PLEASE READ THIS POLICY CAREFULLY BEFORE USING STYLESCAPE LIMITED’S (TRADING AS EDITED) SERVICES
At Stylescape Limited (“ EDITED ”, “ us ”, “ our ” or “ we ”), we take the protection of your data, privacy and personal information very seriously. It is vitally important to us that you feel secure when using our website at www.edited.com (the “Website”).
Information we may collect
We may collect and process the following data about you:
- Information that you provide to us. You will be asked to provide us with your information when:
- you fill in forms on our Website, or correspond with us by phone, email or otherwise;
- you register to use the Website, subscribe to our newsletter, promotional emails or other marketing materials;
- you report a problem with the Website; or
- you complete any surveys we ask you to fill in that we use for research purposes (although you do not have to respond to these if you do not want to).
The information you will be asked to provide to us for these purposes may include your name, job title, job field, email address, phone number, markets you are interested in, reports you are interested in, company name, company type, job function or further information required to verify your identity.
- Information we collect about you. With regard to each of your visits to our Website we may automatically collect the following information; however, this information cannot be used to identify you:
- device-specific information, such as your hardware model, operating system version, unique device identifiers, and mobile network information;
- details of your visits to our Website, including the full Uniform Resource Locators (URL) clickstream to, through and from our Website (including date and time), length of visits to certain pages , and page interaction information (such as scrolling, clicks, and mouse-overs);
- details about your location, approximated using data provided by you and other third-parties;
- details about your interaction with emails and other communication received by us, including opening rate of emails and clickstream through our emails;
If you are using our Website on behalf of a third party, you must have obtained clear permission from the individuals whose data you provide us with before sharing that data with us.
How we use your information and justification of use.
Use of personal information under EU data protection laws must be justified under one of a number of legal “grounds” and we are required to set out the ground in respect of each use of your personal data in this policy. These are the principal grounds that justify our use of your information:
- Consent: where you have consented to our use of your information (you are providing explicit, informed, freely given consent, in relation to any such use and may withdraw your consent in the circumstance detailed below by notifying us);
- Contract performance: where your information is necessary to enter into or perform our contract with you;
- Legal obligation: where we need to use your information to comply with our legal obligations;
- Legitimate interests: where we use your information to achieve a legitimate interest and our reasons for using it outweigh any prejudice to your data protection rights; and
- Legal claims: where your information if necessary for us to defend, prosecute or make a claim against you or a third party.
- We use information held about you (and information about others that you have provided us with) in the following ways:
|Types of Information Collected||Uses of that Information||Use Justification|
|Name, email address, phone number, company, job title and field, how you heard about us||To provide a demo of our service at your request and register you as a potential new customer||Contract performance (taking preparatory steps to enter into a contract on your request); Legitimate interest (provision of a demo)|
|Name, email address, phone number, company, job title||To get in touch with you (by email, telephone or otherwise) to inform you about our services, how they may be of relevance to you and potentially provide a demo||Contract performance; Legitimate interest (prospecting of new customers)|
|Name, email address, job title, company, markets and reports you are interested in, email opening rates and clickstream through emails||To send you our newsletter and industry trends, invite you to events and send you updates on our products and services that we believe might be of interest to you||Consent (when you subscribe to our newsletter on the Website). Legitimate interest (for marketing our own similar products and services and any re-engagement campaigns)|
|Job title and field, markets and reports you are interested in, company name, location||To identify more appropriate products, events and services to market to you||Consent (by updating your preferences when you subscribe to our newsletter on the website)|
|Details of visits to our Website, cookie information, URL, IP address, clickstream to, through and from our Website, length of visits to certain pages and access to our services, and page interaction information (such as scrolling, clicks, and mouse-overs)||To administer the Website and for internal operations, including research, data analysis and data statistics, and to create derived, anonymised and aggregated data to maintain, improve and update our Website.||Legitimate interests (to administer and improve our Website).|
|Email address||To notify you about changes to our Website or our customer terms.||Legitimate interests (to update our Website from time to time).|
We reserve the right to collect anonymous and/or aggregated data regarding your and other visitors or customers’ use of the Website, provided that no individual natural person can be identified from such data (“ Aggregate Data ”). The Aggregate Data is used to improve and enhance the Website and for other development, diagnostic and corrective purposes in connection with the Website.
We will not sell your personal data (or any other data you provide us with) to third-parties, however, we reserve the right to share any data, which has been anonymised and/or aggregated. You acknowledge and accept that we own all right, title and interest in and to any derived data or aggregated and/or anonymised data collected or created by us.
We will provide an option to unsubscribe or opt-out of further communication on any electronic marketing communication sent to you or you may opt out by contacting us.
Where we store and how we protect your personal information
We take the security of your personal information very seriously.
We ensure appropriate technical and organizational measures are in place to make sure the personal data we collect from you (including email addresses that form part of our prospective marketing database) is secure at all time. Where we use sub-processors, we ensure those organizations contractually provide appropriate technical and organizational measures to ensure similar levels of safeguards. A full list of our third party sub-processing activities can be found here www.edited.com/subprocessing.
