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Privacy Policy

PRIVACY POLICY

Welcome to the privacy policy of Morrow’s (Outfitters) Limited.

 

Morrow’s (Outfitters) Limited respects your privacy and is committed to protecting your personal data.

 

The key principles upon we act in relation to your personal data are set out in the General Data Protection Regulation.

 

In brief we act in relation to your personal data in this way; it is:-

  1. processed lawfully, fairly and in a transparent manner;
  2. collected for specified, explicit and legitimate purposes;
  3. processed adequately and is relevant and limited to what is necessary in relation to the purposes for which it is processed;
  4. is accurate;
  5. is kept in a form which permits identification of your data for no longer than is necessary for the purposes for which it is processed;
  6. processed in a manner that ensures appropriate security.

 

It is our hope and intention that our privacy policy will build confidence in our business and a relationship of trust between you and us and thereby enhance our reputation.

 

  1. Introduction

This privacy policy tells you how Morrow’s (Outfitters) Limited uses your personal data when you visit our website, correspond with us and buy our goods and services from us.

It also tells you about your privacy rights and how the law protects you.

It is important that you read this privacy policy, together with any other privacy policies we may provide, so that you are fully aware of how and why we are using your data.

This privacy policy was last updated on 24th of May 2018.

If you have any questions, or would like to exercise your privacy rights, please follow the instructions in this privacy policy. See How to contact Morrow’s (Outfitters) Limited about privacy below.

  1. Our website

On our website at morrowsoutfitters.com we sell items of clothing and accessories.

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

Morrow’s (Outfitters) Limited is the data controller responsible for this website.

  1. Personal data which 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 collect a variety of information about our customers and visitors to our retail outlets and our website. This personal data falls into these categories:

Identity Data includes title, first name, last name, username or similar identifier and an encrypted version of your login/password. If you interact with us through social media, this may include your social media user name.

Contact Data includes billing address, delivery address, email address and telephone numbers.

Financial Data includes payment card details.

Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.

Profile Data includes your username and password, purchases or orders made by you, preferences, feedback and survey responses, as well as any profile data which we have added (for example, using analytics and profiling).

Technical Data includes 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 this website.

Usage Data includes information about how you use our website, products and services.

Tracking Data includes information we or others collect about you from cookies and similar tracking technologies, such as web beacons, pixels, and mobile identifiers.

Marketing and Communications Data includes your preferences in receiving direct marketing from us and our third parties and your communication preferences.

We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature.

If, however, 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 policy.

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.

Remember, if you choose not to share personal data with us, or refuse certain contact permissions, we might not be able to provide the products and services you have asked for.

  1. 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, telephone, e-mail or through chat or social media or when you visit us at our retail outlets or at Fairs, Exhibitions or Events.

This includes personal data you provide when you:

  • sign up to receive the Morrow’s (Outfitters) Limited’s Newsletter;
  • make enquiries or request information be sent to you;
  • create an account on our website;
  • order our products or services;
  • ask for marketing to be sent to you;
  • engage with us on social media;
  • enter a competition, promotion or survey;
  • leave comments or reviews on our products or services; or
  • visit us at our retail outlets or at Fairs, Exhibitions or Events.

Automated technologies or interactions

As you interact with us, including via the morrowsoutfitters.com website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We may also collect Tracking Data when you use our website, or when you click on one of our adverts (including those shown on third party websites).

Third parties or publicly available sources

We may receive personal data about you from various types of third parties, including:

  • Technical Data and/or Tracking Data from analytics providers, advertising networks and search information providers;
  • Contact, Financial and Transaction Data from providers of payment and fraud prevention services;
  • Identity and Contact Data from data partners; and
  • Data from any third parties who are permitted by law or have your permission to share your personal data with us, such as via social media or review sites.
  1. 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 in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you. For example, when you purchase our products we will use your personal data to obtain payment from you and we will collect your address details to deliver your purchase and pass on those details to a courier.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. For example, when we carry out fraud screening as part of the check-out process.
  • Where we need to comply with a legal or regulatory obligation. For example, keeping records of our sales for tax compliance.
  • Where we have obtained your express consent, which is freely given, informed and unambiguous, signifying your agreement to us processing your personal data. For example, we rely on this legal basis in relation to sending you certain direct marketing communications or when you tick a box to receive e-mail newsletters. When we collect your personal data, we will always make clear to you which data is necessary in connection with a particular service.

