Privacy Policy

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.

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 notice?

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 our Customer Care Team or visits to our website
• Information you provide in your reviews of us, our products or survey responses
• Payment details via our third party payment gateway provider only
• Delivery address(s)
• Billing address
• Details of your shopping preferences such as preferred store or product categories
• IP address
• Information from cookies, including information on the devices you may use to make a purchase – please see our separate Cookies Policy

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 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

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 who help us to understand your purchasing behaviour and preferences. They also use this information to provide us with more targeted data for prospective customers who have consented to be marketed to.
  • We currently use Experian Ltd for the purpose of managing a service called Club Canvasse of which we are a member. Your personal data is not shared with any other members of the cooperative. All that is shared is an aggregated view of data on the number and value of purchases made. 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. The participating retailers are active in the clothing, collectables, food & wine, gardening, gadgets & entertainment, health & beauty, household goods, and home interiors categories. Retailers share information about their customers and what they buy. Epsilon Abacus processes this information on behalf of the retailers to help them understand consumers’ wider buying patterns. From this information, retailers can tailor their communications, sending individuals, subject to their marketing preferences, suitable offers that should be of interest to them, based on what they like to buy. You can learn more about how Epsilon Abacus processes your personal information in their Privacy Policy, which is available here: https://abacus.epsilon.com/privacy-policy/
• 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.
• USA customers only – in addition where you are an existing customer (or you have otherwise given us your data) and have consented to third party marketing, when we share your data with carefully selected cooperative database companies (as outlined above) other third party companies who use such databases in the USA may send you details of products and services that may be of interest to you. You can opt out at any time using the methods set out below.
• 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 “refer a friend” marketing programmes.

In connection with the above activities, we may share your personal information with trusted suppliers who assist us in our data processing activities 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 basis we rely on to collect and process your personal data:

i) Consent

If you visit our site or fill in any in-store materials, then depending on how you interact with us, we will ask for your consent to process your data, so that we can send you our special offers and news.

ii) 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.

iii) 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.

iv) Legitimate Interest

We may process your data in a way which might reasonably be expected as part of running our business. This is known as processing for legitimate 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) the provision and operation of referral marketing programmes; (iv) network and information systems security; (v) data analytics; (vi) enhancing, modifying or improving our service; (vii) identifying usage trends; or (viii) determining the effectiveness of promotional campaigns or advertising.

When we process your personal information for our legitimate interests, we make sure to consider and balance any potential impact on you (both positive and negative), and your rights under data protection laws. Our legitimate business interests do not automatically override your interests we will not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted by law).

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, 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 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 European Union.

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

• 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 Team who will do this for you. You can contact them by calling 0345 456 2200 (International +44(0)1494 956700, US 1-866.615.1818) or email: customercare@mintvelvet.co.uk
• 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.
  • Contact our Customer Care Team on 0345 456 2200 (International +44(0)1494 956700, US 1-866.615.1818) 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.

Please submit your requests through the following channels:

Or send an email to: dataprotection@mintvelvet.co.uk

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/make-a-complaint (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 under The California Consumer Privacy Act (CCPA)

The information contained in this Section supplements the details provided in our Privacy Policy, is given in compliance with the Californian Consumer Privacy Act (“CCPA”) and apply only if you are a resident of the State of California.

In addition to the information provided under Section 3 of this Privacy Policy, we would like to let you know that, we may collect the below personal information:

• Commercial information, including purchase information and preferences;
• Geolocation data ;
• Internet or other electronic network activity, including, but not limited to, browsing history, search history, and information regarding your interaction with an Internet website, application or advertisement;
• Inferences drawn from any of the information identified above to create a profile reflecting your shopping preferences.

The collection sources could be also from our business partners or vendors or from your social media account.

Your personal data is collected for the purposes outlined in Section 4 of this Privacy Policy and may be shared with trusted third-party organizations as described in Section 8. These constitute business purposes within the meaning of the CCPA.

As a California resident, you have the right to request access to specific categories of your personal data and to request that we delete the personal data that we hold about you to the extent we are allowed to retain the same in according with the CCPA. You may exercise such rights up to twice every 12 months. If you wish to exercise such rights, please contact dataprotection@mintvelvet.co.uk. We will process your request as soon as it is verified. In order to verify your identity, we may ask you provide certain personal information. In the event that we refuse to fulfil your request (for example if it is unreasonable), we will explain you our reasons for such refusal. Any information that we provide to you will only cover the 12-month period preceding the receipt of your request.

You would also have the right to opt-out of the sale of your personal information, however, please note that Mint Velvet does not disclose nor sell your personal data to third parties for their direct marketing purpose.

Finally, you have the right not to be discriminated against for exercising any of the rights described in section 10, and we will not deny, offer products of inferior quality or charge you a different price for our products if you exercise any of those rights.

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 and we will bring such changes to your attention.