Website Privacy Notice 18/11/2020

 

   

1. INTRODUCTION  

  

We value the privacy of everyone who visits this website and we are fully committed to our obligation to treat your personal data with respect. This privacy notice provides you with details of how we collect and process your personal data through your use of our site www.mysmallworld.co.uk (“our website”). Please read this Privacy Policy carefully and ensure that you understand it. By using our website, you signify acceptance of this Privacy Policy. If you do not agree to this Privacy Policy, please do not use our website.

 

By providing us with your data, you warrant to us that you are over 13 years of age.

  

My Small World Toys is the data controller and we are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice). If you need to email us about anything related to this Privacy Notice, you can email us at sales@mysmallworld.co.uk.

 

We may change this Privacy & Cookie Policy from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection. Any changes will be immediately posted on our website and you will be deemed to have accepted the terms of the Privacy & Cookie Policy on your first use of Our Site following the alterations.  We recommend that you check this page regularly to keep up-to-date. This Privacy & Cookie Policy was last updated on 18 November 2020.

Contact Details

Our full details are: 

 

Full name of legal entity: My Small World Ltd, a company registered in the United Kingdom under number 07280156 whose registered office address is at 19-21 St. Lawrence Street, Southgate, Bath, England, BA1 1AN

 

Email address: sales@mysmallworld.co.uk

    

It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at sales@mysmallworld.co.ukk so we can update our records.

 

1. WHAT DATA DO WE COLLECT ABOUT YOU, FOR WHAT PURPOSE AND ON WHAT GROUND WE PROCESS IT

 

Personal data means any information capable of identifying an individual. our website collects such information only as is necessary or appropriate to fulfill the purpose of the visitors interaction with our website. We do not disclose personally-identifying information. We may release non-personally identifying information in aggregate, e.g. by publishing a report on trends in the usage of our website. Visitors can refuse to supply personally-identifying information, although it may prevent them from engaging in certain website-related activities. Our website may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.

 

 

We may process the following categories of personal data about you:

Communication Data that includes any communication that you send to us whether that be through a contact form on our website, through email, text, social media messaging, social media posting or any other communication that you send us. We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defence of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims. 

Customer Data that includes data relating to any purchases of goods and/or services such as:

• contact information: name, title, postal address (billing and delivery), telephone number, email address.
• social media account ID, profile photo and other data publicly available.
• interactions, including emails, telephone calls or messages, social media messages, comments, or engagement (reviews, photos, videos).
• credit/debit card numbers.
• goods and services purchased.

 

We process this data to provide information that you request and/or supply the goods and/or services you have purchased and to keep records of such transactions. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract. 

 

User Data that includes data about how you use our website and any online services together with any data that you post for publication on our website or through other online services, including social media and review sites. We process this data to operate our website and ensure relevant content is provided to you, to ensure the security of our website, to maintain back-ups of our website and/or databases and to enable publication and administration of our website, other online services and business. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business. 

Technical Data that includes data about your use of our website and online services such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is from our analytics tracking system. We process this data to analyse your use of our website and other online services, to administer and protect our business and website, to deliver relevant website content and advertisements to you and to understand the effectiveness of our advertising.  Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business and to grow our business and to decide our marketing strategy.

Marketing Data that includes data about your preferences in receiving marketing from us and your communication preferences. We process this data to enable you to partake in our promotions such as competitions and offers, to deliver relevant website content and advertisements to you and measure or understand the effectiveness of this advertising. Our lawful ground for this processing is our legitimate interests which in this case are to study how customers use our products/services, to develop them, to grow our business and to decide our marketing strategy. 

We may use Customer Data, User Data, Technical Data and Marketing Data to deliver relevant website content and advertisements to you (including Facebook/Instagram adverts or other display advertisements) and to measure or understand the effectiveness of the advertising we serve you. Our lawful ground for this processing is legitimate interests which is to grow our business. With your permission, we may also use such data to send other marketing communications to you, which may include contacting you by email with information, news, and offers on our products and/ or services. You will not be sent any unlawful marketing or spam and you will always have the opportunity to opt-out. Our lawful ground for this processing is either consent or legitimate interests (namely to grow our business). 

 

Sensitive Data

 

We do not collect any Sensitive Data about you. Sensitive data refers to data that 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. We do not collect any information about criminal convictions and offences.

