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PRIVACY POLICY FOR CUSTOMERS



1. INTRODUCTION


1.1 In this Privacy Policy:

1.1.1 references to we, us or our means Atlasformen company (SAS) registered in the Paris trade and companies register (RCS) under company number B 449 149 038 and with our registered office at 87-89 rue la Boétie, 75008 Paris, France.

1.1.2 references to you or your means any individual who visits our website or who we supply goods to;

1.1.3 references to the Website means the website found at https://www.atlasformen.co.uk and

1.1.4 personal information is information that is about you and which identifies you.


2. PRIVACY POLICY


2.1 This Privacy Policy (together with the General terms and conditions of sales or contract which governs our supply of goods to you) sets out the basis on which we collect and use personal information about you in connection with our supply of goods to you.

2.2 This Privacy Policy describes:

2.2.1 who is responsible for the personal information that we collect about you;

2.2.2 the personal information we collect about you;

2.2.3 how we will use it;

2.2.4 who we may disclose it to; and

2.2.5 your rights and choices in relation to your personal information.

This is to make sure you have a full picture of how we collect and use your personal information.

2.3 You have the right to object to our use of your personal information in certain circumstances. A summary of your right to object (along with other rights under data protection law) and the details of who to contact if you want to exercise them can be found at paragraphs 12 and 15 below.

3. WHO IS RESPONSIBLE FOR THE PERSONAL INFORMATION THAT WE COLLECT?

3.1 We are the data controller for the purpose of data protection law in respect of your personal information collected and used in connection with the provision of goods by us to you. This is because we dictate the purpose for which your personal information is used and how we use your personal information.

4. WHAT PERSONAL INFORMATION DO WE HOLD ABOUT YOU?


4.1 We collect and use personal information about you in the course of us providing goods to you. The personal information we hold includes:

4.1.1 Information that you provide to us / we collect from you

The information that you provide to us / we collect from you may include the following:

Type of Personal Information Examples
General
Contact information. Name, title, address, date of birth, email address, Customer ID, nationality and telephone number.
Log in details. Username and account number for access to the Website.
Financial
Financial information and account details. Payment method, card number and type, card start & expiry dates, CVV code and payment history.
Credit checking information Details of your credit history, credit reference information and credit scores.
Marketing
Marketing preferences. Details of any marketing preferences that you express including any opt outs you provide.
Other
Surveys Your views and opinions about our goods and our customer services.
Conversations between customer services and you. We may record calls with our customer services
Online activity information (to the extent that it constitutes personal 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, browser plug-in types and versions, operating system and platform.
• Information about your visit to the Websites, including the full Uniform Resource Locators (URL) clickstream to, through and from the Websites (including date and time); page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.
Clothing size We collect the size of clothes you order

This information will be provided:

(a) in the course of communications between you and us (including by phone, email or otherwise);
(b) when you submit an order, either through our catalogue or on the Website;
(c) when you fill in forms for us (including those on the Website);
(d) via our social media pages (Facebook), and
(e) when you take part in survey's, quizzes and competitions.

4.1.2 Information we receive / collect from other sources

(a) We may receive your personal information from credit reference agencies (for example, your credit history, credit referencing information and credit score), if when you

5. INFORMATION ABOUT THIRD PARTIES


5.1 In the course of us providing goods to you, you may provide us with personal information relating to third parties.

5.2 We will use this personal information in accordance with this Privacy Policy. If you are providing personal information to us relating to a third party, you confirm that you have the consent of the third party or are otherwise entitled to share such personal information with us and that you have made the information in this Privacy Policy available to the third party.

6. HOW DO WE USE THE PERSONAL INFORMATION WE COLLECT ABOUT YOU?


6.1 We use your personal information for a variety of different purposes during the course of us providing goods to you. The main purposes for which we use your personal information are set out below. Under data protection law, we can only use your personal information if we have a legal basis to do so. Examples of where we have a legal basis to process your personal information, includes when:

6.1.1 we have your consent;

6.1.2 it is necessary to enter into or perform a contract we have with you (or to take steps at your request prior to entering into that contract);

6.1.3 it is necessary to comply with a legal obligation;

6.1.4 it is in our legitimate interests to process your personal information.

6.2 We have set out the main reasons for using your personal information in the table below under the heading Legal Basis. Where we rely on our legitimate interests, we have set out those interests in the table below.

