Privacy policy

This Privacy Policy describes how lcylondon.com (the “Site” or “we”) collects, uses, and discloses your Personal Information when you visit or make a purchase from the Site.

Contact

After reviewing this policy, if you have additional questions, want more information about our privacy practices, or would like to make a complaint, please contact us by e-mail at sales@lcylondon.com.

Collecting Personal Information

When you visit the Site, we collect certain information about your device, your interaction with the Site, and information necessary to process your purchases. We may also collect additional information if you contact us for customer support. In this Privacy Policy, we refer to any information about an identifiable individual (including the information below) as “Personal Information”. See the list below for more information about what Personal Information we collect and why.

Our commitment to you

  • We take the protection of your personal data seriously and will process your personal data fairly, lawfully and transparently. This privacy notice describes the personal data we are collecting about you and how it is used.
  • We will only collect and use your personal data for the following purposes, to:
  • fulfil your order(s)
  • fulfil orders made on your behalf (e.g. e-gift card orders)
  • communicate with you following a "refer a friend" nomination
  • keep you up to date with the latest offers and trends
  • give you a better shopping experience
  • help us to make our marketing more relevant to you and your interests
  • improve our services
  • meet our legal responsibilities

 

How we keep your data safe and secure

We have appropriate organisational safeguards and security measures in place to protect your data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

  • The communication between your browser and our website uses a secure encrypted connection wherever your personal data is involved.
  • We require any third party who is contracted to process your personal data on our behalf to have security measures in place to protect your data and to treat such data in accordance with the law.
  • In the unfortunate event of a personal data breach, we will notify you and any applicable regulator when we are legally required to do so.


The personal data we collect

  • Personal data means any information about an individual from which that person can be identified. It does not include anonymised data, where the identity and identifying information has been removed.
  • While our website is designed for a general audience, we will not knowingly collect any data from children under the age of 13 or sell products to children. If you are under the age of 13, you are not permitted to use or submit your data to the website.
  • The following groups of personal data are collected:
  • Identity Data includes information such as: first name, last name, title, date of birth (optional), occupation, personal description, photo and gender.
  • Contact Data includes information such as: email address, billing address, delivery address, location, country, telephone number, loyalty programme membership number, and social media id (if you log in by social media).
  • Financial Data includes information such as: payment card details and bank account.
  • Transaction Data includes information such as: details of your purchases and the fulfilment of your orders (such as basket number, order number, subtotal, title, currency, discounts, shipping, number of items, product number, single item price, category, tax etc.); payments to and from you and details of other products and services you have obtained from us, correspondence or communications with you in respect of your orders, and details of any rewards and bonuses awarded.
  • Technical Data includes information such as: details of the device(s) you use to access our services, your internet protocol (IP) address, login data, your username and password, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform.
  • Profile Data includes information such as: purchases or orders made by you, product and style interests, preferences, feedback, and survey responses.
  • Usage Data includes information such as: how and when you use our website/app, how you moved around it, what you searched for; website/app performance statistics, traffic, location, weblogs and other communication data; loyalty programme activities; and details of any other LCY London products and services used by you.
  • Marketing and Communications Data includes information such as: your preferences in receiving marketing from us and our third parties and your communication preferences.
  • We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data 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.



 

How we collect your data

  • We may collect personal data about you in the following ways:
  • Direct interactions – you may give us your Identity, Contact, Financial, Transaction, Profile, and Marketing and Communications data (as described above) by filling in forms, entering information online or by corresponding with us by post, phone, email, telephone or otherwise. This includes personal data you provide, for example, when you:


  • Create an account or purchase products on our website;
  • Subscribe to our newsletter, discussion boards, social media sites or create wish lists;
  • Enter a competition;
  • Join a LCY London loyalty programme;
  • Complete a voluntary market research survey;
  • Contact us with an enquiry or to report a problem (by phone, email, social media, or messaging service);
  • Use the “refer a friend” function on our website; or
  • When you log in to our website via social media.
  • Automated technologies or interactions – as you interact with our website, we may automatically collect the following types of data (all as described above): Technical Data about your equipment, Usage Data about your browsing actions and patterns, and Contact Data where tasks carried out via our website remain uncompleted, such as incomplete orders or abandoned baskets. We collect this data by using cookies, server logs and other similar technologies. Please see our Cookie Policy for further details.
  • Third parties – we may receive personal data about you from various third parties, including:


  • Identity and Contact data from another individual when they purchase an e-gift card for you or use the "refer a friend" function on our website;
  • Technical Data from third parties, including analytics providers such as Google. Please see further information in the section entitled ‘Marketing preferences, adverts and cookies’.
  • Technical Data from affiliate networks through whom you have accessed our website;
  • Identity and Contact Data from social media platforms when you log in to our website using such social media platforms;
  • Identity and Contact data from third parties, including organisations (including law enforcement agencies), associations and groups, who share data for the purposes of fraud prevention and detection and credit risk reduction; and
  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services.