 

We will only use your personal data for a purpose it was collected for or a reasonably compatible purpose if necessary. For more information on this please email us at sales@mysmallworld.co.uk. In case we need to use your details for an unrelated new purpose we will let you know and explain the legal grounds for processing.

 

We may process your personal data without your knowledge or consent where this is required or permitted by law.

 

We do not carry out automated decision making or any type of automated profiling.

 

1. HOW WE COLLECT YOUR PERSONAL DATA

 

There are several ways we may collect personal data:

• When you visit our website, and use your account to buy products and services
• When you make an online purchase and check out as a guest (in which case we just collect transaction-based data).
• When you create an account with us on our website
• When you engage with us on social media
• When you contact us by any means with queries, complaints etc.
• When you enter prize draws or competitions
• When you choose to complete any surveys we send you. 
• When you comment on or review our products and services
• When you ask us to contact you when a specific product is back in stock
• When you click submit or place an item in your basket we may have the ability to retain some of your information, even if you don’t complete your registration. Such contact details and data may be used to contact you to enquire why you did not complete your registration/transaction, ie: an abandoned basket email.
• When you subscribe to our newsletter
• In Person or via Telephone: we may collect information during meetings (face-to-face or online) or via a telephone call.
• We may automatically collect certain data from you as you use our website by using cookies and similar technologies, including Google Tag Identifiers, Shopify Pixels and Facebook Pixels. Our cookies do not gather personally identifiable data. We may also use another company to process credit/debit card purchases for our website. We may use the cookie information gathered by these companies.  Please see our cookie policy for more details about this https://www.mysmallworld.co.uk/pages/cookie-policy

 

We may receive data from third parties such as analytics providers, such as Google, based outside the EU, advertising networks such as Facebook based outside the EU, such as search information providers, such as Google based outside the EU, providers of technical, payment and delivery services, such as payment software systems, third party booking sites, data brokers or aggregators. By providing any information, including personal data to us, you consent to such transfer, storage and processing.  

 

 

1. MARKETING COMMUNICATIONS 

 

Our lawful ground of processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business). 

 

Under the Privacy and Electronic Communications Regulations, we may send you marketing communications from us if (i) you made a purchase or asked for information from us about our goods or services or (ii) you agreed to receive marketing communications and in each case you have not opted out of receiving such communications since. Under these regulations, if you are a limited company, we may send you marketing emails without your consent. However you can still opt out of receiving marketing emails from us at any time. 

 

We will not share your personal data with any third party for their own marketing purposes.

 

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by emailing us at sales@mysmallworld.co.uk.

 

If you opt out of receiving marketing communications this opt-out does not apply to personal data provided as a result of other communications with us, such as meetings, telephone conversations, social media posts or comments etc. 

 

 

1. DISCLOSURES OF YOUR PERSONAL DATA

 

We may have to share your personal data with the parties set out below:

• Third-party service providers including IT and system administration services, payment processing, order fulfilment, website hosting, data analysis, customer service, email delivery, marketing and other services.
• Professional advisers including lawyers, bankers, auditors and insurers 
• Government bodies that require us to report processing activities.
• Third parties to whom we sell, transfer, or merge parts of our business or our assets. 

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions. We do not knowingly disclose personal information to third parties for their direct marketing purposes.

 

Any credit/debit card payments that you make through our website will be processed by our third party payment providers and the payment data you submit will be securely stored and encrypted by our payment service providers using up to date industry standards. We do not ourselves directly process or store the credit/debit data that you submit on our website.

 

California law requires us to inform residents in California how we respond to Do Not Track signals (DNT). My Small World Ltd does not track its users across third party websites and therefore does not respond to DNT signals. Other third party sites may keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such sites, Safari allows you to set the DNT signal on your browser so that third parties (particularly advertisers) know you do not want to be tracked. For more information, visit www.allaboutdnt.com.

 

1. INTERNATIONAL TRANSFERS

 

We are subject to the provisions of the General Data Protection Regulations that protect your personal data. Where we transfer your data to third parties outside of the EEA, we will ensure that certain safeguards are in place to ensure a similar degree of security for your personal data. As such:

• We may transfer your personal data to countries that the European Commission have approved as providing an adequate level of protection for personal data by; or
• If we use US-based providers that are part of EU-US Privacy Shield, we may transfer data to them, as they have equivalent safeguards in place; or
• Where we use certain service providers who are established outside of the EEA, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe.

If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time. 

