BLACKYS MENSWEAR GROUP PRIVACY POLICY (“Privacy Policy”)

LAST UPDATED: 5TH AUGUST 2020

  1. ABOUT THE BLACKYS MENSWEAR GROUP AND THIS PRIVACY POLICY We are the BLACKYS MENSWEAR Limited (“we”, “us”, “our”), and we are committed to protecting your privacy.

Blackys Menswear Cy Limited is the controller for the purposes of the General Data Protection Regulation (the “GDPR”) a company registered in Cyprus.

This Privacy Policy provides information on how we collect and use personal data. Blackys Menswear Cy Limited operates blackysmenswear.com.

This Privacy Policy sets out the information that we collect, the reasons for which we collect that information, and how we can use and share that information.

The Website and the services provided by Blackys Menswear are not intended to be used by children. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, you can contact the Blackys Menswear Data Protection Officer at info@blackysmenswear.com.

  1. THIRD-PARTY WEBSITES

Our Website can contain links to and from the websites of our partner boutiques, retailers and brands (collectively our “Partners”), advertisers, and affiliates, amongst others. If you follow a link to any of these websites, please note that this Privacy Policy does not apply to those websites. We are not responsible or liable for the privacy policies or practices of those websites, so please check their policies before you submit any personal data to those websites.

  1. WHAT INFORMATION DO WE COLLECT, AND HOW?

When you interact with us, whether by using our Website or communicating with us, we may collect the following information about you:

Depending on what you provide, this information can include your name, address or location, phone number and email address, gender, purchase information, shopping preferences, images and financial information (including your credit or debit card details, although we do not hold them, our payment processors do).

If you register an account on the Website, then you may choose to give us your photograph and nickname. From your account, you can also invite your friends to shop at our Website (including by email, Facebook, or Twitter). Although we will let them know that we received their details from you, please ensure that you have the permission of your friends before sharing their contact details with us and only forward emails to people you know would be happy to receive them.

 cookies: you can see more details about cookies in section 7, but these small text files can help improve your experience with the Website and make it easier to interact with us. This may include storing your location or language preferences to save you having to re-enter information when returning to, or ensuring that items you wish to order don’t disappear as you navigate between pages on, our Website. We also use cookies to provide you with tailored advertising;§

 device information: the information provided by your device will differ depending on which type of device you are using (whether it’s a PC, Mac, iPhone, Android, or otherwise) and the settings on that device, but includes the type of device you have (such as an iPhone 6S or Samsung Galaxy S7), the device’s IP address, the browser you are using, your mobile network provider (for mobile devices), the pages you have visited, your time zone and country location, and crash or download error reports.§

  1. WHAT DO YOU USE MY INFORMATION FOR?

To provide you services and the Website, including to allow you to order and receive products using our Website, administer your account and to optimise your experience we need to use the information that we collect in a number of different ways.

We also use the information for marketing and advertising purposes. Where you have told us you would like to receive marketing communications or when you have made a purchase using our services, we and our partners will use your personal information (including your name, email address and address) to occasionally send you updates, news, and offers via email, post, or other forms of media. We may use your information (including supplemental information received from partners that we append to our existing customer information as described below), to tailor these messages to you. You may unsubscribe from our email marketing communications by modifying your preferences in your account’s profile management section, or by following the opt-out instructions in the promotional emails that are sent to you.

We use third-party service providers to serve advertisements most relevant to you across your different devices and on our own and others’ websites. In addition to the information about your visits to our website, our service providers may also use the information about your interactions with other websites or applications to target advertisements for products available from Blackys Menswear or from our Partners. For information about opting out of targeted advertising and controlling the use of cookies, please see the cookies section of this Privacy Policy.

We also carry out research, analysis, and surveys on your use of our Website, and views. We keep tracking your spending on our Website to see if you can benefit from our exclusive loyalty programs as the VIP customer program and Access. Finally, we use your information to confirm your identity and perform credit checks or anti-fraud checks, in order to ensure your, and our, financial security. Please scroll down to find out the detailed purposes for which we collect your information, what specific information is collected, and the legal basis for which we purpose that data.

