PUSH ENTERTAINMENT LIMITED
PRIVACY NOTICE FOR OUR WEBSITE AT THEGIRLSBATHROOM.COM
PUSH ENTERTAINMENT LIMITED
PRIVACY NOTICE FOR OUR WEBSITE AT THEGIRLSBATHROOM.COM
This is the privacy notice for the THEGIRLSBATHROOM.COM website (Site) owned and operated by PUSH ENTERTAINMENT LIMITED. PUSH ENTERTAINMENT LIMITED respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you. This privacy notice is provided in the numbered sections set out below, and you can click through to any of the headings listed.
- IMPORTANT INFORMATION AND WHO WE ARE
- THE DATA WE COLLECT ABOUT YOU
- HOW IS YOUR PERSONAL DATA COLLECTED
- HOW WE USE YOUR PERSONAL DATA
- DISCLOSURES OF YOUR PERSONAL DATA
- INTERNATIONAL TRANSFERS
- DATA SECURITY
- DATA RETENTION
- YOUR LEGAL RIGHTS
1. IMPORTANT INFORMATION AND WHO WE ARE
PURPOSE OF THIS PRIVACY NOTICE
This privacy notice aims to give you information on how PUSH ENTERTAINMENT LIMITED collects and processes your personal data through your use of the Site, including any data you may provide through the Site when you access it, purchase a product or complete any online form, such as signing up to a newsletter or similar service. This Site is not intended for children and we do not knowingly collect data relating to children. It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
PUSH ENTERTAINMENT LIMITED is the controller and responsible for your personal data (collectively referred to as “PUSH”, “we”, “us” or “our” in this privacy notice).
If you consent to us doing so, we will share certain personal data (being your name and email address) with the owner of THE GIRLS BATHROOM brand, SOPHIA AND CINZIA LIMITED (referred to as “SC” in this privacy notice) with its principal address at c/o GBP Associates, 6th Floor, Aviation House, 125 Kingsway, London, WC2B 6NH. SC and PUSH will be joint controllers with SC of such personal data in such circumstances and we have agreed with SC that each of us will be responsible for complying with applicable data protection laws.
This personal data will only be used by SC for the marketing purposes stated in relation to the consent you give and at the time you give it. We include more information about such marketing under the heading “Marketing” in Section 4 (HOW WE USE YOUR PERSONAL DATA), below.
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact our data privacy manager using the details set out below.
Our full CONTACT DETAILS are:
PUSH ENTERTAINMENT LIMITED
Contact our data privacy manager at:
Email address: email@example.com
Postal address: Alpha House, 4 Greek Street, Stockport SK3 8AB (c/o Booth Ainsworth LLP).
For those who are based in the European Union, Osano International Compliance has been appointed as our EU Representative. If you wish to exercise your rights under the EU GDPR, or have any queries in relation to your rights or general privacy matters please use the contact details below: Osano International Compliance Services Limited
25/28 North Wall Quay
Dublin 1, D01 H104L
For those who are based in the European Union, Osano International Compliance has been appointed as our EU Representative. If you wish to exercise your rights under the EU GDPR, or have any queries in relation to your rights or general privacy matters please use the contact details below:
Osano International Compliance Services Limited ATTN: ARF9 25/28 North Wall Quay Dublin 1, D01 H104L IRELANDYou have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues. We would, however, welcome the opportunity to address your concerns before you approach the ICO so please contact us in the first instance. You can find the ICO here www.ico.org.uk
CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
This version was last updated in March 2021. Any 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.
Our Site 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 Site, we encourage you to read the privacy notice of every website you visit.
2. THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
- Identity Data includes first name, last name, username or similar identifier.
- Contact Data includes billing address, delivery address, email address and telephone numbers.
- Financial Data includes payment card details.
- Transaction Data includes your order ID and details of products you have purchased 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 and other technology on the devices you use to access our Site.
- Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our Site, and products.
- Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice. We do not collect any Special Categories of Personal Data about you (for example details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service but we will notify you if this is the case at the time.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you; (i) apply to purchase a product or receive a service; (ii) create an account on our Site; (iii) subscribe to our newsletters; (iii) request marketing to be sent to you; (iv) enter a competition, promotion or survey; or (v) give us some feedback.
- Third parties. We may receive personal data about you from various third parties as follows: (i) Technical Data and Usage Data from analytics providers such as Google Analytics based outside the EU; (ii) Identity, Contact and Transaction Data from providers of customer review services such as TrustPilot and Google Customer Reviews based both inside and outside the EU.
4. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
Performance of a contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Legitimate Interests means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights 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). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
The Table below sets out more about the types of lawful basis that we will rely on to process your personal data.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to such marketing at any time by contacting us.
