Last updated 28 February 2022 

1. Introduction 

The purpose of this policy is to explain to you how Bouclème processes, uses and protects  the information we collect about you including procedures that we have in place to safeguard your privacy. The policy applies to websites https://boucleme.co.uk, https://boucleme-eu.com (along with any of their sub-domains, extensions and associated domains), and any products and services offered and supplied by us.

By using our Websites, you are accepting the practices described in this policy. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

Bouclème protects your data by compliance with relevant legislation including UK General Data Protection Regulation (UK GDPR), tailored by the Data Protection Act 2018 and the EU General Data Protection Regulation 2016/679 (GDPR). Bouclème Limited is the “data controller” as defined under this legislation. 

This policy (together with our Terms & Conditions and any other documents referred to in it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.

"Personal data" means any information relating to you that can identify you, directly or indirectly, in particular by reference to an identifier such as a name, email address, an identification number, location data, or an online identifier.

If you have any questions about this privacy policy including any requests to exercise your legal rights, you can contact us at info@boucleme.co.uk stating that your query is about “data protection”.

Please note that when you provide information to us on a third-party site or platform (for example, via our applications), the information you provide may be separately collected by the third-party site or platform. The information we collect is covered by this privacy policy, and the information the third-party site or platform collects is subject to the third-party site or platform’s privacy practices.

2. Your Data

All the information we collect is used to operate and improve the service we offer you. We are committed to using your personal information only for:

  • Processing your order
  • Planning and managing our business activities, including analysis of customers' shopping habits, product and style preferences.
  • To verify details of your payment method or credit card account.

We will not rent or sell your name, address, email address, payment card information or personal information to any third party. If you have purchased goods from Bouclème, subscribed to our newsletter, entered any of our competitions, or advised us of your postal address and phone number we may occasionally update you on news and special opportunities via your preferred communication channels (email, post and phone). 

We will not send you our own promotional emails without your consent. Any promotional email that you receive from us will also allow you to unsubscribe to further email promotions if you decide at a later stage that you no longer wish to receive emails with news and special offers from Bouclème.

Information you give us

You may give us information about yourself via forms or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you register, visit or use the Website, place an order on the Website, subscribe to the newsletter, or contact Customer Services. The information you give us may include your name, address, e-mail address and phone number, personal description, photograph, and which products you have purchased from us. In limited circumstances, you may provide us with your card or bank account details.

 

Information we collect about you

Information we get from your use of our Website.

With regard to each of your visits to the Website 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; session length; browser plug-in types and versions; hostname; operating system and platform and computer specifications;

— information about your visit and use of our Website, including the use of certain features or content on our Website; the full Uniform Resource Locators (URL) clickstream to, through and from our Website (including date and time); products you viewed or searched for; page response times, length of engagement with web 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;

— items you put into your shopping cart including when you have abandoned your cart and this information is used to determine when to send cart reminder messages via SMS or email.

We collect this personal data by using Cookies, in-app analytics tools, and other similar technologies. Please see our Cookie Policy for further details.

 

Information we receive from other sources.

We work closely with third parties — including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers (such as Google Analytics ) search information providers, and credit reference agencies. We may receive information about you from such third parties.

 

How we use information we collect

We will use the information you give us:

— to improve customer service and help us respond to your support needs more effectively.

— to meet our obligations arising from any contract entered into between you and us and to provide you with the information, products and services that you request from us;

— to provide you with information about other goods and services we offer that are closely related to those that you have already purchased or enquired about;

—to provide you with service related messages; these may include order updates, account alerts etc

— to provide you with information about goods or services we feel may interest you. If you are an existing customer, we will contact you by electronic means (e-mail or SMS) only to provide information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you, and you will be given an option to unsubscribe with each communication. If you have not purchased a product, we will contact you by electronic means only if you have consented to this; 

— to notify you about changes to our service and products;

— to provide you with learning and support content to help you make the most of your products;

— to ensure that content from our Website is presented in the most appropriate manner for you and for your computer.

 

We will use the information we collect about you for the reasons above, and also:

— to understand how you use our services and products and further personalise your experience.

— for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;

— as part of our efforts to keep our website safe and secure;

— to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;

— to make suggestions and recommendations to you and other users of our Website about goods or services that may interest you or them.

We may combine information we receive from other sources with information you give to us and information we collect about you. We will use this information and the combined information only for the purposes set out above (depending on the types of information we receive).

 

3. The Legal Basis for Processing your Information

In accordance with GDPR, the main grounds that we rely upon in order to process your information are as follows:

— Necessary for entering into or performing a contract. In order to perform obligations which arise under any contract we have entered into with you, it will be necessary for us to process your information.

— Necessary for compliance with a legal obligation. We are subject to certain legal requirements which may require us to process your information. We may also be obliged by law to disclose your information to a regulatory body or law enforcement agency.

