20  August  2018   

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Silkies.co.uk, Silkiesservice.co.uk and Silkies (UK) Privacy Policy

This Privacy Policy applies to Silkies.co.uk, Silkiesservice.co.uk and the Silkies Made-To-Order Hosiery Service in the UK. When we say 'we', 'our' or 'us', we mean Silkies.co.uk, Silkiesservice.co.uk and the Silkies Made-To-Order Hosiery Service in the UK.

This User Privacy Policy was last updated on the 16th of July 2018. This Privacy Policy may vary from time to time so please check it regularly.

Silkies.co.uk, Silkiesservice.co.uk and the Silkies Made-To-Order Hosiery Service, owned by Sculptz, Inc., a private corporation with limited liability incorporated in Delaware, USA, with Delaware file number 2527763, registered address 1150 Northbrook Drive, Suite 300, Trevose, Pennsylvania 19053-8443, USA, EIN: 23-2819341 is the 'Data Processor' for the personal data we receive.

We regard our customers' privacy as one of our most important values, and we are committed to protecting your privacy whenever you use Silkies.co.uk, Silkiesservice.co.uk or the Silkies Made-To-Order Hosiery Service. We believe that our Privacy Policy will give you the utmost confidence that your data is handled fairly and legally at all times. We are dedicated to being transparent about what data we collect about you and how we use it.

This policy, which applies whether you use Silkies.co.uk, Silkiesservice.co.uk or receive mail deliveries of product through the Silkies Made-To-Order Hosiery Service, provides you with information about:

     - How we use your data
     - What personal data we collect
     - How we ensure your privacy is maintained
     - Your legal rights relating to your personal data

HOW WE USE YOUR DATA

General

We (and trusted partners acting on our behalf) use your personal data to provide goods and services to you; to make a tailored website available to you; to manage any registered account(s) that you have with us; to verify your identity, for crime and fraud prevention, detection and related purposes; with your agreement to contact you electronically, by phone or by mail to make available to you any promotional offers and products and services which we think may interest you; for market research purposes so that we may better understand your needs; to enable us to manage Customer Service interactions with you; and where we have a legal right or duty to disclose your information (for example, in relation to an investigation by a public authority or in a legal dispute).

Promotional Communications

We use your personal data for marketing purposes and may send you emails, postal mail or phone you to update you on the latest Silkies offers. We aim to update you about products and services which are of interest and relevance to you as an individual.

You have the right to opt out of receiving promotional communications at any time by emailing us at comments@Silkies.co.uk, writing to us at Customer Services, PO Box 495, Ashford, TN23 9QH or telephoning us at 01233 214316. Please be sure to include your Silkies account number in all correspondence.

Sharing Data with Third Parties

Our Service Providers and Suppliers

In order to make certain services available to you, we may need to share your personal data with some of our service partners. These include IT, product fulfillment, product delivery and marketing service providers.

We only allow service providers to handle your personal data when we have confirmed that they apply appropriate data protection and security controls.

Other Third Parties

We will not disclose your personal data to any third party except as noted below. We will never rent or sell your personal data to any other organization for marketing purposes.

We may share your data with:

Credit card payment processors as necessary for processing credit card payments

Governmental bodies, regulators, law enforcement agencies, courts/tribunals and insurers where we are required to do so:

   - To comply with our legal obligations
   - To exercise our legal rights (example, court cases)
   - For the prevention, detection, investigation of crime or prosecution of offenders
   - For the protection of our employees and customers

International Transfers

To deliver products and services to you it is necessary for us to process and share your data outside of the European Economic Area (EEA) as we, and some of our service providers, are located outside of the EEA. We will ensure that the transfer of data will be compliant with data protection laws and all personal data will be secure.

How long do we keep your data?

We will not retain your data for longer than necessary for the purposes set out in this Privacy Policy. The length of time for which we retain information depends on the purposes for which we collected it and use it or the requirements of applicable law.

WHAT PERSONAL DATA WE COLLECT

We may collect the following information about you: :

Your name, age/date of birth and gender
Your contact details including postal address, billing address, telephone numbers (including mobile numbers) and email addresses
Transactional data
Your on-line transaction activity at Silkies websites
Your payment card details when you pay for your Hosiery Delivery
Your communication and marketing preferences
Your correspondence and communication with us
Other publicly available personal data which you may have shared via a public platform (such as Twitter feed or Facebook feed)

Our website and our hosiery program are not intended for children and we do not knowingly collect data relating to children.