Purpose Legal Basis
To manage your customer account, shopping basket and orders. Performance of a contract we have with you.
Legitimate interests: We require your personal information in order to enable us to supply the goods to you.
To communicate with you and other individuals. Performance of a contract we have with you.
Legitimate interests: We require your personal information in order to enable us to supply the goods to you.
To manage payment transactions. Performance of a contract we have with you.
To manage the delivery process. Performance of a contract we have with you.
To manage any service or quality related issues, returns, refunds, complaints, feedback and queries in relation to the supply of goods. Performance of a contract we have with you.
Legitimate interests: We require your personal information in order to ensure the goods we supply are fit for purpose.
To analyse the customer services we provide to you and improve the quality/performance of our customer services. Legitimate interests: We require your personal information in order to improve our customer services.
To prevent and detect fraud, financial crime and anti-money laundering. Performance of a contract we have with you.
Necessary for compliance with a legal obligation to which we are subject.
Legitimate interests: We require your personal information in order to conduct and manage our business.
To send you direct marketing communications about our goods. Legitimate interests: It is in our legitimate interest to contact you about goods that we offer.
Consent: In some circumstances, we may rely on your consent to send direct marketing communications to you.
To improve our knowledge and insights of our customers. Legitimate interests: It is in our legitimate interest to understand our customer's requirements so that we can improve the products we offer.
To carry out satisfaction surveys and analysis. Legitimate interests: We require your personal information in order to improve our goods and customer services.
Organising and running competitions and advertising games. Legitimate interests: It is in our legitimate interest to contact you about goods that we offer.
Consent: In some circumstances, we may rely on your consent to contact you about our competitions and/or the information you provide when participating in competitions.
To carry out our obligations arising from any contracts entered into between you and us or in preparation of entering into a contract with. Performance of a contract we have with you.
Legitimate interests: It is in our legitimate interest to comply with the terms of a contract we have in place with a customer.
To comply with any legal or regulatory obligations (including in connection with a court order). Necessary for compliance with a legal obligation to which we are subject.
To carry out credit reference checks on you. Performance of a contract we have with you.
Legitimate interests: We undertake these checks to certify and assess your financial standing to ensure we receive payment for the provision of our goods.
To enforce or apply the contracts concerning you (including contracts between you and us). Performance of a contract we have with you.
Legitimate interests: It is in our legitimate interest in order to conduct and manage our business.

6.3 We may be required to obtain your personal information to comply with our legal requirements, to enable us to fulfil the terms of our contract with you or in preparation of us entering into a contract with you. If you do not provide the relevant personal information to us, we may not be able to perform our obligations pursuant to your contract with us.

7. CREDIT REFERENCE CHECKS


7.1 If we carry out a credit reference check about you, we will provide you with further detail about the personal information that will be shared with the credit reference agency and how it will be used prior to carrying out any checks.

7.2 You can also find out more information about credit reference agencies by reading the Credit Reference Agency Information Notice each credit reference agency makes available on its website (see www.experian.co.uk, www.equifax.co.uk and www.callcredit.co.uk).

7.3 This notice will:

a) tell you about the credit reference agency;
b) provide further details on the information held by the credit reference agency and how they use it;
c) let you know who the credit reference agency shares information with and why;
d) explain how the credit reference agency works with fraud prevention agencies;
e) give you information on your rights.

8. WHO MAY WE DISCLOSE YOUR PERSONAL INFORMATION TO?


8.1 We may share your personal information with:

8.1.1 our business partners, service providers and sub-contractors for the performance of any contract we enter into with you (for example, our IT providers, secure payment processing providers on the Website, shipping providers, marketing service providers, customer contact centre services, insurance providers and document storage providers);

8.1.2 our professional advisors (including accountants, lawyers and auditors) that assist us in carrying out our business activities ;

8.1.3 third parties involved in any matter relating to you such as courts, law enforcement agencies and regulatory bodies;

8.1.4 credit reference agencies (for example : Experian, Equifax or Callcredit) ;

8.1.5 other external agencies and organisations (including the National Crime Agency) for the purpose of preventing and detecting fraud (including fraudulent transactions), money laundering and criminal activity;

8.1.6 third parties if we are under a duty to disclose or share your personal information in order to comply with any legal obligation or instructions of a regulatory body (including in connection with a court order), or in order to enforce or apply the terms of any agreements we have with or otherwise concerning you (including agreements between you and us) or to protect our rights, property or safety of our clients, employees or other third parties; and

8.1.7 French bailiff when drawing out winners for a quiz or competition, in accordance with French Law.

8.2 For a full list of the third parties with whom your particular personal information may be shared, please contact us using the details at paragraph 15 below.

8.3 We will also disclose your personal information to other third parties, for example:

8.3.1 in the event that we sell or buy any business or assets, we will disclose your personal information to the prospective seller or buyer of such business or assets;

8.3.2 if we or substantially all of our assets are acquired by a third party, personal information held by us will be one of the transferred assets; and

8.3.3 if we are under a duty to disclose or share your personal information in order to comply with any legal obligation.