— Necessary for the purposes of legitimate interests. Either we or a third party will need to process your information for the purposes of our (or a third party’s) legitimate interests, provided that we have established that those interests are not contrary to your rights and freedoms, including your rights to privacy, and to have your information protected. Our legitimate interests include responding to requests and enquiries from you or a third party, optimising our website and user experience, informing you about our services, and ensuring that our operations are conducted in an appropriate and efficient manner.

— Consent. In all other circumstances, we will ask for your consent to process your information, or to communicate regularly with you.

4. Cookies

Our Website uses cookies to distinguish you from other users of our Website. Cookies are files downloaded from a web server to the PC of a visitor to our website. They provide the owner of a website with personal details about the purchase made from the site and information viewed. This helps us to provide you with a good experience when you browse our Website and also allows us to improve. For detailed information on the cookies we use, the purposes for which we use them, and how to change your Cookie settings, please see Cookie Policy.

5. Data Protection

Bouclème may transfer and store your personal information with third parties in locations around the world for the purposes described in this privacy policy. Wherever your personal information is transferred, stored or processed by us, we will take reasonable steps to safeguard the privacy of your personal information. These steps may include implementing standard contractual clauses where recognized by law, obtaining your consent, or other lawful means of transferring personal information. It may also be processed by staff operating outside the Territory who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the fulfilment of your order, the processing of your payment details, and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing.

We take all steps reasonably necessary to ensure that your data is treated securely, with adequate protections, and in accordance with this privacy policy.

Unfortunately, the transmission of information via the internet is not completely secure. We will do our best to protect your personal data, meet our obligation to employ best practices, and avoid unnecessary storage or transfer of your data. However, we cannot guarantee the absolute security of your data transmitted to our Website. Bouclème will have no liability for disclosure of information due to errors in transmission or unauthorised acts of third parties. We are not responsible for any damages which you, or others, may suffer as a result of the loss of confidentiality of such information, but may still be responsible for a breach of personal information, and potentially will be required to report this to the Information Commissioner's Office. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

You can check the information that we hold about you by sending us an email at info@boucleme.co.uk. If you find any inaccuracies we will delete or correct them promptly. The personal information that we hold about you will be held securely in accordance with our internal security policy and the law.

 

6. Marketing Preferences 

Except as set out in this privacy policy, we will ask for your permission if we intend to use your data for marketing purposes.

  • Email – you will be explicitly asked if you wish to be contacted by email when you purchase from the website, register or otherwise register your details when you interact with the Website. We will only send you Marketing communication if you opted in to receive them via email. You may withdraw this consent at any time by Opting Out (see below)
  • SMS – you will be explicitly asked if you consent to being contacted by SMS text message when you purchase, register or otherwise interact with the webstore. You may withdraw this consent at any time by Opting Out.

3rd Party Links

We may also share certain data with third party social media platforms in order to show you targeted ads when you visit them. We do this by:

— using cookies to capture your visits to our website. Please refer to our Cookies Policy for more information;

— providing these platforms with your email address to create ‘audiences’ of users fitting a certain demographic/category so that we can show our advertisements to audiences that want to see them. Please check the social media platforms’ terms for more details of these services.

This is in our legitimate interest to send you direct marketing. See ‘Opting out’ below for details of how you can adjust your marketing preferences. Our Cookies Policy also explains how you can adjust your cookies preferences.

Opting Out 

In case you decide that you no longer want to give us permission to send you marketing messages, you may withdraw your consent as follows:

  • Email — unsubscribing from the newsletter or other email communications via the unsubscribe link in the footer in each email.
  • SMS – all SMS communications will include an Opt Out option within them. Please follow those instructions

If you opt out of receiving marketing from us, we will no longer share your contact information with social media platforms (see ‘Third Party Processors’ below). However, you may continue to see our ads through them, due to their general demographic targeting. Please check the social media platforms for more details of how to opt out of seeing these ads.

Where you opt out of receiving these marketing messages, we may still contact you as a result of a product/service purchase, or related correspondence, and we will continue to process such data in accordance with this Privacy Policy, and only ever as permitted by law.

Our Website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies. We cannot accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

7. Third Party Processors

Any personal data that you disclose directly to third party data processors (summarised below) are subject to such processor’s privacy policy. We take all steps reasonable steps to ensure that your data is treated securely, with adequate protections when engaging processors on our behalf.

Payment providers — We use payment providers to process your payment transactions, such as Klarna, Clearpay and PayPal.When you select Klarna as your payment option we will pass to Klarna certain aspects of your personal information, such as contact and order details, in order for Klarna to assess whether you qualify for their payment options and to tailor the payment options for you. General information on Klarna you can find here. Your personal data is handled in accordance with applicable data protection law and in accordance with the information in Klarna’s privacy policy. When you select Klarna as your payment option we will pass to Klarna certain aspects of your personal information, such as contact and order details, in order for Klarna to assess whether you qualify for their payment options and to tailor the payment options for you. General information on Klarna you can find here. Your personal data is handled in accordance with applicable data protection law and in accordance with the information in Klarna’s privacy policy

Cloud storage providers — We use cloud computing platforms that securely store all of our data, including customer details.

