The Little Surprises Company

The Little Surprises Company Ltd - Privacy policy

Last update: 8th October 2018

Welcome to our UK website. We refer to the Site, all features, functionality and content of the Site as the "Services". The Services, including the Site are provided in the UK by The Little Surprises Company Ltd ("we", "us", "our"). For the purposes of UK data protection legislation, we are the data controller.

Your privacy and security is important to us. We know that providing personal information is an act of trust and we take that trust seriously. This Privacy Policy (the “Policy”) describes how we capture your Information (as defined below) and governs how we will deal with it. By using the Site, registering with The Little Surprises Company Ltd, our subsidiaries and/or using the Services, you are accepting and consenting to the collection, use, disclosure and other handling of your Information as described below.

1. Information we collect or receive

When you use the Site, we collect and retain information that you, as a customer or potential customer, provide to us through the Site, as well as information that is automatically or passively collected from you, your device or your browser (the “Information”).

Information that you may provide to us:

Contact and profile information, including name, email address, postal address (including post code) and mobile telephone number.
Account information, including transaction details.
Credit card information, including the name on the card, card type, card number, expiry date and CV2 is collected and processed by our third party payment processor. We retain limited credit card information for our records (e.g. the last four digits for validation purposes) but we do not store or retain complete credit card information.
Your preferences, including reasons for purchasing a Little Surprise collection and how you heard about The Little Surprises Company.
Recipient details, including name, age, gender, postal address (including post code), email address and mobile telephone number.
Recipient preferences, including likes, disliked and accessibility requirements.
Communications to us, for example reporting a problem or submitting queries, concerns or comments regarding the Site, its content or your account.
Any other content or information you choose to provide, including photos you may upload.
Details of your visits to the Site, the resources you access and any data you download.

You are under no obligation to provide any such information. However, if you should choose to withhold requested information, we may not be able to provide you with certain services.

Information that may be automatically collected

We, along with third parties, also may collect Information about you, your computer or device and your use of the Service via automated means. This Information may include:

Information about your visits to the Site and use of the Services, the resources you access, any data you download and information related to the ways in which you interact with the Site and the Services.
IP addresses (including the general information in such address, such as city, county and post code), unique device identifiers, other information about your mobile phone or other mobile device(s), browser types and browser language.
Referral pages and links, URLs, number of clicks, pages viewed, how long you're on a page, your search queries and results.
Information about your device, computer and/or browser you use as well as the device's operating system. This may include your device hardware model, operating system version, or mobile network information.

We may also combine Information that we collect from you with Information we obtain about you from third parties and affiliates and Information derived from any other subscription, product, or service we may provide.

Information from Third Parties

We may obtain additional information about you from third parties such as marketers, partners, researchers and others, but only where we have checked that these third parties either have your consent or are otherwise legally permitted or required to disclose your personal information to us.

We use the information we receive from these third parties to maintain and improve the accuracy of the records we hold about you, and to offer you products that we believe you would be interested in.

Anonymous, pseudonymous or de-identified data

We may anonymise and/or de-identify information collected by the Services or via other means so that the information does not identify you. Our use and disclosure of anonymised and/or de-identified information is not subject to any restrictions under this Privacy Policy and we may disclose it to others without limitation for any purpose.

We may pseudonymise your data through a technique called "hashing".

We may use pseudonymised data with our partners (such as Facebook) to find additional potential customers for our products and services by finding people with similar preferences. These partners will keep the data secure and will only use such data for the purpose for which we provide it to them.

