Privacy Notice

Last updated 7th August 2023

1 Who we are

2 What is a privacy notice?

3 What personal data do we collect and when?

4 How do we use your personal data?

5 Why are we allowed to handle and store your personal data?

6 How do we protect your personal data?

7 How long do we keep your personal data for?

8 Who else sees your personal data?

9 Where is your data stored?

10 What rights do you have over the data we store and how can you ask us to stop storing it?

11 Do we process children’s data?

12 What can you do if you are unhappy with how we handle your data?

13 Additional special Provisions for California Residents

14 Privacy Policy updates

 

1. Who we are

We are Sabre Retail Fashion Limited (“us/we”) and we control the Mint Velvet website and all of our stores.

We are an English company with registered company number: 7920155 and our registered office is at St John’s Place, Easton Street, High Wycombe, Bucks, HP11 1NL. We are the data controller responsible for your personal information and we are registered at the UK Information Commissioner’s Office with registration number Z3291584.

If you are a Californian resident, please visit our Special Provisions for California Residents section, to learn more about our information practises and rights you may have pursuant to applicable law.

The following laws will apply to the protection of your personal data when you shop on our website or stores:

• i) If you are a resident of the United Kingdom, the UK GDPR as defined in the Data Protection, Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations 2019, the Data Protection Act 2018 and the Privacy and Electronic Communications (EC Directive) Regulations 2003;
• ii) If you are a resident of the European Union, the Regulation (EU) 2016/679 (General Data Protection Regulation) and any applicable local laws, statutes and regulatory guidance. As a resident of the European Union, you can direct your data protection queries to our European Representative:
  Sabre Retail (Trading) Limited t/a Mint Velvet
  3rd Floor
  Kilmore House
  Park Lane
  Spencer Dock
  Dublin
  Ireland
• iii) If you are a California resident, the California Consumer Privacy Act (CCPA);
• iv) If you reside in any other country, the applicable data protection laws and regulations in your country of residence.

 

2. What is a privacy policy?

This notice contains our obligations and promises to you about the different types of personal data we might collect about you when you shop, make contact, or browse with us. It explains how we’ll store, handle and protect that data.

 

3. What personal data do we collect and when?

We collect the following information about you:

• Title
• Name and Surname
• Email address
• Birthday
• Contact phone number(s) for delivery purposes
• Purchase information
• An encrypted record of your login password (for your security only)
• Interactions with us e.g. contacting Customer Care (we may record your calls), including Live Chat, or visits to our website and/or stores
• Information you provide in your reviews of us, our products or survey responses
• Personal information you put on social media
• Payment details via our third party payment gateway providers only
• Delivery address(s)
• Billing address
• Reasons for returning or cancelling your order
• Details of your shopping preferences such as preferred store or product categories
• Certain physical appearance data which you may disclose to us when booking a styling advice appointment
• Clothing and shoe size
• IP address
• Images of you (including CCTV footage from some of our stores, where indicated)
• Information from cookies, including information on the devices you may use to make a purchase – please see our separate Cookies Notice.

 

We collect the information in the following circumstances:

• When you register to or use our website, including when you use our guest checkout
• When you register to or use our in-store WIFI (in any of our stores)
• When you sign up for additional services on our website such as Wish List, Back in Stock etc.
• When you allow social media sites to provide your data to us
• When you contact us by telephone, email or post
• When you enter any event, prize draws or competitions
• When completing any of our surveys or leaving us a review
• When completing any forms for transactional, employment or other purposes
• When you buy products or gift cards/vouchers
• When you’ve given a third party permission to share with us the information they hold about you
• When you choose to cancel or return an order

 

4. How do we use your personal data?

We use your personal data in the following ways:

• To enable us to personalise your online shopping experience, and to profile our typical customer, we share your data with carefully selected cooperative database companies (included but not limited to Oracle America Inc, Epsilon Abacus & Experian Ltd) who help us to understand your purchasing behaviour and preferences. Retailers who are members share information about their customers and what and how they buy, however, your personal data is not shared with any other members of the cooperative. The cooperative database companies also use this information to provide us with more targeted data for prospective customers who have consented to be marketed to.

