TGB SPA Privacy Policy

TGB SPA Privacy Promise

‍

TGB SPA are dedicated to safeguarding your privacy online. We will only collect, store and use your personal information for specific purposes. We use your personal information tosupport and develop our connection with you. We only share your personal data in accordance with the Data Protection Act 2018, other appropriate laws and this privacy policy. You may contact TGB SPA at any time with any privacy queries or concerns and to see the personal data you have given us and request modification or to assert your legal rights. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

‍

This website is not intended for children and we do not knowingly collect data relating to children.

‍

Controller

‍

TGB SPA is a subsidiary business that forms part of the DKollection group. This privacy policy is issued on behalf of the group. Any reference to “we, us or our” shall refer to the relevant company in the group who is the controller of your personal data. We will be able to let you know which entity will be the controller of your data wherever you have purchased a product or service with us. TGB SPA is the controller and is responsible for this website.We have appointed a data privacy management team who are responsible for overseeing questions in relation to this privacy policy. If you have any questions about this policy, orwish to exercise your legal rights, please contact the data privacy team using the details set out below:

‍

Email address: info@tgbspa.com
Telephone number: +440 1273 040333
Postal address: TGB SPA Customer Services, 51-53 West Street Brighton and Hove BN12RA United Kingdom

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would,however, appreciate the chance to deal with your concerns before you approach the ICOso please contact us in the first instance.
‍

Agreement

‍

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them. By continuing to use our website and to provide data to us you are agreeing that you have reviewed this privacy policy.

‍

Personal data or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

‍

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data includes billing address, delivery address, email address and mobile and telephone numbers.
• Financial Data includes bank account.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, browser type andversion, time zone setting and location, browser plug-in types and versions, operatingsystem and platform, and other technology on the devices you use to access this website.
• Profile Data includes your username and password, purchases or bookings made by you,your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic datafor any purpose. Aggregated Data could be derived from your personal data but is notconsidered personal data in law as this data will not directly or indirectly reveal youridentity. For example, we may aggregate your Usage Data to calculate the percentage ofusers accessing a specific website feature. However, if we combine or connect AggregatedData with your personal data so that it can directly or indirectly identify you, we treat thecombined data as personal data which will be used in accordance with this privacy policy.

‍

We do not collect any Special Categories of Personal Data about you (this includes detailsabout your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation,political opinions, trade union membership, information about your health, and geneticand biometric data). Nor do we collect any information about criminal convictions andoffences.

‍

How we use your personal data

‍

We will only use your personal data when the law allows us to. Most commonly, we will useyour personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into withy ou.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation.Where we have obtained your consent.

The purposes for which we will use your personal data

‍

We are dedicated to using your personal data only for:

• Registering you as a new customer or as a user of our website.
• Processing your bookings correctly – including managing payments and charges,managing bookings, plus any changes or cancellations to your bookings
• Development and expansion of the business, including examination of customers'shopping behaviours, measurement of advertisements and product style preferences ofour customers.
• Technical management of our website and business.
• To manage our relationship with you – including providing you with information aboutthe services we offer, notifying you of changes to our terms or this privacy policy and askingyou for feedback.
• Letting you know about offers and news.
• To deliver relevant website content and advertisements to you and to measure theeffectiveness of this marketing.
• To use data analytics to improve our website, products, services, marketing,customer relationship and overall experience.

Generally, we do not rely on consent as a legal basis for processing your personal data.You have the right to opt-out of receiving marketing messages at any time. To unsubscribefrom email marketing please follow the link found in the email or contact us in accordancewith this privacy policy.

‍

How is your personal data collected

‍

We use different methods to collect data from and about you including through:

• Direct Interactions – you may give us your data by filling in forms or by corresponding withus by post, phone, in person, email or otherwise. This includes personal data you providewhen you: apply for our products and services, create an account on our website,subscribe to our service or publications, requested promotional material to be sent to you,give us feedback, or contact us.
• Third Parties – we may be provided your personal data from various third parties such as:analytics providers, advertisement networkers, search information providers, publiclyavailable information, from data brokers or aggregators, from third parties which weacquire or merge with our business.

International Transfers

‍

We will share your personal data within the company group. This may involve, although wewill seek to avoid, transferring your data outside of the UK.

‍

Many of our external third parties are based outside of the UK and their processing ofpersonal data will therefore involve a transfer of data outside of the UK. Whenever wetransfer your personal data out of the UK, we ensure a similar degree of protection isafforded to it by ensuring at least one of the following safeguards is implements:

• We will only transfer your personal data to countries that have been deemed to provide anadequate level of protection for personal data.
• Should you want any further information on the specific mechanism used by us you should get in touch with our data privacy management team.

How we protect data

‍

You recognise that the Internet is not a 100% secure platform for communication and,accordingly, we cannot guarantee the security of any data you send to us (or we send toyou) via the Internet. We are not responsible for any damages which you, or others, maysuffer as a result of the loss of confidentiality of such information.