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 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.
Note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal basis we are relying on to process your personal data where more than one basis has been set out in the table below.
Type of data
Lawful basis for processing including basis of legitimate interest
To register you as a new customer
Performance of a contract with you
To process and deliver your order including:
(a) Performance of a contract with you
To manage our relationship with you which will include:
(a) Performance of a contract with you
Entering a prize draw, participate in a competition or complete a survey
(a) Performance of a contract with you
To administer and protect our business and our Site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) 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 Site content to you and measure or understand the effectiveness of the content and marketing we provide and carry out with you
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our Site, products/services, marketing, customer relationships and experiences
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our Site updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you
Necessary for our legitimate interests (to develop our products/services and grow our business)
If you opt into Shopify Pay, Shopify will store and use this information to pre-fill your checkout information; we additionally use this information to help customise and improve your experience when you visit our Site by presenting to you goods or services that are more likely to be of interest to you.
AUTOMATED DECISION MAKING
We use some of the personal information you provide us to conduct some level of automated decision-making - for example, we use certain personal information (for example, IP addresses or payment information) to automatically block certain potentially fraudulent transactions for a short period of time.
Our objective is to enable you to make choices around certain personal data uses, particularly around marketing and advertising. You can contact us in relation to these at any time.
This includes our use of Facebook Pixel which is a tracking plug-in which we use on our Site and which enables us to serve our relevant marketing messages and promotions to you via your Facebook account if you have one and we have agreed with Facebook that we want to do so.
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you and we refer to this generally as marketing.
You will receive marketing communications from us if you have requested information from us or have expressly consented to receive them in the course of purchasing products from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any company outside us for marketing purposes.
As we have referred to above in Section 1, IMPORTANT INFORMATION AND WHO WE ARE we will ask for your consent to receive marketing communications from SC, the owner of THE GIRLS BATHROOM brand. SC wishes to contact you directly by email to keep you updated with information or newsletters about the brand and about similar products, services or events SC may make available or offer from time to time.
You can ask us, SC (or other applicable third parties) to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product purchase, warranty registration, product experience or other transaction.
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the purposes set out in the table in section 4 above.
Specific External third parties such as (and in addition to SC);
- Shopify Inc
Shopify acting as a processor and its affiliated companies (acting as sub-processors) based in Canada, Ireland and the United States provides the online e-commerce platform (Platform) that enables us to operate our Site as a store selling our products and services to you. Your data is stored by the Platform through Shopify’s data storage, databases and the general Shopify application on a secure server behind a firewall.
If you choose a direct payment gateway, payment services providers ApplePay, Google Payments, PayPal and via Shopify Payments, Visa, Mastercard and Amex, Shopify stores your payment card data with your Contact, Identity and Financial Data to the extent necessary. It is encrypted through the Payment Card Industry Data Security Standard (PCI-DSS). Your purchase transaction data is stored only as long as is necessary to complete your purchase transaction. After that is complete, your purchase transaction information is deleted. All direct payment gateways adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of credit card information by our store and its service providers.
If you opt into Shopify Pay, Shopify will store and use this information to pre-fill your checkout information.
- MailChimp (The Rocket Science Group, LLC.)
MailChimp provides an email address management service, automation and marketing platform (message sending) and related services, and is a trade name of The Rocket Science Group, LLC. We use these services to manage our subscriber database which includes Contact and Marketing and Communications Data for example.
Processing may take place in the US or in other countries outside of the UK and EU. MailChimp states that it uses its affiliates and various third party sub-processors to assist it in providing these services and that such sub-processors (whose corporate locations are in the US) provide cloud hosting and storage services; content delivery and review services; assist in providing customer support; and in incident tracking, response, diagnosis and resolution services.
- Zendesk Inc
Zendesk provides messaging, chat and communication services that we use to provide customer relationship services for our users.
Processing may take place in the U.S. or in other countries outside of the UK and the EU.
Other external third parties:
- Services providers (acting as processors and in connection with the products and services offered via the Site) whether as a plug-in or similar application or not, based principally in the EEA, the US and Canada which provide (i) on-demand product manufacturing, printing or similar services to us to enable your orders for products and services made via the Site to be met on a localised basis as proximately relevant to you as possible and (ii) other stock related or payment process related services (at your request or not) which also enable us to provide you with the best and safest products and services via the Site.
- Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
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 notice.
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.
6. INTERNATIONAL TRANSFERS
As referred to in section 6 above, several of our external third parties are based outside the UK so their processing of your personal data will, in limited circumstances, involve a transfer of data outside the UK (as well as the EU).
Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data. This will include countries in the EEA. For further details please contact us.