Additionally, subject to your marketing preferences, the cooperative database companies analyse what sort of products might interest you and pass your name and address to companies whose products are likely to appeal to you. The participating retailers are active in the clothing, collectables, food & wine, gardening, gadgets & entertainment, health & beauty, household goods, and home interiors categories.

We currently use Experian Ltd for the purpose of managing a service called Club Canvasse of which we are a member. To understand more please click through to Experian’s website here.

We also work with Epsilon Abacus (registered as Epsilon International UK Ltd), a company that manages the Abacus Alliance on behalf of UK retailers and charities. The participating retailers are active in the clothing, collectables, food & wine, gardening, gadgets & entertainment, health & beauty, household goods, home interiors and travel categories.

Epsilon Abacus processes this information on behalf of the retailers to help them understand consumers’ wider buying patterns.

You can learn more about how Epsilon Abacus processes your personal information in their Privacy Policy, which is available here:

 

• To allow us to handle your orders, deliver products and process your payments and refunds (including to ensure secure payment and prevent fraud). 

• To respond to your queries, refund requests and complaints.

• To keep a record of when and why you contact us and to keep your contact details up-to-date.

• For statistical, analytical or survey purposes on an anonymised basis – so we can improve our websites and the services we offer you.

• To enable third parties to carry out technical, logistical or other business functions on our behalf such as advertising on social media sites you might use and visit. Our ability to do this will depend on the privacy settings you have on your social media accounts.

• Where you are an existing customer (or you have otherwise given us your data) and have not opted out, or where you have consented, we use your data to send you information about our business and products we think you might like and to notify you of products or special offers that may be of interest to you.

• To send you communications required by law or which are necessary to inform you about our changes to the services we provide you. For example, product recall notices, and legally required information relating to your orders. These service messages will not include any promotional content and do not require prior consent when sent by email or text message. If we do not use your personal data for these purposes, we would be unable to comply with our legal obligations.

• To process your application when you enter a competition, promotion or prize draw. (If there are other purposes specific to that competition promotion or prize draw, these will be explained in the applicable Competition Terms & Conditions).

• To maximise website user engagement and to display the most interesting content to you on our website, we’ll use data we hold about your recently searched and/or favourite products etc. We do so on the basis of your consent for our website to place cookies or similar technology on your device.
• To provide “wish list” and “back in stock” marketing programmes.

In order to help us manage our customer relationships, we use third party platforms. These platforms assist us to do lots of things, including: conduct email marketing campaigns, advertise online, undertake customer analytics, plan and put on events, book appointments, fulfil orders, make deliveries, returns and refunds etc. We therefore pass on your personal data to these third parties, on the condition that they agree to handle your information in line with this notice. For further detail please see section 8.

 

5. Why are we allowed to handle and store your personal data?

The law on data protection sets out a number of different reasons for which a company can collect and use your personal data. The following sets out more detailed explanations of the bases we rely on to collect and process your personal data:

 

1. Consent 

If you visit our site or fill in any in-store materials, then depending on how and why you interact with us, we will ask for your consent to process your data.

2. Contractual obligations 

Our primary use of this basis is when you purchase our products. In this situation it is necessary for us to process your personal data in order to fulfil your order and send your goods to you.

3. Legal compliance

In some circumstances, we may be legally required to collect and process your data e.g. to pass it on to the police if criminal activity is suspected.

4. Legitimate Interest

When we process your personal information for our legitimate interests, we will make sure it does not materially impact your rights, freedom or interests.

‘Legitimate Interests’ means the interests of our company in conducting and managing our business to enable us to give you the best service/products and the best and most secure experience with the aim of improving your customer experience. It can and does also apply to processing which is in your interests too.

Processing for our legitimate interests may include processing for the purposes of (i) fraud prevention and compliance; (ii) certain direct marketing and promotional activities by post and/or email; (iii) personalising and improving your shopping experience with us, (iv) actioning any account upon your account that you request; (v) the provision and operation of referral marketing programmes; (vi) network and information systems security; (vii) data analytics; (viii) enhancing, modifying or improving our service; (ix) identifying usage trends; or (x) determining the effectiveness of promotional campaigns or advertising.

