PRIVACY POLICY

Last Updated November 2021

We at Rodd & Gunn UK Limited (“Rodd & Gunn,” “we,” “us,” or “our”) have created this privacy policy (this “Privacy Policy”) to explain how information you provide to us is used and shared. We are the controller of the Personal Information that is processed in accordance with this Privacy Policy. Our registered company address is Highland House Mayflower Close, Chandler's Ford, Eastleigh, Hampshire, England, SO53 4AR. We are a registered controller with the UK Information Commissioner’s Office (“ICO”) with number ZA865109.

This Privacy Policy relates to our information collection and use practices in connection with our website located at https://roddandgunn.com/uk (our “Site”), and through our mobile application (our “App” and, collectively with the Site, the “Platform”). Capitalized terms not defined in this Privacy Policy shall have the meaning set forth in our Terms of Use.

If You Withhold Provide Personal Data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

What Personal Information About Customers Do We Gather?

In the course of operating the Platform, we will collect (and/or receive) the following types of information. You authorize us to collect and/or receive such information.

Personal Information

We do not collect Personal Information from you unless you voluntarily provide it to us (including by contacting us through the Platform). For purposes of this Privacy Policy, “Personal Information” means information that identifies you or can be used to identify or contact you, such as your name, e-mail address, physical address and telephone number.

Billing Information

In order to process transactions for products through the Platform, you will be required to provide certain information in addition to the Personal Information noted above. Such information may include a debit card number, credit card number, expiration date, bank account information, billing address, activation code, and similar information (collectively, the “Billing Information”). Such Billing Information will be collected and processed by our third-party payment processors pursuant to the terms and conditions of their privacy policies and terms of use, and we do not obtain access to any Billing Information in connection with such transactions.

Transaction Information

We log all data regarding transactions conducted via the Platform, such as what was purchased, when, the purchase price, and similar data (collectively, the “Transaction Information”). We may correlate such Transaction Information with the Personal Information.

Other Information

In addition to Personal Information, Billing Information, and Transaction Information, we may collect additional information (collectively, the “Other Information”). Such Other Information may include:

From You

Additional information about yourself that you voluntarily provide to us (e.g., via a survey or questionnaire), such as gender, product and service preferences, and other information that does not identify you personally.

From Your Activity

Information that we automatically collect when you use the Platform, including, without limitation:

• IP addresses, which may consist of a static or dynamic IP address and will sometimes point to a specific identifiable computer or device; browser type and language; referring and exit pages and URLs; access date and time; amount of time spent on particular pages; what sections of the Platform you visit;
• Information about a mobile device, including universally unique ID (“UUID”), platform type and version (e.g., iOS or Android), carrier and country location, hardware and processor information (storage, chip speed, camera resolution, NFC enabled, and network type (WiFi, 2G, 3G, 4G); and
• Activity and usage information occurring via the Platform, including content that a user views and the duration and sequence of such viewing; in-site purchases; survey responses; preferences; session lengths; and similar data.

From Cookies

Information that we collect using “cookie” technology. Cookies are small packets of data that a Platform stores on your computer’s or mobile device’s hard drive so that your computer will “remember” information about your visit. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer until you delete them) to help us collect Other Information and to enhance your experience using the Platform. If you do not want us to place a cookie on your hard drive, you may be able to turn that feature off on your computer or mobile device. Please consult your Internet browser’s documentation for information on how to do this and how to delete persistent cookies. However, if you decide not to accept cookies from us, the Platform may not function properly.

Third-Party Analytics

We use third-party analytics services (such as Google Analytics) to evaluate your use of the Platform, compile reports on activity, collect demographic data, analyse performance metrics, and collect and evaluate other information relating to the Platform and mobile and Internet usage. These third parties use cookies and other technologies to help analyse and provide us the data.

For more information on Google Analytics, including how to opt out from certain data collection, please visit https://www.google.com/analytics. Please be advised that if you opt out of any service, you may not be able to use the full functionality of the Platform.

Purposes for Which we May use your Personal Information

We may use your Personal Information for the following purposes:

• Where we have a legitimate interest (for example, administering our business and website; keeping the Platform, our products and our services relevant; and making suggestions about products or services that you might be interested in, to grow our business).
• Where we are performing a contract with you (for example, where we register you as a customer or process your order).
• Where we have a legal obligation to process your Personal Information (for example, to protect our business or comply with an order of court or other competent authority).
• Where we have obtained your consent.

Information Collected by or Through Third-Party Companies

We may share Other Information about you with third parties for ad distribution and ad optimization (defined as the tailoring, targeting (i.e., behavioural, contextual, and retargeting), analysing, managing, reporting, and optimizing of ads). These third parties may use cookies, pixel tags (also called web beacons or clear gifs), and/or other technologies to collect such Other Information for such purposes. Pixel tags enable us, and these third-parties, to recognize a browser’s cookie when a browser visits the site on which the pixel tag is located in order to learn which advertisement brings a user to a given site. In addition, we may receive Other Information from advertisers and/or their service providers such as advertising identifiers, IP addresses, and post-conversion data.

How Do We Share The Information We Receive?

We may share your Personal Information with third parties as set out below.

For Transactions:

In order to process transactions for any purchase you make through our Platform, we may need share your Personal Information, Billing Information and Transaction Information with our suppliers, third party payment processors and product manufacturers.

