At Tousled, we collect personal data about our customers or those connected to our customers for a number of reasons. We take our obligations very seriously as we want to ensure you have comfort entrusting us with your personal data.
At the end of May 2018, the law across Europe dealing with personal data changes and introduces some new and enhanced requirements. To help you understand what we’re doing at Tousled to address these, here is a short summary:
Updated Privacy Notice (this tells you how we use your data): Tousled receives and processes certain types of personal data about its customers including those individuals who may pay for or otherwise facilitate services on behalf of our customers (e.g. members of family or those with legal responsibility to manage the wellbeing of our customers). This allows us to provide our services to our customers. Please review our new and enhanced Privacy Notice so you have all the information you need.
Your Rights: We’ve updated our internal processes and procedures to ensure that your new rights introduced by the new privacy law can be complied with. Any questions, feel free to contact us at firstname.lastname@example.org
Meet Florence Merryman - our CEO & Data Protection Officer: We not only take privacy seriously, but we’ve appointed someone responsible for this. We think this should be at the top of the company, therefore our fearless leader and CEO Florence Merryman has taken on this responsibility. To contact our Data Protection Officer, contact: email@example.com
How we use and protect your personal data.
Who are we
Tousled ("we", "our", "us" or “Tousled”) is committed to protecting and respecting your privacy.
Our data protection officer for the purpose of the Data Protection Laws is Florence Merryman, CEO & Founder of Tousled, who may be contacted at firstname.lastname@example.org. You can find more information about us by clicking here: www.tousledstyle.com.
Our Commitment and Obligations to you: We take the collection, usage and security of your personal data seriously. We can only use your personal data under law if we have a good reason for doing so. The law provides examples of those reasons. These include:
To perform or fulfill a contract we have with you; or
If we have a legal duty; or
If it is within our legitimate business interest; or
If there is a public interest reason for doing so; or
If you have given your consent.
A legitimate interest is when we have a business or commercial reason to use your information. But even then, it must not unfairly go against what is right and best for you. If we rely on our legitimate interest, we will tell you what that is.
Types of Personal Data We Collect About You
Contact details of customers or customer connected parties (e.g. families)
Demographic data (e.g. date of birth)
Food and carer preference information (e.g. allergies / likes and dislikes)
Financial data (for payment)
Health data of customers
Technical Information (IP / Cookies)
User login data
Legal data (e.g. power of attorney)
What Personal Data We Collect and Where From
You may give us information about you when filling in forms on our website www.tousledstyle.com ("our site") or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you subscribe to our services, complete a survey, sign up to a newsletter, post material on our site, report a problem with our site, request further services. The information you give us may include your name, address, email address, phone number, and personal description about the customer and/or the responsible party of the customer.
IMPORTANT: For data privacy reasons, we will only collect information from you directly or via your authorized representative who has confirmed that they are authorized to provide this information on your behalf.
Information we collect about you.
With regard to each of your visits to our we may automatically collect the following information:
technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and
information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), cookies and methods used to browse away the page and any phone number used to call our customer service number.
Automated decision making: We do not use automated decision-making processes during our relationship with you. Applications and decisions are always reviewed manually.
Communicate with potential and existing customers for marketing purposes: With your consent
Providing and improving quality of services to customers: This is within our legitimate business interests to perform
To analyse website use and improve services: We review data to ensure we provide customers with the best possible service
Marketing and site metrics performance: We carry this out to enhance our website services and ensure that it meets the best user experience to provide our customers with the best journey possible.
Email marketing: With your consent. We need to use your data to share our promotions and giveaways with you.
Accounting purposes: This is within our legitimate business interests to perform
We may obtain information about your general internet usage by using cookie files stored on your computer or device ("cookies"). Cookies are text files containing small amounts of information which are downloaded to your computer or device when you visit a website. They help us to improve our site and to deliver a better and more personalized service.