 

6. How do we protect your personal data?

It is our duty to protect all personal data gathered and in order to do this our teams follow our internal data management policies and handle the data with the greatest level of care and expertise available to us. They do this by using various security technologies and internal procedures to ensure that it is kept safe and secure.

 

7. How long do we keep your personal data for?

We only keep your personal data for as long as is necessary for the purpose for which it was collected (subject to any legal requirements). Once it is no longer necessary, we will either delete the data, or anonymise it. The use of anonymised data helps us to optimise our customer service.

 

8. Who else sees your personal data?

• We will share your personal data with trusted third parties. We will do this in the following circumstances: 

  • To process your order e.g. with our distribution centre, delivery companies, a third party international fulfilment company or with third party web platform and payment service providers
  • To detect any fraudulent activity, or assist law enforcement authorities
  • To help us offer you a more personalised shopping experience
  • To profile our typical customer and assist our receipt of more targeted potential customer data
  • To understand the behaviour of our customers online.

   

  When we share information with third parties, we will ensure that:

  • We only provide the data they need to perform their specific function
  • They only use the data provided as intended
  • They have the requisite measures in place to protect your data and delete it once the function has been performed, or delete it when we cease working with them.

  For a list of our current providers with whom we share data for marketing and analytics and to see what they do with that data, please click here.

   

9. Where is your data stored?

Some of our partners and third parties who may receive your personal data are based outside of the UK and European Economic Area. In such cases, we ensure that our partners are contractually-bound to protect your data to the same degree that is required in the UK and European Union.

 

10. What rights do you have over the data we store and how can you ask us to stop storing it?

• If you wish to opt out of your data being shared with marketing 3^rd parties please email us at customercare@mintvelvet.com
• You have the right to correct any information we store which might be incorrect, incomplete, or out of date. You can do this yourself by logging into your account, or by contacting our Customer Care who will do this for you. You can contact them by calling 0345 456 2200 (International +44 (0) 1494 956700) or email: customercare@mintvelvet.com
• If we are processing your personal data on the basis of our legitimate interest, you have the right us to ask us to stop. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.
• You have the right at any time to stop us sending you marketing material. You can do this in the following ways:
• Click the ‘unsubscribe’ link in any email communication that we send you. We will then stop any further emails.
• If you have an account, log in into your account, visit the ‘My Account' area and change your preferences.
• Contact Customer Care on 0345 456 2200 (International +44 (0)1494 956720) or email: dataprotection@mintvelvet.co.uk.
• Write to FAO: The Legal Department, Mint Velvet, St John’s Place, Easton Street, High Wycombe, Bucks, HP11 1NL.
•  

  Please note that you may continue to receive communications for a short period after changing your preferences whilst our systems are fully updated.

  Please note that if you follow a link which clicks through to a third party site, this notice will not apply and you will need to review that third party’s privacy terms and conditions.

  • You have the right to ask us what data we hold which concerns you. Such requests are usually free, but we will ask you to submit your query in writing and include the following:
  • Full name (we will ask you to verify your identity)
  • Full address
  • Email address
  • Phone number
  • Specific details of your request

  We will process your request and will either respond within 30 days, or contact you to gather more information before we fulfil your request. In the event that we might refuse to fulfil your request (for example if it is unreasonable), we will give a full explanation as to why. 

• You have the right to obtain from us the erasure of your personal data when the processing is based on your consent and such consent is withdrawn. To exercise your 'right to be forgotten', please contact us at dataprotection@mintvelvet.com and we will comply with your request within 30 days from the date that we have identified you. Please note that your right to erasure does not apply to data related to any of your transactions as we have a legal obligation to keep the same.

• Please submit your requests through the following channels:

  FAO: The Legal Department, Mint Velvet, St John’s Place, Easton Street, High Wycombe, Bucks, HP11 1NL.

  Or send an email to: dataprotection@mintvelvet.com.

 

11. Do we process children's data?

In order to shop with us online, you must be over 16 years old and we do not knowingly collect personal data from children under 16. However, we encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce this notice by instructing children never to provide personal data to us.