Businesses and Individuals:

We work closely with other businesses and individuals, and we may share information about you with those businesses and individuals. We may also from time to time share Personal Information, Transaction Information, and/or Other Information with other companies who may provide you information about the products and services they offer. However, to the extent required by law, you will be given the opportunity to opt-out of such sharing.

Third-Party Service Providers:

We may employ other companies and individuals to perform functions on our behalf. Examples include providing Platform services, fulfilling orders, delivering packages, sending postal mail and e-mail, processing credit card payments, and providing customer service. These Service Providers have access to the Information as needed to perform their functions, but may not use it for other purposes.

Improving our Platform:

In an ongoing effort to better understand our users and our Platform, we may analyse Information in aggregate form in order to operate, maintain, manage, and improve the Platform. This aggregate information does not identify you personally. We may share this aggregate data with our affiliates, agents, and business partners. We may also disclose aggregated user statistics in order to describe our products and services to current and prospective business partners and to other third parties for other lawful purposes.

With Our Affiliates:

We may share some or all of your Information with any of our parent companies, subsidiaries, joint ventures, or other companies under common control with us.

Business Transfers:

As we continue to develop our business, we might sell or buy stores, subsidiaries, or businesses . In such transactions, your Personal Information generally is one of the transferred business assets.

Our Protection and Protection of Others:

We release account and other personal information when we believe release is appropriate to comply with the law; enforce or apply our Terms of Use, Privacy Policy and other agreements; or protect our rights, property, or safety and those of our users, and others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction.

With Your Consent:

Where appropriate, we may obtain your consent to share your Personal Information with third parties. For example, we may post your testimonial about the Platform or our products along with your name. If you want your name and/or your testimonial removed after you’ve granted us such permission, please contact us as set forth below.

How We Protect Your Information

We take appropriate organisational and technical measures to protect the Information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases, nor can we guarantee that the information you supply will not be intercepted while being transmitted to and from us over the Internet. In particular, e-mail sent to or from the Platform may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail.

How Can You Stop the Use of Your Personal Data for Direct Marketing?

There are several ways you can stop marketing communications from us:

• Update or Edit your preferences at anytime through our Data Consent Manager on the website in line the UK GDPR and other applicable UK data protection laws.
• Click the ‘unsubscribe’ link in any email communication that we send you. We will then stop any further emails from that particular division.
• Contact elodge@roddandgunn.com and request the deletion of your contact information.
• Write to Group Customer Insight (Customer Data), Partnership House, 1st Floor, Carlisle Place, London SW1P 1BX.
• Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated.

Automated Decision-Making

We do not process your Personal Information for the purposes of automated decision-making (including profiling).

International Transfers

We may transfer your Personal Information outside the UK. Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your Personal Information to countries that have been deemed to provide an adequate level of protection for such information.
• We may use specific contracts approved for use in the UK which give your Personal Information the same protection it has in the UK.

Please contact us via the contact details below if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

How Long We Retain Your Data

We will only retain your Personal Information for as long as is reasonably necessary for the various purposes set out in this policy or to otherwise comply with any applicable laws and regulations concerning the mandatory retention of certain types of information. To determine the appropriate retention period for Personal Information, we consider the amount, nature and sensitivity of the Personal Information, the potential risk of harm from unauthorised use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

If you would like further information on how long we retain your Personal Information, please contact us using the details set out below.

Your Data Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Those rights include the following:

• Request access to your Personal Information (commonly known as a "data subject access request").
• Request correction of the Personal Information that we hold about you.
• Request erasure of your Personal Information. This enables you to ask us to delete or remove Personal Information where there is no good reason for us continuing to process it.
• Object to processing of your Personal Information where we are relying on a legitimate interest (or those of a third party).
• Request restriction of processing of your Personal Information.
• Request the transfer of your Personal Information to you or to a third party.
• Withdraw consent at any time where we are relying on consent to process your Personal Information.

Important Notice to Non-U.K. Residents

The Platform is operated in the United Kingdom. If you are located outside of the United Kingdom, please be aware that any information you provide to us will be transferred to and processed in the United Kingdom.

Children

We do not knowingly collect Personal Information from children under the age of 13 through the Platform. If you are under 13, please do not give us any Personal Information. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children to never provide us Personal Information without their permission. If you have reason to believe that a child under the age of 13 has provided Personal Information to us, please contact us, and we will endeavour to delete that information from our databases.

External Sites

The Platform may contain links to third-party websites. We have no control over the privacy practices or the content of any of our business partners, advertisers, sponsors, or other websites to which we provide links. As such, we are not responsible for the content or the privacy policies of those third-party websites. You should check the applicable third-party privacy policy and terms of use when visiting any other websites.

Changes to This Privacy Policy

This Privacy Policy is effective as of the date stated at the top of this Privacy Policy. We may change this Privacy Policy from time to time and will post any changes on the Platform as soon as they go into effect. Please refer back to this Privacy Policy on a regular basis.

How to Contact Us

If you have questions about this Privacy Policy, please e-mail us at elodge@roddandgunn.com. If you have any questions, comments or concerns, or would like to make a complaint about how we use the personal information we hold about you, please email, or write to, our Privacy Team, or contact the relevant Data Protection Officer for your country. You may contact our UK Data Protection Officer at elodge@roddandgunn.com. If you are not satisfied with our response, you can contact the competent supervisory authority in the UK (the UK Information Commissioner’s Office or “ICO”) at https://ico.org.uk/make-a-complaint/ or by phone (0303 123 1113).

Copyright 2021 Rodd & Gunn UK Limited. All rights reserved.