Effective May 25th 2018
PART ONE: OVERVIEW
What is Personal Data?
Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).
What is Usage Data?
Usage Data is data collected automatically either generated by the use of the websites or from the websites infrastructure itself (for example, the duration of a page visit).
What are Cookies?
What is a Data Controller?
Data Controller means a natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal data are, or are to be, processed.
Who are the Data Processors (or Service Providers)?
Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller (Dubarry Shoes). We may use the services of various Service Providers in order to process your data more effectively. See below – How we use Data Processors?
What is a Data Subject?
Data Subject is any living individual who is the subject of Personal Data.
What is a User?
The User is the individual using our Service. The User corresponds to the Data Subject, who is the subject of Personal Data.
Dubarry Shoes as Data Controller
Dubarry of Ireland
Ballinasloe, County Galway, H53 H6F3
Tel: +353 90 9642348
Companies register: DUBARRY SHOES, a company registered in the United Kingdom
Company registration number: 93696
Authorised representative: Mr. Ruairi Guckian
VAT registration number: VAT NO. 944 0865 10
Storing your data
The data that we collect from you is stored and processed within the European Economic Area (“EEA”). Any changes to our current method or location for storing or processing your data will be documented within this policy and updated on this website.
How we use Data Processors
From time to time, we will share your personal data with third parties to enhance the offering of our services to you and improve your user experience on our websites.
There are different types of third party Data Processors used for specific purposes as described below. You will be informed if you are obliged to provide personal data to enter a contract (place an order on our websites) and the impact of choosing not to.
PART TWO: HOW DO WE USE YOUR DATA?
ORDERING FROM OUR WEBSITE
We will use your personal data to manage your website order at www.dubarryboots.com. Managing your website order includes;
1. Processing your website order(s) on www.dubarry.com/ie
2. Processing your website returns on www.dubarry.com/ie
3. Managing your website order payments*
4. Sending you email/text notifications of delivery status of the website order
5. Retaining your personal data for product warranty
6. Retaining your personal data to handle customer complaints
*Please note that credit/payment card information is encrypted and sent over a secure server.
What types of personal data do we process for website orders?
1. Account Information for users who create an account on our website, www.dubarry.com/ie
1. User ID
2. Password (in encrypted format)
3. Purchase history
4. Contact Information
1. name, address, e-mail address and telephone number
2. Payment Information
1. payment history
2. credit information
3. order information
Who has access to your personal data?
Your privacy is of utmost importance to us. Continuing to use our services indicates your agreement with the ways in which we process and use your data as set out within this policy.
Dubarry Shoes use the Magento CE Shopping Cart. All account information for website customers is stored in a secure database on the Magento platform.
DUBARRY SHOES and our website Services partners (DPD, COLLECTPLUS, SCURRI, SAGEPAY, MOLLIE, PAYPAL, UNIRGY, PRIMA SOLUTIONS) process customers’ personal information (for example, customer name, email address, and shipping address) and are therefore considered separate and independent data controllers of customers’ personal information under EU law. That means that each party is responsible for the personal information it processes in providing the Services. DUBARRY SHOES is currently in the process of securing written assurances for third party services that they are complying with current data protection laws.
HOW LONG DO WE STORE YOUR DATA?
For Dubarry Shoes Marketing Mailing List Subscribers, the time limit for data storage is 24 months. For Dubarry Shoes Customer Lists the time limit for data storage is 5 years.
We will use your personal data to send you marketing offers, new product launch announcements and invitations to store events in your area via emails, provided you have given explicit consent to being part of our email marketing list.
In order to optimise your experience on www.dubarryboots.com, we may provide you with relevant information, recommended products, send you reminders of products left in your shopping bag and send you personalised offers. All these services are based on your previous purchases, browsing activity and click through information on our website, provided you have given explicit consent to being part of our email marketing list.
What types of personal data do we process?
We will process following categories of personal data
· contact information such as name, email address and telephone number
· gender (if you choose to provide that to us)
· products and offers that we feel may be of interest to you
If you have a Dubarry Shoes online account, we will also process your personal data submitted in relation to the account and membership such as:
· shopping history
· pages visited on www.dubarryboots.com
Dubarry of Ireland may disclose your information to our third party service providers, agents and suppliers for the purposes of providing services to us or directly to you on our behalf, including the mailing of catalogues. All suppliers that work for us will be obliged to follow our instructions and sign a contract that requires recipients to protect your personal information.
