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Privacy Policy

Privacy Notice

This is the privacy notice of Perfect Moment (UK) Ltd. In this document, “we”, “our”, or “us” refer to Perfect Moment (UK) Ltd. We are the controller and are responsible for your personal information.

Introduction

This is a notice to inform you of our policy about all information that we record about you. This policy applies to you if you use our website, are a customer or a business partner or contact us directly. It sets out the conditions under which we may process any information that we process about you whether such information is collect from you, or otherwise provided to us. It covers information that identifies you either directly or indirectly (“personal information”). In the context of the law and this notice, “process” means collect, store, transfer, use or otherwise act on information.

We take seriously the protection of your privacy and confidentiality. We will only process your personal information where we have a lawful basis to do so and in compliance with this privacy policy.

We undertake to preserve the confidentiality of all confidential information you provide to us, and hope that you reciprocate.

We will process your personal information in accordance with this privacy policy and in compliance with UK law as applicable from time to time, including as required by the UK retained General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

The law requires us to tell you about your rights and our obligations to you in regards to the processing and control of your personal information. We do this now, by requesting that you read the information provided in this privacy policy and if you have any additional queries please contact us.

Except as set out below, we do not share, or sell, or disclose to a third party, any information collected through our website.

1. The Basis on Which We Process Information About You

The law requires us to determine under which of six defined bases we process different categories of your personal information, and to notify you of the basis for each category.

If a basis on which we process your personal information is no longer relevant then we shall immediately stop processing your data.

If the basis changes then if required by law we shall notify you of the change and of any new basis under which we have determined that we can legally continue to process your information.

1.1. Information we process because we have a contractual obligation with you

When you create an account on our website, buy a product or service from us, or otherwise agree to our terms and conditions, a contract is formed between you and us.

In order to carry out our obligations under that contract we must process the information you give us. Some of this information may be personal information.

Such personal information may include your name, contact details and the information of purchases you have made with us or services we have provided you.

We may use you personal information in order to:

1.1.1. verify your identity for security purposes;
1.1.2. sell products to you;
1.1.3. provide you with our services;
1.1.4. provide you with suggestions and advice on products, services and how to obtain the most from using our website (provided we have a lawful basis to do so).

We process this information on the basis there is a contract between us, or that you have requested we use the information before we enter into a legal contract.

Additionally, we may aggregate this information in a general way and use it to provide class information, for example to monitor our performance with respect to a particular service we provide. If we use it for this purpose, you as an individual will not be personally identifiable.

We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract or until we no longer have a lawful basis to process the personal information.

1.2. Information we process with your consent

Through certain actions when otherwise there is no contractual relationship between us, such as when you browse our website or ask us to provide you more information about our business, including our products and services, you provide your consent for us to process your personal information.

Wherever legally required, we will obtain your affirmative consent to process this information, for example, by asking you to agree to our use of cookies.

We continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists.

You may withdraw your consent at any time by instructing us at customerservice@perfectmoment.com.

1.3. Information we process for the purposes of legitimate interests

We may process information on the basis there is a legitimate interest to do so, either for us or a third party.

Where we process your information on this basis, we do after having given careful consideration to:

1.3.1. whether the same objective could be achieved through other means;
1.3.2. whether processing (or not processing) might cause you harm;
1.3.3. whether you would expect us to process your data, and whether you would, in the round, consider it reasonable to do so.

For example, we may process your data on this basis for the purposes of:

1.3.4. record-keeping for the proper and necessary administration of our organisational or business;
1.3.5. responding to unsolicited communication from you to which we believe you would expect a response;
1.3.6. protecting and asserting the legal rights of any party;
1.3.7. insuring against or obtaining professional advice that is required to manage out risk; or
1.3.8. protecting your interests where we believe we have a duty to do so.

1.4 Information we process because we have a legal obligation

We are subject to the law like everyone else. Sometimes, we must process your information in order to comply with a statutory or other legal obligation.

For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order.

This may include your personal information.

2. Specific Uses of Information You Provide Us

2.1. Aggregated data

We may collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal information but is not considered personal data in law as that data will not directly or indirectly reveal your identity. For example, we may aggregate your user data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal information so that it can directly or indirectly identify you, we treat the combined data as personal information which will only be used in accordance with this privacy policy.

2.2. Information relating to your method of payment

Payment information is never taken by us or transferred to us either through our website or otherwise. Our employees and contractors never have access to it.

