Date of last update: 18 January 2021
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 (“Liberty”, "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, we are a ‘data controller’ of your personal data. Applicable data protection law includes, without limitation, the General Data Protection Regulation 2016/ 679 (the "GDPR"), the GDPR as amended by the Data Protection, Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations 2019 (the “UKGDPR”), and the Data Protection Act 2018), as amended and updated from time to time.
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.
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 Collective 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.
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 our Cookies Policy below.
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 Collective loyalty programme.
- 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 Collective loyalty 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.
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.
Our European representative is Liberty Fabric Service Italy S.r.l. This representative can also be contacted via email@example.com.
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.
ANNEX – Privacy FAQs
You are entitled to ask us:
- for a copy of your personal data;
- to correct your personal data (if it is inaccurate, incomplete or not up-to-date);
- to 'port' your personal data (i.e. to transfer in a structured, commonly used and machine-readable format, to you or another data controller);
- to erase your personal data; or
- restrict its processing (i.e. processing will temporarily stop (save to the extent that personal data will continue to be stored)).
You also have rights to object to some processing that is based on our legitimate interests, and to processing for direct marketing purposes. Further, where we have asked for your consent to process your data, you are entitled to withdraw this consent as more fully described above.
These rights are limited in some situations – for example, where we can demonstrate that we have a legal requirement to process your personal data. In some instances, this may mean that we are able to retain data even if you withdraw your consent.
Where we require your personal data to comply with legal or contractual obligations, then provision of such data is mandatory: if such data is not provided, then we will not be able to manage our contractual relationship with you, or to meet obligations placed on us.
We hope that we can satisfy any queries you may have about the way we process your personal data. If you have any concerns about how we process your personal data, you can get in touch at: firstname.lastname@example.org. If you live in the EU, or the EEA, you can also get in touch with our European Representative, Liberty Fabric Services Srl via email@example.com.
If you have unresolved concerns you also have the right to complain to the Information Commissioner or, if you are in the EU or the EEA, to your relevant data protection authority. The relevant data protection authority will be the data protection authority of the country: (i) of your habitual residence; (ii) of your place of work; or (iii) in which you consider the alleged infringement has occurred.
Where we process your personal and transaction data, we do this for as long as your account is active and for no more than 7 years after this.
Where we process personal data for marketing purposes or with your consent, we process the data until you ask us to stop and for a short period after this (to allow us to implement your requests). We also keep a record of the fact that you have asked us not to send you direct marketing or to process your data indefinitely so that we can respect your request in future.
Where we process personal data for site security purposes, we retain it for 24 months.
Sometimes Liberty will need to share your personal data with third parties and suppliers outside of the United Kingdom, such as the European Economic Area (the "EEA") (i.e. all 27 EU Member States plus Iceland, Liechtenstein and Norway), the USA, India and Japan.
Where this is the case, we have procedures in place to ensure that your personal data receives the same level of protection as if it were being processed inside of the UK. If you have any questions about how we protect your data outside of the UK, please contact us at firstname.lastname@example.org.