When Dubarry use contractors, we only disclose to them any personal information that is necessary for them to provide their services and only where we have a contract in place that requires them to keep your information secure and only use it in accordance with Dubarry’s specific instructions.
PART THREE: WHAT ARE YOUR RIGHTS?
Right to access:
You have the right to request information about the following at any time:
1. Categories of personal data we store relating to you
2. How long your personal data will be stored
3. The purpose of processing such data
4. Who is in receipt of such data
5. A copy of the collected personal data
Right to restriction of processing:
You have the right to restrict the processing of your personal data if you believe the following:
1. The data is inaccurate
2. The processing is unlawful
3. You have requested an erasure and the Data Controller is verifying it
4. if Dubarry Shoes no longer requires your personal data but it is needed by you to defend legal claims.
Right to rectification:
You have the right to request that your personal data be amended if the information in it is incorrect or untruthful. You also have a right to request that incomplete personal data is made complete.
Your Dubarry Shoes user account can be accessed at any time by you. While logged in to your user account, you have the ability to edit or amend your account or personal details at any time.
Right to erasure:
Your have a right to request that your personal data, processed by Dubarry Shoes, be removed within one month of communicating your request in the following circumstances:
1. Data was collected unlawfully
1. The time limit for the storage of the data has expired***
2. You object to your personal data being processed
3. Your data was collected when you were a child
4. The purpose of collecting and processing data has changed
5. Erasure is necessary in order to comply with EU or Member State law.
*** For Dubarry Shoes Marketing Mailing List Subscribers, the time limit for data storage is 24 months. For Dubarry Shoes Customer Lists the time limit for data storage is 5 years.
The following situations are exceptional to this:
· you have an ongoing matter with Customer Service
· you have an open order which has not yet been shipped or partially shipped
· you have an unsettled debt with Dubarry of Ireland, regardless of the payment method
· if you are suspected or have misused our services within the last four years
· your debt has been sold to a third party within the last three years or one year for deceased customers
· if you have made any purchase, we will be required to keep your personal data in connection to your transaction for inspection by the Revenue Department in your country. In this case, we would store transactional data for up to five years, so long as we have expired a period of redemption requested by the Revenue Department.
Your right to object to direct marketing:
You have the right to object to direct marketing from Dubarry Shoes, including analysis of your visitor behaviours and subscriptions made for direct marketing purposes.
How to exercise your rights under GDPR
You can opt out from direct marketing in the following ways:
For Email Marketing:
1. following the “unsubscribe” link in any of the marketing emails that you receive from us. You will be automatically unsubscribed from receiving any further marketing communication from us.
2. by editing the settings of your Dubarry Shoes account on www.dubarryboots.com.
3. by emailing [email protected] and requesting removal for the Dubarry Shoes marketing email list in your local market.
CAN I BE REMOVED FROM YOUR MAILING LIST?
Dubarry of Ireland will send catalogues by post to customers who have opted into our marketing communications. If you do not want to receive offers and promotions by post, let us know at [email protected] or by calling us on 01608677622 (Monday - Friday 9.00am to 16:30). Please remember our brochures are printed in advance so it can take up to eight weeks for the process to be complete and you may receive one further brochure.
CAN I GO BACK ON YOUR MAILING LIST?
If you have previously asked us not to send offers but have changed your mind please let us know by emailing [email protected] or calling us on +353 909642348 (Monday - Friday 9.00am to 16:30).
Dubarry of Ireland respect your privacy and are committed to protect it.
Data Protection Officer
We take data protection very seriously and therefore we have a dedicated data protection officer to handle your requests about storage, usage, amendments and erasure of personal data. You can email any questions that you may have to [email protected]. Please use Data Protection Query as the email subject.
Right to complain with a higher authority
If you feel that Dubarry Shoes has processed your personal data in a way that may not align with current data protection policies, you can contact Dubarry Shoes and you also the right to raise a complaint with the Data Protection authority in your country.