Privacy Policy


Welcome to Swoon’s Privacy and Cookies Policy.

Sourceable Limited (the company which operates Swoon) respects your privacy and is committed to protecting your personal data. This privacy notice will tell you how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

This privacy notice is provided in a layered format so you can click through to the specific areas set out below. Alternatively you can download a pdf version of the policy here.


    1. IMPORTANT INFORMATION AND WHO WE ARE

    2. THE DATA WE COLLECT ABOUT YOU

    3. HOW IS YOUR PERSONAL DATA COLLECTED

    4. HOW WE USE YOUR PERSONAL DATA

    5. DISCLOSURES OF YOUR PERSONAL DATA

    6. INTERNATIONAL TRANSFERS

    7. DATA SECURITY

    8. DATA RETENTION

    9. YOUR LEGAL RIGHTS


1. IMPORTANT INFORMATION AND WHO WE ARE

PURPOSE OF THIS PRIVACY NOTICE

This privacy notice aims to give you information on how Sourceable Ltd collects and processes your personal data, including any data you may provide through this website when you register on our website, buy products or services from us, or otherwise contact us. This notice also explains how Sourceable Ltd may use data about you that it receives from third parties.

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

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

CONTROLLER

Sourceable Ltd is the controller and responsible for your personal data. The company may be called “Swoon”, “we”, “us” or “our” in this privacy notice. Sourceable Ltd is a company incorporated in England under company number 07714150. Our registered office is at 6 Playhouse Court, London SE1 0AT.

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

CONTACT DETAILS

Our full details are:

Full name of legal entity: Sourceable Ltd

Name or title of data privacy manager: Adam Woodhouse

Email address: privacy@swooneditions.com

Postal address: 6 Playhouse Court, London SE1 0AT

Telephone number: 020 3319 6332

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (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.

CHANGES TO THE PRIVACY NOTICE AND KEEPING YOUR DATA UP TO DATE

This version of our privacy policy was last updated on the 17th May 2018. If you need to see a copy of an earlier version, please contact us.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

THIRD-PARTY LINKS

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.


2. THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

We also collect, use and share Aggregated Data such as statistical or demographic data. Aggregated Data may be derived from your personal data but the law does not consider it personal data because this data does not reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

IF YOU FAIL TO PROVIDE PERSONAL DATA

If we need to collect personal data to be able to fulfil a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract. In that case, we may have to cancel a product or service you have ordered but we will notify you if this is the case at the time.


3. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our Cookies Policy for further details.

Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:


4. HOW WE USE YOUR PERSONAL DATA

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

We explain more about the lawful basis for using your data in the table below.

Generally we do not rely on consent as a legal basis for processing your personal data other than if a third party collects consent on our behalf for us to send email marketing communications to you. You have the right to opt out from receiving marketing materials at any time by Contacting Us.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

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 data. Please Contact Us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity

Type of data

Lawful basis for processing

To register you as a new customer

(a) Identity

(b) Contact

Performance of a contract with you

To process and deliver your order including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you which will include:

(a) telling you about changes to our terms or privacy policy

(b) asking you to leave a review or take a survey

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To enable you to take part in a prize draw, competition or complete a survey

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

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

(a) Identity

(b) Contact

(c) Technical

(a) Necessary for our legitimate interests (for 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)

(b) Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

Necessary for our legitimate interests (to study 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

(a) Technical

(b) Usage

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

(a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

Necessary for our legitimate interests (to develop our products/services and grow our business)

In this table:

Legitimate Interest means we use your personal data to conduct and manage our business in a way that enables us to give you the best service/product and the best and most secure experience. In doing that, we make sure we consider and balance any potential impact on you (both positive and negative) and your rights. We do not use your personal data for activities where our interests are overridden by the impact using your data might have on you (unless we have your consent or are otherwise required or permitted to by law).

Performance of Contract means we are processing your data because it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means we need to process your personal data to comply with a legal or regulatory duty that applies to us.

MARKETING

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

PROMOTIONAL OFFERS FROM US

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what products, services and offers may be of interest to you. This is part of our marketing strategy.

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotional discount and, in each case, you have not opted out of receiving that marketing.

If you do not want to receive promotional offers from us, you can opt out at any time. See OPTING OUT below.

OPTING OUT

You can ask us to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by Contacting Us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

COOKIES

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookies Policy (below).

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, in compliance with the above rules, where this is required or permitted by law.


5. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

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.


6. INTERNATIONAL TRANSFERS

Your personal data will be transferred to recipients located outside the European Economic Area. We will ensure that all such transfers take place in accordance with the applicable data protection laws, including by entering into data transfer agreements with recipients where necessary. If you would like more information about how your personal information may be transferred, please Contact Us.


7. DATA SECURITY

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. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who need to access that data for business purposes. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures 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. KEEPING DATA

We will only keep 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.

By law we have 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.

In some circumstances you can ask us to delete your data: see Request Erasure below for further information.

In some circumstances we may anonymise your personal data (so that you cannot be identified) in which case we may use this information indefinitely without further notice to you for research or statistical purposes.


Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:

If you wish to exercise any of the rights set out above, please Contact Us.