 

12. What can you do if you are unhappy with how we handle your data?

You should contact our Legal Department as outlined in Section 10. However, if you still feel that your data is not being handled appropriately, you have the right to lodge a complaint with the Information Commissioner’s Office.

You can contact them by calling 0303 123 1113, or online at www.ico.org.uk/concerns  (this links through to a third party website over which we have no control).

If you are outside of the UK, please contact the relevant data protection regulator in your country of residence.

 

13. Special Provisions for California Residents

This section of our Privacy Notice provides additional information for California residents ("you" or "your") and describes our information practices pursuant to the California Consumer Privay Act 2018, as amended by the California Privacy Rights Act 2020 and its implementing regulations the "CCPA". Depending on how you interact or engage with us, we may irovide you with other privacy notices with additional details about our privact practices.

This section applies to "Personal Information" as defined by the CCPA, whether collected online or offline. This section does not address or apply to our handling of Personal Information that is exempt under the CCPA, such as publicly available information or eidentified or aggreagated information.

Categories of Personal Information We Collect and Disclose. The following identifies the categories of Personal Information we may collect about you, or have collected in the prior 12 months, as enumerated by the CCPA (see "What personal data do we collect and when?" for more information).

• Identifiers. Such as name, email, phone number, address, unique personal identifier, onlineidentifier, IP address, account name, or other similar identifiers.
• Customer Records. Such as customer records that contain Personal Information, including your name, email, phone number, address, billing and payment information, customer service and support tickets and records, and other information you provide in order to use our services.
• Commercial Information. Such as records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
• Geolocation Data. Such as general location information about a particluar individual or device.
• Internet or Other Electronic Network Activity. Such as usage data, which includes, but is not limited to, browsing history, clickstream data, search history, and information regard ng your interaction with our website, application, advertisements or emails, including other usage data related to your use of any of our services.
• Audio, Electronic, Visual, or Similar Information. Such as information collected via call recordings if you are interacting with us in a customer service capacity or if you call us on a recorded line.
• Inferences. Such as inferences drawn from any of the information described in this section including inferences reflecting a consumer's preferences, characteristics, behaviours, attitudes, abilities, and aptitudes.

Sources of Personal Information. We generally collect Personal Information from the following categories of sources: directly from you, affiliates, data brokers, cooperative data bases, social networks, operating systems and platforms, marketing/advertising agencies, and analytics firms.

Purposes for Collecting and Disclosing Personal Information. In general, we collect and otherwise process Personal Information for the following business or commercial purposes, as further described in the “How do we use personal data?” section above:

• Services and support;
• Analytics and improvement;
• Processing and fulfilling orders;
• Communicating with you;
• Marketing and promotions;
• Research;
• Planning and managing events;
• Security and protection of rights;
• Defending our legal rights;
• Compliance and legal process;
• Auditing, reporting, and other internal operations; and
• General business and operational support

 

Sensitive Personal Information. Mint Velvet does not collect sensitive personal information, nor does it use or disclose sensitive personal information for purposes beyond those specified in the CCPA. 

Retention. We retain your Personal Information for as long as needed, or permitted, based on the reason we obtained it (consistent with applicable law). When deciding how long to keep your Personal Information, we consider whether we are subject to any legal obligations (e.g., any laws that require us to keep records for a certain period of time before we can delete them) or whether we have taken any legal positions (e.g., issued any legal holds or otherwise need to preserve the information). In accordance with our retention policies, rather than delete your Personal Information we may also deidentify your Personal Information in compliance with CCPA.

Disclosure of Personal Information to Third Parties and Other Recipients. The categories of Personal Information we may have disclosed for a business or commercial purpose in the preceding twelve (12) months include: identifiers, customer records, commercial information, usage data, geolocation data, audio, video, and other electronic data, and inferences . The categories of third parties and other recipients to whom we may have disclosed this information for a business or commercial purpose may include: affiliates, business partners, vendors, and service providers, acquirers of business assets, advisors, auditors, consultants, and representatives, government entities, advertising networks, data analytics providers, Internet service providers, operating systems and platforms, cooperative databases, and social networks . 

