Privacy Policy

Last updated: March 2023

Welcome to WE TWELVE LTD’s privacy policy.

WE TWELVE LTD ("We", “us” or “our”) is committed to protecting and respecting your privacy. This policy (together with any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. This website is not intended for children under the age of 13 and we do not knowingly attempt to solicit or receive data relating to children under that age. If you learn that a child has provided us with personal data in violation of this policy, you can alert us at our contact details set out at the end of this policy.

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

1. IMPORTANT INFORMATION AND WHO WE ARE

1.1 Controller

WE TWELVE LTD is the “data controller” for the purposes of data protection legislation. We are responsible for your personal information and, by law, we are required to provide you with information about us, how and why we use your data and the rights you have over it.

1.2 Changes to this privacy policy

We may review this privacy policy from time to time and we will notify you of any changes by uploading the new version of it on our website. We will send you an e-mail or post an update notice on the website so that you become aware of the updated version of this policy. The “Last updated” date at the top of this policy will also be adjusted accordingly.

You are advised to review this privacy policy periodically for any changes. Changes to this policy are effective when they are posted on our website and/or applications.

1.3 Your duty to inform us of changes

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.

1.4 Third-party links

This website 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 website, we encourage you to read the privacy policy 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 as follows:

• Identity Data includes first name, last name, date of birth and gender.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes bank account and payment card details. Although we collect such data in order to allow your order to be processed, we do not store any secure payment information, this is handled by our payment processors Shopify (STRIPE), PayPal, Amazon Pay or Google Pay.
• Transaction Data includes details about payments to and from you and other details of products and services 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 this website.
• 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 website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences. We do not collect any Special Categories of Personal Data about you (this includes 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.

2.1 If you fail to provide personal data

Where we need to collect personal data by law, or in order to complete an order you have placed in our website, and you fail to provide that data when requested, we may not be able to perform the contract we are trying to enter into with you (for example, to provide you with products you have added to your cart). In this case, we may have to cancel your order 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:

a) Information we collect directly from you This is information we collect when you voluntarily submit information to us:

• When making a purchase – this information is only used for the purposes of completing your order.
• When you submit information to us via a form such as registering an account, signing up for our newsletter or making contact via our Contact Us or Press pages. This information is primarily used to complete your request
• When you contact us via telephone, direct email or replying to a support ticket, this information may be stored to help us improve our service
• When you submit responses via a survey or poll. This data may be stored to help us improve our products or your online experience
• When submitting information to take part in a prize draw or competition
• When you report a problem with our website via the Contact Us page, direct email, telephone or a feedback tool
• When you contact us via Facebook Messenger, this information may be stored and used to improve our customer service

b) Information about your browsing activity online We collect Technical Data such as the pages and products you visit, the device you used to visit our website, the categories you spend the most time browsing and which areas of our help section you visit. This information is used to help improve our website content, product offering and online experience.

We also collect cookie information on our website. For more information on cookies and how we use them, please see our Cookie Policy.

4. WHAT DO WE DO WITH THE INFORMATION?

Any information we collect, process or store about you is treated as our own. We are 100% committed to protecting and respecting your privacy. Your personal information is never shared or sold and is used solely by ourselves to complete your order, requests or to improve our online experience and/or product offering.

Below are some explanations of how we use your information, including:

• Type of data Purpose/ Activity Lawful basis for processing
• Payment Information used solely for the purposes of taking payment or making refunds.

4.1 Name and contact information

This is used to identify you as a customer (or not), complete your orders, answer support tickets, send you offers and promotions via email or SMS, to help prevent fraud and to show you relevant marketing material as you browse the web vis one of our third-party partners such as Facebook, for example:

• Performance of a contract with you
• Necessary for our legitimate interest
• Necessary to comply with a legal obligation

4.2 Purchase and browse history

Again, necessary for our legitimate interest to see which of our products are most popular with yourself and others who appear to be interested in the same products to help us provide a better product range. 