At the point of payment, you are transferred to a secure page on the website of SagePay and Paypal payment service providers. That page may be branded to look like a page on our website, but it is not controlled by us.

2.3. Sending a message to our support team

When you contact us, whether by telephone, through our website or by e-mail, we collect the data you have given to us in order to reply with the information you need.

We record your request and our reply in order to increase the efficiency of our business and to respond to your request. We keep personal information associated with your message, such as your name and email address so as to be able to track our communications with you to provide a high quality service.

2.4. Complaints

When we receive a complaint, we record all the information you have given to us. We use that information to resolve your complaint. If so required, we may share personal information from your complaint with our advisors in order to get advice on how to resolve your complaint. Please see section 5 of this privacy policy for more information on how we may share your personal data.

We may aggregate information relating to your complaint in order to compile statistics showing information obtained from complaints to assess the level of service we provide, but not in a way that could identify you or any other person.

2.5. Business partner information

You may provide us with in your capacity as a business partner. Such information may allow us to recognise visitors that you have referred to us. We will only use information provided by you for the purpose for which it was provided.

We undertake to preserve the confidentiality of the information and of the terms of our relationship. The relationship with our business partners shall be governed by any contract we have in place with them.

3. Cookies

Cookies are small text files that are placed on your computer or device by your web browser when you visit any website. They allow information gathered on one web page to be stored until it is needed for use on another, allowing a website to provide you with a personalised experience and the website owner with statistics about how you use the website.

Some cookies may last for a defined period of time, such as one day or until you close your browser. Others last indefinitely.

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.

Our website uses cookies. They are placed by software that operates on our servers, and by software operated by third parties whose services we use.

When you first visit our website, we ask you whether you wish us to use cookies that are not strictly necessary for the operation of our website. If you choose not to accept them, we shall not use them for your visit except to record that you have not consented to their use for any other purpose.

Subject to your consent and cookie settings, we use cookies in the following ways:

3.1. to track how you use our website;
3.2. to record whether you have seen specific messages we display on our website;
3.3. to keep you signed in our site;
3.4. to record your answers to surveys and questionnaires on our site while you complete them;
3.5. to customise content and advertising;

Personal identifiers from your browsing activity

Requests by your web browser to our servers for web pages and other content on our website are recorded.

We record information such as your geographical location, your Internet service provider and your IP address. We also record information about the software you are using to browse our website, such as the type of computer or device and the screen resolution.

We use this information in aggregate to assess the popularity of the webpages on our website and how we perform in providing content to you.

If combined with other information we know about you from previous visits, the data possibly could be used to identify you personally, even if you are not signed in to our website.

4. Our Use of Re-Marketing

Re-marketing involves placing a cookie on your computer when you browse our website in order to be able to serve to you an advert for our products or services when you visit some other website.

We may use a third party to provide us with re-marketing services from time to time. If so, then if you have consented to our use of cookies, you may see advertisements for our products and services on other websites.

5. Disclosure and Sharing of Your Information

We may share your personal information with third parties for the purposes we have detailed within the privacy policy. In particular, we may share your personal information with:

  • Internal third parties which may include other companies within the Perfect Moment group; and

  • External third parties which include:

  • Services providers acting as processors based within the UK, EU or internationally including payment providers, IT and system administration services;

  • Professional advisers including lawyers, bankers, auditors and insurers based in the UK, EU or internationally who provide consultancy, banking, legal, insurance and accounting services;

  • HM Revenue & Customers, regulators and other authorities who require reporting of processing activities in certain circumstances;

  • Third parties to whom we may choose to sell, transfer or merge all or part of our business or 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 information in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal information and to treat it in accordance with all applicable law. We do not allow our third-party service providers or partners to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.

5.1. Credit reference

To assist in combating fraud, we share information with credit reference agencies, so far as it relates to clients or customers who instruct their credit card issuer to cancel payment to us without having first provided an acceptable reason to us and given us the opportunity to refund their money.

5.2. Data may be processed outside the United Kingdom or European Union

Our website is hosted in the United Kingdom

We may also use outsourced services in countries outside the European Union from time to time. Accordingly data obtained within the UK or any other country could be processed outside the European Union.

We use the following safeguards with respect to data transferred outside the UK or the European Union:

5.2.1. the country to which we are transferring personal information has been deemed adequate by the Information Commissioner’s Officer or the European Commission (as recognised by the Information Commissioner’s Office);
5.2.2. the data protection clauses in our contracts with data processors or data controllers based outside the UK include standard contractual clauses approved by the Information Commissioner’s Office.

