This Privacy Notice is effective from 25/11/2019.
Who we are and what this Privacy Notice covers
Throughout this Privacy Notice we refer to the Red Kooga Site and our other products and services to which this Privacy Notice applies collectively as the “Services”.
The privacy of all our customers and visitors to the Red Kooga Site is critical to us. This Privacy Notice outlines the personal information that we process about you and how we process it. It also describes your data protection rights (including a right to object to some of the processing which we carry out) and explains how to exercise them.
For all of our Services, the data controller (i.e. the company that is responsible for deciding what personal data will be collected about you and how it will be used) is Soho Flordis UK Limited, a company registered in England and Wales under company number 09651037.
If you have any questions about this Privacy Notice, please contact us as described in the Contact Details section below.
Summary of how we use your data
- We use your personal data to allow you to use the features on the Red Kooga Site, to administer your online and offline relationship with Soho Flordis, to comply with Soho Flordis’ legal obligations and to provide you with Red Kooga products, services and other offerings. Some of this information will be provided by you, and others will be generated by us or provided by third parties.
- The Red Kooga Site provides interactive features that engage with social media sites, such as Facebook and Twitter. If you use these features, these sites will send us personal data about you.
- Where we rely on your consent, such as for direct marketing purposes, or to place cookies, you can withdraw this consent at any time.
Links to third party sites
This Red Kooga Site may link to other third party websites which we do not have any control over. We are not responsible for the content of such web sites or for their own privacy practices, or for the way in which information about their users is treated. In particular, unless expressly stated, we are not agents for these sites nor are we authorised to make representations on their behalf.
Definitions you should be aware of
Personal data: “personal data” means any information relating to a person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Processing: when we refer to the “processing” of your personal data in this Privacy Notice, this is used to describe all the ways in which your personal data is handled by us. This includes the collection, organisation, sharing, storage, erasure and use of your personal data.
What information do we hold about you, why and how do we use it?
We collect personal data about you in two ways:
1. Information you provide to us
We collect and process personal data about you when you interact with us and the Red Kooga Site. This information will typically be provided directly by you and may include information you provide on registration or in the process of your purchase, such as your name, email address, address, telephone number, position, business name and marketing preferences.
• Basic contact details: We ask for your email address when you register to receive our newsletter.
• Communications with us: You may also provide us with information when you use our contact form to communicate with our team or ask us a question.
2. Information we generate
We may generate or collect information about you ourselves when you visit the Red Kooga Site (which may inform us about you, your use of the Red Kooga Site and how you arrived at the site). Such information may be collected through “traffic data” and may entail the use of “cookies” or other tracking technologies, IP Addresses or other numeric codes used to identify your computer – see the Cookies Notice
for more information.
3. Information we collect from other sources
We may also get information about you from other sources. For example, if you create or log into your account through another service (like Google) or if you connect your account to a social media service (like Twitter), we will receive information from that service (such as your username, basic profile information, and friends list) via the authorization procedures used by that service. The information we receive depends on which services you authorize via those third party sites and any options that are available.
We may also obtain information from third party services about individuals who are not yet our clients (…but we hope will be!), which we may use, for example, for marketing and advertising purposes.
How we use this information and the legal basis for such use
We process personal data about you for the following purposes:
- As required by Soho Flordis to conduct our business and pursue our legitimate interests, in particular:
- We use your information to provide products and services you have requested, and respond to any comments or complaints you may send us;
- We monitor use of the Red Kooga Site and use your information to help us monitor and improve our products, content, services and websites, both online and offline;
- We use information you provide to personalise the Red Kooga Site, our products or services for you;
- We use information you provide and collected about you to investigate any complaints received from you or from others, about the Red Kooga Site or our products or services;
- We will use data in connection with legal claims, compliance, regulatory and investigative purposes as necessary (including disclosure of such information in connection with legal process or litigation); and
- We use data of some individuals to invite them to take part in market research;
Where you give us consent:
- We will send you direct marketing in relation to our relevant products and services, or other products and services provided by us (including offers and promotions or our email newsletter);
- We place cookies and use similar technologies in accordance with our Cookies Notice and the information provided to you when those technologies are used; and
- On other occasions where we ask you for consent, we will use the data for the purpose which we explain at that time;
For purposes which are required by law:
- Where we are required to hold or collect personal data to meet legal requirements on us, such as keeping health and safety records or details of purchases; and
- where in response to requests by government or law enforcement authorities conducting an investigation.
