Privacy Notice

Welcome to our website swavobridal.com (official site). Please read our Privacy Policy carefully. It applies each time you visit our site, surf through our pages or use our services, regardless of whether you purchase any products.

We also ask you to read the “Cookie Policy”, the “Legal Terms & Conditions” of the swavobridal.com website and “General Terms and Conditions of Sale”, which contain detailed information regarding the conditions relating to our services and “Secure Payments” which provides information on web security implementations on swavobridal.com to protect data transmission and unauthorised access. Some services may be subject to specific legal terms, in which case we will give you all the appropriate information from time to time.

For the purposes of this Privacy Notice, (“European Data Protection Legislation”) is defined as, for the periods in which they are in force, the European Data Protection Directive 95/46/EC, all laws giving effect or purporting to give effect to the European Data Protection Directive 95/46/EC (such as the Data Protection Act 1998) or otherwise relating to data protection (to the extent the same apply) and, from 25 May 2018, the General Data Protection Regulation (Regulation (EU) 2016/670) (GDPR) or any equivalent legislation amending or replacing the GDPR.

This Privacy Policy was last updated on 26th February 2019.

Who is the Data Controller

The data controller of the information collected through this website is Swavo via Myra Trading Ltd (the “vendor”) which is formed in England & Wales Company Reg. No. 11235489, with registered office in United Kingdom at 914 Leeds Road, Bradford, West Yorkshire, BD3 8EZ. Swavo independently establishes the purposes and methods of data processing and the implementation of security procedures to guarantee the privacy, integrity and availability of such data.

For any clarification, question or requirement related to your privacy and the processing of your personal data, you can contact us at any time by sending a request to our Data Protection Officer by writing to “Data Protection Officer” at the address above, or by e-mail to privacy@swavobridal.com.

Optional or Compulsory Communication of Personal Data

Communicating your personal data to Swavo when requested in any of the many instances where personal data is collected through the site may be essential in order to achieve the purposes set down by the communication itself, or not prejudicial in this regard.

The compulsory or optional nature of the data provision is specified each time – with reference to the specific data requested – at the point of input for each data collection, by marking compulsory information with an asterisk (*).

If you refuse to communicate the information marked as compulsory to Swavo, it will be impossible to achieve the main purpose of the specific data collection: such a refusal might, for example, make it impossible for Swavo to fulfil the product sale agreement on swavobridal.com or provide the other services available on swavobridal.com such as forwarding of the Swavo company news and special offers newsletter.

Communicating additional data to Swavo other than those marked as compulsory, is optional and will not produce any consequences with regard to the main purposes of the collection (such as using the web site and its services or purchasing the products, for example).

Data Supervisors

We have an appointed data supervisor at Swavo who is responsible for overseeing questions in relation to this privacy notice.

What are your rights

You are entitled, at any time, to obtain confirmation from Swavo that your personal data is or is not being processed, even if not yet registered, and its communication in an intelligible form.

You are also entitled to obtain information from Swavo about the source of your personal data, the purposes and methods of data processing that apply to your personal data; the type of logic applied when electronic instruments are used for data processing; full identification of the data controller and data supervisors; the names of the persons or categories of persons to whom personal data may be communicated or who may become privy to personal data while performing their duties as, by way of example, the data supervisors. All this information is included in this Privacy Notice.

In addition, you may always be entitled to obtain from Swavo:

a. Updating, correction and integration of your personal data;

b. Cancellation, transformation into an anonymous form or the blocking of your personal data if processed in violation of the law, including the data deemed unnecessary for the purposes for which the data was collected or subsequently processed in the first place;

c. Certification that the operations described at letters a) and b) have been notified, even with regard to their contents, to the persons to whom your data has been communicated or disseminated, except in those instances where such certification turns out to be impossible or would require a clearly disproportionate deployment of means compared to the right protected.