Countries outside the European Economic Area (“EEA”) may not provide the same level of adequate protection for the rights and freedoms of data subjects in relation to the processing of personal data. In countries which do not provide appropriate safeguards, we shall transfer your data subject only to your consent except for transfers to and from: (i) any country with a valid adequacy decision from the European Commission; (ii) any country with which we have ensured similar levels of safeguards have contractually been put in place (this may include entering into standard contractual clauses) ; or (ii) any organization, including any of our sub-processors, which ensures an adequate level of protection in accordance with applicable data protection laws.
Please contact us if you would like further details on the specific safeguards applied to the export of your personal information outside EEA.
Although EDITED will do its best to protect your personal data, the transmission of information via the internet is not completely secure, any transmission is at your own risk and we cannot guarantee, during transmission through the internet, the security of your data transmitted to our Website.
Disclosure of your information
We may also disclose your personal information to third parties in the following circumstances:
|Purpose of disclosure and third party(s) to which disclosure might be made||Use Justification|
|We may disclose your personal information to our service providers and business partners, including third party software providers (to assist us in performing any contract we enter into with them or you, including providing our Website it enables), analytics providers, (to assist us in the improvement and optimisation of the Website) and/or a member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.||Contract performance, legitimate interest, (to allow our service providers to provide the necessary services).|
|If we sell or buy any business or assets, we may disclose your personal information to the prospective seller or buyer of such business or assets||Legitimate interest (to sell our business or assets); Consent (for sensitive personal data)|
|If EDITED or substantially all of its assets are acquired by a third party, personal information about our customers will be one of the transferred assets||Legitimate interest (to sell our Company or assets), Consent (for sensitive personal data)|
|If we are under a duty to disclose or share your personal data in order to comply with any legal obligation or to protect the rights, property, or safety of EDITED, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection||Legal obligation|
|Fraud Prevention and other checks. We and other organisations may also access and use your personal information to conduct credit checks and checks to prevent fraud. If false or accurate information is provided and fraud is identified or suspected, details may be passed to fraud prevent agencies.||Legitimate interest (to assist with the prevention of fraud and to assess your risk profile)|
|We may disclose your personal information to third parties, the court service and/or regulators or law enforcement agencies in connection with proceedings or investigations anywhere in the world where compelled to do so. Where permitted, we will direct any such request to you or notify you before responding unless to do so would prejudice the prevention or detection of a crime.||Legal obligation (to cooperate with law enforcement and regulatory authorities)|
How long we retain your personal data
We will hold the above information for as long as is necessary in order to provide you with the Website, deal with any specific issues that may arise, or otherwise as is required by law or any relevant regulatory body.
If information is used for two purposes, we will retain it until the purpose with the latest period expires but we will stop using it for the purpose with a shorter period when that period expires.
We restrict access to your personal information to those persons who need to use it for the relevant purpose(s). Our retention periods are based on business needs and your information that is no longer needed is either irreversibly anonymized (and the anonymized information may be retained) or securely destroyed.
Under the General Data Protection Regulation (EU) 2017/676, you have various rights in relation to your personal data. All of these rights can be exercised by contacting us at [email protected]
In certain circumstances you have the following rights in relation to your personal data:
|Right of Access||The data subject shall have the right to obtain from the controller confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, a copy of the personal data undergoing processing.|
|Right to Rectification||We will use reasonable endeavors to ensure that your personal information is accurate. In order to assist us with this, you should notify us of any changes to the personal information that you have provided to us by sending us a request to rectify your personal data where you believe the personal data we have is inaccurate or incomplete.|
|Right to erasure / ‘Right to be forgotten’||Asking us to delete all of your personal data will result in EDITED deleting your personal data without undue delay (unless there is a legitimate and legal reason why EDITED is unable to delete certain of your personal data, in which case we will inform you of this in writing).|
|Right to restriction of processing||You have the right to ask us to stop processing your personal data at any time.|
|Right to data portability||You have the right to request that EDITED provides you with a copy of all of your personal data and to transmit your personal data to another data controller in a structured, commonly used and machine-readable format, where it is technically feasible for us to do so.|
|Right to complain||You have the right to lodge a complaint to a supervisory authority such as the Information Commissioner’s Office in the UK (see www.ico.org.uk). Although we encourage our customers to engage with us in the event they have any concerns or complaints.|
EDITED will not ordinarily charge you in respect of any requests we receive to exercise any of your rights detailed above; however, if you make excessive, repetitive or manifestly unfounded requests, we may charge you an administration fee in order to process such requests or refuse to act on such requests. We will provide you with a copy of the personal data undergoing processing free of charge; however, any further copies requested may be subject to reasonable fees based on administrative costs.
Asking us to stop processing your personal data or deleting your personal data will likely mean that you are no longer able to use EDITED’s Website, or at least those aspects of our Website which require the processing of the types of personal data you have asked us to delete, which may result in you no longer being able to use our Website.
Where you request EDITED to rectify or erase your personal data or restrict any processing of such personal data, EDITED may notify third parties to whom such personal data has been disclosed of such request.
Changes to this policy
For the purpose of the relevant data protection legislation, the primary data controller is Stylescape Limited (company no. 06366729) with registered address at 26 Hatton Garden, London, EC1N 8BR. Stylescape Limited will share your personal data with Stylescape Inc who acts as a joint data controller.