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PRIVACY POLICY

  1. Introduction

Last Updated: April 2018


WTR is committed to respecting your privacy and complying with applicable laws and regulations to ensure that the personal information you give us is kept appropriately secure and processed fairly and lawfully.


We will treat all your personal details as confidential and we will only disclose this information in the circumstances set out below. We will keep it on a secure server and we will comply with the Data Protection Act 2018 (the 'Act') in relation to the use of your personal data. When you register on this Website, or make a purchase, we will ask you to input and will collect personal details from you such as your name, email address, username, password, telephone number, billing and delivery address(es) and payment details. We may also collect, and our third-party providers may collect, information about where you are on the Internet (e.g. the URL you came from, IP address, domain types like .co.uk and .com), your browser type, the country and telephone area code where your computer is located, the pages of our Website that were viewed during your visit, any advertisements you may have clicked on, and any search terms that you entered on our Website. We confirm that any personal details which you provide to us (or which are available on public registers) and any user information, from which we can identify you, is held in accordance with the registration we have with the Information Commissioner’s Office (registration no. ZA108065). For the purposes of the Act, the data controller is WTR, 188 Westbourne Grove, London, W11 2RH.


This Privacy Policy covers all personal information about you that we collect, use and otherwise process in connection with your relationship with WTR as a customer or potential customer. WTR will collect and use your personal information as described in this Privacy Policy and as permitted by applicable laws, including in circumstances where: (i) it is necessary to provide or fulfil a service requested by or for you; (ii) you have given us your express consent; or (iii) it is necessary for one or more of the following legitimate interests pursued by WTR:


• To analyse, profile and monitor customer patterns and better understand the interests and preferences of our key customer audiences so we can consistently improve our products and services.


• To offer an enhanced customer experience and service, including by ensuring we personalise the Site and WTR updates relating to products, services and events to make them more relevant to our customers’ specific preferences.


• To ensure the proper functioning and security of our services, Site and Application, for example by preventing fraudulent transactions.


• To ensure we continue to comply with applicable laws, for example in maintaining the accuracy of our records




  1. What Personal Information We Collect And How We Use It

When you register for an account with us (whether online or in-store), place an order, interact with our digital content on your computer or mobile device, visit our WTR store, request an in-store service or send us an enquiry, we will collect certain information from you. We will indicate whether this collection involves personal information and, if it does, whether providing your personal information is voluntary or mandatory for the service. Please be aware that where collection is mandatory, we may not be able to provide the relevant products or services to you if you do not provide that information to us.  Please look at the different sections of this Privacy Policy to learn more about what personal information we collect and how we use it.



ACCOUNT MANAGEMENT AND CUSTOMER PROFILE INFORMATION 

We may collect the following information:  your name, postal address, phone numbers, e-mail addresses, credit card numbers and other payment information. You acknowledge that we may also obtain information about you as a result of authentication or identity checks (for example in connection with our standard fraud checks when you make a purchase on our Site). We use this information to identify you as a customer, to process your order, to deliver products and services, to process payments, to update our records and to generally manage your account with us under our terms with you.  Providing us with personal information is voluntary but we may not be able to process your order and send you the required order acknowledgement and shipping confirmation e-mails if you do not provide us with certain requested information.


Where permitted under applicable laws or with your consent (if so required by applicable laws), we may use information about how you use our Site to personalise our communications to you, tailor the content appearing on our Site and how these appear to you, so as to make the Site and our services and communications more relevant to you.


If you have a customer account (whether created online or in-store), you acknowledge that we may also collect information about the products you browse online or purchase, where you purchased the products from and other information related to your purchases or which is otherwise relevant to your customer relationship with WTR. We may also ask for your birthday and gender or you may provide us with information about yourself, your product size preferences and lifestyle interests on our Site.  We use your customer account and profile information to offer you an enhanced service according to your preferences, including by identifying relevant products, services and events which may be of interest to you, personalising your experience with WTR and to share with you information about your past purchases.


We may also use your personal information to contact you in relation to service-related matters, including, on occasion, to request and respond to feedback on your experience in-store and/or on our Site, and to assist you in relation to prospective purchases on our Site, where permitted to do so in accordance with applicable laws or if we have your consent to do so if required by applicable laws.