You do, in any case, have the right to totally or partially oppose:

a. Processing of your personal data, for valid reasons, even if pertinent to the purpose of collection;

b. The processing of your personal data for the purposes of advertisement or direct marketing mailings, or if used for the purposes of market surveys or commercial communications.

You may freely exercise your rights at any time by sending a written request to Swavo – to the mailing address or to the e-mail address privacy@swavobridal.com – and we will reply promptly.

To ensure that your personal data is always exact, up to date, pertinent and complete, please advise us of any variations by writing to privacy@swavobridal.com.

We wish to inform you that the law regulating protection of personal data permits Swavo – without any obligation to obtain your prior consent – to use your data for direct selling activities involving products similar to those you have already purchased, unless you refuse to allow such use of the e-mail address you communicate to us.

All of the above constitute the minimum information that Swavo is obliged to provide you with: for any further information about processing of your personal data by Swavo, we invite you to read this entire Privacy Notice.

A summary of our Privacy Notice

The principles on which our privacy notice is based are listed below:

1. Process data exclusively for the purposes and according to the methods illustrated in the notice presented to users at the time of its collection;

2. Use data for other purposes, with respect to those specified at the time of collection, only where the user has expressed its express consent to such use;

3. Make data available to third party companies only for purposes that are strictly necessary to provide the requested service(s) and only where monitored by a data supervisor; not communicate, cede or transfer data to third parties for purposes exclusive to the third party unless the users have received prior warning and have granted their consent;

4. Answer all requests for cancellation, variation and integration of personal data, opposition to data processing for the purpose of sending commercial information and advertising;

5. Ensure that data processing is conducted fairly and legally, protecting user privacy and implementing appropriate measures for security and protection of the privacy, integrity and availability of the data provided by users.

What information we collect when you register and why?

When you buy goods from us, you are entering into a contract with us. When shopping swavobridal.com to purchase an instock item or if you place a made-to-order with us then we will require information before you can place an order with us.

We will ask you to provide some personal information in a secure page such as:

Full name

Address (shipping and billing address)

Contact numbers

Email address

How and why we process your personal data

Personal data processing is conducted primarily by means of information systems and electronic devices by swavobridal.com and other parties who, selected with care for their reliability and competence, conduct operations that are essential in order to achieve the purposes strictly related to the use of the web site, its services and sale of products via the web site (see below, ‘Parties who may process your personal data’).

The specific purposes for which your personal data is processed are summarized each time you communicate your personal data, in the notice presented in compliance with this Privacy Notice (European Data Protection Directive 95/46/EC & General Data Protection Regulation (Regulation (EU) 2016/670) (GDPR)). In general, data is processed in order to provide the following services available to those who visit our site:

1. Registration on the site for frequent shoppers;

2. Subscription to additional specific services, such as our Swavo company news & special offers newsletter, and other similar information bulletins about our activities, inviting your friends to join the Swavo social networks (twitter, facebook, instagram, snapchat, youtube or flickr), making yourself known to other users by sending us your comments / product reviews;

3. Payments, including anti-fraud checks (3D Secure) for credit card payments; in this case, the data provided during the order process (first name, surname, address, credit card number, delivery address if different from billing address) will be sent to the supervisor responsible for anti-fraud control, Cardinal Commerce, and will be processed strictly for that purpose (see also the section “Data supervisors”);

4. Handling of your requests: be they technical, commercial, concerning progress reports on your orders and generally speaking all information requests;

5. Contacting the managers of our services (Press Office, Business Development, Web Marketing, Customer Care);

6. Evaluating requests on your behalf to be included in our personnel by submitting your CV. In processing personal data that may, directly or indirectly, identify you, we aim to abide by the principle of strict necessity.

7. For appointment bookings where we require your contact details to inform you of instore or video bookings and placing made-to-order.

8. For event bookings such as new jewellery collection launch shows;

9. Completing surveys we send you;

10. When you comment on or review our products and services Google or Facebook reviews or via social media comments relating to any of our posts;

11. Completing any of our online forms;

12. When visit our retail store which has CCTV systems operated for the security of both customers and our staff members. These systems may record your image during your visit.