6. Data Subject Rights

Under applicable data protection law, you have rights of which we would like to make you aware. The rights available to you depend on our reason for processing your personal information. If you wish to exercise your rights as a data subject you may send us a request at customerservice@perfectmoment.com.

When we receive any request to access, edit or delete personal identifiable information we shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.

6.1. Access to your personal information

At any time you may review or update personally identifiable information that we hold about you, by signing in to your account on our website.

You have a right to ask us for copies of your personal information.

6.2. Rectification of your information

You have a right to ask us to rectify information we hold about you that you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.

6.3. Removal of your information

You have the right to request that the personal information we hold on you is erased in certain circumstances.

6.4. Objection to processing

You have the right to object to processing if we are able to process your information on the basis of our legitimate interest.

6.5. Data portability

For information that you have given us, you have the right to ask that we transfer the information you gave us to another organisation, or give it to you. This right only applies if we are processing information based on your consent or under the terms of a contract we have with you.

6.6. Restriction of processing

You have a right to ask us to restrict the processing of your personal information in certain circumstances.

7. Other Matters

7.1. Use of site by children

We do not sell products or provide services for purchase by children, nor do we market to children. If you are under 18, you may use our website only with consent from a parent or guardian.

7.2. Encryption of data sent between us

We use Secure Sockets Layer (SSL) certificates to verify our identity to your browser and to encrypt any data you give us. Whenever information is transferred between us, you can check that it is done so using SSL by looking for a closed padlock symbol or other trust mark in your browser’s URL bar or toolbar.

7.3. How you can complain

7.3.1. If you are not happy with our privacy policy or if have any complaint then you should tell us by email. Our address is customerservice@perfectmoment.com.
7.3.2. If a dispute is not settled then we hope you will agree to attempt to resolve it by engaging in good faith with us in a process of mediation or arbitration.
7.3.3. If you are in any way dissatisfied about how we process your personal information, you have a right to lodge a complaint with the Information Commissioner’s Office. This can be done at ico.org.uk/concerns/.

7.4. Retention period for personal data

Except as otherwise mentioned in this privacy notice, we keep your personal information only for as long as required by us:

7.4.1. to provide you with the services you have requested;
7.4.2. to comply with other law, including for the period demanded by our tax authorities;
7.4.3. to support a claim or defence in court.

In any event, we will not retain any personal information for longer than is necessary to fulfil the purpose for which it was collected.

7.5. Compliance with the law

Our privacy policy has been compiled so as to comply with the law of every country or legal jurisdiction in which we aim to do business. If you think it fails to satisfy the law of your jurisdiction, we should like to hear from you.

8. Review of this Privacy Policy

We may update this privacy notice from time to time as necessary. The terms that apply to you are those posted here on our website on the day you use our website. We advise you to print a copy for your records.

If you have any question regarding our privacy policy, please contact us.


Klarna Cookie Notices

Klarna Bank AB (publ) (“Klarna”) uses cookies to recognize the user’s device for the purpose of providing personalized advertising of Klarna products the next time the user will browse a merchant website offering Klarna products, and for analytics purposes.

Persistent marketing and analytics cookies

These cookies contain a unique user ID which will enable Klarna to recognize the user’s device the next time that user returns to a merchant using Klarna’s services. These are persistent cookies, stored on the device for a period of up to 540 days as of the last interaction with Klarna, or until they are deleted and allow Klarna (i) to show personalized marketing of Klarna products, including credit promotions to the user, and (ii) to perform analytics of the user behaviour.

By connecting the unique user ID stored in the cookie on the device to the information Klarna has about the user, Klarna will be able to recognize the user of that device. The information Klarna collects through the cookies is not shared with any third party.

The user’s consent and revocation of consent

Setting cookies for marketing purposes is subject to the user’s consent, which will have to be obtained before the cookies are set on the user’s device. In addition, the web browser or device often allows the user to change the settings for the use of cookies. More information on how to adjust the settings can be found in the browser of device reference information, and on aboutcookies.org.

About Klarna

Klarna Bank AB (publ) is subject to Swedish Data Protection legislation, and is the data controller for the purpose of processing the personal data as described above. Klarna has a data protection officer and a team consisting of personal data experts. Klarna also has a customer service team handling questions relating to personal data. You are welcome to contact Klarna at dataskydd@klarna.se. Please visit www.klarna.com for more information about Klarna, and how Klarna processes personal data.

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