The policy sets out the different areas where user privacy is concerned and outlines the obligations & requirements of the users, the website and website owners. Furthermore the way this website processes, stores and protects user data and information will also be detailed within this policy.
Suburban Turban’s Privacy Notice 18/05/2018
The following privacy notice outlines how Suburban Turban collects, uses, protects and transfers your personal data. Suburban Turban designs and manufactures specialist headwear for hair loss, and sells its range of headwear online at https://www.suburbanturban.co.uk
The data protection ofﬁcer/data owner for the organisation is Nicola Smetham. You can contact the data protection ofﬁcer/data owner by sending an email to email@example.com or writing to Suburban Turban Ltd, Masters Yard, Guildford Road, Westcott, Surrey RH4 3NG.
Personal data collected
The personal data that we collect is:
- Home address
- Email Address
- Date of Birth
- Phone number
- Health information
- We DO NOT store any financial information on our clients.
Purpose and Legal Basis for Processing Your Data
Suburban Turban takes your privacy seriously and we will never sell or rent your personal data to any third-party. Sharing of your data and direct marketing activities are only carried out with your express consent, which you are free to withdraw at any time.
We need to obtain and process your personal data to provide you with our products and to fulﬁl our business and legal obligations. We will never collect any personal information from you that we do not need or retain any data that is no longer necessary for the purposes speciﬁed in this notice.
Where we request sensitive personal data from you (i.e. health status), the reason(s) for the request will be clearly given along with the purposes of the processing (i.e for the purposes of HRMC VAT exemption.) Explicit consent through an online screen will always be required for us to obtain and process this information.
Who is processing my data?
Suburban Turban Ltd, Masters Yard, Guildford Road, Westcott, Surrey RH4 3NG are the data controller and processes your personal information for the purposes laid out in this privacy notice. Art of Data Ltd, The Studio, 47 Brooksby Road, Reading, Berkshire, RG31 6LZ, acts as data processor on behalf of Suburban Turban only in cases of technical support, or troubleshooting is required by Suburban Turban Ltd. Furthermore, Art of Data must process the personal information in accordance with this Privacy Notice and as permitted by applicable data protection laws.
Your personal data is processed to:
- Collect speciﬁc personal data (name, address, email, contact number, DOB) that is required to enter into a contract to sell a product.
- Engage in communication with you including conﬁrmation and reminders of appointments, and requests to cancel or change orders / appointments.
- Collect health status information in order to sell our products.
- Select relevant offers, promotions and information for you.
- Estimate the number of customers we have.
- Hold personal data that is required by law or to respond to legal process.
- Hold in accordance with HRMC guidelines on VAT exemption status.
- Store customer records.
Your rights as the individual
If your personal data is held by Suburban Turban you hold particular rights over it.
Where you have provided consent for us to contact you as part of our marketing services, you have the right to modify or withdraw your consent at any time by using the unsubscribe option accompanied with all of our direct marketing or by contacting Suburban Turban’s Data Ofﬁcer.
You also have the right:
- To be informed of how your personal data will be used before it is collected.
- To access your personal data and information on how your information is used after it has been gathered.
- To have personal data corrected if it is incomplete, inaccurate or out-of-date.
- To request the removal or deletion of personal data where there is no compelling reason for its continued processing.
- To restrict processing, to ‘block’ processing of your personal data.
- To data portability, having your data moved, copied or transferred from Suburban Turban to another organisation in an easily readable format.
- To object to direct marketing from us.
Special categories of personal data collected
Health status is requested online through the site or requested by email after ordering, if the order has been received via our Etsy shop and you live in the UK. Health status needs to be established at the time of each and every order so that we can justify your VAT exemption should we be asked to by HRMC (UK). Suburban Turban asks for consent prior to gathering and processing order information, unless as stated above. At any time after giving consent, you can withdraw you consent, subject to legal, insurance and contractual restrictions (see more on ‘your rights as an individual’). Your privacy is very important to us and we only use this information for determining your final order value.
Process of collection
Your personal data is collected when you provide it to us through Art of Data software - our website, over the phone, in Suburban Turban’s studio, by email, social media, in writing or any other means by which you provide it to us. Information is stored using the Art of Data software platform as well as some level of paper record keeping. Suburban Turban gives you access to information about your account and bookings through the website software, for the limited purpose of viewing and updating that information.