For this reason we have set up the site in such a way as to reduce use of your personal data to the absolute minimum: therefore, your personal data is not processed when the purpose of the specific activity can be achieved by using anonymous data (such as market surveys intended to improve services) or by means of other methods that make it possible to identify the person involved only if strictly necessary or at the request of authorities or the police (such as site traffic data, the time you spend visiting our site or your IP address).

In some cases, as expressly cited in the notice, your personal data will be processed, if you expressly grant your consent, to create a user profile based on your preferences and your purchases, so that we can send you information that is pertinent to your needs and interests. With the exception of the case specified in this Privacy Notice (European Data Protection Directive 95/46/EC & General Data Protection Regulation (Regulation (EU) 2016/670) (GDPR)), authorising the data controller to use your data to send you advertising e-mails about products and services similar to those you have already purchased, unless you refuse your consent for such use, Swavo may use your personal data to send you advertising about its products and services only if you grant your consent.

Your personal data will be communicated to third parties only with your express consent, except for the cases when such communication is obligatory by law or is required for purposes envisaged by the law, for which the person’s consent is not required; in these cases the personal data may be made available to third parties who will process the data autonomously and exclusively for such purposes (for example, in reply to a request from police or the courts or other competent authorities, or in order to fulfil duties that descend from a completed contract with you, such as communicating your personal data to Swavo for payment of the products you have bought).

Any other type of processing, other than related to the specific purpose for which you have communicated your personal data will be indicated in the information notice and will be carried out by Swavo only if you have expressly granted your consent (this is the case, for example, when a customer profile is created based on your preferences and buying habits).

There are, however, instances of data processing for which the law established that your consent is not required: for example, we wish to inform you that Swavo can process your personal data without your consent if this is necessary to comply with the provisions of the law or whenever this is necessary to fulfil the contractual obligations it may have entered into with you (for example, when you have bought products or have requested specific services through our web site).

Finally, we wish to inform you that your personal data will not be transferred abroad to countries that do not provide a sufficient level of privacy protection. If such a transfer should be necessary to provide you with the services or to conclude a contract with Swavo for purchasing our products, we wish to assure you that your personal data will not be transferred to countries that do provide a sufficient level of privacy protection unless specific agreements are concluded by Swavo with such parties, in accordance with applicable laws and regulations.

It could happen that Swavo may find itself processing personal data of third parties, communicated directly to Swavo by its own users, such as when a user has bought a product to be delivered to a friend, or when the person who pays for a product is different from the addressee, or again, when a user wishes to inform a friend about a service or the sale of a specific product on swavobridal.com.

In these circumstances, Swavo will deliver the notice pursuant in compliance with this Privacy Notice to the third party, when the personal data of the same is registered in its archives, it is however your own responsibility to obtain consent from this person before communicating his/her personal data to Swavo and to inform him/her about this Privacy Policy, because you will be the sole person responsible for communication of information and data about third parties without them having granted their consent or in the event that such data be used in an illicit or improper way.

We wish to inform you that the consent of these persons is not required when their data is communicated to Swavo in order to conclude a contract with Swavo in their favour.

How and why we use your personal data

To process any orders that you make by using our website swavobridal.com or in store. If we cannot collect your personal data during the checkout process, we will be unable to process your order and comply with our legal obligations.

For example, we will need your details deliver the product that you ordered, and we may keep your details for a reasonable period afterwards in order to fulfil any contractual obligations such as refunds, guarantees and so on.

To respond to your queries, refund requests and complaints. Handling the information you sent enables us to respond. We may also keep a record of these to inform any future communication with us and to demonstrate how we communicated with you throughout. We do this on the basis of our contractual obligations to you, our legal obligations and our legitimate interests in providing you with the best service and understanding how we can improve our service based on your experience.