2. Information Uses

We use your Information to better serve you, such as by letting you know about products we've added to the range that we think you'll like. Some other examples of how we may use your Information include to:

Process your orders and provide you with the Services.
Customise our Services to you and the recipient, for instance using the details of likes, dislikes, hobbies and accessibility requirements to select appropriate surprises.
Inform the recipient about delivery of the gift card and ask you for feedback on your purchases and/or surprises.
Provide, operate and maintain, our Services, including, for instance (without limitation) to administer your account, provide you with order and billing information, monitor use of and downloads from the Site.
Improve the Site and Services for customers, analyse Site usage, investigate complaints or Site operations and identify visitors to the Site.
Analyse our users' demographics and track sales data.
Provide you with offers, competitions, marketing materials and other promotional materials, both online and through other marketing channels, such as third party social networks, like Facebook.
To assist us in finding other potential customers similar to you (but we would never disclose your data in doing so to any of those customers).
Send you information or content you have requested and develop relevant advertising material for you which will be viewable when you visit the Site or other websites across the Internet.
Communicate with you and investigate any complaints.
Perform market research, data analytics and data appends. To accomplish some of these tasks, we may enhance or append other data collected from or about you to the Information we possess.
Ensure that as an existing customer you are not included on proposed marketing campaigns aimed at attracting new customers.
Protect against fraud, unauthorised transactions, security issues, claims and other liabilities and manage risk exposure and quality.
Verify whether you have had a previous account with us to prevent fraudulent take-up of our offers.
Provide customer support and diagnostic assistance, for instance, by analysing the Information, our Service’s integration with other platforms and the contact information and other materials you submit to us.
Associate an email address that you have provided to us with previous browsing and purchase experiences. We may be able to make this connection whether you are logged on or not and we will know whether you receive email alerts and will be able to associate this with any other contact information you may have given us.

If you have elected to unsubscribe from marketing communications we will keep a record of this and ensure that we include your email address on suppression lists to ensure that we do not contact you with marketing communications.

3. Information Sharing and Disclosure

We are committed to protecting the privacy and security of your personal information. We will only share it with third parties in accordance with this Policy, or as otherwise required by law.

We may share your personal information in the following ways:

With trusted service providers, to perform or assist us in performing any of the functions listed in Section 2 (Information Uses), for instance (without limitation) to assist us with email delivery, customer and technology support, hosting services, fraud prevention and marketing, data enhancement, advertising and market research services.
If you refer a new customer to us or you sign up as a result of a referral, we may share your first name and first initial of your surname with the referred person or person making the referral as set out in the referral program details.
We also provide analyses of our customers in the aggregate to prospective partners, advertisers and other third parties. We do this so that we and our business partners can understand our customers better and so we can keep bringing you first-rate services. We may also disclose, on an anonymous basis, statements made by our customers such as comments or feedback we receive on our products or Services.
As we continue to develop our business, we may sell, buy, merge or partner with other companies or businesses, or sell some or all of our assets. In such transactions, your Information may be among the transferred assets or may be shared with the other company or business for purposes of evaluating the transaction.
We may share your information with third-parties with whom we have a contractual relationship.
We may share your feedback or comments. If you post anything to this Site or through the Services that can be viewed by the general public, we may share that with third parties.
We may use third-party Web analytics Services on the Site, such as those of Google Analytics. We may also share certain information about you and the device you use to access the Services in order to deliver tailored advertising. These service providers use the technology described in the Our use of cookies and similar technologies section to help us analyse how users use the Site and to deliver advertising. The information collected by the technology (including your IP address) will be disclosed to or collected directly by these services providers, who use the information to evaluate your use of the Site.
We may share your Information when we believe in good faith that such sharing is reasonably necessary in order to investigate, prevent, or take action regarding possible illegal activities or to comply with legal process. We may also share your information in situations involving potential threats to the physical safety of any person, violations of this Privacy Policy or the Terms of Service; or to respond to the claims of violation of the rights of third parties and/or to protect the rights, property and safety of The Little Surprises Company Ltd, our employees, users, or the public. This may involve the sharing of your information with law enforcement, government agencies, courts and/or other organisations.
We may share your Information in any other circumstances where we have your consent.

Sometimes, we may combine certain parts or portions of the Information with each other. For instance, when we provide you with customer support or other assistance, we may combine your account information and other personal information you've provided to us with Information about your usage of the Services.

