Privacy policy
Introduction
Important information and who we are
Hello! Welcome to Estrid’s privacy policy for users of our website https://estrid.com.
This privacy policy is issued, if you are in the UK, in accordance with the UK GDPR. If you are based in the EU, the privacy policy is issued in accordance with the EU GPDR (the UK GPDR together with the EU GDPR, the Applicable Data Protection Laws).
We will process your personal data in accordance with the Applicable Data Protection Laws, depending on which apply to you as a data subject.
We take data privacy extremely seriously. This privacy policy gives you information about how Estrid collects and uses your personal data.
This privacy policy is for:
o Potential and current customers that are individual consumers
o The staff of customers and potential customers that are organisations
o Potential and current suppliers (including wholesalers) and their staff
o Users of the Website
o Job applicants
The Website and our products and subscriptions are not intended for children and we do not knowingly collect personal data relating to children.
This privacy policy is in addition to any other privacy policy any member of the Estrid group may issue from time to time.
The controller of your personal data is Estrid Studios AB. Its registration number is 559197-2400 and its address is Grev Turegatan 30, 114 38 Stockholm.
If you have any questions about this privacy policy, the specific identity of the controller of the personal data provided by you or collected by us or in respect of any requests to exercise your legal rights (section 8) using the information set out in the contact details section (section 9).
1. The types of personal data we collect about you
Personal data means any information about an individual from which that person can be identified.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
· Identity Data includes first name, last name, any previous names, marital status, title, date of birth and gender.
· Profile Data includes, where you create an account with us on the Website, your username (or similar identifier), password, purchases or orders made by you, your interests and preferences.
· Contact Data includes billing address, delivery address, email address and telephone numbers.
· Correspondence Data any additional personal data you provide to us when you contact us, whether directly or via the chat function on the Website.
· Feedback Data any reviews, ratings or feedback you provide in respect of our products (which may be displayed on our Website).
· Financial Data includes bank account and payment card details.
· Transaction Data includes details about payments to and from you and, where applicable, other details of products and subscriptions you have purchased from us.
· Subscription Data includes your preferences around your purchase of a product subscription from us.
· 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, device ID and other technology on the devices you use to access this Website.
· Usage Data includes information about how you interact with and use our Website, products and subscriptions.
· Marketing and Communications Data includes your preferences in receiving marketing from us (such as our newsletter) and our third parties and your communication preferences.
· CV Data includes information about you that would appear in a CV or other media.
Aggregated Data
We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific Website feature in order to analyse general trends in how users are interacting with our Website to help improve the Website and our service offering.
Special Category Personal Data
You may have heard special category personal data be called ‘sensitive’ data. Special category personal data is subject to enhanced protections under the Applicable Data Protection Laws. It includes:
· Personal data revealing racial or ethnic origin
· Personal data revealing political opinions
· Personal data revealing religious or philosophical beliefs
· Personal data revealing trade union membership
· Genetic data
· Biometric data (where it is used for identification purposes)
· Personal data concerning health
· Personal data concern a person’s sex life
· Personal data concerning a person’s sexual orientation
We do not intentionally collect any special category personal data as part of our organisation’s day-to-day activities or as a requirement of supplying our products, if you purchase our products from us.
However, you could potentially provide Special Category Personal Data to us if you provide us with Correspondence Data which, for example, contains information about a skin condition you may have. In these circumstances we would be processing personal data concerning your health. The same is true in respect of any other special category personal data you provide to us.
2. How is your personal data collected?
We use different methods to collect data from and about you including through:
· Your interactions with us. You may give us your personal data by filling in online forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
· purchase our products or a subscription for them;
· supply or offer to supply your or your organisation’s goods or services to us;
· apply for a job with us;
· create an account on our Website (and manage it);
· request marketing to be sent to you;
· enter a competition, promotion or survey; or
· give us feedback or contact us.
· Automated technologies or interactions. As you interact with our Website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy [LINK] for further details.
· Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources such as LinkedIn when you apply for a job with us or want to supply goods or services to us.
· Technical Data is collected from analytics providers such as Google based outside the UK and EEA.
