Privacy Policy

This Privacy Policy is effective upon 25 May 2018.

This Privacy Policy aims to give you information on how we collect and process your personal data.

The RSANDERSON.COM website, mobile app and any other means of collecting personal data are controlled by R. SANDERSON Holding Limited, referred to as “we”, “us” or “our” throughout this Privacy Policy. We are the primary data controller for the purposes of this website and our registered office is Harbour Place, 2nd Floor, 103 South Church Street, P.O. Box 472, George Town, Grand Cayman, Cayman Islands KY1-1106.

It is important that you read this Privacy Policy 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 Policy supplements the other notices and is not intended to override them.

We may amend this Privacy Policy at any time by posting the amended terms herein. All amended terms automatically take effect 30 days after they are posted. We will announce any material changes and their rationale to this Privacy Policy through email.

Scope

This Privacy Policy describes our collection, use, disclosure, retention and protection of your personal data. It applies to any RSANDERSON.COM web or mobile view where this Privacy Policy appears.

By navigating to a RSANDERSON.COM website or mobile view, by transacting and by registering an account, you are agreeing to the terms of this Privacy Policy.

Rupert Sanderson Shoes Limited is the data controller of your personal data and is responsible for the collection, use, disclosure, retention and protection of your personal information in accordance with the General Data Protection Regulation.

Rupert Sanderson Shoes Limited may transfer your personal information outside of the European Economic Area to our group companies and authorised third parties. Where we use third party service providers based outside of the European Economic Area, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. Where we use third party service providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.

Collection and cookies

We collect, process and retain personal information from you and any devices you may use when you navigate to a RSANDERSON.COM web or mobile view, by transacting, by registering an account and otherwise interacting with us.

We may also collect personal information from you if you physically enter one of our stores or attend an event.

The personal information we collect includes the following:

  • Personal information including payment related information you give us when you register or purchase through the site or mobile app;
  • Content that you generate when interacting with our customer services team including details we require to contact you and verify your identity;
  • Content we generate via machine learning algorithms as they apply to personalising your experience by curating more specifically the items you have an interest in, as well as supporting general service optimisation including bid / markdown automation
  • Other content that you generate through browsing activity including intended purchases, your marketing preferences, completion of surveys, wishlists, and participation in promotional activity; and
  • Device identifiers such as IP addresses, cookie IDs, IDFAs and other device identifiers, as well as geo location information, IoT technologies and connection information such as statistics on your page views, traffic to and from the sites, referral URL, ad data, your browsing history, hashed email addresses, and your web log information.

If you give us personal data about someone else, you must do so only with their explicit and prior consent.

We may allow you to share information with social media sites, or use social media sites to create your account or to connect your account with the respective social media site. Those social media sites may give us automatic access to certain personal information retained by them about you (e.g., content viewed by you, content liked by you and information about the advertisements you have been shown or may have clicked on). Where this information is received by us, we will use this information to further personalise your experience with RSANDERSON.COM.

We use cookies, web beacons and similar technologies to collect information about the pages you view, the links you click and other actions you take on our Services, within our advertising or e-mail content.

Cookies are text files stored on your computer when you visit web pages.

To make full use of the online shopping and personalised features on RSANDERSON.COM, your computer, tablet or mobile phone will need to accept cookies, as we can only provide you with certain personalised features of this website by using them.

Here’s a list of the main cookies we use and what we use them for.

Cookie Name Cookie Description
PHPSESSID, form_key, mage-cache-sessid, mage-cache-storage-section-invalidation, mage-cache-storage, mage-messages, mage-translation-file-version, mage-translation-storage, persistent_shopping_cart, private_content_version, section_data_ids, X-Magento-Vary, r_sanderson_session, XSRF-TOKEN These cookies are set by our e-commerce platform and are essential to facilitate normal user activity.
o_subscribe_dismiss This cookie lets us know that you do not want to be prompted to sign-up to our mailing list.
cookieconsent_status This cookie lets us know that you accepted cookie consent.
store_location This cookie lets us know which online store location you have selected. For example, 'United Kingdom'.

First party cookies – cookies that RSANDERSON.COM drop. At RSANDERSON.COM, we use cookies to keep track of what you have in your basket and to remember you when you return to our site.

Third-party cookies - cookies dropped by third parties RSANDERSON.COM has a contractual relationship with. We use cookies to enable specific functionalities and enhance the customer experience

Cookie Name Cookie Purpose
_ga, _gat, _gid These cookies are dropped by our partner Google Analytics for traffic and user behaviour analytics.

Third-party cookies used for retargeting

We have relationships with carefully selected third parties who may also set cookies during your visit to be used for remarketing purposes – in other words to show you different products and services based on what you appear to be interested in. This type of advertising is designed to provide you with a selection of products based on what you’re viewing on RSANDERSON.COM, which are presented to you by our business partners when you visit other selected websites. The adverts may highlight products you’ve viewed, alternative styles and colours, as well as products from other categories deemed relevant to your browsing history. The technology behind these adverts is based on cookies.

Disabling these advertisements

We would like to continue to display content that's relevant to you, however, you can choose to opt out of this type of advertising permanently by clicking the opt out icon appearing in the top right hand of the ad. Please note that if you delete your cookies, we will no longer know that you have opted out, and the banners from Criteo or RTB House will reappear when you visit other selected websites.

