate interests, in particular:
- facilitating the creation of, and securing, online registered accounts;
- managing, operating and improving online registered accounts (incl. enabling you to: manage your account details, manage your Liberty Loyalty (and Beauty) Account, manage your marketing preferences, track your orders, return products, and manage your wish lists), and customers’ journeys on the website;
- monitoring any online registered accounts to prevent, investigate and/or report fraud, terrorism, misrepresentation, security incidents or crime, in accordance with applicable law;
- delivering tailored advertising (incl. via Facebook look-a-like and custom audience);
- we will use data in connection with legal claims which concern our company, group or partners, compliance, regulatory and investigative purposes as necessary (including disclosure of such information in connection with legal process or litigation);
- creating user/customer insights based on user behaviour to drive targeted direct marketing;
- creating user/customer insights based on demographic segments to drive targeted email direct marketing and also carrying out market research and surveys;
- communicating with you; and
- investigating and handling any complaints received from you about our website, or our products and services
You can obtain further information on the legitimate interests balancing exercises which we have carried out by contacting us using the contact details provided below
- Legal Compliance: To ensure compliance with applicable laws and legal processes including, but not limited to, use in connection with legal claims, compliance, regulatory, tax, investigative purposes (including disclosure of such information in connection with legal process or litigation and to law enforcement agencies)
- Consent: Subject to the following, we will send you direct marketing by email, SMS, telephone, post and online about Liberty products and services which we think may be of interest to you. This will only be sent where you have given your consent to Liberty during the online sign-up process or via your online account on the website or verbally in-store, or (where permissible) you have been given an opportunity to opt out. You will be able to opt-out of electronic direct marketing by clicking the unsubscribe link contained in the email or following the instructions in the SMS itself and, in all other cases, by updating your preferences in your account on the Liberty website or by contacting us on the contact details provided below
Visitors under 16 years of age are not permitted to subscribe to our services or use and/or submit their personal information on any of our website or applications. We do not knowingly solicit or collect information from visitors under 16 years of age. We encourage parents and guardians to spend time online with their children and to participate and monitor the interactive activities of their children.
If you make a purchase on the website, we may use automated tools as part of our fraud prevention measures. This means that your purchase may be declined if your payment has been rejected by the bank or if other factors indicate that the purchase may be fraudulent. If you have any concerns, please contact us on the contact details below.
Who will your personal data be shared with, and where?
We will share your personal data with:
- members of our group of companies, including Liberty Fabric Limited, Liberty of London Limited, Liberty Limited, Liberty Zeta Limited, Liberty Theta Limited and Liberty Gamma Limited;
- third party service providers, who will process it on our behalf for the purposes above. Such third parties include, but are not limited to, logistics providers and couriers for delivery of your orders (which are located in the EU) and marketing providers (which are located in the UK, EU and US);
- government authorities and/or law enforcement officials if required for the purposes above, if mandated by law or if required for the legal protection of our own legitimate interests in compliance with applicable laws; and
- purchasers or prospective purchasers of all or part of our assets or our business, and their professional advisers, in connection with the purchase.
What cookies will be used on the website?
We don't have access to the cookies which third parties place on the website; other than allowing them to be served. These companies have their own privacy policies which we encourage you to review.
Strictly Necessary Cookies
Some cookies are essential for the operation of the website. For example, some cookies allow us to identify registered users and ensure they can access the website. If a registered user opts to disable these cookies, the user may not be able to access all of the content of the website.
Other cookies may be used to analyse how users use the site and to monitor site performance. This allows us to provide a high quality experience by customising the offering and quickly identifying and fixing any issues that arise. For example, performance cookies may be used to keep track of which pages are most popular and to determine why some pages are receiving error messages.
Functionality cookies are used to allow us to remember users’ preferences and tailor the website to provide enhanced features.
Targeting cookies are used to serve users with content and adverts, and to collect information about users' browsing habits and usage of the website in order to make adverts more relevant to users and their interests. We may use remarketing technologies to enable third parties to display relevant and personalised ads to users through their networks. They are also used to limit the number of times users see an advert as well as help measure the effectiveness of an advertising campaign.
Social Media Cookies
These cookies allow users to share what they’ve been doing on the website on social media such as Facebook and Instagram. These cookies are not within our control. Please refer to the respective privacy policies for how their cookies work.
We use Facebook services to deliver our ads to you during your browsing experience/ whilst you are online. Facebook services include the delivery of ads on other platforms owned by Facebook, such as Instagram. You can control how Facebook uses data to show you ads by turning off ads which may be based on interests and / or your relationship with specific advertisers, in your ad preference settings. For further information, please visit the various Facebook pages which allow you to learn more about Facebook ads and tracking technologies and to update your settings:
Further, by visiting the Your Online Choices link above, you can opt out from seeing Facebook's interest-based ads and you can also use your mobile device settings to configure your advertising preferences.
On your Facebook ad preferences, you will see that ads may be delivered to you according to 'interests' or specific advertisers and you can manage your ad preference settings for both of these.
Please note that where you have opted out of receiving our email marketing communications via the methods described above, you may still see our non-targeted adverts whilst you are online, if your interests settings on Facebook are aligned to an audience segment (pre-defined by Facebook) which our business is also associated with. We do not control whether these ads are displayed to you. Please see the relevant links above for details on how to learn more and manage Facebook ad settings.
Further, to learn more about adverts which are displayed to you whilst you are online, please consult the applicable website's privacy and cookies policy on which you see our ads and the Your Online Choices link above.
Users are always free to decline cookies if their browser permits, although doing so may interfere with their use of the website. More information about how to control cookies is available here ico.org.uk/for-the-public/online/cookies.
Changes to this policy
Any changes we may make to the policy in the future will be posted on the website and, where appropriate, notified to you by email or otherwise. The changes will be also available in hard-copy in store.
If you have any questions about this policy and / or our processing of your personal data, please contact us at firstname.lastname@example.org
Where can I find more information about the handling of my personal data?
See our Privacy FAQs for further details on your rights, retention periods, and international transfers.