  1. WHO DO YOU SHARE MY INFORMATION WITH?

To provide the Website and our services, we work with a number of carefully selected third parties. To do this, we may share your information with these third parties in the following limited circumstances:

o Courier companies, that we use in order to deliver the products to you and, as such, they need to have access to your order information, including your name and address. These providers have a global outreach, with many local companies that can be engaged depending on your shipping address;

o Payment providers that we use to process your payment information (including your credit/debit card details) so that we can collect payment from you. These are based in the European Union, United States, and China and are engaged depending on your location;

o Anti-fraud and credit check providers to keep us and you secure. They have access to and process your information and associated orders in order to check for any fraudulent behaviour. Our current providers are based in The United States, Europe, and Israel.

o Analytics and search engine providers, like Google, that we use to assist us in the improvement and optimization of the website. These providers are based in the United States and in Europe.

o Marketing Tools providers that help us to enable our marketing. These providers are based in the United States.

o Performance Marketing and Recommendations Providers that help us deliver advertising and recommendations of  Blackys Menswear products tailored to your interests and needs. These providers are based in Europe (mostly in the UK) and in the United States

o Research companies that we can engage to help us carry out surveys regarding your use of our Website and Services. These providers are mostly based in Europe (mostly in the UK) or in the United States.

o IT/technology providers that we use to support, maintain, and provide our technology and IT infrastructure that supports our Website and the storage of your information. This includes Microsoft Azure that we use to host your information and that it is based in the Netherlands and in Ireland.

  1. TRANSFERS OF YOUR PERSONAL DATA

To provide our Website and our services, in accordance with the purposes set out above, we may transfer and store the personal information that we collect from you to a destination outside of the European Economic Area (“EEA”), mostly to the United States, either to one of our Group Companies, to one of our Partners or to one of the third parties with which we work with, as stated below:

o When transferring personal information to one of our Group Companies outside the EEA, which may be the USA, Brazil, Russia, Japan, or China, we rely on the Commission’s model contracts for the transfer of personal data to third countries (i.e. the standard contractual clauses) pursuant to Decision 2010/87/EU;

o We transfer the personal information to one of our partners outside the EEA, to the extent such transfer is needed to fulfill the contract between you and the Partner from which you are ordering the products from.

o When transferring personal information to one of our third-party services’ providers set out above, we rely on different adequacy measures, as set out below:

Adequacy Decision: We transfer the personal data that we collect from you to conduct fraud checks to Israel, which was found to have an adequate level of protection for personal data under Commission Decision 2011/61/EU of 31 January 2011.

Privacy Shield: Some of our third party providers based in the US, where we transfer your information to, comply with the US Department of Commerce’s EU-US Privacy Shield and have certified that adhere to the EU-US Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. For more information about the EU-US Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield website.

Model Clauses: We rely in the Commission’s model contracts for the transfer of personal data to third countries (i.e. the standard contractual clauses) pursuant to Decision 2010/87/EU when transferring your information to our US service providers who do not adhere to the US Department of Commerce’s EU-US Privacy Shield.

  1. COOKIES

We use technology such as “cookies” to collect information and store your online preferences. Cookies are small pieces of information sent by a web server to a web browser, which allows the server to uniquely identify the browser on each page.

We use the following categories of cookies on our Website:

 CATEGORY 1: STRICTLY NECESSARY COOKIES These cookies are essential in order to enable you to move around the website and use its features. Without these cookies, services you have asked for such as remembering your login details or shopping basket items cannot be provided.§

 CATEGORY 2: PERFORMANCE COOKIES These cookies collect anonymous information on how you use our Website. For example, we use Google Analytics cookies to help us understand how customers arrive at our site, browse or use our site and highlight areas where we can improve areas such as navigation, shopping experience and marketing campaigns. The data stored by these cookies does not show personal details from which your individual identity can be established. You may opt-in to these cookies using your browser settings..§

 CATEGORY 3: FUNCTIONALITY COOKIES These cookies remember choices you make such as the country you visit our website from, language and search parameters such as size, colour or product line. These can then be used to provide you with an experience more appropriate to your selections and to make the visits more tailored and pleasant. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites. You may opt into these cookies using your browser settings.§

 CATEGORY 4: TARGETING COOKIES OR ADVERTISING COOKIES These cookies collect information about your browsing habits in order to make advertising more relevant to you and your interests. They are also used to limit the number of times you see an advert as well as help measure the effectiveness of an advertising campaign. The cookies are usually placed by third-party advertising networks. They remember the websites you visit and that information is shared with other parties such as advertisers. For example, we use third-party companies to provide you with more personalised adverts when visiting other websites. You may opt-in to these cookies using your browser settings.§

 CATEGORY 5: SOCIAL MEDIA COOKIES These cookies allow you to share what you’ve been doing on the website on social media such as Facebook and Twitter. Please refer to the respective privacy policies for how their cookies work. If you want to delete any cookies that are already on your computer, please refer to the help and support area on your Internet browser for instructions on how to locate the file or directory that stores cookies. Information on deleting or controlling cookies is available at www.AboutCookies.org. Please note that by deleting our cookies or disabling future cookies you may not be able to access certain areas or features of our Website.§

You can withdraw your consent to these cookies at any time through the following options:

Please note that refusing cookies does not mean you will no longer receive online advertising. It does mean that the company or companies from which you opted out will no longer deliver adverts tailored to your web preferences and usage patterns, so you may see a greater number of adverts that are irrelevant to you and your preferences.