Suburban Turban does not collect the personal data of children under the age of 16 without parental or guardian consent. If you believe that we hold any information from or about a child under age 16, please contact Suburban Turban and if we cannot immediately obtain appropriate parental or guardian consent, will remove the personal data from storage.
Your personal data is shared only with Art of Data in cases that technical support and troubleshooting is required for the business. Suburban Turban does not share your personal information with any third-party without your prior consent, other than those already disclosed in this privacy notice or as part of our legal obligations under the relevant data protection laws. We appreciate the sensitive nature of information our clients share with us and we do not sell or share this information for commercial gain.
Use of Data Processors
Data processors are third parties who provide some elements of our business services for us. Where we use a third-party, we have strict agreements in place governing the processing of your personal data, on which no action can be taken without instruction from us. The third-parties with whom we work will never share or disclose your personal information and will hold it securely at all times.
Art of Data - Suburban Turban use software provided by Art of Data
Suburban Turban uses SagePay as our payment gateway
How Long Do We Keep Your Data?
Suburban Turban retains your personal data for as long as necessary to provide you with our services as our client. Suburban Turban is required under tax laws to keep your personal data for a minimum of 7 years. Where we have your consent for marketing purposes, we will retain the minimum required data until you notify us that you no longer wish to receive such information.
The criteria for which we would continue to process your personal information includes:
- Where there is a legal basis, obligation or legitimate interest to continuing processing your personal information.
- Where processing is necessary for the establishment, exercise or defence of legal claims.
Transfers of personal information
When your personal data is processed through Art of Data software, all of it is held within the EU. Your information is processed by the Art of Data software and stored at the Bunker Sandwich Kent. During this process your data is encrypted in transit and at rest.
Consequences of not providing your personal information to Suburban Turban.
In the event that you want to purchase a product from Suburban Turban, certain personal information is required to enter into a contract with you. Suburban Turban will not be able to enter into a contract with you to fulﬁl an attempt to purchase a product, if you do not provide your personal information.
As noted in this privacy statement, we are processing your personal data to comply with legal and statutory obligations and in the performance of a contract. You can always choose not to provide personal information; however, we will be unable to sell a product to you and for it then to be dispatched to you.
Safeguarding your Personal Data
Appropriate measures are taken to protect your personal data from access from unauthorised persons or inappropriate access, internal or external. Your connection to the Art of Data system uses a HTTPS Secure communication protocol and TLS security. This means all information passed to the Art of Data system is encrypted during data input and transfer to the server. Any paper ﬁles recording your personal data are destroyed at close of play on the same working day by authorised personnel. Employees are only assigned speciﬁc access rights and can only access the website software from secure terminals in the studio.
In the occurrence that you want to make a complaint about how your personal data was gathered, how it is being processed by Suburban Turban or third parties used by Suburban Turban, or you are not satisﬁed about how a complaint has been handled, you retain the right to lodge a complaint directly with the supervisory authority and also Suburban Turban’s Data Protection Ofﬁcer/ GDPR Owner.
Data Protection Commissioner, Information Commissioner’s Ofﬁce, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF +44 (0) 303 123 1113
Suburban Turban’s Data Protection Ofﬁcer/GDPR Owner
Nicola Smetham - Suburban Turban Ltd, Masters Yard, Guildford Road, Westcott, Surrey RH4 3NG.
Changes to our Privacy Statement
End of GDPR notice
This website and its owners take a proactive approach to user privacy and ensure the necessary steps are taken to protect the privacy of its users throughout their visiting experience. This website complies to all UK national laws and requirements for user privacy.
Cookies are small files saved to the user’s computer hard drive that track, save and store information about the user’s interactions and usage of the website. This allows the website, through its server to provide the users with a tailored experience within this website.
Users are advised that if they wish to deny the use and saving of cookies from this website on to their computers hard drive they should take necessary steps within their web browsers security settings to block all cookies from this website and its external serving vendors.
Performance Tracking Cookies
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Used by Google Analytics
Controlled by vendor
If you don’t want to be tracked please install this browser Add-on https://tools.google.com/dlpage/gaoptout .