We may use both "session" cookie and "persistent" cookies on the website. Session cookies will be deleted from your computer when you close your browser. Persistent cookies will remain stored on your computer until deleted, or until they reach a specified expiry date.
We will use the session cookies to: keep track of you whilst you navigate the website; keep track of your bookings; prevent fraud and increase website security; and other uses. We will use the persistent cookies to: enable our website to recognize you when you visit; keep track of your preferences in relation to your use of our website; and other uses.
Our payment services providers may also send you cookies.
You can find more information about cookies and how to manage them at http://www.allaboutcookies.org/ You may disable cookies by changing the settings on your browser. However, if you do so, this will affect your enjoyment of our site and we will no longer be able to offer to you a personalized service.
E-mail marketing and newsletters
We may make suggestions and recommendations to you that we think may be of interest to you or members of your team / organisation. We will only contact you by electronic means (email) with information about services similar to those which you have shown an interest in.
We may also use your data, or permit selected third parties to use your data, to provide you with information about services which may be of interest to you and we or they may contact you about these by electronic means only if you have consented to this.
You have the right to ask us not to process your information for marketing purposes. You can exercise your right to prevent such processing by ticking the relevant boxes on the forms we use to collect your information, or you can opt out of receiving future marketing communications from us at any time by following the directions contained in the marketing email to unsubscribe. You can also exercise this right at any time by contacting us at email@example.com .
We do not disclose information about identifiable individuals to our advertisers, but we may provide them with aggregate information about our users. We may also use such aggregate information to help advertisers reach the kind of audience they want to target. We may make use of the personal data we have collected from you to enable us to comply with our advertisers' wishes by displaying their advertisement to that target audience.
How we share your personal data
We take your privacy very seriously and we’ll only share your information where:
we need to for the purposes of providing you with products or services you have requested;
we have a public or legal duty to do so e.g. to assist with detecting fraud and tax evasion, economic crime prevention, regulatory reporting, litigation or defending legal rights;
we have a legitimate reason for doing so e.g. to manage risk, or assess your suitability for services; or
we have asked you for your permission to share it, and you’ve agreed.
We may share with third parties, including:
business partners, suppliers and subcontractors for the performance of any contract we enter into with them or you;
fraud prevention agencies who will use it to prevent fraud and money-laundering and to verify your identity;
provided you have consented; marketing, market research, advertisers and advertising networks that require the data to select and serve relevant adverts to you and others;
analytics and search engine providers that assist us in the improvement and optimization of the website;
any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries for the purposes set out above;
in the event that we buy or sell any business or assets, including the sale of an individual website owned by us, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets; and
if Tousled or substantially all of its assets are acquired by a third party, in which case personal data held by it about its members and customers will be one of the transferred assets.
Sharing Aggregated or Anonymised Data:
Where we have made your information anonymous, we may share it this outside of Tousled with partners such as research groups, universities, advertisers or connected sites. For example, we may share information publicly to show trends about the financial services market.
Where we store your personal data
Security of your personal data
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of the data transmitted to our site; any transmission of your data is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.
Our site may, from time to time, contain links to and from the websites of our member and associate member organisations, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
How Long We Keep Your Information
We will retain your personal information for as long as you use our services and for a reasonable time thereafter. After you have terminated your use of our services, we will retain your personal information for up to 10 years and thereafter may store it in an aggregated and anonymised format.
Access to information. The Data Protection Laws give you the right to access information held about you. Your right of access can be exercised in accordance with Data Protection Laws by contacting us.
Consent. You may withdraw your consent to any processing of your personal data at any time by contacting us.
Rectification. You have the right to rectify any personal data held about you that is inaccurate. Your right of rectification can be exercised by contacting us.
Erasure. You may have the right to erasure of personal data held about you by contacting us.
Complaints. In the event that you wish to make a complaint about how we process your personal data, please contact us in the first instance at firstname.lastname@example.org and we will endeavor to deal with your request as soon as possible. This is without prejudice to your right to launch a claim with your local Data Privacy Commission.