- Where we use certain service providers as referred to in section 5 above, we may use specific contracts approved for use in the UK which give personal data the same or substantially similar protection to that which it has in the UK under the usage terms we have with such service providers. In some limited cases, these may not provide you with full recourse - for example you should be aware that the US offers levels of protection below those of the UK, EEA countries and Canada and that the service provider may not offer further guarantee to address that deficit, so it is possible that government agencies can access your personal data through the transmission without you having any legal recourse. For further details please contact us.
- Shopify states (amongst other things) via its own privacy notices, that if you are located in the UK (or in the EEA and Switzerland), your personal information is processed by Shopify International Ltd in Ireland. As part of Shopify’s services for the Site, it may transfer your personal information to other regions, including to Canada and to its subprocessors in the US. These may be Shopify’s affiliates (Shopify Data Processing (USA) Inc., Shopify Payments (USA) Inc., and Shopify (USA) Inc.) but also third party cloud service providers. In respect of your personal data if you are located in the UK, transfers to Ireland are considered protected as are transfers within the EEA and Switzerland. Transfers to Canada are considered by the UK and EEA/Switzerland as adequately protected, provided the applicable personal data falls within Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA). Shopify states that when it transfers personal data to its US subprocessors that it does so on the basis that its binding contractual commitments comparable to those set out in the Standard Contractual Clauses approved by the UK and the EU as between data controllers and data processors. Shopify International Limited in Ireland also states that it has applied to the Irish Information Commissioner for approval of its Binding Corporate Rules which will, if approved, protect personal data transferred between the Shopify group of companies. You should be aware however that the US offers levels of protection below those of the UK, EEA countries and Canada and that Shopify offers no further guarantee to address that deficit, so it is possible that government agencies can access your personal data through the transmission without you having any legal recourse. Transfers are also exceptionally permitted to the US if necessary for the performance of a contract that we may have with you.
Further information is provided by Shopify here: https://www.shopify.com/legal/privacy
(B) Google has stated (amongst other things) that it complies with GDPR in meeting certain conditions prior to transfer of personal data outside of the UK, the EEA and Switzerland, and to do this relies on EU Commission approved Standard Contractual Clauses for relevant transfers in its Ads and measurement products. It also uses these as a transfer mechanism in respect of Google Cloud. Google’s general policies can be found here; https://privacy.google.com/businesses/compliance/?hl=en_US
(C) Mailchimp has stated (amongst other things) that as set out through use of its Data Protection Addendum it maintains compliance with UK regulation and EU GDPR regarding the collection, use, and retention of personal information from data subjects in the UK, the EEA and Switzerland. Mailchimp is headquartered in the US and sends personal data there including using the services of subprocessors. mailchimp also states that it takes all steps necessary to ensure that its agreements with its third-party international vendors (including sub-processors) contain appropriate commitments from such third parties regarding the transfer and processing of European personal data outside the EEA and that it implements an appropriate and lawful data transfer mechanism (such as the Standard Contractual Clauses) and additional safeguards as necessary. Mailchimp states that it also continues to honour its Privacy Shield related commitments enabling data subject rights of redress against Mailchimp. You should be aware however that the US offers levels of protection below those of the UK and EEA countries so it is possible that US government agencies can access your personal data through the transmission without you having any legal recourse; in this regard Mailchimp states that such information requests have in the past been received by it and that these are noted in its annual transparency report accessible via its online transfers policy here: https://mailchimp.com/help/mailchimp-european-data-transfers/
Mailchimp’s general policies can be found here: https://mailchimp.com/legal/privacy/
(D) Zendesk states that if you are located in the UK (or in the EEA) that it has adopted Binding Corporate Rules that have been authorised by the EU data protection authorities, and which enable it to transfer personal data lawfully from EEA member states to other Zendesk Group companies around the world, and that it also uses Standard Contractual Terms. Its policies can be seen here: https://www.zendesk.co.uk/company/customers-partners/privacy-policy/
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK to a non-EU country.
7. 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.
8. DATA RETENTION
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, tax, or reporting requirements.
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, 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 purposes.
In some circumstances you can ask us to delete your data: see section 9 below in respect of requesting erasure for further information.
In some circumstances we may 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.
9. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These rights include;
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
You have the right to:
Request access to your personal data (commonly known as a “data 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. 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) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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 (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
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.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us
NO FEE USUALLY REQUIRED
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 may refuse to comply with your request in these circumstances.
WHAT WE MAY NEED FROM YOU
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.
TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally it may 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.
In order to be able to offer you Klarna’s payment options, we will pass to Klarna certain aspects of your personal information, such as contact and order details, in order for Klarna to assess whether you qualify for their payment options and to tailor the payment options for you.