The business partners that set cookies on the RSANDERSON.COM website include:

Partner Name What its cookies are used for
Doubleclick, Google Analytics, Google AdWords, Facebook, Instagram Sometimes we'll advertise on third-party websites. Cookies are used to help us and our advertisers see which advertisements you click on and interact with. Each individual advertiser uses its own tracking cookies and the data taken is not confidential or interchangeable.

Cookies and social-media tools

If you ‘share’ RSANDERSON.COM content with friends through social networks – such as Facebook, Pinterest and Twitter – you may be sent cookies from these websites. RSANDERSON.COM doesn’t control the settings of these cookies and is not responsible for how these cookies work.

Flash cookies

RSANDERSON.COM may display video content using Adobe Flash Player, delivered by Vimeo. Adobe uses Flash cookies (also known as Local Shared Objects) to help improve your experience as a user. Flash cookies are stored on your device in much the same way as other cookies but they’re managed differently by your browser.

If you wish to disable or delete a Flash cookie, go to: https://www.adobe.com/uk/privacy/opt-out.html

Please note that RSANDERSON.COM is not responsible for the content of external websites. If you do disable Flash cookies, you will be unable to access certain content (such as videos) on the website.

Managing cookies

Most web browsers have cookies enabled; should you need to turn them on, see managing cookies below for help.

If you’d prefer to restrict, block or delete cookies from RSANDERSON.COM, or any other website, you can use your browser to do this. Each browser is different, so check the Help menu of your particular browser (or your mobile phone’s handset manual) to learn how to change your cookie preferences.

Managing your settings will differ depending on the type and version of web browser you use. The links below provide information about cookie settings for the most popular browsers:

  • Microsoft Edge
  • Internet Explorer
  • Firefox
  • Chrome
  • Safari
  • For all other browsers, please consult your documentation or online help files

Use

We use the personal information we collect to: provide and improve our services, provide you with a personalised experience on our sites, contact you about your account, provide you customer service, provide you with personalized advertising and marketing, and detect, prevent, mitigate and investigate fraudulent or illegal activities.

We process personal data for purchases, payments, customer support and fulfilment to enable us to perform our contract with you; where your contact details and transactional information are processed.

We process personal data relating to your interaction (transactions, site visits, app usage) with RSANDERSON.COM to enable us to personalise your experience with RSANDERSON.COM. This processing constitutes profiling under the GDPR and we process your personal data in this way as it is in our legitimate interest to offer you a personalised experience on our sites and to provide you with personalised advertising and marketing.

We retain your personal information as long as it is necessary and relevant for our operations. In addition, we may retain personal information from closed accounts to comply with legal requirements, prevent fraud and resolve disputes. Where a legal requirement obliges the retention of personal data for a specific minimum period, we will retain data for at least that period. When we determine the maximum retention duration of any personal data we hold we do so with regard to our legitimate interests to retain data, our obligation under GDPR to minimise data we hold with what we do hold as personal data being kept proportionate; the nature, and sensitivity of the personal data and the potential risk of harm from unauthorised use or disclosure of your personal data.

We use and retain your personal information to provide, improve and personalise our service to:

  • Offer you site content that includes items and services that you may like and to keep track of your basket
  • Customize, measure and improve our services
  • Hold views between web and mobile sites, deep linking and device linking
  • Provide other services requested by you as described when we collect the information

Where we have the right to do so, we shall use and retain your personal information to personalise communications, to contact you, either via email, telephone, social media, text messages or postal mail in order to inform you of account activity, delivery fulfilment and marketing related activity.

We use and retain your personal information to prevent, detect, mitigate and investigate fraudulent or illegal activities. This will involve the machine learning based statistical analysis which permits the identification of buying patterns which allow us to further personalise your experience.

We retain your personal information as long as it is necessary and relevant for our operations. In addition, we may retain personal information from closed accounts to comply with legal requirements, prevent fraud and resolve disputes. After it is no longer necessary for us to retain your personal information, we dispose of it securely according to our data retention and deletion policies.

Your rights

The General Data Protection Regulation provides for rights of access, modification and deletion of your personal information.

You can submit your rights servicing request here.

Managing preferences

You can control how we send personalized marketing, by channel and by frequency, from the Manage Preferences section of a registered account.

Accessing Manage Preferences allows you to control how we communicate with you. If you do not wish to receive marketing communications from us, you can unsubscribe from the link in the email you received, or by changing your Marketing Preferences.

Disclosure and security

We may disclose your personal information to legal entities within the RSANDERSON.COM group of undertakings, and to third authorised third parties. We do not disclose your personal information to third parties for marketing purposes.

We protect your information using measures that reduce the risks of loss, misuse, unauthorised access, disclosure and alteration. We minimise the amount of personal information we disclose to what is directly relevant and necessary to accomplish the specified purpose.

In so doing we may disclose your personal information to authorised third party service providers who help us to provide our services such as:

  • Payment providers to facilitate purchases
  • Fulfilment providers to facilitate order management, packaging and delivery
  • Marketing and advertising providers in order to personalise your experience

We do not disclose your personal information to third parties for marketing purposes.

Where legally compelling grounds exist, we may also disclose your personal information to governmental and law enforcement agencies, and otherwise in the defence of legal claims.

We protect your information using measures that reduce the risks of loss, misuse, unauthorised access, disclosure and alteration. 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.

If we were to be acquired by another company, we may share information with them and we will require that company to agree follow this Privacy Policy with respect to your personal information.

Questions

If you have a question about this Privacy Policy, please contact: customerservice@rsanderson.com.

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the data protection supervisory authority in the UK (www.ico.org.uk).

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.

Previous versions of this Privacy Policy can be found here.