Privacy Policy

INTRODUCTION

Choosing to shop with BOCCOGNANI means you've placed a great deal of trust in us. In sharing your personal information we hope you in return you benefit from a tailored and convenient shopping experience. With trust comes responsibility and we take this responsibility very seriously.

This privacy policy helps you to understand how we use your personal information and who we share it with. It applies if you shop on the BOCCOGNANI website, use the BOCCOGNANI app or if you have indicated you are happy to receive marketing and other communications from us.

We change the terms of this privacy policy from time to time and you should check it regularly. The last updated date is shown at the beginning of the document. If we make any material changes we will take steps to bring it to your attention.

If you shop in REISS stores you will find more information at the end of this document about how REISS will use your data.

WHO WE ARE

Santa Teresa Limited T/A BOCCOGNANI are data controllers of your data which means we are responsible for deciding how and why your personal information is used. We are also responsible for making sure it is kept safe, secure and handled legally when we are processing it. We operate to the highest standards when protecting your personal information and respecting your privacy.

We are Santa Teresa Limited (company number: 12375246), when we say “we”, “our” or “us” in this policy we are referring to Santa Teresa Limited

If you have any questions about your personal information, or how we use it, you can contact our Data Protection Officer via email at contact@boccognani.com or by writing to our registered offices below:

UK registered address: 15 Pinewood House, Chaldon Road, Caterham, Surrey CR3 5PE

YOUR RIGHTS

You have a number of “Data Subject Rights”, we have explained below what they are and how you can exercise them. You can read more about these rights on the Information Commissioner's Office website at https://ico.org.uk/for-the-public/, or on your local Data Protection Authority website.

• Right of access - You have the right to request a copy of the personal information that we hold about you.
• Right to rectification – If you think any of your personal information that we hold is inaccurate, you have the right to request it is updated. We may ask you for evidence to show it is inaccurate.
• Right to erasure (also known as the Right to be Forgotten) – You have the right to request that we delete your personal information that we hold.
• Right to restriction of processing – You have the right to request we restrict or suppress the personal data we hold about you.
• Right to data portability – You have the right to ask us to electronically transfer your personal information to another organisation in certain circumstances.
• Rights with regards to automated decision making, including profiling – We sometimes use your personal information to make decisions by automated means. This involves us analysing your account activity including applications, orders, payments etc. We do this to confirm your identity, prevent and detect crime, and lend responsibly. This automated decision making is necessary if you would like to continue to shop with us online. You have a right to reject automated decisions, but it may mean that you can only shop with us in our stores.
• Right to withdraw Consent – Where we are relying on your consent for processing you can withdraw or change your consent at any time.

The above rights may be limited in some circumstances, for example, if fulfilling your request would reveal personal information about another person, if you ask us to delete information which we are required to have by law, or if we have compelling legitimate interests to keep it. We will let you know if that is the case and will then only use your information for these purposes. You may also be unable to continue using our services if you want us to stop processing your personal information.

If you have any general questions or want to exercise any of your rights, please see the “how you can get in touch” section of this privacy policy. In order to maintain the security of our customers' personal details, we may need to request proof of identity before we disclose personal information to you in response to any request.

We encourage you to get in touch if you have any concerns with how we collect or use your personal information. You have the right to lodge a complaint directly with the Information Commissioner's Office (ICO), the data protection regulator in the UK where Santa Teresa Limited is based. The contact details for the ICO can be found on their website or you may also lodge a complaint with your local Data Protection Authority

THE LAWFUL BASES WE USE TO PROCESS DATA

We will only ever process your information if we have a lawful basis to do so. The lawful bases we rely on are:

• Contract – This is where we process your information to fulfil a contractual arrangement we have made with you.
• Consent – This is where we have asked you to provide explicit permission to process your data for a particular purpose.
• Legitimate Interests - This is where we rely on our interests as a basis for processing. Generally this is to provide you with the best products and services in the most secure and appropriate way, but not where our interests are overridden by your interests.
• Legal Obligation – This is where we have a statutory or other legal obligation to process the information, such as for the investigation of crime or to meet responsible lending criteria.
• Vital interests – This is where the processing of personal information is necessary to protect someone’s life.

THE INFORMATION WE COLLECT AND HOW WE USE IT

We collect and use the information that you provide to us directly, for example; when you register for an account; we use cookies and other similar technologies to collect information from your devices when you interact with our advertising or use our website (you can find out more information in the "Cookie Policy" section below); we keep records when you speak to our customer service teams; we take personal information from a number of third parties to help us manage your account and improve your shopping experience.