Withdrawing consent or otherwise objecting to direct marketing
Wherever we rely on your consent, you will always be able to withdraw that consent, although we may have other legal grounds for processing your data for other purposes, such as those set out above. In some cases, we are able to send you direct marketing without your consent, where we rely on our legitimate interests. You have an absolute right to opt-out of direct marketing, or profiling we carry out for direct marketing, at any time. You can do this by following the instructions in the communication where this is an electronic message, or by contacting us using the details set out below.
How we share your personal data
We do not sell our users’ private personal information.
We share your personal data in the limited circumstances set out below in order to fulfil the purposes set out above:
- Subsidiaries, employees, and independent contractors: We may disclose your personal data to our subsidiaries, our employees, and contractors that need to know the information in order to help us provide our Services or to process the information on our behalf. We require our subsidiaries, employees, and contractors to process your personal data in compliance with this Privacy Notice.
- With your consent: We may share and disclose information with your consent or at your direction. For example, we may share your information with third parties with which you authorize us to do so. Where we require your consent to share your data with 3rd parties you will find these listed under Sharing with Third Parties.
- Sharing with third parties: We may share your personal data with relevant third party vendors who need to know information about you in order to provide their services to us. For example, we use vendors that help us provide our Services to you such as those that help us understand and enhance our Services (like analytics providers). We require vendors to agree to privacy commitments before we share any information with them.
- As Required by Law: We may disclose your personal data to government authorities and/or law enforcement officials if required for the purposes above, if mandated by law or if required for the legal protection of our legitimate interests in compliance with applicable laws.
- Business Sale or Transfers: In the event that any part of the Soho Flordis business is sold or integrated with another business, your details may be disclosed to our advisers and any prospective purchaser’s adviser and will be passed to the new owners of the business.
Please note that we may also publically share information that has been aggregated or de-identified (i.e. so that the information could not be used to identify you). For instance, we may publish aggregate statistics about the use of our Services or, if you send us a request (for example, via a support email or one of our feedback mechanisms), we may anonymously publish that request in order to help us clarify or respond to your request or to help us support other users.
Transfer of Information outside of the EEA
From time to time we may transfer your personal information to our group companies, suppliers or service providers based outside of the EEA for the purposes described in this Privacy Notice. If we do transfer data outside the EEA to a country that is not subject to an adequacy decision by the EU Commission, we ensure that your personal data is adequately protected via another legal mechanism. This might be through the use of model contracts in a form approved by regulators, or through an appropriate privacy scheme approved by regulators (like the US ‘Privacy Shield’ scheme). A copy of the relevant mechanism can be provided for your review on request using the Contact Details set out below.
Your personal data will be deleted once it is no longer required for the purpose for which it was collected (e.g. as part of a contractual relationship). In particular:
- Where we process personal data in the provision of our products or services, we do this for as long as you are an active user of our products or services and for 6 years after this.
- Where we process personal data for marketing purposes or with your consent, we process the personal data until you ask us to stop and for a short period after this (to allow us to implement your requests. We also keep a record of the fact that you have asked us not to send you direct marketing or to process your personal data indefinitely so that we can respect your request in future.
- Where we process personal data in connection with performing a contract or for a competition, we keep the personal data for 6 years from your last interaction with us.
- Where we process personal data to monitor and compile statistics about the use of our Red Kooga Site, we keep the Personal Data in accordance with our Cookies Notice
- Where we process personal data to meet legal requirements, we hold this for as long as the law requires.
When it comes to your personal data, you have defined rights regarding how your data is collected, processed and shared. These rights are explained below:
- The right of access: You have the right to request a copy of your personal data that we hold and process.
- The right to erasure: In specific circumstances, you have the right to request that any personal data we hold about you be erased. This includes where:
- your personal data is no longer necessary in relation to the purpose for which it was originally collected/processed;
- you withdraw consent on which the processing was based; or
- you object to the processing and there is no overriding legitimate interest for us to continue the processing.