4.3 Information on your phone or laptop

This helps us recognise your device and browsing behaviour. Using cookies, we can sometimes match this to your purchase history and build a picture of the products and categories you like. This helps us better optimise our content, products and allow for preferences to be saved online which is necessary for our legitimate interest. For example:

• Gender information

To ensure our products for women are appropriately directed.

• Date of birth

To see which of our products are most popular in certain age groups and improve our product range or marketing communications based on this analysis. Also to send you birthday gifts!

4.4 Information submitted via competitions or surveys

This is usually used to contact you if you win, send promotions or offers to you if you sign up for our newsletter at the same time or we use the survey data to feed back to our internal product teams for our legitimate interest to help improve our products range.

5. DISCLOSURE OF YOUR PERSONAL DATA

Only if you give us explicit consent, might we share your information with our partners, subsidiaries or subsidiary companies in order that they can contact you with information, promotions, products, services, and offers that may be interesting to you.

However, we will share some of your data with the following types of companies to help us complete our contractual obligations to your and provide a better online experience: 

Payment services providers – to enable your orders to be processed such as Amazon Pay, Google Pay, PayPal. Fulfilment warehouse and courier companies – to enable us to have your order delivered to you.

Professional service providers – this mostly covers our customer management platforms (including email and support) and advertising partners such as Meta, TikTok, Google Tag Manager, Shopify, Klaviyo, AWIN and DoubleClick

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.

We may also provide third parties with aggregated but anonymised information and analytics about our customers to help us improve our online experience and marketing activities. Before we do so, we will make sure that it does not identify you. We will never sell your information to any other company. We do not store credit card details nor do we share financial details with any 3rd parties.

6. INTERNATIONAL TRANSFERS

The data that we collect from you may be transferred to, and stored at, a destination outside the UK. It may also be processed by staff operating outside the UK who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely 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 (for example, EU countries).
• Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK. This includes EU approved standard contractual clauses used for the transfer of personal data.

We do not store customer data ourselves. Any payment transactions will be encrypted using SSL technology and are stored by our payment service providers for a time suitable to enable any transactions to be completed.

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. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone and will not ever ask you to share it with ourselves. If you’d like to reset your password, please click here.

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

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, tax, accounting or other requirements.

9. YOUR LEGAL RIGHTS

• Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see below to find out more about these rights:
• The right to be informed about how your personal information is being used (starting with this policy!)
• The right to request access to the personal information we hold about you and to check that we are lawfully processing it (commonly known as a "data subject access request")
• The right to request the correction of inaccurate or incomplete personal information we hold about you (although you can probably do most of this through my Account)
• The right to request that we delete your data, or stop processing it or collecting it, in some circumstances.
• The right to object to processing your personal data where we are relying on a legitimate interest (of those of a third party) and there is something about your particular situation which makes you feel such processing impacts on your fundamental rights and freedoms.
• The right to request the transfer of personal data we hold about you, either to you or a third party you have chosen, 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.
• The right to complain to your data protection regulator — in the UK, the Information Commissioner’s Office
• The right to opt out from direct marketing. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us on the contact details set out below. 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 could 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 could 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.

10. MARKETING

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. Promotional offers from us We may use your personal 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 and offers may be relevant for you (we call this marketing).

We may send you marketing communications from time to time about our new products and offers, provided that we obtain your consent to do so. If you no longer wish to receive marketing messages from us, you have the right to opt-out at any time by following the instructions below.

If you have already purchased goods or services from us, we may send you electronic marketing communications about products we feel may interest you (based on your prior experience with us) if you have not opted out/ unsubscribed from that marketing messages. How to Unsubscribe from emails, SMS and /or Postal Mail Our policy is to allow users to unsubscribe from our regular emails at any time. You can do this by clicking on the Unsubscribe link at the bottom of the email you’ve received. Should you experience any problems or continue to receive emails, please contact our customer Services team who will assist you. You can do this by emailing support@lociwear.co.uk.

If you’d like to unsubscribe from SMS or Postal Mail, please email us via support@lociwear.co.uk. 

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 through our website.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see the Cookie Policy.

11. CONTACT DETAILS

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to support@lociwear.co.uk.