Privacy policy
We take your privacy very seriously.
Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint.
Introduction:
We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation (UK GDPR).
Key terms
It would be helpful to start by explaining some key terms used in this policy:
We, us, our CIRCE-MEHRA Limited, trading as
VICKISARGE, Nanna Milan, Circe-Mehra and Venomous
Our data protection officer Our DPO can be reached by emailing
Admin@vickisarge.com.
Personal data Any information relating to an identified or
identifiable individual
Special category personal data Personal data revealing racial or ethnic origin,
political opinions, religious beliefs, philosophical
beliefs or trade union membership
Genetic data
Biometric data (where used for identification
purposes)
Data concerning health, sex life or sexual
orientation
Data subject The individual who the personal data relates to Personal data we collect about you. The personal data we collect about you depends on the particular products we provide to you. We will collect and use the following personal data about you:
• your name and contact information, including email address and telephone number.
• measurements as required for custom fittings.
• location data, if you choose to give this to us.
• your billing information, transaction and payment card information.
• your purchase history through our platforms and saved items.
• information about how you use our website, IT, communication and other systems.
• .your responses to surveys, competitions and promotions.
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We collect and use this personal data for the purposes described in the section ‘How and why we
use your personal data’ below. If you do not provide personal data we ask for, it may delay or prevent us from providing products and services to you.
The data that we collect is a requirement necessary to enter into a contract. Any information that is not necessary for this purpose can be withheld if so chosen.
How your personal data is collected.
We collect most of this personal data directly from you—in person, by telephone, text or email, and via our website. However, we may also collect information:
• from cookies on our website provided by Shopify Inc.
• via our IT systems, eg:
– through automated CCTV monitoring
– through our till point provided by SumUp.
How and why we use your personal data
Under data protection law, we can only use your personal data if we have a proper reason, e.g.:
• where you have given consent;
• to comply with our legal and regulatory obligations;
• for the performance of a contract with you or to take steps at your request before entering into
a contract; or
• for our legitimate interests or those of a third party.
A legitimate interest is when we have a business or commercial reason to use your personal data, so
long as this is not overridden by your own rights and interests. We will carry out an assessment when
relying on legitimate interests.
The table below explains what we use your personal data for and why.
What we use your personal data for Our reasons
Providing products and services to you To perform our contract with you or to take
steps at your request before entering into a
contract.
Preventing and detecting fraud against you or
us
For our legitimate interest, i.e. to minimise fraud
that could be damaging for you and/or us
To enforce legal rights or defend or undertake
legal proceedings
Depending on the circumstances:
—to comply with our legal and regulatory
obligations;
—in other cases, for our legitimate interests, i.e.
to protect our business, interests and rights
Gathering and providing information required by
or relating to audits, enquiries or investigations
by regulatory bodies.
To comply with our legal and regulatory
obligations.
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Ensuring business policies are adhered to, e.g.
policies covering security and internet use
For our legitimate interests, i.e. to make sure we
are following our own internal procedures
Operational reasons, such as improving
efficiency, training and quality control
For our legitimate interests, i.e. to be as efficient
as we can so we can deliver the best service to
you at the best price
Ensuring the confidentiality of commercially
sensitive information
Depending on the circumstances:
—for our legitimate interests, i.e. to protect trade
secrets and other commercially valuable
information;
—to comply with our legal and regulatory
obligations
Statistical analysis to help us manage our
business, e.g. in relation to our financial
performance, customer base, and product
range.
For our legitimate interests, i.e. to be as efficient
as we can so we can deliver the best service to
you at the best price
Preventing unauthorised access and
modifications to systems
Depending on the circumstances:
—for our legitimate interests, i.e. to prevent and
detect criminal activity that could be damaging
for you and/or us;
—to comply with our legal and regulatory
obligations
Protecting the security of systems and data
used to provide the goods and services
To comply with our legal and regulatory
obligations.
We may also use your personal data to ensure
the security of systems and data to a standard
that goes beyond our legal obligations, and in
those cases our reasons are for our legitimate
interests, i.e. to protect systems and data and to
prevent and detect criminal activity that could be
damaging for you and/or us
Updating and enhancing customer records Depending on the circumstances:
—to perform our contract with you or to take
steps at your request before entering into a
contract;
—to comply with our legal and regulatory
obligations;
—for our legitimate interests, e.g. making sure
that we can keep in touch with our customers
about existing orders and new products
Statutory returns To comply with our legal and regulatory
obligations.
Ensuring safe working practices, staff
administration and assessments
Depending on the circumstances:
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—to comply with our legal and regulatory
obligations;
—for our legitimate interests, e.g. to make sure
we are following our own internal procedures
and working efficiently so we can deliver the
best service to you
Marketing our services to:
—existing and former customers;
—third parties who have previously expressed
an interest in our services;
—third parties with whom we have had no
previous dealings.
For our legitimate interests, i.e. to promote our
business to existing and former customers
To share your personal data with members of
our group and third parties that will or may take
control or ownership of some or all of our
business (and professional advisors acting on
our or their behalf) in connection with a
significant corporate transaction or restructuring,
including a merger, acquisition, asset sale, initial
public offering or in the event of our insolvency
In such cases information will be anonymised
where possible and only shared where
necessary
Depending on the circumstances:
—to comply with our legal and regulatory
obligations;
—in other cases, for our legitimate interests, i.e.
to protect, realise or grow the value in our
business and assets
How and why we use your personal data—sharing
See ‘Who we share your personal data with’ for further information on the steps we will take to
protect your personal data where we need to share it with others.
Marketing
We will use your personal data to send you updates (by email, text message, telephone or post)
about our products and services, including exclusive offers, promotions or new products and services.