9. WHERE WILL WE TRANSFER YOUR PERSONAL INFORMATION?


9.1 Sometimes it is necessary for us to process or share your personal information outside of the European Economic Area (EEA)

9.2 When we transfer Personal Information outside of the EEA, we will implement appropriate and suitable safeguards to ensure that such personal information will be protected as required by applicable data protection law (e.g. contractual protections).

9.3 For further information as to the safeguards we implement, please contact us using the details at paragraph 15 below.

10. HOW LONG WILL WE KEEP YOUR PERSONAL INFORMATION


10.1 We will retain your personal information for no longer than is necessary for the purposes for which the personal information are processed. The length of time we hold on to your personal information will vary according to what that information is and the reason for which it is being processed.

10.2 We will keep your personal information for the duration of our contract with you and for a period of 5 years after that contract is terminated.

10.3 For further information about how long we keep your personal information, please contact us using the details at paragraph 15 below.

11. DATA SECURITY


11.1 We have put in place appropriate security measures to guard against your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. For further information about these measures, please contact us using the details at paragraph 15 below.

12. YOUR RIGHTS


You have certain rights with respect to your personal information. The rights will only apply in certain circumstances and are subject to certain exemptions. Please see the table below for a summary of your rights. Details of who to contact to exercise these rights can be found in paragraph 15.

Summary of your rights
Right of access to your personal information You have the right to receive a copy of your personal information that we hold about you and information about how we use it, subject to certain exemptions
Right to rectify your personal information You have the right to ask us to correct your personal information that we hold where it is incorrect or incomplete.
Right to erasure of your personal information You have the right to ask that your personal information be deleted in certain circumstances. For example:
• where your personal information is no longer necessary in relation to the purposes for which it was collected or otherwise used;
• if you withdraw your consent and there is no other legal ground for which we rely on for the continued use of your personal information;
• if you object to the use of your personal information (as set out below);
• if we have used your personal information unlawfully; or
• if your personal information needs to be erased to comply with a legal obligation.
Right to restrict the use of your personal information You have the right to suspend our use of your personal information in certain circumstances. For example:
• where you think your personal information is inaccurate but only for so long as is required for us to verify the accuracy of your personal information;
• the use of your personal information is unlawful and you oppose the erasure of your personal information and request that it is suspended instead;
• we no longer need your personal information, but your personal information is required by you for the establishment, exercise or defence of legal claims; or
• you have objected to the use of your personal information and we are verifying whether our grounds for the use of your personal information override your objection.
Right to data portability You have the right to obtain your personal information in a structured, commonly used and machine-readable format and for it to be transferred to another organisation, where it is technically feasible.

The right only applies:
• to personal information you provided to us;
• where we rely on the following legal bases:
• consent; or
• for the performance of a contract; and
• when the use of your personal information is carried out by automated (i.e. electronic) means.
Right to object to the use of your personal information You have the right to object to the use of your personal information in certain circumstances and subject to certain exemptions. For example:

• where you have grounds relating to your particular situation and we use your personal information for our legitimate interests (or those of a third party);
• if you object to the use of your personal information for direct marketing purposes; and
• where we use your personal information to take a decision which is based solely on automated processing where that decision produces a legal effect or otherwise significantly affects you.
Right to withdraw consent You have the right to withdraw your consent at any time where we rely on consent to use your personal information.
Right to complain to the relevant data protection authority If you think that we have processed your personal information in a manner that is not in accordance with data protection law, you can make a complaint to the relevant data protection regulator. In the UK this is the Information Commissioner's Office (ICO) and they can be contacted on 0303 123 1113 or please see www.ico.org.uk.

13. COOKIES


13.1 For detailed information on the cookies we use and the purposes for which we use them, see our Cookie Policy.

14. CHANGES TO OUR PRIVACY POLICY


Any changes we make to this Privacy Policy in the future will be posted on this page and, where appropriate, we will give you reasonable notice of any changes.

15. QUERIES


15.1 If you have any questions regarding this Privacy Policy or the way we use your personal information, please contact us by:

15.1.1 telephone on 0333 336 0852;

15.1.2 Using the "My Account" section on the Website; or

16. DPO


16.1 AtlasforMen has appointed a Data Protection Officer (DPO). The DPO is responsible for overseeing data protection strategy and implementation. The DPO can be contacted by:

16.1.1 Email at: DPO@atlasformen.com;

Post at: ATLASFORMEN - DPO - PO Box 9303 – RINGWOOD BH 24 9GE

This Privacy Policy was last updated in September 2018.

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