Where our legal basis is consent, you have the right to withdraw consent any time.

We do not carry out any automated decision making.

  1. The legal bases we rely on to process personal data

Here are the ways we plan to use personal data and which of the legal bases we rely on to do so.

To process any orders that you make by using our website or in our retail outlets or or at Fairs, Exhibitions or Events or when you telephone us.

  • If we do not collect your personal data, we will not be able to process your order and comply with our contractual obligations.

To respond to your queries, refund requests and complaints.

  • Handling the information you sent enables us to respond. We may also keep a record of these to inform any future communication with us and to demonstrate how we communicated with you throughout. We do this on the basis of our contractual obligations to you, our legal obligations and our legitimate interests in providing you with the best service and understanding how we can improve our service based on your experience. 

To protect our business and your account from fraud and other illegal activities. This includes using your personal data to maintain, update and safeguard your account. We will also monitor your browsing activity with us to identify and resolve any problems and protect the integrity of our websites.

  • We do this as part of our legitimate interest.

To process payments and to prevent fraudulent transactions.

  • We do this on the basis of our legitimate business interests.

We will use your personal data, preferences and details of your transactions to keep you informed by e-mail, web, text and telephone about relevant products and services including tailored special offers, discounts, promotions, events, competitions and so on.  

  • We do this with your consent. You are free to opt out of hearing from us by any of these channels at any time.

To send you relevant, personalised communications by post in relation to updates, offers, services and products.

  • We do this on the basis of our legitimate business interest. You are free to opt out of hearing from us by post at any time.

To 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, product recall notices, and legally required information relating to your orders. These service messages will not include any promotional content and do not require prior consent when sent by email or text message.

  • If we do not use your personal data for these purposes, we would be unable to comply with our legal obligations.

To display the most interesting content to you on our website, we will use data we hold about your favourite products and so on.

  • We do so on the basis of your consent to receive such information and/or for our website to place cookies or similar technology on your device. For example, we might display a list of items you have recently looked at, or offer you recommendations based on your purchase history and any other data that you have shared with us.

To administer any of our prize draws or competitions which you enter.

  • We do this based on your consent given at the time of entering.

To develop, test and improve the systems, services and products we provide to you.

  • We do this on the basis of our legitimate business interests. For example, we will record your browser’s Session ID to help us understand more when you leave us online feedback about any problems you’re having

To send you survey and feedback requests to help improve our services. These messages will not include any promotional content and do not require prior consent when sent by email or text message.

  • We have a legitimate interest to do so as this helps make our products or services more relevant to you. Of course, you are free to opt out of receiving these requests from us at any time by updating your preferences in your online account.

To build a picture of who you are and what you like, and to inform our business decisions, we will combine data captured from our website, third parties and data from publicly-available lists.

  • We will do this on the basis of our legitimate business interest. For example, by combining this data, this will help us personalise your experience and decide which inspiration or content to share with you. We also use anonymised data from customer purchase histories to identify trends in different areas of the country. This may then guide which products we display in particular stores.

We will also share data to comply with our obligations to disclose it for the purposes of law enforcement.

  1. Advertising, marketing and your communications preferences

We may use your Identity, Contact, Technical, Tracking, Usage and Profile Data to form a picture of what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you and tell you about them. This is what we call direct marketing.

We may carry out direct marketing by email, telephone, text or post. For example, you might have a promotion arrive in your inbox or a brochure sent to you in the post.

On our website, we always try hard to make it really clear what we are doing and what communications you will be sent, whether it’s you deciding to sign up to the Morrow’s (Outfitters) Limited’s mailing list or as part of creating an account or the purchase journey. You have a right at any time to change your mind and opt out. The easiest way to opt out is to use the unsubscribe link at the bottom of the communication.

