This privacy policy sets out how Finale uses and protects any information that you give us when you use this website.

 

Finale is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using this website, then you can be assured that it will only be used in accordance with this privacy statement.

In line with GDPR, this policy is effective from 19/05/2018, and we will update you with any changes to future updates to our Privacy Notice.

 

We understand the importance of GDPR and our role as a custodian of the data you have provided to us either as an interested person or as a customer of ours (thank you for that).

 

Here is a simple summary of the content of this policy.

 

  • We act as a data controller for data we collect.
  • We don’t do everything ourselves, we use other sub-processors such as Shopify, Paypal, Google Analytics, and Mailchimp as part of our data processing.
  • As part of the move to GDPR compliance we have used legitimate interests as a legal method of consent to continue to process the data of our customers, and people that have previously signed up, or have provided their details as part of ongoing business discussions.
  • As has always been the case, when it comes to removing yourself from Finale communications, you can unsubscribe at anytime.
  • We do collect cookies, but we don’t really do anything with them. It’s really just aggregated reporting within Google Analytics.  If that changes, so will this bullet point.
  • If you wish us to remove your data, or wish to request a subject access request, please let us know by contacting us at info@finaleshoes.com

 

 

The Legal Bit

Introduction

This notice sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your sensitive information and how we will deal with it. For the purposes of the Data Protection Act (‘the DPA’) and the EU General Data Protection Regulation (‘the GDPR’), sensitive information includes what is defined as your ‘personal data’.

 

By visiting www.finaleshoes.com (our ‘Website’) you accept and consent to the practices described in this Privacy Notice including the processing of your personal data under this lawful basis.

 

In this Privacy Notice, we seek to abide by the letter and spirit of the guidelines laid out by the UK Information Commissioner’s Office in the document ‘Privacy Notices, Transparency and Control’.

 

Who We Are

More formally, we are LC Fashions Ltd trading as Finale. We are a company registered in England and Wales (company number 5397917) our registered office is at 8 Middle Street, Corbridge, Northumberland, NE45 5AT

 

We are registered with the Information Commissioners Office under registration number [ICO] ZA413524.

 

For the purposes of the DPA and in-line with the GDPR, LC Fashions Ltd is the Data Controller. 

 

If you have any concerns about the way we use your information or any questions about this Privacy Notice, please let us know.  We can be contacted via email at info@finaleshoes.com, or you can write to us at the address above.

 

What we do with your information

We will use your information to:

  • Send our newsletter to you and to send you information about our products and offers;
  • Send you updates about new products or services we introduce;
  • Collect feedback about our services; and
  • Send you information about the services we provide by other agreed means.

 

We compile statistics about user trends on our Website, which are used by third party organisations to understand how users interact with businesses, brands and one another online and to advise about these things. These statistics are drawn from a dataset which does not contain any information from which you can be identified.

  • If you are an existing customer of Finale prior to the date of this notice than any communication will be delivered on the legal basis of Legitimate Interests.
  • If you have provided us with your contact details as part of initial or ongoing business discussions, we will continue to process your information on the legal basis of legitimate interests.
  • If you purchase from us we will process your order on the legal basis of legitimate interests
  • If you have previously signed up to receive marketing information from us by signing up to the website, we will continue to process your information on the legal basis of legitimate interests.

 

Wherever, we used the legal basis of legitimate interests, we have carried out a Legitimate Interests Assessment to document this legal basis.

 

 

Information we collect from you

We will collect and process the following information about you:

  • Information you give us – this is information about you that you give us by filling in forms on our Website or by corresponding with us by phone, email or otherwise. We only request from you the minimum data required for you to use our service.
  • The information we require from you to sign up to our mailing list will include your first name and an email address.
  • If you create an account to order from us, then we will ask you for your full name, email address, and delivery and billing address. We do not hold your financial details on file.  These are held by the financial sub processors we use and you can select which one you prefer to use when making your payment for our products.
  • Information we collect about you – Whenever you visit our Website we will automatically collect the following 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 – this includes the full Uniform Resource Locators (URL), clickstream to, through and from our Website (including date and time), pages you have visited, page response times, download errors, length of visits to certain page and page interaction information (such as scrolling, clicks, and mouse-overs).
  • Information we receive from other sources – This is information we receive about you if you use any of the other websites we operate or the other services we provide.