To process any orders that you place with us and to facilitate any returns (Contract & Consent)

• We take payment details to process payment for any credit or debit card orders you place with us. We share these details with our chosen payment processors.
• We use your account information plus your chosen delivery address details to; deliver your purchases and keep you informed of their status, and to process any returns including (where appropriate) collecting the item from you.
• Our chosen payment processors may store your payment card details at your request to speed up your checkout in the future.
• We collect your email address to allow us to send you an e-receipt.

To provide you with access to an account (Contract)

• To register an account with us we capture information such as your name, contact and delivery information, and a password to protect your account (account information). We use the same information on an ongoing basis to manage and provide secure access to your account, and provide you with the services you request.

To provide customer service to you (Legitimate Interest)

• We record calls and keep correspondence (customer service records) when you contact our customer service teams or interact with us on social media. We use these customer service records to manage your queries or complaints effectively, for quality monitoring and to continually improve our services

To offer and manage any credit we provide to you (Contract & Legitimate Interest)

• When you apply for and use credit with us we will use your account information to make searches with third parties who will give us information about you, such as your financial history. We do this to assess your creditworthiness and product suitability.
• We use purchase and payment history, along with your account information on a cyclical basis to manage your credit facility with us.
• We use your account information, purchase history, payment history and third party information to collect and recover money that is owed to us should your account fall into arrears. Please see the section on “third parties we share data with and receive data from” below for more information.

To personalise and improve your experience when you shop (Legitimate Interest)

• We keep a record of how you interact with our website and any marketing you are exposed to, we use this data, along with purchase history, demographics, account information and third party information, to show you products and offers from across our brands that we think you will be most interested in and to tailor your experience.
• We use your account information, information on the devices you use to access our sites and your interactions with us to operate personalised features across our websites, apps and communication.
• We will use marketing preferences and previous transaction history data to manage customer appointments and make recommendations to you when you shop in store or through virtual appointments.

To inform you about products and services that may interest you (Legitimate Interest)

• We use technologies such as cookies within digital marketing networks, ad exchanges and social media networks such as Facebook’s Custom Audience to get relevant marketing messages across to you and other customers. We share aggregated and anonymised information about the customer segments we are interested in reaching with advertising partners, so they can focus on showing adverts to those who are most likely to be interested in our products, services and offers, and to prevent them showing you irrelevant or repetitive advertisements.
• We share limited information with selected suppliers to enable them to identify new prospective customers on our behalf and to prevent us repeatedly advertising products or services you have already bought
• We receive information on how you interact with our adverts and content on third party websites and social media platforms (such as Google or Facebook) which we use to tailor the information that is displayed to you.

To keep in touch with you (Legitimate Interest & Consent)

• Unless you tell us you don’t want us to, when you register for an account and shop with us we start to keep you up to date with news of products and services, offers, promotions and Sale information. You can change your preferences at any time by accessing your online account or by using the link in every email that we send to you.
• When we send you communications we use records of how you interact with our website and any other marketing we have sent to you, along with purchase history, to tailor the messages to include information you are most likely to be interested in.
• We use your account information to notify you about important service messages, such as material changes to this policy, product recalls or information about your account.
• Where you interact directly with the promotion of an event, prize draw or competition, and you provide your consent, we will use the details you provide, specific in that instance, to send invites, identify entrants and winners, or to enter you into the competition, in-line with the terms and conditions.

To ensure the Website and the services we offer you operate properly (Legitimate Interest/Consent)

• We use cookies and other similar technologies to keep track of your preferences when using our site.
• We use other cookies and similar technologies to help us understand how you use the site, this allows us to optimise your shopping experience and continually improve our site.
• We gather information about the devices you use to access our sites (desktop and mobile) for example your IP address and device type, to ensure the site is secure and works across multiple platforms.
• We use information for logistics planning, demand forecasting, management information, dealing with errors on our site, and general research and development.

To develop and improve our products, range and services (Legitimate Interest & Consent)

• We may contact you to take part in customer satisfaction surveys, if you respond we collect your feedback and contributions (customer feedback). We use this information to develop the services we offer.
• We work with information providers that specialise in consumer profiling, such as Experian and Merkle. These organisations provide demographic or other data to help better understand customers' demographics, lifestyles or shopping behaviours, usually linked to the areas where people live.
• We use information about how you browse and engage with our website to improve our websites.
• We use all information, including third party data in the development of new products, services and systems to ensure they work as expected and will be useful to our customers.

To prevent and detect crime (Legitimate interest/Legal obligation)

• We use your account information, order history and payment history to assist in monitoring for fraudulent transactions or suspected money laundering.
• When you register an account, apply for credit or contact our call centres we use your account, application and purchase history information to confirm your identity.
• We use device identifiers and IP addresses in fraud prevention and investigation, and to maintain network and data security.