We may also use your personal information for our internal marketing analysis and demographic studies, together with non-personal information, to analyse, profile and monitor customer patterns so we can consistently improve our products and services and understand what may be of interest to you and other customers. This means that we can offer more personalised and integrated shopping and interactive experiences to our customers in store and on our Site.


We may supplement information we collect about you with marketing and demographic information which we receive from affiliated third-party companies, in addition to other information which is available in the public domain or which we are otherwise lawfully permitted to be provided with, in order to ensure the accuracy of our records, better understand the interests and preferences of our key customer audiences and improve our service to our customers. If you don’t want us to use your personal information in this way then you can contact us at any time to ask us to stop (see “Contacting WTR" below).


Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.



DEVICE AND LOCATION INFORMATION

We collect information about the device you are using to connect to the services on our Site. This includes the type of device you use, your internet browser, your location based on the unique identifier for your device such as an Internet Protocol address. We use this information to ensure the proper functioning and security of our Site, to optimise our services to you and to better understand how our content and services are used and their effectiveness.



SUBMISSIONS

We welcome enquiries or feedback on the products you use or might like to purchase; however, it is our policy to decline unsolicited suggestions and ideas. Notwithstanding our policy with regard to unsolicited suggestions and ideas, any inquiries, feedback, suggestions, ideas or other information you provide us (collectively, ‘Submissions’) will be treated as non-proprietary and non-confidential. Subject to the terms of our Privacy Policy, by transmitting or posting any Submission, you hereby grant us a non-exclusive, royalty-free, transferable, and fully sub-licensable right to use, reproduce, modify, adapt, publish, sell, assign, translate, create derivative works from, distribute, and display any Submission in any form, media, or technology, whether now known or hereafter developed, alone or as part of other works. You also acknowledge that your Submission may not be returned and we may use your Submission, and any ideas, concept or know-how contained therein, for any purpose including, without limitation, developing, manufacturing, distributing and marketing products.


If you make a Submission, you represent and warrant that you own or otherwise control the rights to your Submission. You further represent and warrant that such Submission does not constitute or contain software viruses, commercial solicitation, chain letters, mass mailings, or any form of ‘spam’. You may not use a false email address, impersonate any person or entity, or otherwise mislead us as to the origin of any Submission. You agree to fully indemnify us for all claims arising from your claims to any rights in any Submission.



COOKIES

Cookies are small pieces of information which are issued to your device when you visit a website and sometimes track information about your use of the website. When you enter our Site our web server sends a cookie to your device which allows us to recognise your device. By associating the identification numbers in the cookies with other customer information that you provide when for example you log-in to the Site, then we know that the cookie information relates to you. 


We use cookies, local storage and other similar technologies which may place codes on or access information from and/or about your device to elevate your user experience and the quality of our Site and service. This includes keeping track of what you have in your shopping bag, remembering you when you return to our Site, identifying how you navigate around the internet, including where you click, and which website you arrived from. We may also use cookies and other technologies to understand how parts of our Site are used, and may also partner with third party advertising networks who may use cookies in helping us display advertising that is relevant to you on other websites that you visit and to enable us to assess the effectiveness of that advertising. 


Most web browsers are initially set up to accept cookies.  You can reset your web browser to refuse all cookies or to indicate when a cookie is being sent, however, certain features of our Site may not work if you delete or disable cookies.  Some of our Service Partners (discussed below) may use their own cookies, anonymous identifiers, or other tracking technology in connection with the services they perform on our behalf.


We use Google Analytics on our Site to collect usage data, to analyse how users use the Site, and to provide advertisements to you on other websites.  For more information about how to opt out of having your information used by Google Analytics, visit https://tools.google.com/dlpage/gaoptout/


We inform you where relevant of our use of cookies and other device identifiers on arriving at our Site. You acknowledge and agree that by continuing to use our Site or services without managing your cookie and device choices and preferences, that you consent to our cookie and device identifier settings and agree that you understand our Cookies Policy. Please see the Cookies Policy for more information about cookies and other technologies which are used on our Site, including information on how you can manage your cookie choices and preferences. 