Of course, there are lots of different ways you will see adverts for Morrow’s (Outfitters) Limited’s and not all of these are based on using personal data – sometimes we just buy advertising space in newspapers and periodicals and websites and social media. If you see Morrow’s (Outfitters) Limited’s adverts on websites and in social media, these may not be directed specifically at you. But here are some things we may do that may be specifically directed at you:

  • Emails or text messages, for example with discount codes;
  • promotions by post; and/or
  • telephone calls, to tell you something that might be relevant to you.

We work with partners to try and promote the reach of our adverts and use analytics and retargeting for this reason.

We use Tracking Data to deliver relevant online advertising, including via websites and social media.

Tracking Data, and in particular cookies, help us to deliver website and social advertising that we believe is most relevant to you and to potential new customers of Morrow’s (Outfitters) Limited. The cookies used for this purpose are often placed on our website by specialist organisations. This includes retargeting.

Cookies can also tell us if you have seen a specific advert, and how long it has been since you have seen it. This is helpful, because it means we can control the effectiveness of our adverts and control the number of times people might be shown our adverts. Cookies also help us understand if you have opened a marketing email because we do not want to send you things you do not read.

If you want more information about Tracking Data, in particular cookies, see Cookies below.

Almost all the cookies that relate to advertising are part of third party online advertising networks. If you would like to read about how you can control which adverts you see online, see opt-out programmes established by the Digital Advertising Alliance (United States), the Digital Advertising Alliance of Canada and the European Interactive Digital Advertising Alliance. We do not control cookies which are set by advertising networks.

  1. Cookies

Cookies are a tool which we and many others who operate online use for advertising.

Cookies help morrowsoutfitters.com work better and provide much help in the background to make the process of being one of our customers easier, such as making it easy to log in and to move from page to page and for items to remain in your cart while you look at other pages.

Other cookies collect information about how visitors use morrowsoutfitters.com, for instance which pages visitors go to most often, and if they get error messages from web pages. These cookies do not collect information that identifies a visitor. All information these cookies collect is aggregated and used to improve how morrowsoutfitters.com works.

There are also cookies that allow morrowsoutfitters.com to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. They may also be used to provide services you have asked for such as watching a video or commenting on a blog.

There are cookies that collect information about your browsing habits in order to make advertising delivered to you more relevant to you and your interests. They are usually placed by advertising networks with our permission. They remember that you have visited a website and this information is shared with other organisations such as advertisers. Quite often targeting or advertising cookies will be linked to site functionality provided by the other organisation.

When you use morrowsoutfitters.com, your device or browser may be sent cookies from third parties, for example when using embedded content and social network links. It is important for you to know that we have no access to or control over cookies used by these companies or third-party websites. We suggest you check the third-party websites for more information about their cookies and how to manage them.

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.

  1. Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in this privacy policy. We may also share your personal data if the law otherwise allows it.

We may share personal data with the following categories of third party:

  • Suppliers and service providers (such as technology service providers, payment processing and fraud prevention providers, manufacturers and post and courier services);
  • auditors and professional advisers such as bankers, lawyers, accountants and insurers; and
  • government, regulators and law enforcement officers.

We share data with third parties connected to advertising, retargeting and analytics, who will process your personal data as part of their contracts with us. We currently use Google, Twitter, Instagram, Facebook, Mail Chimp, Add People, Farrer Digital and Fresh Evoke.

We may also share data with third parties to 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.

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.

  1. Payment information

Morrow’s (Outfitters) Limited uses third party payment processors Shopify and PayPal to process payments made for products and services via the Website. All online payments will be conducted in accordance with Payment Card Industry (PCI) data security standards and your billing information (which is only used by these payment processors for the purpose of performing fraud protection) is encrypted before being communicated to them. Subject to the below exceptions, your credit card details are communicated directly from your browser to these payment processors - Morrow’s (Outfitters) Limited does not see your full Permanent Account Number (PAN). This means that the payment form is either off-site or displayed in a frame on the payment page.

For Shopify Payments, if on the payment page you have requested that your card details be remembered, for the purposes of saving time and the payment was successful, Morrow’s (Outfitters) Limited stores the card type, a Masked PAN and the card’s expiry date as well as an associated token. We store this information so that you and we can identify your stored card and use it for further payments at morrowsoutfitters.com. This stored information can be deleted via the payment form on the Website should you wish to do so.