 

In this case we will have informed you when we collected that data if we intend to share those data internally and combine it with data collected on this Website. We will also have told you for what purpose we will share and combine your data.

 

We are working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies).

 

We will notify you when we receive information about you from them and the purposes for which we intend to use that information.

 

Where we hold and what we do with your information

The information and content held on our Website is deployed geographically to maximise user experience. All information that could identify individuals within the European Union is stored exclusively within the European Union.  We will never share your user information with third parties for promotional purposes.

 

We hold our data with Shopify who are contracted by us for the provision of technical services and for the processing of payment processing. We remain responsible at all times for the security of your information, but if you want to know more about how we interact with Shopfiy you can view their Privacy Notice, amongst their other policies here

 

We use Mailchimp to deliver our email messages as part of our service.  You can view more information about Mailchimp and their policies here.

 

We may also disclose your information to third parties to whom we may choose to sell, 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.

 

What we do to ensure the security of your personal information

 

General practice

We take the security of your personal data very seriously. Our approach to information security is constantly evolving and continually reviewed.

 

We have adopted industry best practices from both technological and business process perspectives in order to make the security of your data a key part of the way we do business.

 

We have policies and practices in place that not only ensure our compliance under the DPA but also the GDPR, including training and adequate procedures put in place for any staff that handle or have access to sensitive information.

 

 

Data security

To protect your personal information, we take reasonable precautions and follow industry best practices to make sure it is not inappropriately lost, misused, accessed, disclosed, altered or destroyed. 

If you provide us with your credit card information, the information is encrypted using secure socket layer technology (SSL) and stored with a AES-256 encryption. Although no method of transmission over the Internet or electronic storage is 100% secure, we follow all PCI-DSS requirements and implement additional generally accepted industry standards.

 

 

Payment security

If you choose a direct payment gateway to complete your purchase, then Shopify stores your credit card data. It is encrypted through the Payment Card Industry Data Security Standard (PCI-DSS). Your purchase transaction data is stored only as long as is necessary to complete your purchase transaction and issue a refund should this be required. After that is complete, your purchase transaction information is deleted. 

All direct payment gateways adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of credit card information by our store and its service providers. 

For more insight, you may also want to read Shopify’s Terms of Service (https://www.shopify.com/legal/terms) or Privacy Statement (https://www.shopify.com/legal/privacy).

 

 

 

Your rights regarding your personal information

 

We may contact you via email with updates about the services that we offer or any changes that we have made to our Website.

 

You can opt in or out at any time by clicking the ‘Unsubscribe’ link in our emails.

 

Our Website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates (including, but not limited to, websites on which our service may be advertised). If you follow a link to any of these websites, please note that these websites and any services that may be accessible through them have their own privacy policies and that we are not responsible or liable for these policies or for any personal data that may be collected through these websites or services, such as contact and location data. Please check these policies before you submit any personal data to these websites or use these services.

 

Your Rights

You have the right to find out about what information we hold about you. You can exercise that right by contacting us and we will send you any request for information in a suitable electronic form within 20 working days.

 

To make a request for information please contact info@finaleshoes.com and a member of our team will be in touch.

 

If your personal data is incorrect then you have the right to rectify this information and ensure that it is accurate and up to date.  If your data is incorrect then please contact us at the email address above and a member of the team will rectify this on your behalf.

You have the right ‘to be forgotten’ and to have your personal identifiable information permanently deleted from our systems.  Again, if you would like to exercise this right then please contact us at info@finaleshoes.com.