Sales and Sharing of Personal Information. The CCPA defines "sale" as disclosing or making available Personal Information to a third-party in exchange for monetary or other valuable consideration, and “sharing” includes disclosing or making available Personal Information to a third-party for purposes of cross-contextual behavioural advertising. While we do not disclose Personal Information to third parties in exchange for monetary compensation, we may “sell” or “share” the following categories of Personal Information: identifiers, commercial information, usage data, and inferences   . We disclose these categories to third-party advertising networks, analytics providers, cooperative databases, and social networks for purposes of marketing and advertising and to improve and measure our ad campaigns   . We do not sell or share Sensitive Personal Information, nor do we sell or share Personal Information about individuals we know are under the age of sixteen (16).

Your California Privacy Rights
In general, California residents have the following rights with respect to their Personal Information, subject to certain conditions and exceptions:

Right to Know/Access. With respect to the Personal Information we have collected about you, you have the right to request:

• The categories or Personal Information we collected about you;
• The categories of sources from which the Personal Information is collected;
• Our business or commercial purposes for collecting, selling, or sharing Personal Information;
• The categories of third parties to whom we have disclosed Personal Information; and
• A copy of the specific pieces of Personal Information we have collected about you.

Right to Correct. You have the right to request that we correct inaccuracies in your Personal Information.

Right to Delete. Subject to certain exceptions, you have the right to request we delete Personal Information we have collected from you.

Right to Opt-Out of Sales and Sharing. You have the right to opt-out of “sales” and “sharing” of your Personal Information, as those terms are defined under the CCPA. To exercise your right to opt-out of the “sale” or “sharing” of your Personal Information, click the Do Not Sell or Share My Personal Information link at the bottom of our website. Please note that submitting an opt out request will only opt you out of disclosures that are considered “sales” or “sharing” under the CCPA, but it will not opt out of other disclosures, such as to our service providers.

You also have the right to opt-out of “sales” and “sharing” of your Personal Information through the use of an opt-out preference signal. If we detect that your browser or device is transmitting an opt-out preference signal, such as the “global privacy control” or “GPC” signal, we will opt that browser or device out of cookies that result in a “sale” or “sharing” of your Personal Information.

If you come to our website or use our services from a different device or from a different browser on the same device, you will need to opt-out, or use an opt-out preference signal, for that browser and/or device as well.

Right to Limit Use of Sensitive Personal Information. We do not engage in uses or disclosures of “Sensitive Personal Information” that would trigger the right to limit use of Sensitive Personal Information under the CCPA.

Right to Non-Discrimination. We will not discriminate against you for exercising any of the rights described in this section.

Exercising Your Rights. If you are a California resident and would like to exercise your CCPA rights, you may do so via any of the methods described below:

• Emailing us at customercare@mintvelvet.com

Verification. Before responding to your request, we must first verify your identity using the Personal Information you recently provided to us. You must provide us with: your email address and your previous order details. We will take steps to verify your request by matching the information provided by you with the information we have in our records. In some cases, we may request additional information in order to verify your identity, or where necessary to process your request. If we are unable to verify your identity after a good faith attempt, we may deny the request and, if so, will explain the basis for the denial.

Authorized Agent. You may designate someone as an authorized agent to submit requests and act on your behalf. Authorized agents will be required to provide proof of their authorization in their first communication with us, and we may also require that the relevant consumer personally verify their identity and the authority of the authorized agent.

Shine the Light. Under California's "Shine the Light" law (Cal. Civ. Code § 1798.83), California residents who provide us certain Personal Information are entitled to request and obtain from us, free of charge, information about the Personal Information (if any) we have shared with third parties for their own direct marketing use. Such requests may be made once per calendar year for information about any relevant third party sharing in the prior calendar year. California residents who would like to make such a request may contact us by using the information provided below. The request should attest to the fact that the requester is a California resident and provide a current California address.

 

Contact Us
If you have any questions or concerns regarding this Policy or our privacy practices, you may contact us using the information provided below:

• Email us at customercare@mintvelvet.com

 

14. Privacy Policy updates

We may change this Privacy Policy from time to time as we develop and update our offering across our stores, websites and applications in order to improve our services so please check back here for the latest version. If the changes are significant, we may also choose to email you.