COOKIE POLICY

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1. Definitions and Interpretation

 

Earls & Pearls (and its affiliate company, Club 1942) is committed to protecting and respecting the privacy of third parties (including its clients and all visitors to the website www.earlsandpearls.com (the “website”).

 

We endeavour to ensure that all information from which you can be identified (“personal information”) provided to, or otherwise obtained by us, is handled in accordance with the UK Data Protection Act 1998, from 25 May 2018 the EU General Data Protection Regulation and the Data Protection Act 2018 (which replace the Data Protection Act 1998) and all similar or related legislation (the “Data Protection Legislation”).

 

You can be assured that your personal information will only be used by Earls & Pearls in accordance with this privacy policy (this “policy”).

 

In this policy, “Earls & Pearls”, “we”, “us” and “our” refer to Earls & Pearls.

 

“Cookie” means a small text file placed on your computer or device by our site when you visit certain parts of our site or when you use certain features on our site. Details of the cookies used by our site are set out in the section 11.

 

“UK and EU Cookie Law” means the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended by the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011.

 

This policy (together with our terms of use and any other documents referred to on it) sets out the basis on which any personal information we collect, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting and/or contacting us through the website you are accepting and consenting to the practiced described in this policy.

 

2. Information About Us

 

Our Site is owned and operated by Earls & Pearls.

 

Our Data Protection Number is ZA258728

 

Our Data Protection Officer is EmmaJane Henningham who can be contacted by email at ejh@earlsandpearls.com, by telephone on 0207 504 1329, or by post at 78 York Street, London, W1H 1DP.

 

3. Links to Other Websites

 

Our website may contain links to other websites. However, once you have used these link to leave our website, we do not then have any control over that site. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy policy. You should exercise caution and look at the privacy policy relevant to the website in question.

 

4. Your Rights

 

As a data subject, you have the following rights under the GDPR, which this policy and our use of personal data have been designed to uphold:

 

  • The right to be informed about our collection and use of personal data;

  • The right of access to the personal data we hold about you (see section 10);

  • The right to rectification if any personal data we hold about you is inaccurate or incomplete;

  • The right to be forgotten – i.e. the right to ask us to delete any personal data we hold about you;

  • The right to restrict (i.e. prevent) the processing of your personal data;

  • The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);

  • The right to object to us using your personal data for particular  purposes; and

  • Rights with respect to decision making and profiling.

 

If you have any cause for complaint about our use of your personal data, please contact us and we will do our best to solve the problem for you. If we are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.

 

For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.

 

5. What Data Do We Collect?

 

We collect, store and process personal data given by its clients, past clients and potential clients (all collectively known as clients). Your data is continually updated based on any information provided to us whether written or verbal. We use this data pursuant to our contract with you or for taking steps to enter into a contract with you. We may collect some or all of the following data (please also see section 13 on our use of Cookies and similar technologies):

 

  • Name, office/home address, phone, email, mobile;

  • Gender, date of birth, job title/profession, height, interests, etc;

  • Client photo;

  • Client ID;

  • Information relevant to our service delivery such as lifestyle, values, career and other personal information disclosed to us;

  • IP Address, web browser type and version, operating system, a list of URLs starting with a referring site, your activity on this Website, and the site you exit to (automatically collected);

  • Other relevant data

 

 

6. How Do We Use Your Data?

 

All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with our obligations and safeguard your rights under the GDPR at all times. For more details on security please see section 7.

 

Our use of your personal data will always have a lawful basis, either because it is necessary for our performance of a contract with you, because you have consented to our use of your personal data (e.g. by subscribing to emails), or because it is in our legitimate interests. Specifically, we may use your data for the following purposes:

 

  • internal record keeping;

  • improvement of our products / services;

  • transmission by post, phone or email of promotional materials we think may be of interest to you;

  • to verify your identity;

  • to enable us to provide our services to you and/or to process your orders for tickets, reservations, specific goods and/or services;

  • for security purposes;

  • contact for market research purposes which may be done using email, telephone, fax or mail. Such information may be used to customise or update the website.