How we use your data

  • The legal basis for processing your personal data
  • We will only collect and process your personal data where we have a legal basis to do so. As a data controller, the legal basis for our collection and use of your personal data varies depending on the manner and purpose for which we collected it.
  • We will only collect personal data from you when:
  • we have your consent to do so, or
  • we need your personal data to perform a contract with you. For example, to process a payment from you, fulfil your order or provide customer support connected with an order, or
  • the processing is in our legitimate interests and not overridden by your rights, or
  • we have a legal obligation to collect or disclose personal data from you.

Uses made of your personal data

  • Your personal data is used by LCY London to support a range of different activities. These are listed in the table below together with the types of data used and the legal bases we rely on when processing them, including where appropriate, our legitimate interests. Please be aware that we may process your personal data using more than one lawful basis, depending on the specific activity involved. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To create an account and register you as a new customer (either directly or via social media).
  • Identity
  • Contact
  • Performance of a contract with you

To process and deliver your order including: recording your order details; keeping you informed about the order status; process payments and refunds, collect money owed to us; and automated decision making to assist fraud prevention and detection.
  • Identity
  • Contact
  • Financial
  • Transaction
  • Performance of a contract with you
  • Necessary for our legitimate interests (e.g. to recover debts due to us)
  • For automated decision making we consider that fraud detection and prevention is in our legitimate interests to ensure that fraudulent transactors are unable to benefit from our services and in the legitimate interest of the public as whole due to the impact of fraud on the consumer market; we also consider it a necessary element of entering into a contract with you that we are able to verify your identity and prevent fraud.

To manage our relationship with you, including: providing you with any information, products and services that you request from us(or that has been requested on your behalf through our "refer a friend" function); notifying you about changes to our services, terms and conditions or privacy notice; asking you to leave a review or take a survey.
  • Identity
  • Contact
  • Profile
  • Marketing and Communications
  • Performance of a contract with you
  • Necessary for our legitimate interests (to keep our records updated and to study how customers use our products and services)

To enable you to take part in a competition, event, survey, or receive a reward for shopping with us.
  • Identity
  • Contact
  • Profile
  • Usage
  • Marketing and Communications
  • Necessary for our legitimate interests (to study how customers use our products and services, to develop them and grow our business)
  • Where you have decided to enter into a competition or event, for the performance of a contract with you

To administer, protect and improve our business and our website/app, including: troubleshooting, data analysis, testing, system maintenance, support, data analysis, reporting and hosting of data; setting default options for you, such as language and currency. 
  • Identity
  • Contact
  • Profile
  • Technical
  • Transaction
  • Marketing and Communications
  • Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, and to detect and prevent fraud)
  • Necessary to comply with a legal obligation

To deliver relevant website content, online advertisements and information for you; and measure the effectiveness of the advertising provided.
  • Identity
  • Contact
  • Profile
  • Usage
  • Marketing and Communications
  • Technical
  • Necessary for our legitimate interests (to study how customers use our products and services, to develop them, to grow our business and to inform our marketing strategy)

To use data analytics to: improve our website, products, services, marketing, customer relationships and experiences;

and for market research, statistical and survey purposes.
  • Technical
  • Usage
  • Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

To recommend products, services discounts and offers that may be of interest to you, including to send you such information by email, post or SMS.
  • Identity
  • Contact
  • Technical
  • Usage
  • Profile
  • Marketing and Communications
  • Necessary for our legitimate interests (to develop our products and services and grow our business) or
  • Consent.

See further details in the section ‘Marketing preferences, adverts and cookies'

To inform or remind you by email of any task carried out via our website which remains uncompleted, such as incomplete orders or abandoned baskets.
  • Identity
  • Contact
  • Usage
  • Necessary for our legitimate interests (to improve the shopping experience of our customers)

To protect our customers, LCY London and website from fraud and theft
  • Identity
  • Contact
  • Profile
  • Necessary for our legitimate interests (to detect and prevent fraud)

To process and deliver your e-gift card orders including taking payment and communicating with you and/or the nominated recipient if delivered to another person.
  • Identity
  • Contact
  • Financial
  • Transaction
  • For automated decision making we consider that fraud detection and prevention is in our legitimate interests to ensure that fraudulent transactors are unable to benefit from our services; we also consider it a necessary element of entering into a contract with you that we are able to verify your identity and prevent fraud.

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we wish to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. We may process personal data without your consent, in compliance with the above rules, where this is required or permitted by law.