  1. SECURITY

Keeping you and your personal information secure is very important to us. We take a number of reasonable steps to try to protect the personal information that you provide, including:

  1. HOW LONG WILL YOU USE MY INFORMATION FOR?

We retain the data you provide to us for as long as you have your account with us and thereafter for such period as you may have questions or a claim in relation to our services, notwithstanding any superior retention period that we may be obliged to observe in accordance with legal requirements applicable to us.

In some circumstances, you can ask us to delete your data as set out below.

After you have terminated your use of our services, we may store your information in an aggregated and anonymised format.

  1. WHAT ARE MY PRIVACY RIGHTS?

You have certain rights in relation to the personal data we hold about you, which we detail below. Some of these only apply in certain circumstances as set out in more detail below. We also set out how to exercise those rights. Please note that we will require you to verify your identity before responding to any requests to exercise your rights and that can include asking a set of security questions to ensure it is you. When you have appointed someone else to do the request on your behalf, that person and/or organization needs to show a valid power of attorney issued by you. We must respond to a request by you to exercise those rights without undue delay and at least within one month (although this may be extended by a further two months in certain circumstances). To exercise any of your rights, please contact us at privacy@blackysmenswear.com.

You can also request a copy of your information. If you require more than one copy of the data we hold about you, we may charge a reasonable administration fee.

We may not provide you with certain personal data if providing it would interfere with another’s rights (e.g. where providing the personal data we hold about you would reveal information about another person) or where another exemption applies.

 you believe that it is no longer necessary for us to hold the personal data we hold about you;§

 we are processing the personal data we hold about you on the basis of your consent, and you wish to withdraw your consent and there is no other ground under which we can process the personal data;§

 we are processing the personal data we hold about you on the basis of our legitimate interest and you object to such processing. Please provide us with detail as to your reasoning so that we can assess whether there is an overriding interest for us to retain such personal data;§

 you no longer wish us to use the personal data we hold about you in order to send you promotions and special offers;§

 you believe the personal data we hold about you is being unlawfully processed by us.§

Also, note that you may exercise your right to restrict our processing the data whilst we consider your request as described below.

Please provide as much detail as possible on your reasons for the request to assist us in determining whether you have a valid basis for erasure. Please note, however, that we may retain the personal data if there are valid grounds under law for us to do so (e.g., for the defence of legal claims or freedom of expression) but we will let you know if that is the case.

Where you have requested that we erase data that we have made public and there are grounds for erasure, we will use reasonable steps try to tell others that are displaying the data or providing links to the data to erase the data too.

Please scroll down to know the cases where you may request we stop processing and just store the personal data we hold about you.

 you believe the personal data is not accurate for the period it takes for us to verify your claim;§

 we wish to erase the personal data as the processing we are doing is unlawful but you want us to retain the personal data for storage but not further process it;§

 we wish to erase the personal data as it is no longer necessary for our purposes but you require it to be stored for the establishment, exercise or defence of legal claims; or§

 you have objected to us processing personal data we hold about you on the basis of our legitimate interest and you wish us to stop processing the personal data whilst we determine whether there is an overriding interest in us retaining such personal data.§

You also have the right to object to our processing of data about you and we will consider your request in other circumstances as detailed below: o we are processing the data we hold about you (including where the processing is profiling) on the basis of our or a third party’s legitimate interest and you object to such processing. Please provide us with detail as to your reasoning so that we can assess whether there is a compelling overriding interest in us continuing to process such data or we need to process it in relation to legal claims. Also, note that you may exercise your right to request that we stop processing the data whilst we make the assessment on an overriding interest;

  1. COMPLAINTS

If you have any questions or concerns about this Privacy Policy, please contact us:

This is without prejudice to your right to launch a claim with the Information Commissioner’s Office (www.ico.org.uk) or the data protection supervisory authority in the EU country in which you live or work where you think we have infringed data protection laws.”

  1. UPDATES TO THIS POLICY

Any changes we may make to this Privacy Policy in the future will be posted on this page and, where appropriate, notified to you by email. Please check back regularly to keep informed of updates or changes to this Privacy Policy.