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Privacy Policy for Cosyfeet

You can trust Cosyfeet to ensure we keep your data safe because your privacy and security is extremely important to us. All information that you share with us will only be used with your permission and we will share with you all data held if you request that of us. We may process your personal information for carefully considered and specific purposes which are in our interest and enable us to enhance the services we provide, but which we believe also benefit our customers. See below for more details.

Under the GDPR definition, Cosyfeet uses “Legitimate Business Use” as the basis for processing your data. This does not affect any of your rights under the regulation and you have the right to object to us processing your data in this way.

General Data Protection Regulation and what it means to you

The GDPR (EU) 2016/679 (or ‘GDPR’) will ensure that you have right on how and with whom your data is used and stored. Under GDPR you will have fundamental right to:

  1. 1. be processed lawfully, fairly and in a transparent manner
  2. 2. be forgotten
  3. 3. not be profiled or to limit profiling
  4. 4. not have your data passed to someone else
  5. 5. see a copy of all data stored by us
  6. 6. object
  7. 7. data portability

We will comply with all the above rights but please note that if you have claimed VAT relief on your purchases we are required to keep this information for 7 years after the purchase to comply with HMRC VAT regulations. In addition to this, other data relating to financial transactions may need to be held to comply with financial regulations.

Under these circumstances your data will be moved to a separate part of our customer database, obfuscated (if appropriate) and will not be available to marketing or customer services.

You will be informed of any instances where we have not been able to comply with a specific data request and why.

What data do we collect about you?

  • We collect your personal data such as your name, address, your date of birth (if you want to give it to us), telephone number and email address.
  • We will ask if you are the end user, a relative or a carer for the end user.
  • We also store details of what you have purchased from us, goods you have returned to us and whether you are entitled to VAT relief, which will also contain the medical reason for allowing VAT relief.
  • All payment card details are encrypted ahead of transmission to payment processors.
  • The last 4 digits of your PAN and the card expiry date are visible within our system, which is allowed under the PCI DSS 3.2 (Please see the section on Payment Processing for more information).
  • Online we also collect information about visitors to our website via e-mails, online forms and contact us pages, as well as some tracking information (please see ‘Use of Cookies’).

How do we ensure your data is safe?

Cosyfeet takes several steps to ensure the data we hold about you is safely & securely held.
PCI DSS 3.2 Compliance

Our systems are secured by firewalls and other security measures that meet accepted industry standards and are regularly tested to ensure they meet standards set by the PCI DSS Security Council.

Our websites & external internet connections are tested monthly by Trustwave Holdings, Inc., an Approved Scanning Vendor (ASV) and Qualified Security Assessor Company (QSA-C).

Trustwave https://www.trustwave.com
SSL

All connections to our web sites are encrypted and are verified by Geo-Trust.

We do not store any payment card information online beyond that which is permitted under the PCI DSS 3.2.

Geo-Trust https://www.geotrust.com
NCSC Cyber Essentials

Cosyfeet is working towards Cyber Essentials accreditation from the UK National Cyber Security Centre.

CyberEssentials https://www.cyberessentials.ncsc.gov.uk

Payment Processing

Cosyfeet follows industry best practices with our customer cardholder data, using technologies such as strong encryption, payment card tokenisation & obfuscation.

Web Payment Processing on our Website(s)
CyberSource

Card transactions via our website (WEB) & over the phone (MOTO) are handled by our payment processor, CyberSource, a secure card processing company, owned and operated by Visa.

We use 3D Secure (also known as Verified by Visa and MasterCard SecureCode) to keep you safe online and protect your existing card account against unauthorised use when you shop with us.

MasterCard Visa
CyberSource https://www.cybersource.com

CyberSource are fully PCI DSS 3.2 compliant.

Link
PayPal

We also accept payment via PayPal to provide an alternative way to purchase without giving us your card details.

PayPal https://www.paypal.com/uk/home

PayPal are fully PCI DSS 3.2 compliant.

Link
Payment Processing in our retail store(s)
Lloyds Bank Cardnet

Payments taken in our retail shop are handled by Lloyds Bank Cardnet, who work with First Data to process the transactions.

Card transactions are sent directly to the processor using Chip & PIN machines provided by First Data.

No data from these transactions is recorded on our EPOS machines & merchant slips are stored securely and destroyed when they are no longer required.

Lloyds Bank https://lloydsbankcardnet.com

First Data are fully Payment Card Industry (PCI) DSS 3.2 compliant.

Link

Please Note: Cosyfeet does not operate any of the stores in our stockist network (https://www.cosyfeet.com/stockists) and is not liable for the security of their systems or processing practices.