We use no other tracking cookies and would never share your data with any third party companies.
Strictly necessary cookies
Just a random number
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Contact & Communication
Users contacting this website and/or its owners do so at their own discretion and provide any such personal details requested at their own risk. Your personal information is kept private and stored securely until a time it is no longer required or has no use, as detailed in the Data Protection Act 1998. Every effort has been made to ensure a safe and secure form to email submission process, but advise users using such form to email processes that they do so at their own risk.
This website and its owners use any information submitted to provide you with further information about the products / services they offer or to assist you in answering any questions or queries you may have submitted. This includes using your details to subscribe you to any email newsletter program the website operates but only if this was made clear to you and your express permission was granted when submitting any form to email process. Or whereby you the consumer have previously purchased from or enquired about purchasing from the company a product or service that the email newsletter relates to. This is by no means an entire list of your user rights in regard to receiving email marketing material. Your details are not passed on to any third parties.
This website operates an email newsletter program, used to inform subscribers about products and services supplied by this website. Users can subscribe through an online automated process should they wish to do so but do so at their own discretion. Some subscriptions may be manually processed through prior written agreement with the user.
Subscriptions are taken in compliance with UK Spam Laws detailed in the Privacy and Electronic Communications Regulations 2003. All personal details relating to subscriptions are held securely and in accordance with the Data Protection Act 1998. No personal details are passed on to third parties nor shared with companies / people outside of the company that operates this website. Under the Data Protection Act 1998 you may request a copy of personal information held about you by this website’s email newsletter program. A small fee will be payable. If you would like a copy of the information held on you please write to the business address at the bottom of this policy.
Email marketing campaigns published by this website or its owners may contain tracking facilities within the actual email. Subscriber activity is tracked and stored in a database for future analysis and evaluation. Such tracked activity may include; the opening of emails, forwarding of emails, the clicking of links within the email content, times, dates and frequency of activity [this is not a comprehensive list].
This information is used to refine future email campaigns and supply the user with more relevant content based around their activity.
In compliance with UK Spam Laws and the Privacy and Electronic Communications Regulations 2003 subscribers are given the opportunity to unsubscribe at any time through an automated system. This process is detailed at the footer of each email campaign. If an automated unsubscription system is unavailable clear instructions on how to unsubscribe will by detailed instead.
Although this website only looks to include quality, safe and relevant external links, users are advised to adopt a policy of caution before clicking any external web links mentioned throughout this website. (External links are clickable text / banner / image links to other websites.)
The owners of this website cannot guarantee or verify the contents of any externally linked website despite their best efforts. Users should therefore note they click on external links at their own risk and this website and its owners cannot be held liable for any damages or implications caused by visiting any external links mentioned.
Social Media Platforms
Communication, engagement and actions taken through external social media platforms that this website and its owners participate on are custom to the terms and conditions as well as the privacy policies held with each social media platform respectively.
Users are advised to use social media platforms wisely and communicate / engage upon them with due care and caution in regard to their own privacy and personal details. This website nor its owners will ever ask for personal or sensitive information through social media platforms and encourage users wishing to discuss sensitive details to contact them through primary communication channels such as by telephone or email.
This website may use social sharing buttons which help share web content directly from web pages to the social media platform in question. Users are advised before using such social sharing buttons that they do so at their own discretion and note that the social media platform may track and save your request to share a web page respectively through your social media platform account.
Shortened Links in Social Media
This website and its owners through their social media platform accounts may share web links to relevant web pages. By default some social media platforms shorten lengthy urls [web addresses] .
Users are advised to take caution and good judgement before clicking any shortened urls published on social media platforms by this website and its owners. Despite the best efforts to ensure only genuine urls are published many social media platforms are prone to spam and hacking and therefore this website and its owners cannot be held liable for any damages or implications caused by visiting any shortened links.
Resources & Further Information
- Data Protection Act 1998
- Privacy and Electronic Communications Regulations 2003
- Privacy and Electronic Communications Regulations 2003 – The Guide
Business address - Suburban Turban Ltd, Masters Yard, Guildford Road, Westcott, Surrey RH4 3NG. Limited Co. No. 6054668, VAT reg no. 116749500.