 

1. DATA SECURITY

 

We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorisation. We also allow access to your personal data only to those employees and partners who have a business need to know such data. They will only process your personal data on our instructions and they must keep it confidential.

 

We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to.

 

 

1. DATA RETENTION

  

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, whichever is the longer. When you consent to receive marketing communications, we will keep your data until you unsubscribe. 

 

When deciding what the correct time is to keep the data for we look at its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.

  

In some circumstances we may anonymise your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

 

1. YOUR LEGAL RIGHTS

 

Under data protection laws you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent.

 

You can see more about these rights at: 

https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

If you wish to exercise any of the rights set out above, please email us at sales@mysmallworld.co.uk

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 or refuse to comply with your request in these circumstances.

  

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 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.

 

If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.

 

1. THIRD-PARTY LINKS

 

Our 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 notice of every website you visit.

 

1. COOKIES

 

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. Privacy Policy describes how www.mysmallworld.co.uk (the “Site” or “we”) collects, uses, and discloses your Personal Information when you visit or make a purchase from the Site.

Collecting Personal Information

When you visit the Site, we collect certain information about your device, your interaction with the Site, and information necessary to process your purchases. We may also collect additional information if you contact us for customer support. In this Privacy Policy, we refer to any information that can uniquely identify an individual (including the information below) as “Personal Information”. See the list below for more information about what Personal Information we collect and why.

Device information

• Examples of Personal Information collected: version of web browser, IP address, time zone, cookie information, what sites or products you view, search terms, and how you interact with the Site.
• Purpose of collection: to load the Site accurately for you, and to perform analytics on Site usage to optimize our Site.
• Source of collection: Collected automatically when you access our Site using cookies, log files, web beacons, tags, or pixels.
• Disclosure for a business purpose: shared with our processor Shopify.

Order information

• Examples of Personal Information collected: name, billing address, shipping address, payment information (including credit card numbers), email address, and phone number.
• Purpose of collection: to provide products or services to you to fulfill our contract, to process your payment information, arrange for shipping, and provide you with invoices and/or order confirmations, communicate with you, screen our orders for potential risk or fraud, and when in line with the preferences you have shared with us, provide you with information or advertising relating to our products or services.
• Source of collection: collected from you.
• Disclosure for a business purpose: shared with our processor Shopify

Customer support information

• Purpose of collection: to provide customer support.
• Source of collection: collected from you.

 

Minors

The Site is not intended for individuals under the age of 18. We do not intentionally collect Personal Information from children. If you are the parent or guardian and believe your child has provided us with Personal Information, please contact us at the address below to request deletion.

Sharing Personal Information

We share your Personal Information with service providers to help us provide our services and fulfill our contracts with you, as described above. For example:

• We use Shopify to power our online store. You can read more about how Shopify uses your Personal Information here: https://www.shopify.com/legal/privacy.
• We may share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.

Behavioural Advertising

As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For example:

• We use Google Analytics to help us understand how our customers use the Site. You can read more about how Google uses your Personal Information here: https://policies.google.com/privacy?hl=en.You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.
• We share information about your use of the Site, your purchases, and your interaction with our ads on other websites with our advertising partners. We collect and share some of this information directly with our advertising partners, and in some cases through the use of cookies or other similar technologies (which you may consent to, depending on your location).

For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.

You can opt out of targeted advertising by:

• FACEBOOK - https://www.facebook.com/settings/?tab=ads
• GOOGLE - https://www.google.com/settings/ads/anonymous
• BING - https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads]

Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/.

Using Personal Information

We use your personal Information to provide our services to you, which includes: offering products for sale, processing payments, shipping and fulfillment of your order, and keeping you up to date on new products, services, and offers.

Lawful basis

Pursuant to the General Data Protection Regulation (“GDPR”), if you are a resident of the European Economic Area (“EEA”), we process your personal information under the following lawful bases:

• Your consent;
• The performance of the contract between you and the Site;
• Compliance with our legal obligations;
• To protect your vital interests;
• To perform a task carried out in the public interest;
• For our legitimate interests, which do not override your fundamental rights and freedoms.

Retention

When you place an order through the Site, we will retain your Personal Information for our records unless and until you ask us to erase this information. For more information on your right of erasure, please see the ‘Your rights’ section below.

Automatic decision-making

If you are a resident of the EEA, you have the right to object to processing based solely on automated decision-making (which includes profiling), when that decision-making has a legal effect on you or otherwise significantly affects you.