 

You have the right to object to the processing of your data and/or withdraw your consent to us using your personal data at any time, and to request that we delete it. To do so email ejh@earlsandpearls.com or follow the procedure to ‘unsubscribe’ that is specified in any marketing email that you receive.

 

We will only keep your personal information for as long as reasonably require and, in any event, only for as long as the Data Protection Legislation allows.

 

7. How and Where Do We Store Your Data?

 

Some or all of your data may be stored outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). You are deemed to accept and agree to this by using our site and submitting information to us. If we do store data outside the EEA, we will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the GDPR.

 

We are committed to ensuring that your data is secure.  In order to prevent unauthorised access or disclosure, we put in place certain and suitable physical, electronic and managerial procedures to safeguard and secure the information we collect, to include secure password protection.

 

8. Do We Share Your Data?

 

We won’t sell or share your personal information with any third parties unless we have specific consent to do so. At the point of obtaining your consent, we will disclose to you the third parties your personal information will be shared with.

 

We may process your data with our affiliate brand/sister company, Club 1942, by sending you promotional information which we think you may find of interest.

 

We may compile statistics about the use of our site including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.

 

We may sometimes use third party data processors that are located outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). Where we transfer any personal data outside the EEA, we will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the GDPR.

 

In certain circumstances, we may be legally required to share certain data held by us, which may include your personal data, for example, where we are involved in legal proceedings, where we are complying with legal requirements, a court order, or a governmental authority.

 

9. What Happens If Our Business Changes Hands?

 

If Earls & Pearls enters into a joint venture with, purchases or is sold to or merges with another business entity, or in the event that we sell or buy any business or assets, or substantially all of our assets are acquired by a third party, your personal information may be disclosed or transferred to the purchaser, our new business partners or owners or their advisors.

 

10. How Can You Access Your Data?

 

You have the right to ask for a copy of any of your personal data held by us (where such data is held). Under the GDPR, no fee is payable and we will provide any and all information in response to your request free of charge and within 1 calendar month.

 

11. Our Use of Cookies

 

Our website may place and access certain first party cookies on your computer or device. First party cookies are those placed directly by us and are used only by us. We use cookies to facilitate and improve your experience of our website and to provide and improve our services. We have carefully chosen these cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.

All cookies used by and on our website are used in accordance with current Cookie Law.

 

Before cookies are placed on your computer or device, you will be shown a requesting your consent to set those cookies. By giving your consent to the placing of cookies you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of cookies; however certain features of our site may not function fully or as intended.

 

Certain features of our site depend on cookies to function. Cookie Law deems these cookies to be “strictly necessary”. These cookies are shown below.

 

Your consent will not be sought to place these cookies, but it is still important that you are aware of them. You may still block these cookies by changing your internet browser’s settings as detailed below, but please be aware that our site may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.

 

Our site uses analytics services provided by Google Analytics. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling us to better understand how our site is used. This, in turn, enables us to improve our site and the services offered through it. You do not have to allow us to use these cookies, however whilst our use of them does not pose any risk to your privacy or your safe use of our site, it does enable us to continually improve our site, making it a better and more useful experience for you.

 

The analytics service(s) used by our site use(s) cookies to gather the required information.

 

In addition to the controls that we provide, you can choose to enable or disable cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party cookies. By default, most internet browsers accept cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.

 

You can choose to delete cookies on your computer or device at any time.

 

It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.

 

12. Contacting Us

 

If you have any questions about our site or this Privacy Policy, please contact us by email at ejh@earlsandpearls.com, by telephone on 0207 504 1329 or by post at 78 York Street, London, W1H 1DP. Please ensure that your query is clear, particularly if it is a request for information about the data we hold about you.

 

13. Changes to Our Privacy Policy

 

We may change this Privacy Policy from time to time (for example, if the law changes). Any changes will be immediately posted on our site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of our site following the alterations. We recommend that you check back regularly to keep up-to-date.

PRIVACY PROMISE

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©  2019 EARLS & PEARLS. ALL RIGHTS RESERVED.