This list is not exhaustive and, in specific circumstances, we may need to collect additional data for the purposes set forth in this Policy. Some of the above personal data is collected directly from you when you sign up for our Made-To-Order Hosiery Service, when you use Silkies.co.uk, Silkiesservice.co.uk, or contact our Customer Services team. We may also collect data from third parties who have your consent to do so.

HOW WE INSURE YOUR PERSONAL DATA IS PROTECTED

We are committed to keeping your data safe and secure. Sculptz stores and processes your data in a highly secure 'Class A/Tier IV' data center employing the highest levels of physical and logical security controls in the data center, network services and systems. Data center certification and compliances include Type 2 SOC 1 (SSAE 16/SAS70) compliance, PCI-DSS compliance and EU Safe Harbor Security Certification. Data in transit between our data center and Customer Service center travels through a highly secure IKEv2 VPN tunnel. All other periodic file transfers to our Customer Service center and fulfillment center occur using encrypted SFTP.

YOUR LEGAL RIGHTS RELATING TO YOUR PERSONAL DATA

The Right of Access: You have the right to ask for a copy of personal data that we hold about you.

The Right to be Forgotten: You have the right, in certain circumstances, to request that we delete any personal data we hold on you, where we no longer have any legal reason to retain it.

The Right to Object: You have the right to request that we update or correct any out-of-date or incorrect personal data that we have about you.

The Right to Restrict Processing: You have the right, in certain circumstances, to request that we 'restrict processing of data' - which means that we have the right to secure and retain data for your benefit but not otherwise use it.

The Right to Data Portability: You have the right to ask us to supply you with the data we hold on you or to ask us to provide a copy of the data to another organization.

If you wish to exercise any of the above rights, please contact us:

By email: DPO@silkies.co.uk
By mail: Data Protection Officer, PO Box 495, Ashford, TN23 9QH
By Telephone: 01233 214316

Please be sure to include your account number on all correspondence.

LEGAL BASIS FOR SCULPTZ, INC. PROCESSING CUSTOMER PERSONAL DATA

General

We collect, use and store ('process') your information to provide the services related to your account, to fix and improve the services, to develop new services, and to market our products and services. Some specific examples of how we use information are:

 - Collect payment
 - Communicate with you - using mail, email or telephone - about your account or activity or to market products and services
 - Test changes in the services and develop new features
 - Analyze use of the services and personalize content, including ads and prices
 - Fix problems you may have with the services or a particular delivery or purchase, including answering support questions and resolving disputes
 - Prevent, detect, investigate and respond to fraud, unauthorized access/use of the services, breach of terms and policies or other wrongful behavior

Legal Basis

The legal basis for processing customer data, is that it is necessary for the legitimate interests of Sculptz, Inc., including:

 - Selling and supplying goods and services to our customers
 - Promoting, marketing and advertising our products and services
 - Sending promotional communications which are relevant and tailored to individual customers
 - Understanding our customers' behavior, activities, preferences and needs
 - Improving existing products and services and developing new products and services
 - Complying with our legal and regulatory obligations
 - Preventing, investigating and detecting crime, fraud, anti-social behavior and prosecuting offendings, including working with law enforcement agencies
 - Handling customer contacts, queries, complaints and disputes
 - Protecting Sculptz, Inc., its employees and customers, by taking appropriate legal action against third parties who have committed criminal acts or are in breach of legal obligations to Sculptz, Inc.
 - Effectively handling any legal claims or regulatory enforcement actions taken against Sculptz, Inc.
 - Fulfilling our duties to our customers, colleagues and stakeholders

Cookies Policy

What are cookies?

Cookies are small data files which are placed on your computer or other devices (such as smart phones or tablets), as you browse a website. Cookies are essential for the effective operation of our website and to help you manage your Silkies Made-To-Order Hosiery Account online.

Information collected

No information is collected and stored on cookies. We do create temporary cookies to store uniquely generated session codes to maintain the continuity of your web session with us. These cookies are deleted at the end of your web session and we do not retain these codes.

Ads for Products and Services

We may use services like Facebook, Twitter, Pinterest and Instagram to serve tailored ads to you about Sculptz, Inc. products and services.

DATA PROTECTION OFFICER

Silkies has appointed a Data Protection Officer to ensure we protect the personal data of our customers and to comply with GDPR.

If you have any questions about how Silkies uses your personal data or if you want to exercise your rights regarding your personal data, please contact our Data Protection Officer:

 - By email: DPO@silkies.co.uk
 - By mail: Data Protection Officer, PO Box 495, Ashford, TN23 9QH
 - By phone: 01233 214316


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