Privacy & Cookie Policy

Privacy & Cookie Policy

Privacy Policy

Star Street Limited is a company incorporated and registered in England and Wales with company number 11890883. Star Street Limited is the owner of the Verdi™ brand and operator of www.verdionline.com

Website Privacy Policy         Last updated on 11th August 2020

BACKGROUND:

This policy explains the types of personal data we may collect when you interact with us and how we’ll store and handle that data. The policy applies as between you, the user of this website, and Star Street Limited, the owner and provider of this website. This policy applies to our use of any and all data collected by us in relation to your use of the website and any services or systems therein. 

1.0 Important information

1.1 Our website is not intended for children and we do not knowingly collect data relating to children.

1.2 This privacy policy supplements the other policies (including our terms of use) and is not intended to override them.

1.3 Star Street Limited is the controller and responsible for your personal data (we, us or our).

1.4 To assist you further in understanding this privacy policy, we have set out in Part 5 of Schedule 1 a glossary of terms used, examples of the types of personal data we collect, how we use it, the lawful basis for processing such data and further details of your rights.

1.5 If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us in writing, either:

1.6 By email to: clientcare@verdionline.com

1.7 By post to: Star Street Limited, 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ

1.8 You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO) (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

1.9 It is important that the data we hold about you is accurate and current, therefore please keep us informed of any changes to your personal data.

1.10 Our website may include links to third-party websites, plug-ins and applications. By clicking on these links or enabling connections you may be allowing third parties to collect or share your personal data. We have no control over these third-party websites, plug-ins or applications and are not responsible for their privacy policies, therefore you should also read their privacy policy to understand what personal data they collect about you and how they use it.

2.0 The data we collect about you

2.1 We may collect, use, store and transfer the types of personal data about you listed in Part 1 of Schedule 1.

2.2 We also collect, use and share aggregated data. However, if we combine aggregated data with your personal data so that it can directly or indirectly identify you, we treat this as your personal data.

2.3 We do not collect any special categories of personal data.

2.4 If we are required by law, or under the terms of a contract we have with you, to collect your personal data and you fail to provide it, we may not be able to enter into or perform the contract with you and we may have to cancel a product or service. We will notify you of this at the relevant time.

3.0 How personal data is collected

We collect personal data in the following ways:

Direct interactions

You may provide personal data when you complete online forms, request products/services, subscribe to our services, create a user account, join our mailing list, or otherwise correspond with us (by post, phone or email).

Automated technology

We automatically collect personal data (technical and usage) when you browse or interact with our website, by using cookies, server logs and other similar technologies. We may also receive technical data about you if you visit other websites which use our cookies.

Publicly available sources 

We may collect personal data from publicly available sources such as Companies House and the Electoral Register and credit reference agencies, based inside the European Economic Area (EEA).

Third parties 

We may receive personal data from: (a) analytics providers based outside the EEA (such as Google); (b) advertising networks based inside or outside the EEA; and (c) search information providers based inside or outside the EEA; (d) our suppliers such as payment providers, delivery services, website support and maintenance providers.

4.0 How we use your personal data

4.1 We will only use your personal data when the law allows us to. Most commonly, we will use your personal data:

4.2 To perform the contract we are to enter into or have entered into with you;

4.3 To comply with a legal obligation; and 

4.4 Where it is necessary to carry out our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

4.5 Part 2 of Schedule 1 sets out the lawful basis we will rely on to process your personal data.

4.6 We do generally only rely on consent as a legal basis for processing your personal data to send email and SMS marketing communications and you have the right to withdraw your consent at any time by contacting us. Please note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your information.

4.7 We may analyse your personal data to form a view on what products and/or services we think may be of interest to you. You will only receive marketing communications from us if you have requested information from us or purchased services from us, if you consent to marketing at the time we collect your personal data and you have not subsequently opted out or withdrawn your consent, or if we have another basis to send you the marketing communications.

4.8 We will not share your personal data with third parties for their marketing purposes.

4.9 You can opt out of email marketing by clicking the unsubscribe button within the marketing email. You can also withdraw your consent to marketing at any time by contacting us in writing.

4.10 Even if you opt out of receiving marketing, we may still use your personal data for other purposes provided we have a lawful basis to do so.

4.11 We will only use your personal data for the purpose that we originally collected it for, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

4.12 If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to use your personal data in this manner.

4.13 We may process your personal data (without your knowledge or consent) where this is required or permitted by law.

4.14 By using this website, you agree to allow third parties to process your IP address, in order to determine your location for the purpose of currency conversion. You also agree to have that currency stored in a cookie on your browser. This is done in order to set up your checkout currency.

5.0 Disclosure of your personal data

5.1 We may have to share your personal data with third parties, further details of which are set out in Part 4 of Schedule 1. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes. They can only process your personal data for specified purposes and in accordance with our instructions.

6.0 International transfers

6.1 We may transfer the personal data that we collect from you to third party data processors outside the EEA. It we do, we ensure a similar degree of protection is afforded to it.