‍

We have put in place appropriate security measures to prevent your personal data frombeing accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Inaddition, we limit access to your personal data to those employees, agents, contractorsand other third parties who have a business need to know. They will only process yourpersonal data on our instructions and they are subject to a duty of confidentiality.

‍

We have put in place procedures to deal with any suspected personal data breach and willnotify you and any applicable regulator of a breach where we are legally required to do so.

‍

We will only retain your personal data for as long as reasonably necessary to fulfil thepurposes we collected it for, including for the purposes of satisfying any legal, regulatory,tax, accounting or reporting requirements. We may retain your personal data for a longerperiod in the event of a complaint or if we reasonably believe there is a prospect oflitigation in respect to our relationship with you.

‍

To determine the appropriate retention period for personal data, we consider the amount,nature and sensitivity of the personal data, the potential risk of harm from unauthoriseduse or disclosure of your personal data, the purposes for which we process your personaldata and whether we can achieve those purposes through other means, and the applicablelegal, regulatory, tax, accounting or other requirements.

‍

By law we have to keep basic information about our customers for six years after theycease being customers for tax purposes.

‍

Disclosures of your personal data

‍

By law we have to keep basic information about our customers for six years after theycease being customers for tax purposes.

‍

We may share your personal data with the parties set out below in accordance with ourongoing business purposes.

‍

We require all third parties to respect the security of your personal data and to treat it inaccordance with the law. We do not allow our third-party service providers to use yourpersonal data for their own purposes and only permit them to process your personal datafor specified purposes and in accordance with our instructions.

‍

Internal Third Parties – shall mean other companies in the company Group who are eitheracting as joint controllers or processors.

External Third Parties – such as:

• Service providers acting as processors who provide IT and system administration services.
• Professional advisers acting as processors or controllers including lawyers, bankers,auditors and insurers who provide consultancy, banking, legal, insurance and accountingservices.
• Regulators and other authorities (such as HMRC) acting as processors or joint controllerswho require reporting of processing activities in certain circumstances.
• Social media platforms (such as Meta – Facebook & Instagram), acting as processors andjoint controllers, based within the EEA or US who host social media platforms.
• Marketing automation platforms, acting as a processor, such as The Rocket Science GroupLLC t/a MailChimp based in the US who provide email marketing automation services.Integrated live chat applications, such as Zendesk, Inc based in the US, who provide ourintegrated live chat.
• Analytics and search engine providers, such as Google, who provide analytics andadvertisement servicesMerchant services, acting as a processor, who provide secure payment processing services.

Your Legal Rights

‍

You have the right to:

• Request access to your personal data (commonly known as a "data subject accessrequest"). This enables you to receive a copy of the personal data we hold about you and tocheck that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to haveany incomplete or inaccurate data we hold about you corrected, though we may need toverify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or removepersonal data where there is no good reason for us continuing to process it. You also havethe right to ask us to delete or remove your personal data where you have successfullyexercised your right to object to processing (see below), where we may have processedyour information unlawfully or where we are required to erase your personal data tocomply with local law. Note, however, that we may not always be able to comply with yourrequest of erasure for specific legal reasons which will be notified to you, if applicable, atthe time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (orthose of a third party) and there is something about your particular situation which makesyou want to object to processing on this ground as you feel it impacts on your fundamentalrights and freedoms. You also have the right to object where we are processing yourpersonal data for direct marketing purposes. In some cases, we may demonstrate that wehave compelling legitimate grounds to process your information which override your rightsand freedoms.
• Request restriction of processing of your personal data. This enables you to ask us tosuspend the processing of your personal data in the following scenarios:
• If you want us to establish the data's accuracy.
• Where our use of the data is unlawful but you do not want us to erase it.
• Where you need us to hold the data even if we no longer require it as you need it toestablish, exercise or defend legal claims.
• You have objected to our use of your data but we need to verify whether we have overridinglegitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you,or a third party you have chosen, your personal data in a structured, commonly used,machine-readable format. Note that this right only applies to automated information whichyou initially provided consent for us to use or where we used the information to perform acontract with you.
• Withdraw consent at any time where we are relying on consent to process your personaldata. However, this will not affect the lawfulness of any processing carried out before youwithdraw your consent. If you withdraw your consent, we may not be able to providecertain products or services to you. We will advise you if this is the case at the time youwithdraw your consent.

Further information

‍

If you have questions about your personal data or our privacy policy, please contact us at info@tgbspa.com. To see all the information we have about you, and to correct any inaccuracies, please write to us at: TGB SPA Customer Services, 51-53 West StreetBrighton and Hove BN1 2RA United Kingdom.

‍

Changes to Privacy Policy

‍

We reserve the right to amend our privacy policy, whilst keeping it within all appropriatelegislation and guidelines. We will do all we can to ensure that these pages show the mostup to date information at all times, and may notify you of such changes by uploading therevised privacy policy on the TGB SPA website.