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Privacy Policy

Tots & Frocks Limited are committed to protecting your privacy when you are using any of our websites (https://www.poshtotsonline.co.uk, https://www.pikinini.co.uk, https://www.primacommunion.co.uk) (the "Site", “Sites”), interacting with us via social media platforms or purchasing Products from our Sites (" Products").It is important that you read an understand this policy, in conjunction with our Terms & Conditions. If you have any questions relating to this, please Contact Us.

This Privacy Policy explains the following:

• What information we may collect about you;

• How we use the information we collect about you;

• Whether we will share your details with anyone else;

• How you can instruct us if you prefer to limit the use of that information;

• The procedures that we have in place to safeguard your privacy; and

• The use of cookies on the Site and how you can reject those cookies.

Information About Us

Tots & Frocks Limited (" we", " our", " us") is the data controller which means we are responsible for protecting your personal information. We're a company registered in England and Wales with company number 06979856. Our registered office is 80a The Brent Dartford, Kent, England. Our registered VAT number is GB984271196. We will only use information about you in accordance with this Privacy Policy (as amended from time to time) or as otherwise permitted by law. By using our Site or interacting with us via social media platforms, or by submitting information to us, you signify your consent to the collection, use and sharing of your personal information in accordance with this Privacy Policy. If you have any requests or questions about how we use your personal information please Contact Us. If you do not agree with this Privacy Policy, you must not use this Site or interact with us via social media platforms, or submit any information to us.

What Information Do We Collect?

Our philosophy is to try to collect the minimum data necessary to operate our websites.

When setting up an account on the Site, you will be asked to provide us with your name, billing address and delivery address details, your email address, telephone number, a username and a password.

When making a purchase, we will collect transaction data which comprises of the products purchased from us and their value. Whilst we do not collect any payment details directly when a purchase is made, you acknowledge that these will be collected by our secure 3rd party payment processor SagePay.

We may collect information about you such as your name, address and contact details where you enter a competition, prize-draw or promotion that we are operating. We may also obtain information about your usage of our Site to help us develop and improve it further.

Technical data such as 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 may be collected when making a purchase. If you are not logged in, this data will be anonymous by default.

Aggregated Data such as statistical or demographic data for any purpose may be collected. Aggregated Data can be based upon your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

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.

Protecting Your Information - Data Security

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online. Access to your personal data is limited 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.

If you would like to know what information we hold about you, please Contact Us.

How Long Do We Keep Your Data - Data Retention

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 you can ask us to delete your data: please Contact Us for further information.

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.

Who Might We Disclose Your Information To?

• We may disclose your information to members of our group, our employees, our subsidiaries, affiliated companies and any successors in title to our business, for the purposes listed above. We will not disclose your information to any third party outside of the group except under the following limited circumstances:

• We may disclose your personal information to carefully selected service providers and agents who operate elements of our Site and process data on our behalf. These may include businesses who provide technology services such as hosting for our servers and email distribution and business partners who provide delivery fulfilment services. Where such disclosures are made, this will be under contractual arrangements with us and carried out in accordance with the requirements of the law.

• We may also use aggregate information and statistics for the purposes of monitoring Site usage in order to help us develop the Site and our services and may provide such aggregate information to third parties. These statistics will not include information that can be used to identify any individual.

• We may also share your information with auditors or contractors or other advisers auditing, assisting with or advising on any of our business purposes.

We do not sell on personal data, at all. We do not hold your credit card details, although we do have the ability to recharge or refund cards as required in fulfilment of your contract. Financial transactions take place directly and securely with our payment handling provider. If you believe your details are incorrect you can amend your details by logging onto your account on the 'Sign In' section on our Site or you can Contact Us.

Changes to Our Privacy Policy

Any changes we may make to our Privacy Policy in the future will be posted on this page and, where appropriate, notified to you by email.

How Do We Use Your Information?

We use your information for the following purposes:

• To serve website content to you.

• To handle orders, deliver Products, process payments and refunds and provide statements.

• To communicate with you about your orders.

• To update our records and generally maintain your account with us.

• If you contact us, we may keep a record of that correspondence and your contact details.

• For our statistical or survey purposes to improve our Site and blog and our services to you.

• To prevent or detect fraud or abuses of our Sites and enable third parties to carry out technical, logistical or other functions on our behalf.

• To contact you by email, post, or telephone, to ask you for feedback and comments on our services.

• Interact with you on social media platforms (see below).

• To notify you by email of our Products, promotions, competitions and special offers that may be of interest to you, unless you ask us not to.

• To comply with regulatory law, for example, retention of data for Tax purposes.

If you stop using our Site, we may continue to use and disclose your personal information in accordance with this Privacy Policy and as permitted by law. If you wish us to remove you from our email mailing list or registration database, and stop contacting you with information in connection with the Sites, or our Products and services, please send us an email using the contact details in the Contact Us section of our Sites, including your full name and the email address used when accessing or ordering from our Site.

The Legal Basis to Collect Your Data

• Performance of Contract - Processing and fulfilling orders

• Legitimate interests - To keep our records up to date and accurate, to prevent fraud, to administer our websites and security, to develop and operate our business, to inform our marketing strategy.

• Legal obligations

• Consent - For marketing purposes

How do we Collect Your Data

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

•  Direct interactions. You may give us your identity, contact details and other data by filling in forms or by corresponding with us by email, phone or otherwise. This includes personal data you provide when you:

  • buy our products or services;
  • create an account on our website;subscribe to our services;
  • request marketing to be sent to you;
  • enter a competition, promotion or survey; or
  • give us some feedback.

• Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.

• Contact, Financial and Transaction Data from providers of technical, payment and delivery services.

Social Media Platforms

Information we have access to through social media platforms will depend on your personal settings. We will have access to all public information on these platforms. We may also be able to access information that others share about you (as they control how that is shared). We may collect any data that is accessible to us or that you provide through social media platforms, including for example your Facebook and/or Twitter profile picture, gender, and usernames. We will interact with you through social media platforms in accordance with each site's rules but we are not responsible for how the site owners collect and handle your data. We are not responsible for what third parties post on our social media accounts. If you 'Like' our Facebook Page or post on our Facebook Wall, we can interact with you and send you things via these platforms. If at any time you want us to stop interacting with you in this way, please Contact Us.

Cookies

A cookie may be used in the processing of your personal data. A cookie is a text file stored on your computer by our Site. A copy of this text file is sent by your computer to our Site whenever you visit our Site. We use cookies to identify you, to personalise your experience and to store items in your shopping bag. We may also collect the following information during your visit to our Sites:

• The fully qualified domain name from which you accessed our Sites, or alternatively, your IP address;

• The date and time you accessed each page on our Sites;

• The URL of any webpage from which you accessed our Sites (the referrer); and

• The web browser that you are using and the pages you accessed.

We use this information to improve our Sites and so that we can tell which pages are the most popular and where shoppers spend most of their time. Most browsers allow you to turn off cookies. If you want to know how to do this please look at the help menu on your browser. However, if you do not accept cookies your user experience on our Sites may be affected and you may be unable to purchase Products from our Site.

Links to Other Sites

We may from time to time make available through our Sites links to other sites and certain services provided by third parties. To gain access to the third party services, you must register with these third parties and deal with them direct. Please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites. We have no responsibility for these websites and provide these links solely for the convenience and information of our visitors.

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.

Contact

If you have any questions, comments or requests regarding this Privacy Policy, please Contact us and we will be happy to answer them. Tots & Frocks Limited Privacy Policy v2.0 updated May 2018