We engage in fully automated decision-making that has a legal or otherwise significant effect using customer data.

Our processor Shopify uses limited automated decision-making to prevent fraud that does not have a legal or otherwise significant effect on you.

Services that include elements of automated decision-making include:

• Temporary denylist of IP addresses associated with repeated failed transactions. This denylist persists for a small number of hours.
• Temporary denylist of credit cards associated with denylisted IP addresses. This denylist persists for a small number of days.

Your rights

GDPR

If you are a resident of the EEA, you have the right to access the Personal Information we hold about you, to port it to a new service, and to ask that your Personal Information be corrected, updated, or erased. If you would like to exercise these rights, please contact us through the contact information below.

Your Personal Information will be initially processed in Ireland and then will be transferred outside of Europe for storage and further processing, including to Canada and the United States. For more information on how data transfers comply with the GDPR, see Shopify’s GDPR Whitepaper: https://help.shopify.com/en/manual/your-account/privacy/GDPR.

CCPA

If you are a resident of California, you have the right to access the Personal Information we hold about you (also known as the ‘Right to Know’), to port it to a new service, and to ask that your Personal Information be corrected, updated, or erased. If you would like to exercise these rights, please contact us through the contact information below.

If you would like to designate an authorized agent to submit these requests on your behalf, please contact us at the address below.

Cookies

A cookie is a small amount of information that’s downloaded to your computer or device when you visit our Site. We use a number of different cookies, including functional, performance, advertising, and social media or content cookies. Cookies make your browsing experience better by allowing the website to remember your actions and preferences (such as login and region selection). This means you don’t have to re-enter this information each time you return to the site or browse from one page to another. Cookies also provide information on how people use the website, for instance whether it’s their first time visiting or if they are a frequent visitor.

We use the following cookies to optimize your experience on our Site and to provide our services.

Cookies Necessary for the Functioning of the Store

Name	Function
_ab	Used in connection with access to admin.
_secure_session_id	Used in connection with navigation through a storefront.
cart	Used in connection with shopping cart.
cart_sig	Used in connection with checkout.
cart_ts	Used in connection with checkout.
checkout_token	Used in connection with checkout.
secret	Used in connection with checkout.
secure_customer_sig	Used in connection with customer login.
storefront_digest	Used in connection with customer login.
_shopify_u	Used to facilitate updating customer account information.

Reporting and Analytics

Name	Function
_tracking_consent	Tracking preferences.
_landing_page	Track landing pages
_orig_referrer	Track landing pages
_s	Shopify analytics.
_shopify_fs	Shopify analytics.
_shopify_s	Shopify analytics.
_shopify_sa_p	Shopify analytics relating to marketing & referrals.
_shopify_sa_t	Shopify analytics relating to marketing & referrals.
_shopify_y	Shopify analytics.
_y	Shopify analytics.

 

The length of time that a cookie remains on your computer or mobile device depends on whether it is a “persistent” or “session” cookie. Session cookies last until you stop browsing and persistent cookies last until they expire or are deleted. Most of the cookies we use are persistent and will expire between 30 minutes and two years from the date they are downloaded to your device.

You can control and manage cookies in various ways. Please keep in mind that removing or blocking cookies can negatively impact your user experience and parts of our website may no longer be fully accessible.

Most browsers automatically accept cookies, but you can choose whether or not to accept cookies through your browser controls, often found in your browser’s “Tools” or “Preferences” menu. For more information on how to modify your browser settings or how to block, manage or filter cookies can be found in your browser’s help file or through such sites as www.allaboutcookies.org.

Additionally, please note that blocking cookies may not completely prevent how we share information with third parties such as our advertising partners. To exercise your rights or opt-out of certain uses of your information by these parties, please follow the instructions in the “Behavioural Advertising” section above.

Do Not Track

Please note that because there is no consistent industry understanding of how to respond to “Do Not Track” signals, we do not alter our data collection and usage practices when we detect such a signal from your browser.

Changes

We may update this Privacy Policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal, or regulatory reasons.

Contact

For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e-mail at dawn@mysmallworld.co.uk or by mail using the details provided below:

My Small World Ltd, 19-21 St Lawrence Street, Bath, BA1 1AN, United Kingdom

Last updated: 13.05.2021

If you are not satisfied with our response to your complaint, you have the right to lodge your complaint with the relevant data protection authority. You can contact your local data protection authority, or our supervisory authority here: https://ico.org.uk/make-a-complaint/]