We have a legitimate interest in using your personal data for marketing purposes (see above ‘How
and why we use your personal data’). This means we do not usually need your consent to send you
marketing information. If we change our marketing approach in the future so that consent is needed,
we will ask for this separately and clearly.
You do, however, have the right to opt out of receiving marketing communications at any time by:
• contacting us at admin@vickisarge.com
We may ask you to confirm or update your marketing preferences if you ask us to provide further
products and services in the future, or if there are changes in the law, regulation, or the structure of
our business.
We will always treat your personal data with the utmost respect and never sell OR share it with other
organisations for marketing purposes.
Who we share your personal data with
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We routinely share personal data with:
• third parties we use to help deliver our products and services to you, e.g. payment service
providers, delivery companies and point of sale providers;
• other third parties we use to help us run our business, e.g. marketing agencies or website
hosts;
• third parties approved by you, e.g. social media sites you choose to link your account to or
third party payment providers;
• our banks;
We only allow those organisations to handle your personal data if we are satisfied they take
appropriate measures to protect your personal data. We also impose contractual obligations on them
to ensure they can only use your personal data to provide services to us and to you.
We or the third parties mentioned above occasionally also share personal data with:
• our and their external auditors, e.g. in relation to the audit of our or their accounts, in which
case the recipient of the information will be bound by confidentiality obligations;
• our and their professional advisors (such as lawyers and other advisors), in which case the
recipient of the information will be bound by confidentiality obligations;
• law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal
and regulatory obligations;
• other parties that have or may acquire control or ownership of our business (and our or their
professional advisers) in connection with a significant corporate transaction or restructuring,
including a merger, acquisition, asset sale, initial public offering or in the event of our
insolvency—usually, information will be anonymised but this may not always be possible. The
recipient of any of your personal data will be bound by confidentiality obligations.
Who we share your personal data with—further information
If you would like more information about who we share our data with and why, please contact us (see
‘How to contact us’ below).
Where your personal data is held
Personal data may be held at our offices, third party agencies, service providers, representatives and
agents as described above (see above: ‘Who we share your personal data with’).
How long your personal data will be kept
We will not keep your personal data for longer than we need it for the purpose for which it is used.
Different retention periods apply for different types of personal data.
Transferring your personal data outside of the UK and EEA
We will not transfer your data outside of the UK and EEA unless we are required to do so to meet any
legal obligations.
Your rights
You have the following rights, which you can exercise free of charge:
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Access The right to be provided with a copy of your
personal data
Rectification The right to require us to correct any mistakes in
your personal data
Erasure (also known as the right to be forgotten) The right to require us to delete your personal
data—in certain situations
Restriction of processing The right to require us to restrict processing of
your personal data in certain circumstances, eg
if you contest the accuracy of the data
Data portability The right to receive the personal data you
provided to us, in a structured, commonly used
and machine-readable format and/or transmit
that data to a third party—in certain situations
To object The right to object:
—at any time to your personal data being
processed for direct marketing (including
profiling);
—in certain other situations to our continued
processing of your personal data, eg processing
carried out for the purpose of our legitimate
interests unless there are compelling legitimate
grounds for the processing to continue or the
processing is required for the establishment,
exercise or defence of legal claims
Not to be subject to automated individual
decision making
The right not to be subject to a decision based
solely on automated processing (including
profiling) that produces legal effects concerning
you or similarly significantly affects you
The right to withdraw consent If you have provided us with a consent to use
your personal data you have a right to withdraw
that consent easily at any time
You may withdraw consent by [insert details as
relevant depending on consents]
Withdrawing consent will not affect the
lawfulness of our use of your personal data in
reliance on that consent before it was withdrawn
For more information on each of those rights, including the circumstances in which they apply, please
contact us (see ‘How to contact us’ below) or see the Guidance from the UK Information
Commissioner’s Office (ICO).
If you would like to exercise any of those rights, please:
• email, or write to us—see below: ‘How to contact us’; and
• provide enough information to identify yourself and any additional identity information we may
reasonably request from you;
• let us know what right you want to exercise and the information to which your request relates.
Keeping your personal data secure
We have appropriate security measures to prevent personal data from being lost accidentally, or used
or accessed unlawfully. We limit access to your personal data to those who have a genuine business
need to access it. Those processing your personal data will do so only in an authorised manner and
are subject to a duty of confidentiality.
We also have procedures to deal with any suspected data security breach. We will notify you and any
applicable regulator of a suspected data security breach where we are legally required to do so.
How to complain
Please contact us if you have any queries or concerns about our use of your personal data (see
below ‘How to contact us’). We hope we will be able to resolve any issues you may have.
You may also have the right to lodge a complaint with the Information Commissioner (the UK data
protection regulator).
Changes to this privacy policy
This privacy notice was published on 14/05/2024 and last updated on 14/05/2024.
We may change this privacy notice from time to time—when we do we will inform you via [insert
mechanism for informing the data subject of changes to the notice, eg our website or other means of
contact such as email].
Updating your personal data
We take reasonable steps to ensure your personal data remains accurate and up to date. To help us
with this, please let us know if any of the personal data you have provided to us has changed, e.g.
your surname or address—see below ‘How to contact us’.
How to contact us
Individuals in the UK
You can contact us and/or our Data Protection Officer by post, email or telephone if you have any
questions about this privacy policy or the information we hold about you, to exercise a right under
data protection law or to make a complaint.
Our contact details are shown below:
Our contact details
Address: 12 Kensington Church Street, London, W8 4EP
Email: admin@vickisarge.com
Phone: 07903099746