If you have any questions about how boohoo use any of your personal data, please contact our Data Protection Officer,

Minors

The Site is not intended for individuals under the age of [18. We do not intentionally collect Personal Information from children. If you are the parent or guardian and believe your child has provided us with Personal Information, please contact us at the address above to request deletion.

Sharing Personal Information

We share your Personal Information with service providers to help us provide our services and fulfil our contracts with you, as described above. For example:

  • We use Shopify to power our online store. You can read more about how Shopify uses your Personal Information here: https://www.shopify.com/legal/privacy.
  • We may share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.

Using Personal Information

We use your personal Information to provide our services to you, which includes: offering products for sale, processing payments, shipping and fulfilment of your order, and keeping you up to date on new products, services, and offers.

[INCLUDE THE FOLLOWING SECTION IF YOUR STORE IS LOCATED IN OR IF YOU HAVE CUSTOMERS IN EUROPE]

Lawful basis

Pursuant to the General Data Protection Regulation (“GDPR”), if you are a resident of the European Economic Area (“EEA”), we process your personal information under the following lawful bases:

[INCLUDE ALL THAT APPLY TO YOUR BUSINESS]

  • Your consent;
  • The performance of the contract between you and the Site;
  • Compliance with our legal obligations;
  • To protect your vital interests;
  • To perform a task carried out in the public interest;
  • For our legitimate interests, which do not override your fundamental rights and freedoms.

Retention

When you place an order through the Site, we will retain your Personal Information for our records unless and until you ask us to erase this information. For more information on your right of erasure, please see the ‘Your rights’ section below.

 

Your rights

Subject to certain limitations on certain rights, you have the following rights in relation to your information, which you can exercise by writing to by sending an email to sales@lcylondon.com:

to request access to your information and information related to our use and processing of your information;

to request the correction or deletion of your information;

to request that we restrict our use of your information;

to receive information which you have provided to us in a structured, commonly used and machine-readable format (e.g. a CSV file) and the right to have that information transferred to another data controller (including a third party data controller);

to object to the processing of your information for certain purposes (for further information, see the section below entitled Your right to object to the processing of your information for certain purposes); and

to withdraw your consent to our use of your information at any time where we rely on your consent to use or process that information. Please note that if you withdraw your consent, this will not affect the lawfulness of our use and processing of your information on the basis of your consent before the point in time when you withdraw your consent.

In accordance with Article 77 of the General Data Protection Regulation, you also have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or of an alleged infringement of the General Data Protection Regulation. Further information on your rights in relation to your personal data as an individual

The above rights are provided in summary form only and certain limitations apply to many of these rights. For further information about your rights in relation to your information, including any limitations which apply, please visit the following pages on the ICO’s website: 

Verifying your identity where you request access to your information

Where you request access to your information, we are required by law to use all reasonable measures to verify your identity before doing so. 

These measures are designed to protect your information and to reduce the risk of identity fraud, identity theft or general unauthorised access to your information.

How we verify your identity 

Where we possess appropriate information about you on file, we will attempt to verify your identity using that information. 

If it is not possible to identity you from such information, or if we have insufficient information about you, we may require original or certified copies of certain documentation in order to be able to verify your identity before we are able to provide you with access to your information. 

We will be able to confirm the precise information we require to verify your identity in your specific circumstances if and when you make such a request.

YOUR RIGHT TO OBJECT TO THE PROCESSING OF YOUR INFORMATION FOR CERTAIN PURPOSES

You have the following rights in relation to your information, which you may exercise in the same way as you may exercise by sending an email to sales@lcylondon.com

  • to object to us using or processing your information where we use or process it in order to carry out a task in the public interest or for our legitimate interests, including ‘profiling’ (i.e. analysing or predicting your behaviour based on your information) based on any of these purposes; and
  • to object to us using or processing your information for direct marketing purposes (including any profiling we engage in that is related to such direct marketing).

You may also exercise your right to object to us using or processing your information for direct marketing purposes by:

  • clicking the unsubscribe link contained at the bottom of any marketing email we send to you and following the instructions which appear in your browser following your clicking on that link; and
  • sending an SMS message containing only the words “OPT OUT” in reply to any marketing communication we send by text message.

For more information on how to object to our use of information collected from cookies and similar technologies, please see the section entitled How to accept or reject cookies in our cookies policy, which is available here: https://www.lcylondon.com/cookie-policy.htm

 

GDPR

If you are a resident of the EEA, you have the right to access the Personal Information we hold about you, to port it to a new service, and to ask that your Personal Information be corrected, updated, or erased. If you would like to exercise these rights, please contact us through the contact information above. 