Why we collect this data and what we do with it

We use the data to contact you via our mailing and email programmes and to keep you up to date on new products, competitions and prize draws that we run from time to time.

We will profile your data by using your name, address and purchasing history to keep our offers and mailings relevant to you and your requirements.

If you do not wish us to profile your data, we will not be able to add you to our marketing programme.

We use the following criteria to categorise your purchase behaviour to add you to an appropriate mailing cell.

  • Catalogue requested 0-6 months = Enquirer
  • Last purchased 0-18 months = Active customer
  • Last purchased 18-36 months = Lapsing customer
  • Last purchased over 36 months = Lapsed customer

How long do we keep this data?

Data from Enquirers who do not go on to purchase will be removed from our systems 6 months after their most recent catalogue request.

Data from Active, Lapsing and Lapsed customers will be kept indefinitely, to honour our ‘No Quibble Guarantee’ (https://www.cosyfeet.com/guarantee).

Data Backups

Cosyfeet uses industry standard backup technologies to protect sensitive customer data against loss, theft or disaster.

All data backups are stored within the European Economic Area & are retained for 30 days.

Who do we pass your data to?

We will pass your data to 3rd parties that we think will be of interest to you.

We will only do this if you have given us permission to do so or for the explicit means of getting our products to you.

Which Third Parties do we share data with and what data do we share?

We share your full name, address, last purchase date and order value with:

Epsilon Abacus (registered as Epsilon International UK Ltd)

Registered Address:

67 Broad Street, Teddington, Middlesex, TW11 8QZ

The above may share your information with companies who offer products or services that they have identified as likely to be of interest to you. These companies may contact you via postal mail only.

Epsilon Abacus manage the Abacus Alliance on behalf of UK retailers. The participating retailers are active in the clothing, food & wine, gardening, gadgets & entertainment, health & beauty, household goods, and home interiors categories. They share information on what their customers have purchased.

Epsilon Abacus pools and analyses this data to understand what consumers like to buy. Based on the resultant insights, retailers can tailor their communications, sending offers by post that should be of interest to the individual.

Other companies that we send data to produce mailings, emails, offer data cleansing services and to gather feedback. All these companies do not pass your data to anyone else and will delete your data once processed.

Payment Processing in our retail store(s)
Company Reason

Sunline Direct Mail Limited

Registered Address: Cotton Way, Weldon Rd Industrial Estate, Loughborough, Leicestershire. LE11 5FJ

Web: http://sunline.co.uk/

Mailing Production

dotmailer Limited

Registered Address: No. 1 London Bridge, London, SE1 9BG

Web: https://www.dotmailer.com/

Email Marketing, abandoned cart & Processing

MailaDoc Limited

Registered Address: Unit 4 Festival Units, Crossways Rd, Show Ground Business Park, Bridgwater, Somerset, TA6 6LS

Web: http://mailadoc.co.uk/

Catalogue Request Mailing

Follow-Up Mailings

VAT renewal letters

AFD

Registered Address: Mountain View Innovation Centre, Jurby Road, Lezayre, Ramsey, ISLE OF MAN, IM7 2DZ

Web: http://www.afd.co.uk/

Address Cleansing, Deduplication & Suppression

Wood for Trees Limited

Registered Address: Unit 1 Citizen House, Crescent Office Park, Bath, B&NES, BA2 2AF

Web: http://www.woodfortrees.net/

Data Profiling & Processing

Off-site Disaster Recovery

Feefo Holdings Limited

Registered Address: Heath Farm, Heath Road East, Petersfield, GU31 4HT

Web: https://www.feefo.com/business/gb_en

Third-Party Customer Reviews

To opt out of emails you will need to go direct to Feefo

We share relevant personal data with the following delivery and fulfilment partners (where appropriate) to ensure you receive our products and services:

Disclosures

We will only disclose data when obliged to disclose personal data by law, or the disclosure is ‘necessary’ for purposes of national security, taxation and criminal investigation, or we have your consent, and to the following:

  • Other companies within our Group of companies: Walktall (https://www.walktall.co.uk/)
  • Suppliers we engage to process data on our behalf: Epsilon Abacus, Wood for Trees Ltd
  • Successors in title to our business.

Use of personal information

We process personal information collected via our websites and mail order for the purposes of:

  • Providing information about products and services
  • Providing and personalising our services
  • Dealing with your enquiries and requests
  • Administering orders and accounts relating to our suppliers or customers
  • Trading in personal information (selling, hiring or exchanging information) - Abacus UK
  • Conducting market research

Data Capture Information

We will send you information according to the preferences you submitted via our order form/data capture form/contact us page.