· Contact, Financial and Transaction Data is collected from providers of technical, payment and delivery services such as PayPal or Apple Pay based inside and outside the UK and EEA. We may also indirectly receive personal data from our storefront provider Shopify, if you purchase a product or subscription from us.
3. How we use your personal data
The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:
· Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
· Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Where we process special category personal data (as set out above), we must identify both a lawful basis for processing that data and further identify a special condition (set out below).
· Explicit consent: This means where you have given us clear consent for us to process your special category personal data.
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 the various categories of 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.
|
Purpose/Use |
Type of data |
Legal basis |
|
To process and deliver your order, including to manage payments, fees, charges and refunds (if you are individual that is our customer) |
(a) Identity (b) Contact (c) Financial (d) Transaction (e) Profile |
Performance of a contract with you
|
|
To manage your subscription |
(a) Identity (b) Contact (c) Financial (d) Transaction (e) Profile (f) Subscription |
Performance of a contract with you |
|
To manage our relationship with you by notifying you about changes to our terms or privacy policy or to address your requests, complaints or queries (where you are an individual customer) |
(a) Identity (b) Contact (c) Financial (d) Transaction (e) Profile (f) Correspondence |
Performance of a contract with you |
|
To process and deliver your order, including to manage payments, fees, charges and refunds (if you are an employee of an organisation that is our customer)
|
(a) Identity (b) Contact (c) Financial (d) Transaction
|
Necessary for our legitimate interests (to sell our products to your organisation)
|
|
To manage our relationship with you by notifying you about changes to our terms or privacy policy or to address your requests, complaints or queries (if you are an employee of an organisation that is our customer) |
(a) Identity (b) Contact (c) Financial (d) Transaction (e) Correspondence |
Necessary for our legitimate interests (to manage our relationship with your organisation)
|
|
To enable you to create a profile on our Website (or one is automatically created for you where you are an individual customer) |
(a) Identity (b) Contact (c) Financial (d) Transaction (e) Profile
|
Necessary for our legitimate interests (to make the purchase of our products and subscriptions more seamless)
|
|
To publish and manage any contribution you may make about us or our products to our Website (including any ratings of our products) |
(a) Identity (b) Contact (c) Profile (d) Correspondence (e) Feedback |
Necessary for our legitimate interests (to share your opinions on our products or other relevant material to other customers) |
|
To receive your or your organisation’s goods or services |
(a) Identity (b) Contact (c) CV (d) Financial (e) Transaction |
Necessary for our legitimate interests (to receive the supply of goods or services to us) |
|
To manage our relationship with you by notifying you about changes to our terms or privacy policy or to address your requests, complaints or queries (where you or your organisation supplies goods or services to us) |
(a) Identity (b) Contact (c) Correspondence |
Necessary for our legitimate interests (to manage our relationship with suppliers) |
|
To consider whether to receive your or your organisation’s goods or services |
(a) Identity (b) Contact (c) CV
|
Necessary for our legitimate interests (to consider the supply of goods or services to us) |
|
To consider your application for a job with us |
(a) Identity (b) Contact (c) CV
|
Necessary for our legitimate interests (to recruit additional staff) |
|
To respond to your enquiries about our products (where you are not our customer or your organisation is not a customer of ours) |
(a) Identity (b) Contact (c) Correspondence |
Necessary for our legitimate interests (to respond to your queries to attract new customers and improve our products) |
|
To respond to your enquires about our products, where you provide us with special category personal data (whether or not you are our customer or your organisation is a customer of ours) |
(a) Identity (b) Contact (c) Correspondence |
Necessary for our legitimate interests (to respond to your queries to attract new customers and improve our products) Special condition: explicit consent |
|
To enable you to partake in a prize draw, competition or complete a survey |
(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications |
Necessary for our legitimate interests (to study how customers use our products/subscriptions, to develop them and grow our business)
|
|
To administer and protect our business and the Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
(a) Identity (b) Contact (c) Technical |
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)
|
|
To deliver relevant Website content and online 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/subscriptions, to develop them, to grow our business and to inform our marketing strategy) |
|
To use data analytics to improve our Website, products, customer relationships and experiences and to measure the effectiveness of our communications and marketing |
(a) Technical (b) Usage (c) Feedback |
Necessary for our legitimate interests (to define types of customers for our products, to keep our Website updated and relevant, to develop our business and to inform our marketing strategy)
|
|
To send you relevant marketing communications and make personalised suggestions and recommendations to you about products that may be of interest to you |
(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications |
Necessary for our legitimate interests (to carry out direct marketing, develop our products/subscriptions and grow our business)
|
|
To carry out market research through your voluntary participation in surveys |
(a) Identity (b) Contact (c) Feedback (d) Marketing and Communications |
Necessary for our legitimate interests (to study how customers use our products/subscriptions and to help us improve and develop our products)
|
During, the purchase process on our Website, when you create an account (or when you manage it) on our Website or subscribe to our newsletter, you will be asked to indicate your preferences for receiving direct marketing communications from us via email and SMS. You may also receive marketing communications from us if you have requested information from us or purchased products from us and you have not opted out of receiving the marketing.