Your Personal Information will be initially processed in Ireland and then will be transferred outside of Europe for storage and further processing, including to Canada and the United States. For more information on how data transfers comply with the GDPR, see Shopify’s GDPR Whitepaper: https://help.shopify.com/en/manual/your-account/privacy/GDPR.

Cookies

A cookie is a small amount of information that’s downloaded to your computer or device when you visit our Site. We use a number of different cookies, including functional, performance, advertising, and social media or content cookies. Cookies make your browsing experience better by allowing the website to remember your actions and preferences (such as login and region selection). This means you don’t have to re-enter this information each time you return to the site or browse from one page to another. Cookies also provide information on how people use the website, for instance whether it’s their first time visiting or if they are a frequent visitor.

We use the following cookies to optimize your experience on our Site and to provide our services.

[Be sure to check this list against Shopify’s current list of cookies on the merchant storefront: https://www.shopify.com/legal/cookies ]

Cookies Necessary for the Functioning of the Store

Name

Function

Duration

_ab

Used in connection with access to admin.

2y

_secure_session_id

Used in connection with navigation through a storefront.

24h

_shopify_country

Used in connection with checkout.

session

_shopify_m

Used for managing customer privacy settings.

1y

_shopify_tm

Used for managing customer privacy settings.

30min

_shopify_tw

Used for managing customer privacy settings.

2w

_storefront_u

Used to facilitate updating customer account information.

1min

_tracking_consent

Tracking preferences.

1y

c

Used in connection with checkout.

1y

cart

Used in connection with shopping cart.

2w

cart_currency

Used in connection with shopping cart.

2w

cart_sig

Used in connection with checkout.

2w

cart_ts

Used in connection with checkout.

2w

cart_ver

Used in connection with shopping cart.

2w

checkout

Used in connection with checkout.

4w

checkout_token

Used in connection with checkout.

1y

dynamic_checkout_shown_on_cart

Used in connection with checkout.

30min

hide_shopify_pay_for_checkout

Used in connection with checkout.

session

keep_alive

Used in connection with buyer localization.

2w

master_device_id

Used in connection with merchant login.

2y

previous_step

Used in connection with checkout.

1y

remember_me

Used in connection with checkout.

1y

secure_customer_sig

Used in connection with customer login.

20y

shopify_pay

Used in connection with checkout.

1y

shopify_pay_redirect

Used in connection with checkout.

30 minutes, 3w or 1y depending on value

storefront_digest

Used in connection with customer login.

2y

tracked_start_checkout

Used in connection with checkout.

1y

checkout_one_experiment

Used in connection with checkout.

session

Reporting and Analytics

Name

Function

Duration

_landing_page

Track landing pages.

2w

_orig_referrer

Track landing pages.

2w

_s

Shopify analytics.

30min

_shopify_d

Shopify analytics.

session

_shopify_s

Shopify analytics.

30min

_shopify_sa_p

Shopify analytics relating to marketing & referrals.

30min

_shopify_sa_t

Shopify analytics relating to marketing & referrals.

30min

_shopify_y

Shopify analytics.

1y

_y

Shopify analytics.

1y

_shopify_evids

Shopify analytics.

session

_shopify_ga

Shopify and Google Analytics.

session

The length of time that a cookie remains on your computer or mobile device depends on whether it is a “persistent” or “session” cookie. Session cookies last until you stop browsing and persistent cookies last until they expire or are deleted. Most of the cookies we use are persistent and will expire between 30 minutes and two years from the date they are downloaded to your device.

You can control and manage cookies in various ways. Please keep in mind that removing or blocking cookies can negatively impact your user experience and parts of our website may no longer be fully accessible.

Most browsers automatically accept cookies, but you can choose whether or not to accept cookies through your browser controls, often found in your browser’s “Tools” or “Preferences” menu. For more information on how to modify your browser settings or how to block, manage or filter cookies can be found in your browser’s help file or through such sites as: www.allaboutcookies.org.

Additionally, please note that blocking cookies may not completely prevent how we share information with third parties such as our advertising partners. To exercise your rights or opt-out of certain uses of your information by these parties, please follow the instructions in the “Behavioural Advertising” section above.

Do Not Track

Please note that because there is no consistent industry understanding of how to respond to “Do Not Track” signals, we do not alter our data collection and usage practices when we detect such a signal from your browser.

Changes

We may update this Privacy Policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal, or regulatory reasons.

Complaints

As noted above, if you would like to make a complaint, please contact us by e-mail using the details provided under “Contact” above.

If you are not satisfied with our response to your complaint, you have the right to lodge your complaint with the relevant data protection authority. You can contact your local data protection authority, or our supervisory authority here: [Add contact information or website for the data protection authority in your jurisdiction. For example: https://ico.org.uk/make-a-complaint/]

Last updated: [22.05.2022]