CHILDREN’S PRIVACY

You must be at least 13 years old to use our Site.  If you are under 13 or a minor in your country or state of residence, your parent or legal guardian must provide their information and agree to this Privacy Policy on your behalf and you may only access and use our Site with permission from your parent or legal guardian. We do not knowingly collect personal information from children under the age of 13 or equivalent minimum age depending on jurisdiction.  If we become aware that we have inadvertently received personal information from a child under the age of 13 or equivalent minimum age depending on jurisdiction, we will delete such information from our records.



ADVERTISING AND ONLINE TRACKING

We may allow third-party companies to serve ads and collect certain anonymous information when you visit our Site.  These companies may use non-personally identifiable information (e.g. click stream information, web browser type, time and date, subject of advertisements clicked or scrolled over) during your visits to the Site and other websites in order to provide advertisements about goods and services likely to be of interest to you.  These companies typically use a cookie to collect this information.  Our systems do not recognize browser “Do Not Track” signals, but several of our Service Partners who utilize these cookies on our Site enable you to opt out of targeted advertising practices.  To learn more about these advertising practices or to opt out of this type of advertising, you can visit www.networkadvertising.org or www.aboutads.info/choices/.  We also provide you with additional tools to opt out of marketing from us (see "Unsubscribe from WTR updates" below). 



  1. Receiving And Unsubscribing From WTR Updates

WTR UPDATES

We can only send you WTR updates about our products, services and events with your consent. If you have provided your consent, you can withdraw it at any time (see "Unsubscribe from WTR updates" below). If you have consented, we will send you WTR updates through the preferred communication method you selected.


We may also obtain personal information where you “like” us or otherwise interact with our pages on social media platforms and may in response, use this information to communicate with you or provide relevant content via those social media platforms about our products, events and promotions where permitted to do so in accordance with applicable laws. Please refer to the privacy policies of the social media platforms for information about how they collect and use your personal information.



UNSUBSCRIBE FROM WTR UPDATES

If you have registered to receive WTR updates relating to our products, services and events, and you no longer wish to receive these, you can request that we amend your preferences. You can do that either as indicated in the particular communication, e.g.by using the unsubscribe link which is included on all email updates. WTR will stop sending updates in respect of which you withdraw your consent within a reasonable period and in any event within 28 days of receiving your request, in order to allow sufficient time for the change to be administered. If you opt out of receiving WTR updates relating to our products, services and events, we may still send you non-marketing communications such as emails about your account or purchases you have made from the Site.




  1. Who We Share Your Personal Information With

In certain circumstances, we may share your personal information with selected service providers who perform functions on our behalf such as fulfilling orders, processing payments, and carrying out promotional services or data management as permitted by applicable laws or with your consent (if so required by applicable laws) as further described below (“SERVICE PROVIDERS”). Please click here for a current list of our Service Providers. We may also share aggregated or anonymised information that does not directly identify you. Please select from different sections of this Privacy Policy below to learn more about who we may share your information with and when.



SERVICE PARTNERS

We may share information about you with companies we have chosen to handle our order dispatch service, any delivery company that we may use from time to time and with other companies that provide support services to us, including website hosting companies. In addition, we may also share certain limited information with companies who assist WTR with other services, for example, in analysing our customer data in order to better understand, profile and monitor customer patterns so we can consistently improve our products and services and understand what may be of interest to you and other customers. In each case, we will only provide these companies with the information which they need to carry out their services and they will not be permitted to use the information for other purposes. They will only be allowed to use your information in the way in which we instruct them and as permitted by applicable laws.



FINANCIAL INSTITUTIONS AND PAYMENT PROCESSING PARTNERS

Payments using our Site are made through our payment solutions providers. You will be providing credit or debit card information direct to our providers who process payment details further.