We may also analyse your Identity, Contact, Technical, Usage and Profile Data to form a view which products and offers may be of interest to you so that we can then send you relevant marketing communications.
We will get your express consent before we share your personal data with any third party for their own direct marketing purposes.
You can ask to stop sending you marketing communications at any time by logging into the Website and checking or unchecking relevant boxes to adjust your marketing preferences, by following the opt-out links within any marketing communication sent to you or by contacting us.
If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes for example relating to order confirmations and updates for a product or subscription, updates to our terms or this privacy policy or to check that your contact details are correct.
For more information about the cookies we use and how to change your cookie preferences, please see [LINK].
4. Disclosures of your personal data
We may share your personal data where necessary with the parties set out below for the purposes set out in the table above.
· Internal Third Parties such as other members of the Estrid group.
· External Third Parties such as:
o our delivery and logistic partners
o marketplace providers like Shopify
o payment providers
o Advertising partners like Google or Meta
· 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.
We share your personal data within the Estrid group. If you are based in the UK, this will involve transferring your data outside the UK to our overseas offices in Sweden (in the EEA). As Sweden is in the EEA, this is not an international transfer for the purposes of the EU GDPR.
We may transfer your personal data to service providers that carry out certain functions on our behalf. This may involve transferring personal data outside the UK or EEA to countries which have laws that do not provide the same level of data protection as the UK law.
Whenever we transfer your personal data out of the UK or EEA to countries which have laws that do not provide the same level of data protection as the UK or EU (as applicable) law, we always ensure that a similar degree of protection is afforded to it by using specific standard contractual terms approved for use in the UK or EEA which give the transferred personal data the same protection as it has in the UK or EEA. To obtain a copy of these contractual safeguards, please contact us.
6. 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.
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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, regulatory, tax, accounting or other 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 and other legal purposes.
In some circumstances you can ask us to delete your data: see below for further information.
In some circumstances we will 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.
You have a number of rights under data protection laws in relation to your personal data.
· Request access to your personal data (commonly known as a "subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
· Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
· Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
· Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
· You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes (see opting out of marketing in section 3 for details of how to object to receiving direct marketing communications).
· Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
· Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
· If you want us to establish the data's accuracy;
· Where our use of the data is unlawful but you do not want us to erase it;
· Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
· You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
If you wish to exercise any of the rights set out above, please contact us (see section 9).
You will not 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 if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
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.
We try to respond to all legitimate requests within one month. Occasionally it could 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.
If you have any questions about this privacy policy or about the use of your personal data or you want to exercise your privacy rights, please contact us in the following ways:
· Email address: hello@estrid.com
· Postal address: please use the for us address set out at the beginning of this privacy policy.
If you’re based in the UK, you have the right to make a complaint at any time to the Information Commissioner’s Office, the UK regulator for data protection issues (www.ico.org.uk).
If you’re based in the Republic of Ireland, you can complain to the Irish data supervisory authority (the Data Protection Commission), the Irish regulator for data protection issues (https://www.dataprotection.ie/en).
We would, however, appreciate the chance to deal with your concerns before you approach your regulator so please contact us in the first instance.
11. Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review. This version was last updated on [DATE]. Historic versions can be obtained by contacting 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, for example a new address or email address.
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 policy of every website you visit.