To protect our business and your account from fraud and other illegal activities. This includes using your personal data to maintain, update and safeguard your account. We’ll also monitor your browsing activity with us to quickly identify and resolve any problems and protect the integrity of our websites. We’ll do all of this as part of our legitimate interest.

For example, by checking your password when you login and using automated monitoring of IP addresses to identify possible fraudulent log-ins from unexpected locations.

To protect our customers, premises, assets from crime, we operate CCTV systems in our store which record images for security. We do this on the basis of our legitimate business interests.

To process payments and to prevent fraudulent transactions. We do this on the basis of our legitimate business interests. This also helps to protect our customers from fraud.

If we discover any criminal activity or alleged criminal activity through our use of CCTV, fraud monitoring and suspicious transaction monitoring, we will process this data for the purposes of preventing or detecting unlawful acts. We aim is to protect the individuals we interact with from criminal activities.

With your consent, we will use your personal data, preferences and details of your transactions to keep you informed by email, web, text and telephone about relevant products and services including tailored special offers, discounts, promotions, events, competitions and so on.

Of course, you are free to opt out of hearing from us by any of these channels at any time by unsubscribing to our emails or phone communication via SMS.

To send you relevant, personalised communications by post in relation to updates, offers, services and products. We’ll do this on the basis of our legitimate business interest.

You are free to opt out of hearing from us by post at any time.

To send you communications required by law or which are necessary to inform you about our changes to the services we provide you. For example, updates to this Privacy Notice, product recall notices, and legally required information relating to your orders. These service messages will not include any promotional content and do not require prior consent when sent by email or text message. If we do not use your personal data for these purposes, we would be unable to comply with our legal obligations.

To display the most interesting content to you on our website swavobridal.com, we will use data we hold about your favourite products and so on. We do so on the basis of your consent to place cookies or similar technology on your device.

For example, we might display a list of items you’ve recently looked at, or offer you recommendations based on your purchase history and any other data you’ve shared with us.

To administer any competition which you enter, based on your consent given at the time of entering.

To develop, test and improve the systems, services and products we provide to you. We’ll do this on the basis of our legitimate business interests.

For example, we’ll record your browser’s Session ID to help us understand more when you leave us online feedback about any problems you’re having.

To comply with our contractual or legal obligations to share data with law enforcement.

For example, when a court order is submitted to share data with law enforcement agencies or a court of law.

To send you survey and feedback requests to help improve our services. These messages will not include any promotional content and do not require prior consent when sent by email or text message. We have a legitimate interest to do so as this helps make our products or services more relevant to you.

To build a buying profile of what you like, and to inform our business decisions, we will combine data captured from your instore visit and data from publicly-available lists as we have described in the section ‘How and why we process your personal data’ We will do this on the basis of our legitimate business interest.

For example, by combining this data, this will help us personalise your experience and decide which inspiration or content to share with you. We also use anonymised data from customer purchase histories to identify trends. This may then guide us to ascertain which products you are most likely to be interested in.

To process your appointment requests (for example for bespoke made-to-order jewellery orders). Sometimes, we will need to discuss your order requirements and timescales with our production team overseas and for customers placing orders in Pakistan we may need to share your details with a courier company to deliver your order. We may also need to reschedule your appointment on another day. We do so to maintain our appointment with you. Without storing your personal data, w would be unable to fulfil your request.

Parties that may process your personal data

We will share your personal data with third parties only in the ways set out in this Policy Notice or set out at the point when the personal data is collected. We consider your personal data to be a vital part of our relationship with you. We do not sell your personal data to third parties, including to third-party advertisers.

Legal Requirement

We may use or disclose your personal data in order to comply with a legal obligation, in connection with a request from a public or government authority, or in connection with court or tribunal proceedings, to prevent loss of life or injury, or to protect our rights or property. Where possible and practical to do so, we will tell you in advance of such disclosure.