Email service providers — in order to send you marketing content and transactional emails, we share your details with our email service providers.

SMS service providers – to send you marketing messages by SMS you phone number is processed by a 3rd party system

Social Media Platforms — We may make your name and email address available to companies in order to advertise and market our services to you through other platforms on the internet (e.g. Instagram, TikTok, Facebook). See the ‘Marketing’ section of this Privacy Policy above.

Analytics tools — We use analytics tools to understand the way that users interact with our website. We also collect, use and share aggregated and/or anonymised data (“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.

Stockists and delivery providers — In order to package and mail your orders to you, it is necessary to share your information with stockists and delivery providers.

Marketing and insights providers — Marketing and insights tools allow us to understand our customers better so that we may continually improve our website, products and customer service experience. We may share anonymised information about our customers to facilitate this process.

Customer service platforms — When you interact with our Support team, your details are shared with our customer service platform providers.

Feedback forms — when you make a purchase, we engage a third party to request and collate your feedback on our behalf.

8. Compliance and cooperation with regulatory authorities

We regularly review our compliance with our Privacy Policy and our statutory duties. When we receive formal written complaints, we will contact the person who made the complaint to follow up. We are willing to work with the appropriate regulatory authorities, including data protection authorities, to resolve any complaints regarding the transfer of personal data that we cannot resolve with our users directly. Please see ‘complaints’ under section 11.

9. How long we hold your information

We will only retain your information for as long as is necessary to fulfil our purposes, including for the purposes of satisfying any legal, accounting or reporting requirements. The criteria that we use to determine retention periods will be determined by the nature of the data and the purposes for which it is kept, the sensitivity of the data and the potential risk of harm from unauthorised use or disclosure.


10. Your rights – residents in the UK and European Economic Area

You have certain rights in relation to the personal data that we hold about you. Details of these rights and how to exercise them are set out below. Please note we will require evidence of your identity before we are able to respond to your request.


Right of Access. You have the right at any time to ask us for a copy of the personal information that we hold about you and to check that we are lawfully processing it. Where we have good reason, and if the GDPR permits, we reserve the right to decline such a request, or certain elements of the request. If we refuse your request or any element of it, we will provide you with our reasons for doing so.


Right of Data Portability. In certain instances, you have a right to receive any personal information that we hold about you in a structured, commonly used and machine-readable format. In such circumstances, you can ask us to transmit that information to you or directly to a third party organisation. While we are happy for such requests to be made, we are not able to guarantee technical compatibility with a third party organisation's systems. We are also unable to comply with requests that relate to personal information of others without their consent. You can exercise any of these rights at any time by contacting us using the details in the 'Contact’ section below.


Right of Correction or Completion. If personal information we hold about you is not accurate or is out of date and requires amendment or correction, you have a right to have the data rectified or completed. This can usually be done by interacting with our platform.


Right of Erasure. In certain circumstances, you have the right to request that personal information we hold about you is erased e.g. if the information is no longer necessary for the purposes for which it was collected or processed or our processing of the information is based on your consent and there are no other legal grounds on which we may process the information.


Right to Object to or Restrict Processing. In certain circumstances, you have the right to object to our processing of your personal information e.g. if we are processing your information on the basis of our legitimate interests, but there are no compelling legitimate grounds for our processing which override your rights and interests. You may also have the right to restrict our use of your personal information, such as in circumstances where you have challenged the accuracy of the information and during the period where we are verifying its accuracy.


Right to Withdraw Consent

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. This can usually be done by interacting with our platform. Alternatively, you can do this by contacting us using the details in the 'Contact' section below.


Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.


11. For Residents outside of the UK and the European Economic Area

    If you live or work outside of the UK or you have a complaint concerning our activities outside of the UK, you may prefer to lodge a complaint with a different supervisory authority. A list of relevant authorities in the EEA can be accessed here.


    12. Children 

    Bouclème does not knowingly collect information from any person Under 16. If a child has provided us with personally identifiable information, a parent or guardian of that child may contact us if they would like this information deleted from our records. We will use reasonable efforts to delete the child's information from our databases.


    13. Complaints

    If you are unhappy about our use of your information, you can contact our data protection team or contact us using the details in the Contact section below.


    14. Changes to our privacy policy

    Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our Privacy Policy. We will not reduce your rights under this Privacy Policy without your explicit consent. We will also keep prior versions of this Privacy Policy in an archive for your review.


    15. Contact

    If you wish to exercise any of your rights (Section 10 and 12 above), to ask questions, or have comments regarding this privacy policy please email them to info@boucleme.co.uk.


    Boucleme is the trading name of Bouclème Limited a company registered in England and Wales (Company Number 8680247) whose registered office is at 27 Mortimer Street, London, W1T 3BL.