6.2 We will only transfer your personal data to countries that have been
deemed to provide an adequate level of protection for personal data by the
European Commission.

6.3 We use specific contracts approved by the European Commission which
give personal data the same protection it has in Europe with our services
providers.

6.4 We may transfer data to US based service providers under the Privacy
Shield which requires them to provide similar protection to personal data
shared between Europe and the US.

6.5 Please contact us if you want further information on the specific mechanism used by us when transferring your personal data.

7.0 Data security

7.1 We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We also limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They can only process your personal data on our instructions and will be subject to a duty of confidentiality.

7.2 We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8.0 Data retention

8.1 We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

8.2 Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us. However, we are legally required to keep basic information about our customers (including contact, identity, financial and transaction data) for six years after they cease being customers, for tax purposes.

8.3 We may also anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes. We can use anonymised information indefinitely without further notice to you.

9.0 Your legal rights

9.1 You have certain rights in certain circumstances under data protection law. These are set out in full in Part 3 of Schedule 1. If you wish to exercise any of your rights, please contact us in writing.

9.2 You will not have to pay a fee to exercise any of your rights. However, if your request is clearly unfounded, repetitive or excessive, we may charge a reasonable fee for this information or refuse to comply with your request.

9.3 We may request specific information from you to help us confirm your identity when you contact us and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who does not have the right to receive it.

9.4 We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Schedule 1: Personal Data

Part 1: Types of personal data

Contact data

Billing address, delivery address, email address and telephone number.

Financial data

Bank account and payment card details.

Identity data

First name, maiden name, last name, username or similar identifier, title, date of birth and gender.

Marketing and communication data

Your preferences in receiving marketing from us and your communication preferences.

Profile data

Your username and password, purchase or orders made by you, preferences, feedback and survey responses.

Technical data

Internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website.

Transaction data

Details about payments to and from you and other details of products and services you have purchased from us.

Part 2: Lawful basis for processing and processing activities

The lawful basis upon which we may rely on to process your personal data are:

Consent

You have given your express consent for us to process your personal data for a specific purpose.

Contract

The processing is necessary for us to perform our contractual obligations with you under our contract, or because you have asked us to take specific steps before entering into a contract with you.

Legal obligation

The processing is necessary for us to comply with legal or regulatory obligations.

Legitimate interests

The processing is necessary for our or a third party’s legitimate interest e.g. in order for us to provide the best service to you via our website. Before we process your personal data on this basis we make sure we consider and balance any potential impact on you, and we will not use your personal data on this basis where such impact outweighs our interest.

Set out below are specific details of the processing activities we undertake with your personal data and the lawful basis for doing this.

Purpose/Activity

Type of data

Lawful basis for processing 

to register you as a new customer

identity & contact

to perform our contract with you

to process and deliver your order, manage payments, fees and charges and debt recovery

identity, contact, financial, transaction and marketing & communications

(i) to perform our contract with you;

(ii) as necessary for our legitimate interest in recovering debts due to us.

to manage our relationship with you, notifying you about changes to our Terms or Privacy Policy and ask you to leave a review [or take a survey]

identity, contact, profile & marketing & communications

(i) to perform our contract with you 

(ii) as necessary to comply with a legal obligation

(iii) as necessary for our legitimate interests in keeping our records updated and analysing how customers use our products/services.

to administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)  

identity, contact & technical

(i) as necessary for our legitimate interests in running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise

(ii) as necessary to comply with any legal obligations

to deliver relevant website content/advertisements to you and measure or understand the effectiveness of our advertising 

identity, contact, profile, usage, marketing & communications & technical 

as necessary for our legitimate interests in studying how customers use our products/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

technical & usage 

as 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 make suggestions and recommendations to you about goods or services that may be of interest to you, including promotional offers

identity, contact, technical, usage & profile 

as necessary for our legitimate interests to develop our products/services and grow our business

 

Part 3: Your legal rights

You have the following legal rights in relation to your personal data:

Access your data

You can ask for access to and a copy of your personal data and can check we are lawfully processing it

Correction

You can ask us to correct any incomplete or inaccurate personal data we hold about you

Erasure

You can ask us to delete or remove your personal data where:

(a) there is no good reason for us continuing to process it;

(b) you have successfully exercised your right to object (see below);

(c) we may have processed your information unlawfully; or 

(d) we are required to erase your personal data to comply with local law 

(e) we may not always be able to comply with your request for specific legal reasons, which will be notified to you at the time of your request

Object

You can object to the processing of your personal data where:

(a) where we are relying on our legitimate interest (or those of a third party) as the basis for processing your personal data, if you feel it impacts on your fundamental rights and freedoms;

(b) where we are processing your personal data for direct marketing purposes

(c) in some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms, and, in such circumstances, we can continue to process your persona data for such purposes

Restrict processing

you can ask us to us to suspend or restrict the processing of your personal data, if:

(a) you want us to establish the accuracy of your personal data;

(b) our use of your personal data is unlawful, but you do not want us to erase it;