Service Providers and Other Third Parties

We use a variety of third party service providers to deliver and help us improve our products and services. Service providers may be within or located outside the EEA. We may share your personal data with marketing agencies acting as processors, courier companies acting as controllers, backup and disaster recovery service providers, email service providers and others but only to maintain and improve our products and services.

Data Aggregation and Analytics

We may collate your personal data you provide to us or we collect and use it anonymously for analytics, benchmarking and to effectively monitor the website and improve your user experience.

Third Party Cookies

Swavo allows selected Third Parties who participate with us in marketing programs to place cookies when you visit our site. These cookies enable us to monitor which adverts you see and click on to get to our site.

For details of the Third Party cookies we use please see the list below. Swavo is not responsible for the content or privacy policies of Third Parties or other websites, and we advise that you check these yourself.

The following Cookies are all used for Analytical and Targeting purposes:

Google Tag Manager

Google Analytics

GA Audiences

Facebook Custom Audiences

Facebook Pixel Code

Contacting the Regulator

If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.

You can contact them by calling 0303 123 1113.

Or go online to www.ico.org.uk/concerns (opens in a new window; please note we can’t be responsible for the content of external websites)

If you are based outside the UK, you have the right to lodge your complaint with the relevant data protection regulator in your country of residence. Details can be found in Section 16.

Jurisdiction

This Privacy Policy complies with the “European Data Protection Legislation” and is defined as, for the periods in which they are in force, the European Data Protection Directive 95/46/EC, all laws giving effect or purporting to give effect to the European Data Protection Directive 95/46/EC (such as the Data Protection Act 1998) or otherwise relating to data protection (to the extent the same apply) and, from 25 May 2018, the General Data Protection Regulation (Regulation (EU) 2016/670) (GDPR) or any equivalent legislation amending or replacing the GDPR which regulates treatment of personal data – including data stored abroad – effected by anyone who resides or has a business office in United Kingdom/Europe.

The code guarantees that the processing of personal data must be conducted in accordance with the fundamental rights and liberties as well as the dignity of the person, with particular reference to confidentiality, personal identity and the right to protection of personal data.

Your rights under GDPR

You have a right to access the personal data that we hold on you. If you would like to see a copy please send a £10 fee and a written request to the Group Data Protection Manager at Head Office, quoting Security and Privacy Enquiry. If you think the information we hold on you is incorrect please contact the Group Data Protection Manager at Head Office or via privacy@swavobridal.com, quoting Security and Privacy Enquiry.

The GDPR provides the following rights for individuals:

The right to be informed

The right of access

The right to rectification

The right to erasure

The right to restrict processing

The right to data portability

The right to object

Rights in relation to automated decision making and profiling

You can find further detail explanation of your rights under GDPR by visiting: Right to be informed

Head Office Contact Details

Group Data Protection Manager
Swavo via Myra Trading Ltd
914 Leeds Road,
Bradford,
West Yorkshire
BD3 8EZ

Variations and updates of this Privacy Notice

Swavo may modify or simply update this site Privacy Notice, in part or completely, even owing to variations of the laws and regulations that govern this matter and protect your rights.

Such variations and updates of the Privacy Notice will be notified to users on the Home Page as soon as they are introduced and will be binding as soon as published on the web site. We therefore invite you to visit this section often to read the most recent and updated version of this Privacy Notice.

Opt Out

Website visitors who don’t want their data used by Google Analytics can install the Google Analytics opt-out browser add-on. To opt-out of Analytics for the web, visit the Google Analytics opt-out page and install the add-on for your browser. Learn more about the opt-out and how to properly install the browser add-on here.

Visitors can also opt-out of Google Analytics for Display Advertising and customize Google Display Network ads using the Ads Settings.

Customers can also opt out of our mailing list by clicking the unsubscribe option.

Contact

Should you need to contact us please write to:

Data Protection Officer Swavo, 914 Leeds Road, Bradford, West Yorkshire, BD3 8EZ, UK or email us: privacy@swavobridal.com quoting Security and Privacy Enquiry.