We may include links to third party websites on the Site which we think you might be interested in. Any such third party websites are not controlled by us and therefore our Privacy Policy does not apply to them.

Our use of Cookies and Similar Technologies

Cookies are small pieces of information which are issued to your computer when you visit a website and which store and sometimes track information about your use of that website.

4. Legal Basis for Processing Personal Information

Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it. However, we will normally collect personal information from you only (i) where we need the personal information to perform a contract with you, (ii) where the processing is in our legitimate interests and not overridden by your rights; or (iii) with your consent. In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person.

If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).

Similarly, if we collect and use your personal information in reliance on our legitimate interests (or those of any third party), this interest will normally be for us to operate our platform and communicating with you as necessary to provide our services to you and for our legitimate commercial interest, for instance, when responding to your queries, improving our platform, undertaking marketing, or for the purposes of detecting or preventing illegal activities. We may have other legitimate interests and if appropriate we will make clear to you at the relevant time what those legitimate interests are.

If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the "contact us" heading below.

5. Marketing

Email or Other Electronic Marketing

We will only use your email address for marketing when permitted by law. You can opt out of receiving future communications at any time. Please note, when opting out that you may continue to receive some information from us where this is already in the communication pipeline, typically for up to 48 hours after the date and time you update your account.

You may unsubscribe from receiving all marketing emails by emailing us (Hannah-beth@thelittlesuprisescompany.co.uk).

Post

We will send one welcome card to either the purchaser or the recipient. We will also send three gift cards to the recipient over the one-year period following the purchase of a Little Surprises collection.

6. Security and Retention

We have implemented appropriate technical and organisational measures and security features, as well as internal guidelines, designed to safeguard the privacy of your personal information from loss, alteration, unauthorised access or improper use. Our security and privacy policies are periodically reviewed and we will continue to enhance our security procedures as new technology becomes available. Whilst we cannot ensure or guarantee that loss, alteration, unauthorised access or improper use of information will never occur, we use all reasonable efforts to prevent it.

While we make every effort to ensure that your information is secure on our system, you should bear in mind that submission of information over the Internet is never entirely secure. As a result, we cannot guarantee the security of any information you transmit to us and you do so at your own risk.

Only key members of our personnel have access to personal information. Backups are run to prevent loss of information and our Internet servers are housed in secure facilities.

It is advisable to log out and close your browser when you have finished your user session to help ensure others do not access your personal information if you use a shared computer or a computer in a public place.

7. data retention

We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).

Information will be retained for three years following your purchase of a Little Surprise collection. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

8. Your choices and your rights

If you are a customer of ours, we may provide you access to account and usage information, such as:

Your Service and transaction history.
Your delivery information (name, email, delivery addresses, first line and post code of billing address), which you can change at any time.
Your payment information, which you can change at any time.
Your preferences, which you can change at any time.

You have the following data protection rights:

If you wish to access, correct or update your personal information, you will be able to do so by emailing us or using the “contact us’ form on our website.
If you wish to request deletion of your personal information, you can exercise this right by contacting us using the contact details below.
In addition you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. Again, you can exercise these rights by contacting us using the contact details provided below.
You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe here” link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us using the contact details provided on our website.
Similarly, if we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact the Information Commissioner's Office.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

9. External Links

The Site may contain links to external websites. We assume no responsibility for the privacy practices or the content of those websites. Therefore, please read carefully any privacy policies on those websites before either agreeing to their terms or using those websites.

10. Contact Us

If you have questions or concerns regarding this Policy, please contact us via email (Hannah-beth@thelittlesurprisescompany.co.uk) or via the “contact us” section of our website.

11. Changes to our Policy

We may update this Privacy Policy at any time for any reason. If we do so, we will post the updated Privacy Policy on the Site and indicate its effective date or the date it was posted. We encourage you to review the changes carefully. Your continued use of the Service will mean you agree to those changes.