 

There will be no charge made for reasonable electronic access to your information, your right to rectification or for your right to be forgotten from our systems.

 

How long we hold your information for

At Finale we have procedures in place to regularly review every 18 months what personal data we hold.  If you have not interacted with us or accessed our services during this or the subsequent period then we will delete your personal data from our systems, but will send you an email first informing you of our intention to do so.

 

Of course, you have the right to forgotten at any point and can find out more about this in the ‘Access to Information’ section above.

 

Changes to this Privacy Notice

Any changes we may make to our Privacy Notice in the future will be posted on this page. Should you register for an account with Finale then any changes will be notified to you when you next log in to make use of our services.

 

The new terms may be displayed on-screen and you will be required to read and accept them to continue your use of our services.

 

Our Cookie Policy

If you’d like to manage your use of cookies or completely turn off cookies then you can find out how to do so by using the link here.  Please note that if you do limit or block cookie use on our Website the functionality of both the Website and our services will be affected.

 

Our Website uses cookies to distinguish you from other users of our Website. This helps us to provide you with a good experience when you browse our Website and also allows us to improve our site.  By continuing to browse the Website, you agree and consent to our use of cookies.

 

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.

 

As part of our overall approach to privacy and transparency, this section describes what cookies are in the context of our web and mobile interfaces, and what their use means to you. At the end, we’ve included some links to help you research cookies and their impact, and how you can use your web browser to control the way it manages cookies.

 

We use the following types of cookies:

  • Strictly necessary cookies –these are cookies that are required for the operation of our Website. They include, for example, cookies that enable you to log into secure areas of our Website, use a shopping cart or make use of e-payment system.
  • Analytical/performance cookies – these allow us to recognise and count the number of visitors and to see how visitors move around our Website when they are using it. This helps us to improve the way our Website works, for example, by ensuring that users are finding what they are looking for easily.
  • Functionality cookies –these are used to recognise you when you return to our Website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
  • Targeting cookies –these cookies record your visit to our Website, the pages you have visited and the links you have followed. We will use this information to make our Website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose but these cookies will contain no information capable of identifying you personally to us.

 

You can find more information about the individual cookies we use and the purposes for which we use below:

 

 

Shopify

Here is a list of cookies that we use. We’ve listed them here so you that you can choose if you want to opt-out of cookies or not. 

  • _session_id, unique token, sessional, Allows Shopify to store information about your session (referrer, landing page, etc). 
  • _shopify_visit, no data held, Persistent for 30 minutes from the last visit, Used by our website provider’s internal stats tracker to record the number of visits 
  • _shopify_uniq, no data held, expires midnight (relative to the visitor) of the next day, Counts the number of visits to a store by a single customer. 
    cart, unique token, persistent for 2 weeks, Stores information about the contents of your cart. 
  • _secure_session_id, unique token, sessional storefront_digest, unique token, indefinite If the shop has a password, this is used to determine if the current visitor has access. 
  • PREF, persistent for a very short period, Set by Google and tracks who visits the store and from where

 

 

Google Analytics

We use Google Analytics to understand general trends about our content and traffic sources; for example, where users come from, which pages are most popular, which sites provide most traffic, how our marketing efforts impact the amount of visits we receive.

Google’s statement about privacy can be found here.

 

Twitter button

The Twitter button allows our users to share details of Finale with their followers more easily. Twitter’s privacy policy states they use cookies “to collect additional Website usage data and to improve our Services” – You can read the policy in full here.

 

Facebook Button

We use Facebook button to allow you to share details of Finale with your friends and other

 

Facebook users.

Facebook’s statement about privacy relating their Connect feature is here and also here.

 

More information about cookies

 

Still don’t know what cookies are?  Then why not follow the link conveniently located here which provides more information about what they are and how they work.

Contact the Information Commissioner if there is a problem

 

If you consider we have not addressed your problem, you can contact the UK Information Commissioner’s Office for assistance. Further information can be found here.