www.asprey.com is operated by Asprey London Limited (Asprey). This policy is in line with GDPR and the Data Protection Act 2018 and the data controller is Asprey London Limited of 36 Bruton Street, Mayfair, London, W1J 6QX, United Kingdom. We are registered in England and Wales under company number 1004355. Our VAT number is GB 238 48 31 46.
Asprey is the “data controller” for the purposes of data protection law. We are committed to ensuring your privacy is protected and we want to fully inform you on how your data is used.
Lawful reasons for using your personal data
We collect and use information about you to ensure that we can continue to provide you with a luxury retail experience. You provide us with your information directly when you make a purchase in store, online or sign up to the Asprey newsletter.
We may collect and process the information that you provide us when completing forms on our site www.asprey.com (our site) or making a purchase in one of our stores. This includes information provided at the time of registering to use our site, subscribing to our service, posting material or requesting further services. Similarly, if you contact us, we may keep copies of that correspondence.
There are a number of reasons as to why we may collect and use your personal data which the law on data protection allows us to, including:
We will always request your consent when we collect and process your personal data
For example, when you sign up to receive our newsletters, you will need to tick the opt-in box
· Contractual obligations
In order for us to fulfil our contractual obligations to you, we will need to use your personal data
For example, for us to deliver a product to you we will need your personal data including name and address
· Legal or regulatory obligation
For example, we will need to pass and process your personal data to law enforcement if there is any involvement in fraud or criminal activity
· Legitimate Interests
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
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 do so.
Please note that we may process your personal data without your knowledge or consent, where this is required or permitted by law.
For example, we may send you promotional offers based on your past purchase history
What personal data do we collect?
We may collect the following information about you:
· Personal data including name, job title and company name
· Contact data including email address, telephone number, postal address and postcode
· If you connect, comment or provide feedback on our social media channels including Instagram, Facebook, Twitter and LinkedIn we will see your username
When you make a purchase at any of our retail outlets or online, we will collect necessary information about you to ensure we can fulfil your order or chosen service.
If you choose to pay by card, we will need to collect your payment information to process card payments. We may also need to ask for additional information from you, e.g. to prevent fraudulent transactions, to comply with anti-money laundering obligations for high value transactions. Where you place an order with Asprey for products or services that will be delivered, collected, or provided later, we will need to take additional contact details and delivery information from you so that we may complete your order. We may use third party couriers to deliver your order and will need to share your contact information with them for this purpose.
Details of your visits to our site including, but not limited to traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access, may also be recorded.
There are various reasons for this. Asprey must ensure that content from our site is presented in the most effective manner for you and for your computer. It also enables us to carry out our obligations under any contract that you and Asprey enter.
We will use the information we collect about you to provide you email with information, products or services that you request from us or which we feel may interest you, to notify you about changes to our service or for marketing purposes.
· IP addresses
We may collect information about your computer, including where available your IP address, operating system and browser type and for system administration. This is statistical data about our users' browsing actions and patterns and does not identify any individual.
For the same reason, we will obtain information about your general internet usage by using a cookie file which is stored on your browser or the hard drive of your computer.
Cookies are small files stored on your computer or other device when you visit certain web pages. For more information on cookies, please visit www.aboutcookies.org(this link opens in a new window). Please note that Asprey cannot be held responsible for the content of external websites.
This cookie enables the add-to-bag and shopping basket functionality of the Asprey site. The site will not operate correctly without it.
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These cookies are required by the Google Analytics service that anonymously tracks user behaviour and statistics. This information enables us to improve the Asprey website for visitors.
This cookie anonymously registers the broad geographical location (country level) of visitors so as to enable the site to display location appropriate content and the correct currency.
These cookies are required by the Klaviyo service that anonymously tracks user behaviour and statistics. This information enables us to improve the Asprey website for visitors.
You may adjust the settings in your browser to prohibit the setting of cookies. If you do so, our website will not work correctly for you. You will not be able to add products to your shopping basket. You will be able to use the site to browse products for research.
For information on how to change your browser’s cookie settings, follow the links related to your browser below (these links open in a new window). Please note that Asprey cannot be held responsible for the content of external websites.
For other browser software, you should consult the relevant online help information or documentation supplied with the product.
· Web Beacons
Web beacons, also known as “clear gifs,” “one-pixel gifs,” “web bugs,” “Internet tags” or “pixel tags,” are small graphic images on a website or in an e-mail that allow us and third parties to monitor the activity on our site or to make cookies more effective. Web beacons allow us, or third parties working on our behalf, to gauge and enhance the effectiveness of our marketing by transmitting information about whether you follow links in our e-mails or website, and by gathering information about the sites you visit before and after visiting our website. We use log files to store the data that is collected through Web beacons.