LEGAL DISCLOSURES

In certain circumstances (where required or permitted under applicable laws or with your consent (if so required by applicable laws), we may disclose personal information relating to you to third parties in other jurisdictions in order to conform to any requirements of law, to comply with any legal or regulatory process, for the purposes of obtaining legal advice, for the purposes of credit risk reduction, to prevent and detect fraud and/or to protect and defend the rights and property of WTR. At all times where we disclose your information for the purposes of credit risk reduction and fraud prevention we will take all steps reasonably necessary to help ensure that it remains secure.



BUSINESS OR PROCESS CHANGE PARTNERS

In the event that we or a part of our business undergo re-organisation or are sold or licensed to a third party, any personal information we hold about you may be transferred to that re-organised entity, licensee or third party.



OVERSEAS TRANSFERS OF DATA

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (the ‘EEA’). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.




  1. Your Rights In Relation To Your Personal Information

You may have the right under applicable laws to ask for details of the personal information we hold about you, to amend, limit or delete your personal information, or ask for a copy of the personal information you gave us. You can also withdraw any consent you give to us at any time and object to us using your personal information for WTR’s legitimate purposes. 


If you would like to exercise any of these rights in relation to the personal information we hold about you or wish to change your preferences at any time, please contact our Customer Service Team at customerservices@wtrlondon.com. Please note that we may require you to verify your identity before allowing you to access your personal information.


If you have an online customer account, you can also access, amend or update your information by logging into My Account on the Site and amending your details as appropriate. If you remain unhappy with a response you receive from us you can also refer the matter to your data protection supervisory authority (see http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm).




  1. Retention And Deletion Of Personal Information

We will only keep your information as long as you remain an active customer and for 5 years afterwards or otherwise as required for our business operations or by applicable laws. We may need to retain certain personal information even once a customer account has been closed or deleted to enforce our terms, for fraud prevention, to identify, issue or resolve legal claims and/or for proper record keeping purposes. We may also retain a record of any stated objection by you to receiving WTR updates for the purpose of ensuring we can continue to respect your wishes and not contact you further. Your personal information will be deleted or destroyed in a manner that cannot be restored or reproduced.




  1. Security And Third Party Links

We take reasonable steps to protect your personal information against unauthorized or accidental access, processing, erasure, loss or use.  Unfortunately, transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information submitted to us and any transmission is at your own risk.


We do however use strict procedures and security features to try to prevent unauthorised access wherever possible. Personal information may be accessed by persons within our organization, or our third-party service partners, who require such access to carry out the purposes indicated above, or such other purposes as may be permitted or required by the applicable law.


Personal information provided to WTR via the Site and online credit card transactions are transmitted through a secure server using Secure Socket Layering (SSL), encryption technology. When the letters "http" in the URL change to "https," the "s" indicates you are in a secure area employing SSL; also, your browser may give you a pop-up message that you are about to enter a secure area or display a padlock image. The Site use this encryption technology to protect your information during data transport. SSL encrypts ordering information such as your name, address and credit card number. Our customer service centre and stores also operate over a private, secure network. Please note that e-mail is not encrypted and is not considered to be a secure means of transmitting credit card information.


We are not responsible for the content of any off-Website pages or any other websites linked to or from the Website. Links appearing on the Website are for convenience only and are not an endorsement by us, our affiliates or our partners of the referenced content, product, service, or supplier. Your linking to or from any off-Website pages or other websites is at your own risk. We are in no way responsible for examining or evaluating, and we do not warrant the offerings of, off-Website pages or any other websites linked to or from the Website, nor do we assume any responsibility or liability for the actions, content, products, or services of such pages and websites, including, without limitation, their privacy statements and Terms. You should carefully review the Terms and privacy policies of all off-Website pages and other websites that you visit.




  1. Changes To This Privacy Policy

We may update this Privacy Policy from time to time. The amended Privacy Policy will be posted on the Site. Please check this page regularly for changes to this Privacy Policy. If we make any material changes to this Privacy Policy we will notify you before they take effect either through the Site or by sending you an email.  Any such material changes will only apply to personal information collected after the revised Privacy Policy took effect.




  1. Contacting WTR

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to customerservices@wtrlondon.com. Alternatively, you can write to us at 28-30 Hanway Street, W1T 1UL, London or call us on +44 (0)207 2433 776