If you would like to change these preferences at any point, please contact us using the details at the end of this document.

Other websites

Our website may contain links to other websites that are outside our control and are not covered by this Privacy Policy. If you access other sites using the links provided, the operators of these sites may collect information from you that will be used by them in accordance with their privacy policy, which may differ from ours.

Subject Access Requests

You have the right to see what personal data we hold about you.

To obtain a copy of the personal information we hold about you, please write to our Data Officer using the details at the end of this document.

The Right to be Forgotten

Under the EU GDPR, you have a right to request to be forgotten.

We will endeavour to honour this request as quickly as possible . If we are not able to satisfy the request to be forgotten for legitimate business reasons, we will notify you in writing.

Data will be removed from our Live database(s) as soon as possible. It will also leave our system backup rotation within 30 days.

Please note that exercising your ‘Right to be Forgotten’ will void your rightentitlement to our ‘No Quibble Guarantee’.

Internet-based transfers

Given that the Internet is a global environment, using it to collect and process personal data necessarily involves the transmission of data on an international basis. This means for instance that data you pass to us may be processed outside the European Economic Area, although the data will always be held securely and in line with the requirements of UK data protection legislation . By communicating electronically with us, you acknowledge and agree to our processing of personal data in this way.

Use of Cookies

A cookie is a small piece of information sent by a web server to a web browser, which enables the server to collect information from the browser.

Find out more about cookies on www.allaboutcookies.org.

We use cookies to identify you when you visit this website and to keep track of your browsing patterns and build up a demographic profile.

Our use of cookies also allows registered users to be presented with a personalised version of the site, carry out e-commerce transactions and have access to information about their account.

Most browsers will allow you to turn off cookies. If you want to know how to do this, please see your browser help documents or follow instructions on www.allaboutcookies.org.

Please note, turning off certain cookies means you won’t be able to access your account or checkout. You will need to call us on 01458 447275 to place your order.

We use the following cookies on our site:

aw_pop*.www.cosyfeet.com1 hour1st PartyUsed when visiting the website to control alerts
Cookie Information
Cookie Who owns this data How long this data is kept for Is this a 1st party or a 3rd party cookie? Data collected by the cookie
_ga .cosyfeet.com 2 years 1st Party Google analytics
_gali .cosyfeet.com 0 seconds 1st Party Google analytics
_gid .cosyfeet.com 1 day 1st Party Google analytics
_gat .cosyfeet.com 1 minute 1st Party Google analytics (used to control request rate)
frontend .cosyfeet.com 4 days 1st Party Magento preset cookie
civicCookieControl .cosyfeet.com 0 seconds 1st Party Used to control the 'Cookie Control' banner
_uetsid .cosyfeet.com 30 minutes 1st Party Unspecified
civicCookieControl .www.cosyfeet.com 0 seconds 1st Party Used to control the 'Cookie Control' banner
__atuvc www.cosyfeet.com 2 years 1st Party Unspecified
__atuvs www.cosyfeet.com 30 minutes 1st Party Unspecified
civicCookieControl www.cosyfeet.com 3 months 1st Party Unspecified
allow_mailshot www.cosyfeet.com 2 years 1st Party Used to save checkout preferences
billing:city www.cosyfeet.com 2 years 1st Party Used to save checkout preferences
billing:company www.cosyfeet.com 2 years 1st Party Used to save checkout preferences
billing:email www.cosyfeet.com 2 years 1st Party Used to save checkout preferences
billing:firstname www.cosyfeet.com 2 years 1st Party Used to save checkout preferences
billing:lastname www.cosyfeet.com 2 years 1st Party Used to save checkout preferences
billing:postcode www.cosyfeet.com 2 years 1st Party Used to save checkout preferences
billing:prefix www.cosyfeet.com 2 years 1st Party Used to save checkout preferences
billing:region www.cosyfeet.com 2 years 1st Party Used to save checkout preferences
billing:street1 www.cosyfeet.com 2 years 1st Party Unspecified
billing:street2 www.cosyfeet.com 2 years 1st Party Used to save checkout preferences
billing:telephone www.cosyfeet.com 2 years 1st Party Used to save checkout preferences
current_quote_id www.cosyfeet.com 2 years 1st Party Used to store items in basket
id_accept_terms www.cosyfeet.com 2 years 1st Party Used to save checkout preferences
new_registrant_name_other[*] www.cosyfeet.com 2 years 1st Party Used to save checkout preferences
new_registration_id_* www.cosyfeet.com 2 years 1st Party Used to save checkout preferences
loc .addthis.com 2 years 3rd Party Geolocation, used to help publishers know approximately where people sharing information are located. (State level)
di2 .addthis.com 2 years 3rd Party Maintenance cookies that help manage expiration for other cookies
ssc .addthis.com 2 years 3rd Party Recording user sharing and social activity
uvc .addthis.com 2 years 3rd Party Recording user sharing and social activity
uid .addthis.com 2 years 3rd Party Uniquely assigned machine-generated user ID
bt2 .addthis.com 8 months 13 days 3rd Party User interest modeling
um .addthis.com 2 years 3rd Party Unspecified
vc .addthis.com 2 years 3rd Party Unspecified
MR .bat.bing.com 6 months 3 days 3rd Party Bing tracking cookie
MUID .bing.com 13 months 3rd Party Bing tracking cookie
IDE .doubleclick.net 2 years 3rd Party Google Ads tracking cookie
id .doubleclick.net 2 years 3rd Party Google Ads tracking cookie
test_cookie .doubleclick.net 1 hour 15 minutes 3rd Party Google Ads tracking cookie
_ga .feefo.com 2 years 3rd Party Feefo Google analytics
_gid .feefo.com 2 years 1 day 3rd Party Feefo Google analytics
APISID .google.co.uk 2 years 3rd Party Unspecified
CONSENT .google.co.uk 21 years 3rd Party Unspecified
HSID .google.co.uk 2 years 3rd Party Unspecified
NID .google.co.uk 6 months 3rd Party Unspecified
SAPISID .google.co.uk 2 years 3rd Party Unspecified
SID .google.co.uk 2 years 3rd Party Unspecified
SSID .google.co.uk 2 years 3rd Party Unspecified
NID .google.com 6 months 3 days 3rd Party Unspecified
AID .googleadservices.com 18 months 3rd Party Google Ads tracking cookie
MUIDB bat.bing.com 2 years 3rd Party Unspecified
ups s7.addthis.com 2 years 3rd Party Unspecified
DV www.google.co.uk 10 minutes 3rd Party Unspecified
OTZ www.google.com 0 seconds 3rd Party Unspecified
KHcl0EuY7AKSMgfvHl7J5E7hPtK .paypal.com 20 years 3rd Party Used when using Paypal payment method
LANG .paypal.com 9 hours 3rd Party
X-PP-ADS .paypal.com 1 year 3rd Party
X-PP-K .paypal.com 1 month 3rd Party
X-PP-SILOVER .paypal.com 30 minutes 3rd Party
_ga .paypal.com 2 years 3rd Party
consumer_display .paypal.com 2 years 3rd Party
cookie_check .paypal.com 10 years 3rd Party
feel_cookie .paypal.com 2 years 3rd Party
login_email .paypal.com 6 months 3rd Party
navlns .paypal.com 2 years 3rd Party
s_pers .paypal.com 2 years 3rd Party
ts .paypal.com 3 years 3rd Party
tsrce .paypal.com 1 day 3rd Party
ui_experience .paypal.com 6 months 3rd Party
x-csrf-jwt .paypal.com 1 week 3rd Party
x-pp-p .paypal.com 1 year 3rd Party
x-pp-s .paypal.com When the browsing session ends 3rd Party
44907 www.paypal.com 3 months 3rd Party
47364 www.paypal.com 30 minutes 3rd Party
AKDC www.paypal.com 30 minutes 3rd Party
KHcl0EuY7AKSMgfvHl7J5E7hPtK www.paypal.com 20 years 3rd Party
X-PP-SILOVER www.paypal.com 0 seconds 3rd Party
X-PP-SILOVER www.paypal.com 0 seconds 3rd Party
akavpau_ppsd www.paypal.com When the browsing session ends 3rd Party
ectoken www.paypal.com Indefinitely 3rd Party
nsid www.paypal.com When the browsing session ends 3rd Party
xppcts www.paypal.com 5 minutes 3rd Party
aw_popup_closed_* www.cosyfeet.com When the browsing session ends 1st Party
current_popid www.cosyfeet.com When the browsing session ends 1st Party
firstvisittime www.cosyfeet.com 99 years 1st Party
session-set www.cosyfeet.com 20 years 1st Party

Contacting us regarding this Privacy Policy

You may ask us at any point not to share your information with 3rd Parties, by contacting us by email at comfort@cosyfeet.com

If you wish to speak to someone over the phone regarding any issues, concerns or comments about this document, please call us on 01458 447275.

Alternatively, you can also write to our Data Officer at:

Jackie Bemmer, Data Officer,
Cosyfeet,
Unit 5, The Tanyard,
Leigh Road,
Street,
Somerset
BA16 0HR.

Amendments

Please note that this privacy policy is subject to change from time to time.

It was last updated on 08/05/2018.

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