For PayPal we only store the tokens required to identify the transaction with PayPal, issue refunds and identify transactions made using PayPal.

If you provide us with your credit card details over the telephone the information will normally be input contemporaneously and no written record will be kept. If, however, it is necessary to record any part of the credit card details in writing such written record will be securely destroyed once payment has been made.  

We will not ask you confirm any account or credit card detail via e-mail. If you receive such an e-mail please contact us immediately.

  1. International transfers

Whenever we transfer your personal data out of the EEA, we will comply with applicable data protection law. Some of the mechanisms we may choose to use when undertaking an international transfer are:

  • The transfer of your personal data is to a country that has officially been deemed to provide an adequate level of protection for personal data by the European Commission.
  • We may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe (called the “EU Model Clauses”).
  • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. If the provider is not EU-US Privacy Shield certified, we may use the EU Model Clauses.

Many of our external third-party providers are based outside the EEA, so their processing of your personal data will involve a transfer of data outside the EEA.

  1. 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 have a business need to know. 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.

  1. Third-party links

This website may include links to third-party websites, plug-ins and applications (for example, the ability to sign in with Facebook). 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 policy of every website you visit.

  1. Data retention

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.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers for tax purposes.

You can come back at any time in the future and re-print products you have ordered from us in the past. So, unless you actively delete this information, we will keep it.

In some circumstances you can ask us to delete your data; see Your legal rights below for further information.

In some circumstances we may anonymise your personal data (so that 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.

  1. Your legal rights

If the General Data Protection Regulation applies to you because you are in the European Union, you have rights under data protection laws in relation to your personal data:

  • The right to be informed – that is an obligation on us to inform you how we use your personal data;
  • The right of access – that is a right to make a ‘data subject access request’ for a copy of the personal data we hold about you;
  • The right to rectification – that is a right to make us correct personal data about you that may be incomplete or inaccurate;
  • The right to erasure – that is the ‘right to be forgotten’ where in certain circumstances you can ask us to delete the personal data we have about you (unless there is an overriding legal reason we need to keep it);
  • The right to restrict processing – that is a right for you in certain circumstances to ask us to suspend processing personal data;
  • The right to data portability – that is a right for you to ask us for a copy of your personal data in a common format (for example, a .csv file);
  • The right to object – that is a right for you to object to us processing your personal data (for example, if you object to us processing your data for direct marketing); and
  • Rights in relation to automated decision making and profiling – that is a right you have for us to be transparent about any profiling we do, or any automated decision making.

These rights are subject to certain rules about when you can exercise them. You can see a lot more information on them, if you are interested, on the UK Information Commissioner’s Office website.

If you wish to exercise any of the rights set out above, please contact us (see How to contact Morrow’s (Outfitters) Limited about privacy).

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). We may, however, charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

Your right to withdraw consent

Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent.

Where we rely on our legitimate interest

In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.

Direct marketing

You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We must always comply with your request.

Checking your identity

We may need to request 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 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 ask them to prove they have your permission to act.

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.

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.

  1. How can you stop the use of your personal data for direct marketing?

You can stop direct marketing communications from us by clicking the ‘unsubscribe’ link in any email communication that are sent to you. You can also manage your preferences on our website and opt out of being sent such communications.  You can also contact us as set out below.

Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated.

  1. How to contact Morrow’s (Outfitters) Limited about privacy

If you have any questions about this privacy policy, or would like to exercise any of your rights, please email us at morrowsoutfitters@gmail.com or write to us with your letter addressed to: Morrow’s (Outfitters) Limited, The Stables, Drewell Road, Liverpool, L18 8AT, United Kingdom.

If you need help about our products and services, or this website generally, please contact us here.

  1. A request from Morrow’s (Outfitters) Limited to you

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. You can do this by updating your account.

  1. Changes to this privacy policy

The General Data Protection Regulation is new and the ICO may continue to issue new guidance about how businesses should follow it. So, you may see updates to our privacy policy in the future. Periodically, please take the opportunity to check our up-to-date police.

Thank you for taking the time to read our Privacy Policy.