- The right to rectification: If you become aware that any of your personal data that we hold is incorrect you have the right to request that this data be corrected.
- The right to data portability: In some cases, you may the right to request that we provide you with an electronic copy of any data you have given to us as part of a contractual relationship or following your consent.
- The right to restrict processing: In some situations you may require us to restrict processing, such as following an objection to processing while an assessment is made or if the data accuracy is in question. Where you exercise your right to restrict processing we shall not recommence processing without first notifying you.
In addition, you can object to the processing of your personal data in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement, or where we are using the data for direct marketing).
These rights may be limited, for example if fulfilling your request would reveal personal data about another person, or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping.
Data that is mandatory is indicated on relevant forms that you complete. Where provision of data is mandatory, if relevant data is not provided, then we will not be able to fulfil your requests to register, make a purchase or otherwise engage with Soho Flordis. All other provision of your information is optional.
Exercising your rights
If you wish to exercise any of your rights we would be happy to help you. Please use the Contact Details below to communicate a complaint.
Registering a Complaint
If you have any complaints about the way in which your personal data is being handled, then please contact us using the Contact Details below. Alternatively, you may also contact the national supervisory authority to register a complaint; their details can be found at ico.org.uk.
To contact us about this Privacy Notice, to ask questions about your personal data or with any data requests, you may contact us at:
Soho Flordis UK Limited
1 Botanic Court
Data Policy Officer:
Steven Hicks – Head of Sales and Marketing UK & Ireland
Last Updated: 04/11/2019
This Cookies Notice is effective from 25/11/2019.
What are cookies and when are they used?
This site may use standard technology called ‘cookies’. A cookie is a small piece of information stored by your browser on your computer’s hard drive which often includes an anonymous unique identifier. Cookies are created when your browser loads a particular website. The website sends information to the browser which then creates a text file. Every time the user goes back to the same website, the browser retrieves and sends this file to the website’s server. For more information about cookies or to switch off cookies on your browser please visit www.allaboutcookies.org.
We also use other forms of technology (such as web beacons, and invisible graphics which are associated with the user ID of the relevant e-mail subscriber) which serve a similar purpose to cookies and which allow us to monitor and improve the Red Kooga Site and our email communications. We use these in connection with cookies to help operate our websites and email communications and collect information about online activity. When we talk about cookies in this Cookies Notice, this term includes these similar technologies.
Why do we use these technologies?
1. Strictly Necessary Cookies
These cookies are essential in order to enable you to move around the Red Kooga Site and use its features. Without these cookies, services you have asked for such as remembering your login details cannot be provided.
2. Performance Cookies
These cookies collect anonymous information on how people use our Red Kooga Site. For example, we use Google Analytics, cookies to help us understand how customers arrive at our Red Kooga Site, browse or use our Red Kooga Site and highlight areas where we can improve, such as navigation, shopping experience and marketing campaigns. The data stored by these cookies never shows personal details from which your individual identity can be established.
3. Functionality Cookies
These cookies remember choices you make such as the location you visit our website from, language and search parameters such as volume or product line. These can then be used to provide you with an experience more appropriate to your selections and to make the visits more tailored and pleasant. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites.
4. Targeting cookies or advertising cookies
These cookies collect information about your browsing habits in order to make advertising more relevant to you and your interests. They are also used to limit the number of times you see an advert as well as help measure the effectiveness of an advertising campaign. The cookies are usually placed by third party advertising networks. They remember the sites you visit and that information is shared with other parties such as advertisers. For example, we use third party companies such as Double Click to provide you with more personalized adverts when visiting other sites.
5. Social Media Cookies
These cookies allow you to share what you’ve been doing on the Site on social media such as Facebook, LinkedIn and Twitter. These cookies are not within our control. Please refer to the respective privacy notices for how their cookies work.
How do you manage these technologies?
Our cookies expire after thirteen months. The web beacons used in emails are deleted when you delete the email.
You may set your browser to block all cookies or to indicate when a cookie is being set, although our services may not function properly if your cookies are disabled. To find out how to control or disable cookies within most browsers, consult the “Help” section of your browser or device or visit www.allaboutcookies.org.
Alternatively, to prevent the use of the web beacons in our e-mails, adjust the settings in your e-mail programme to stop HTML being displayed in messages.