1. Important information
This privacy notice aims to give you information on how personal data is collected through your use of this website, including any data you may provide when you purchase a product or service. This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice 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 notice supplements the other notices and is not intended to override them.
2. Who we are
Internet Fusion Ltd (Co number 06012780 whose registered office is at 2 Stone Buildings, Lincoln's Inn, London, England, WC2A 3TH (“IFL”) operates the website and sells branded products as an authorised distributor of products produced by Brand Machine International Ltd (Company number 06873920) whose registered office is at Unit 1 Windsor Industrial Estate, 424 Ware Road, Hertford, Hertfordshire, SG13 7EW (“BMIL”),
• IFL will be a data controller in relation to the performance of any order you place through the website. • BMIL will be a data controller in relation to any subsequent marketing activities which may take place as a result of you placing an order through the website IFL and BMIL are not joint data controllers, operate independently from one another and will use your data for separate purposes. This policy refers to the actions of both IFL and BMIL to simplify the explanation.
IFL - Please contact our Data Privacy Manager: Email: email@example.com Postal address:Data Privacy Manager, Internet Fusion Ltd, 2 Stone Buildings, Lincoln's Inn, London, England, WC2A 3TH.
BMIL - Please contact our Data Privacy Manager Internet Fusion Limited: Email: firstname.lastname@example.org Postal address: Portofino Kids Data Privacy Manager, Brand Machine International Limited Unit 1 Windsor Industrial Estate, 424 Ware Road, Hertford, Hertfordshire, SG13 7EW.
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (ico.org.uk). Both IFL and BMIL would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
3. Third-party links
This Portofino Kids website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. IFL does not control these third-party websites and is not responsible for their privacy statements. When you leave IFL’s website, we encourage you to read the privacy notice of every website you visit.
4. The data that is collected about you
Personal data, or personal information, means any information about an individual from which that person can be identified. The following categories of personal data may be collected about you which we have grouped together follows:
- Identity Data includes first name, last name.
- Contact Data includes billing address, delivery address, email address and telephone numbers.
- Financial Data may include payment card details.
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
- Technical Data may includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
- Profile Data may include your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data may include information about how you use our website, products and services.
- Marketing and Communications Data: your preferences in receiving marketing from BMIL and your communication preferences. Where IFL needs to collect personal data to fulfil your order and you fail to provide that data when requested, we will have to cancel your order. We will notify you if this is the case at the time.
We may share non-personal aggregate statistics (group) data about visitors to this site, sales and traffic patterns. The information collected will also be used to help us provide further services on this site in the future. However we do not sell or share any information about you as an individual user of this site unless you agree to us doing so.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
5. 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 Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
apply for our products or services;
create an account on our website;
subscribe to our service or publications;
request marketing to be sent to you; or
give us some feedback.
Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
Technical Data from the following parties:
- (a) analytics such as Google;
- (b) advertising networks; and
- (c) search information providers
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
6. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- 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 or regulatory obligation.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or facilitating your participation in a prize draw, competition or survey you have voluntarily entered. You have the right to withdraw consent to marketing at any time by contacting us.
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as a new customer||(a) Identity
|Performance of a contract with you|
|To process and deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(e) Marketing and Communications
|(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
|To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey
(d) Marketing and Communications
|(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
|To enable you to partake in a prize draw, competition or complete a survey||(a) Identity
(e) Marketing and Communication
|(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
(c) Your consent
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity
|(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||(a) Identity
(e) Marketing and Communications
|Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences||(a) Technical
|Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
|To make suggestions and recommendations to you about goods or services that may be of interest to you||(a) Identity
|(a) Necessary for our legitimate interests (to improve our services, develop our products/services and grow our business)
(b) Your consent
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
A cookie is a small file and holds a certain amount of data, which the website can send to your browser. It may then be stored on your computer's hard drive and can be accessed by our web server. This cookie data can then be retrieved and can allow us to customise our web pages and services accordingly. It's important to clarify that cookies do not collect any personal data stored on your hard drive or computer.
You can find out all about cookies from this website AllAboutCookies.org.
Our website uses both persistent and session cookies: Persistent cookies are used to allow the website to recognise users when they return to the site and to remember certain information about their preferences. These cookies are cookies which stay on your computer permanently, until you "manually" delete them.
Session cookies are used in order to allow customers to carry information across pages of the website, without having to re-enter such information. These cookies delete themselves automatically when you leave a website and go to another, or when you shut down your browser.
We have also developed relationships with carefully selected and monitored partners, to assist in the delivery of a high quality website. Some of these partners may also set cookies during your visit to support customisation of adverts that you may see elsewhere on the Internet, and/or in order to meet contractual obligations with us.
While these cookies do not store any personal details relating to you or your credit cards, please note we do not have access or control over the cookies and similar technologies that our partners use.
How to control and delete cookies
Should you choose to disable, reject or block our cookies, some parts of our website will not function fully, or in some cases, our website will not be accessible at all. Our cookies do not contain any personally identifying information, but they do enable us to provide features such as enabling us to store items in your shopping basket between visits. Most web browsers automatically accept cookies, but you can usually change your browser settings to prevent this. It is not possible to make a purchase unless you have cookies turned on and we recommend that you leave them turned on.
For more information on how to control your cookie settings and browser settings, or how to delete cookies on your hard drive, please visit AllAboutCookies.org. The "help" portion of the toolbar on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Disabling cookies may result in loss of functionality of the website.
8. Who do we share personal data with?
IFL will not share your personal data with any third parties other than those third parties who provide part of our sales service. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. We may also share your personal data with third parties to whom we may choose to transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
In particular, in order to be able to offer you Klarna’s payment options, we will pass to Klarna a certain amount of your personal information, such as contact and order details, in order for Klarna to assess whether you qualify for their payment options and to tailor the payment options for you. General information on Klarna can be found here. Your personal data is handled in accordance with applicable data protection law and in accordance with the information in Klarnas privacy statement.
9. International transfers
We do not generally transfer your personal data outside the UK or European Economic Area (EEA).
If we do need to transfer your personal data out of the UK or EEA (for example to certain service providers located abroad), we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK or EEA.
At the date of this policy the position in respect of transfers of data between the UK and EEA is constantly changing, but we will ensure that such transfers are made subject to appropriate safeguards as may be required by any applicable data protection laws from time to time. These will include the use of the above safeguards, as far as possible.
10. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal 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 will notify you and any applicable regulator of a breach where we are legally required to do so.
11. Data retention
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
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 unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
12. Your legal rights
Under the privacy regulations you have rights under data protection laws in relation to your personal data (See "your Legal Rights" section below for more information):
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us preferably by this email DataSubjectRequests@internetfusion.co.uk or the address listed towards the top of this policy.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do 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 to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify 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 remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate 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 which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.