(c) you need us to hold your personal data (where we no longer require it) as you need it to establish, exercise or defend legal claims; or

(d) you have objected to our use of your personal data, but we need to verify whether we have overriding legitimate grounds to use it

Request a transfer

you can request a transfer of your personal data which is held in an automated manner and which you provided your consent for us to process such personal data or which we need to process to perform our contact with you, to you or a third party. We will provide your personal data in a structured, commonly used, machine-readable format

Withdraw your consent

you can withdraw your consent at any time (where we are relying on consent to process your personal data). This does not affect the lawfulness of any processing carried out before you withdraw your consent


Part 4: Third Parties


Service providers

acting as processors or controllers based in the EEA but also around the world who provide services and IT and system administration services

Professional advisors

including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services

HM Revenue & Customs, regulators and other authorities

based in the EEA who require reporting of processing activities in certain circumstances

Third parties

third parties whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy


Part 5: Glossary

Aggregated data

Information such as statistical or demographic data which may be derived from personal data, but which cannot by itself identify a data subject.

Controller

A body that determines the purposes and means of processing personal data.

Data subject

An individual living person identified by personal data (which will generally be you).

Personal data

Information identifying a data subject from that data alone or with other data we may hold but it does not include anonymised or aggregated data.

Processor

A body that is responsible for processing personal data on behalf of a controller.

Special categories of personal data

Information about race, ethnicity, political opinions, religious or philosophical beliefs, trade union membership, health, genetic, biometric data, sex life, sexual orientation.

ICO

Information Commissioner’s Office, the UK’s supervisory authority for data protection issues.

Changes to this policy

Star Street Limited reserves the right to change this privacy policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the website and you are deemed to have accepted the terms of the policy on your first use of the website following the alterations.

 

Cookie Policy

What are cookies?

Our website uses cookies. Cookies are text files placed on your computer, phone or tablet to collect standard Internet log information and visitor behaviour information to help us improve your experience. When you visit our website, we may collect information from you automatically through cookies or similar technology.

There are two types of cookies. 

Session cookies - these are temporary files that are deleted when you close your browser.

Persistent cookies - these are files that remain on your device after you’ve finished browsing so that your preferences are remembered the next time you visit the site. These remain on your device unless you manually delete them or your browser deletes them based on the duration period contained within the file.

How do we use cookies?

We use cookies in a range of ways to improve your experience on our website. These are either first-party cookies, that are put on your device directly by our website; or third-party cookies, that are placed on your device by a third party like an analytic system or advertiser.

Strictly necessary cookies - These cookies are essential for you to browse our website and use its features. This includes accessing secure areas of the site and allowing the web shop to hold your items in your cart while you are shopping online.

Functionality cookies - We use these cookies so that we recognise you on our website and remember your previously selected preferences. These could include what language you prefer and location you are in.

Performance cookies - These cookies are used to improve website functions and collect information about how our site is used, such as which pages were visited and the number of visitors. None of this information can be used to identify you. It is all aggregated and, therefore, anonymised. This includes cookies from third-party analytics services.

Marketing cookies - These cookies track your visit to our website such as the pages you visited, allowing us to link to social media networks. These cookies can share that information with other organizations or advertisers. These are persistent cookies and from a third-party.

You can find more information about the cookies we use and their function in the table below:

Cookie                                                         Function

_gat Google analytics cookie, used to throttle the request rate - limiting the collection of data on high traffic sites.
_fbp Facebook cookie to track the visitor across devices and marketing channels and deliver advertisement products.
_shopify_sa_p Shopify analytics relating to marketing & referrals.
_shopify_s Shopify analytics.
_s
Shopify analytics.
cart_sig Used in connection with checkout.
_gid Google analytics cookie, used to distinguish users.
_orig_referrer
Used in connection with shopping cart.
secure_customer_sig Used in connection with customer login.
_landing_page Used to track landing pages.
_ga Google analytics cookie, used to distinguish users.
_shopify_sa_t Shopify analytics relating to marketing & referrals.
_cfduid Used to protect site from malicious traffic.
shopify_pay_redirect Used for the secure checkout and payment function.
_shopify_sa_p Shopify analytics relating to marketing & referrals.
_y Shopify analytics.
cart_currency Used to recognise the user's country of origin.
_shopify_fs Shopify analytics.
_shopify_y Shopify analytics.
_pin_unauth Used by Pinterest to track the usage of services.
zHello Used by Zonos to recognise the user's country of origin.
zCountry Zonos analytics.
exemptify Used by Exemptify to recognise the user's country of origin.

 

How to manage cookies

You can choose to enable or disable cookies in your web browser. By default, your browser will usually accept cookies, however this can be altered. For further details please consult the help menu in your browser. In some cases, should you choose to remove or disable cookies, certain website features may not function as a result.

For further information on controlling, understanding and deleting cookies, please visit www.allaboutcookies.org

Further enquiries

If you have any comments regarding this policy please direct them to clientcare@verdionline.com

This policy was last updated on 27th April 2020.