To fulfil our legal obligations (Legal obligation)

• We use your data to ensure we comply with any requirements imposed on us by law or court order, including disclosure to law or tax enforcement agencies and authorities or pursuant to legal proceedings.
• We will share data with regulatory and other official bodies if they make formal requests.
• We will maintain records to meet regulatory and tax requirements.
• We will use your account information to contact you in connection with product recalls or other similar product quality issues and to comply with our legal obligations in connection with the sale of age restricted products.

COOKIE POLICY

What are cookies?

Cookies are small text files that are stored on your computer, mobile device or other web enabled device when you visit the BOCCOGNANI website or app. Cookies allow us to “remember” your actions or preferences over a period of time, or they may contain data related to the function or delivery of our websites. We also use the term “cookie” to describe similar technologies such as pixels or tags.

What do we use cookies for?

Some cookies are required by our site to enable you to transact whilst other cookies enable us to give you an enhanced, personalised web experience. We use cookies for the following purposes:

• To allow you to securely sign in to your BOCCOGNANI account, so that you can use "My Account" features such as order information, making payments and viewing statements.
• To store the content of your online shopping bag whilst you browse the site and to complete an order.
• To record the areas of the website that you have visited, products you have viewed and time spent browsing, as well as the products you purchased. BOCCOGNANI uses this information to help make the website more user friendly, develop our website design and to continuously improve the quality of the service we provide.
• To distribute visitors to our website evenly across platforms to ensure the content is served at the fastest possible speed.
• Provide relevant products and services to you when you come to the website and ensure that relevant marketing material is provided to you.
• Detect and prevent fraud and other crimes.

We also offer you the facility to share your experience on our website through social sites such as facebook and twitter. More information about how these providers use cookies can be found on their websites.

What cookies do we use?

BOCCOGNANI uses the following cookies on our website and apps:

• Strictly necessary Cookies. These cookies are necessary for the website to function and cannot be switched off. They are used, for example, to make sure your transaction is secure, to enable you to log in to the secure areas of your account, such as your order history and to add items to your basket. Blocking these cookies through your browser will mean that some parts of our website won’t work.
• Performance Cookies or analytical Cookies. These cookies allow us to monitor visitors to our website and ensure it is performing correctly. We use this information to measure overall performance, improve your website experience and improve the design of our website. These cookies don’t collect any information that could identify you - all information collected by these cookies is anonymous.
• Functionality Cookies. These cookies enable enhanced functionality on our website, such as allowing you to add to favourites or remember your language preferences.
• Onsite Targeting: Marketing and Personalisation Cookies. These cookies are placed by BOCCOGNANI and are used to help us to build an understanding of your interests (for example by understanding what products you have browsed on our website) and show you products, services and advertisements relevant to you whilst you are on the BOCCOGNANI website. These cookies make it possible for us to personalise your experience on this website and (if you are subscribed) in our email marketing.
• Off Site Targeting: Marketing and Personalisation Cookies. These cookies are placed by our trusted advertising and marketing partners (including social networks). These help us to build an understanding of your interests (for example by understanding what products you have browsed on our website) and show you products, services and advertisements relevant to you. These cookies make it possible for us to ensure that you don’t see irrelevant, duplicate or multiple ads from us in a short period of time. We do want to prevent ads continuously re-appearing and annoying you.

For more detailed information and a full list of cookies used on our website please select “Manually Manage Cookies” at the bottom of the page then click “Cookies Detail”.

Can I turn off or block cookies?

BOCCOGNANI uses cookies to ensure that we provide the best possible standard of service to our online customers. You can change your cookie preferences at any time by clicking on “Manually Manage Cookies” at the bottom of the page. You can then adjust the available sliders to on or off, then click “Confirm my choices”. If you choose not to consent to the use of cookies your experience of our website may be impaired and many integral aspects of the website, including (but not limited to) adding items to your shopping bag and accessing your account, will not work.

Alternatively, most web browsers allow some control of most cookies through the browser settings. To find out more about how to manage cookies, including how to delete cookies, visit www.allaboutcookies.org

HOW LONG WE KEEP YOUR DATA FOR

We keep your personal information as long as you are a customer of ours and generally for 7 years afterwards to comply with legal requirements. During that time we take steps to remove any personal data as soon as we no longer need it.

We consider you a customer:

• As long as you hold an open credit account,
• For 2 years from the point you last made a purchase from our website using a non-credit account, or
• During any time we are managing a customer service request from you.