How do we collect your personal data?
We use a number of methods to collect data from you and about you including:
· New customer account forms
· Product enquiries via the website, on email or by phone
· Visiting us at an exhibition or show or exchanging business cards
· Engaging with us on social media
· Purchasing a product from us
· Opting in to receive our newsletter
· When you have given a third party the permission to share with us the information they hold for you, for example an authorised Asprey salesperson has requested a direct shipment to you as a customer of that dealer
How and why do we use your personal data?
At the time of providing personal data, we will advise you why we are collecting it and how it will be used. At any time, you can change how you wish us to use your data.
How and why we use your data include:
· To set you up as a new customer and commence trading
· To deliver or service products to you
· To respond to any product enquiries or issues
For example, you may get in touch by phone, email or website. In order for us to find out details of the issue and help identify the solution, we will need to follow up by contacting you directly. We may also pass your details internally within Asprey to ensure the correct person can deal with your enquiry.
· To send you communication via email, newsletters and other important business information
We will only send marketing communication if you have actively opened communications in the last year or you have opted-in to receive communications.
For example, we will send newsletters that include product updates, new products and launches.
You are free to opt-out at any point; the unsubscribe link is available at the bottom of all emails sent out.
Please note that if there is a legitimate business reason for us to communicate with you and to ensure we can fulfil our contract with you, we may 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, price changes, corporate updates, amendments to our Terms & Conditions and legally required information relating to your orders. These Essential Business Information emails will not include any promotional content and do not require prior consent when sent by email. If we do not use your personal data for these purposes, we would be unable to comply with our legal obligations.
· To follow up any comments or queries that you have left on one of our social media channels
· To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
We want to provide our customers with relevant information about products that are of interest whilst providing great customer service. We will monitor which web pages are most visited and build our marketing strategy around this.
If you fail to provide Personal Data that we have requested either under the terms of contract with you or required by law, we may not be able to perform the contract we have or are trying to enter with you, for example provide you with products or services. In this case, we would notify you that we may have to cancel a product or service you have with us.
Protecting your personal data
Asprey has several GDPR compliant processes and procedures as follows:
· All key Asprey employees have received training in GDPR and how to handle your personal data
· Access to your personal data is restricted to the relevant employees/departments that are required to process your data
· Where hard copies are created, these are securely kept.
· According to each business unit’s process and procedure, your personal data will be periodically reviewed and securely deleted if required
· All personal information is transferred by secure email to secure servers on site, to which access is granted only to key personnel.
How long will we keep your personal data for?
By law we have to keep basic information about out customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances, we may anonymise your personal data, which means it can no longer be associated with you, for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Who will we share your personal data with?
We will sometimes need to share your personal data with our trusted third parties, these can include:
· Delivery couriers including, but not limited to, Fedex, DHL, Royal Mail and pallet carriers
· Service engineers
· HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances
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 and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Your legal rights over your personal data
You have the rights under the data protection laws in relation to your personal data including:
· Request access to your personal data (commonly known as a ‘data subject access request’). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
· Request correction of the personal data that we hold about you. This enables you to have any incomplete or out of date data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
· Request erasure of your personal data .This enables you to ask us to delete or remove personal data where there is no Business or legal reason for us continuing to process it.
· Object to processing of your personal data where we are relying on a Legitimate Interest (or those of a third party) and there is something about your situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.
· Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if 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 data but we need to verify whether we have overriding legitimate grounds to use it.
· Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
· Withdraw consent any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.
Please email us on requesting for Data Subject Access Request if you wish to exercise any of these rights.
· No fee in most cases – You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. There is the possibility that we will refuse to comply with your request in these circumstances.
· What we may need from you – to protect your personal data we will ask you to verify your identity before proceeding with your request 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 has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
If you have authorised a third party to submit a request on your behalf, we will request proof that they have your permission to do so.
· Time limit to respond - We will respond to all legitimate requests within 1 month from the date of receipt of your request. Occasionally, it may take us longer if your request is particularly complex or if you have made a number of requests. In this case, we will notify you and keep you updated. Where you are sending us a request via post rather than email, we recommend you send it via recorded delivery to guarantee safe delivery.
We take any complaints about our collection and use of personal information very seriously.
If you think that our collection or use of personal information is unfair, misleading or inappropriate, or have any other concern about our data processing, please raise this with us in the first instance.