NO FEE USUALLY REQUIRED

You will not usually 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 where permitted by law if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

WHAT WE MAY NEED FROM YOU

We may need to ask for specific information from you to help us confirm your identity 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 anybody who does not have a 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.

TIME LIMIT TO RESPOND

We try to respond to all valid requests within the period required by applicable law. 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.


Cookies Policy

We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users' browsing actions and patterns, and does not identify any individual.

For the same reason, we may obtain information about your general internet usage by placing cookies on the hard drive of your computer. Cookies contain information that is transferred to your computer's hard drive. They help us to improve our site and to deliver a better and more personalised service. For example, they enable us:

The following types of cookie may be used during your visit to our site:

We use Remarketing with Google Analytics to advertise online. Third-party vendors, including Google, show our ads on sites across the Internet. We and third-party vendors, including Google, use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimize, and serve ads based on someone's past visits to our website.

You may at any stage refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. However, if you select this setting you may be unable to access certain parts of our site. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you log on to our site. By continuing to use our site without activating your browser to block cookies, you are consenting to us using cookies on our site.

You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

Cookie name

Purpose

Lifetime

Type

Provider

bmec

Used to notify you if you have left an item in your basket

365 days

functional

Bronto module

add_to_cart

Information about what has been added to your cart

No expiry

performance

Magento

remove_from_cart

Information about what has been removed from your cart

No expiry

performance

Magento

SWO-017-ticker

Functionality of web site pop ups

No expiry

functional

Swoon

SWO-017-exit-popup

Functionality of web site pop ups

No expiry

functional

Swoon

CUSTOMER_JUST_SIGNED_UP

Information about your sign up

No expiry

functional

Magento

CUSTOMER_A1

Information about whether you were referred to Swoon by a friend

No expiry

functional

Magento

CUSTOMER_SOURCE_PARAMETER

Information about the way you came to the site

365 days

functional

Magento

CustomerSegmentIds

Identifies customer grouping

29 days

functional

Magento

yrd_prodClick

Tracking which products you're looking at

No expiry

performance

Yard

_signupPopupSeen

Making sure you only see pop ups once

No expiry

functional

Swoon

no_popup

Controlling which pop ups to show you

No expiry

functional

Swoon

_ping

Testing the browsers local storage capabilities

No expiry

functional

Swoon

selectedQuizAnswer

Finding out how you heard about Swoon

No expiry

functional

Swoon

referralUrl

Stores the URL via which you came to the site

No expiry

functional

Swoon

signup_object

Contains information about the signup method used

No expiry

functional

Swoon

_voucherPopupSeen

Making sure you only see pop ups once

No expiry

functional

Swoon

_signupPopupColor

Information about the colour of pop ups you see

No expiry

functional

Swoon

was_referred

Information about whether you were referred by a friend

No expiry

functional

Swoon

USER_ALLOWED_SAVE_COOKIE

Indicates if a customer is allowed to use cookies

365 days

functional

Magento

external_no_cache

Finding out if Caching are disabled

365 days

functional

Magento

persistent_shopping_cart

Persists customer log-in throughout the site

365 days

functional

Magento

Stf

Information on products you have sent to friends

365 days

functional

Magento

pollN

Finding out how you heard about Swoon

365 days

functional

Magento

frontend

Storing your session ID

365 days

strictly necessary

Magento

frontend_cid

Storing your session ID

365 days

strictly necessary

Magento

guest-view

Allowing you to edit your order if you're browsing as a guest

365 days

functional

Magento

CUSTOMER

Your customer ID

365 days

strictly necessary

Magento

CUSTOMER_INFO

Your customer ID

365 days

strictly necessary

Magento

NEWMESSAGE

Indicates if a new message has been received

365 days

functional

Magento

CART

Your Cart ID

365 days

strictly necessary

Magento

COMPARE

Information about products you're looking at

365 days

functional

Magento

POLL

The ID of any polls you have recently voted on

365 days

functional

Magento

RECENTLYCOMPARED

Information about products you're looking at

365 days

functional

Magento

WISHLIST

Information about products in your wishlist

365 days

functional

Magento

WISHLIST_CNT

The number of items in your wishlist

365 days

functional

Magento

CUSTOMER_AUTH

Indicates whether you are logged in

365 days

strictly necessary

Magento

CATEGORY_INFO

Stores category information so pages can load more quickly

365 days

functional

Magento

LAST_CATEGORY

Stores recently visited categories

365 days

functional

Magento

VIEWED_PRODUCT_IDS

Information about your recently viewed products

365 days

functional

Magento

currency

Your preferred currency

365 days

functional

Magento

store

The store view or language you have selected

365 days

functional

Magento

NO_CACHE

Indicates whether caching can be used

365 days

functional

Magento

LAST_PRODUCT

The product ID of the last product you viewed

365 days

functional

Magento

_utma

Distinguishes users and sessions

365 days

performance

Magento

_utmb

Determines new sessions/visits

365 days

performance

Magento

_utmc

Determines if you are in a new session or visit to the site

365 days

performance

Magento

_utmz

Stores the traffic source or campaign that explains how the user reached your site.

365 days

performance

Magento

_secure_cookie_check_cid

To protect your site visit from hacking

365 days

strictly necessary

Magento

Please note that our advertisers and people who link to our site may also use cookies, over which we have no control.