Here at Flip Flop I Was Ltd (trading as Ocean Sole UK, hereafter referred to as Ocean Sole UK) we understand that privacy and security online is a concern of our customers. Therefore we have set out the guidelines we use for protecting your personal information. The Ocean Sole UK website is owned and operated by Ocean Sole UK. We are committed to safeguarding your privacy online. Will only collect and use personal data in ways that are described here, and in a manner that is consistent with our obligations and your rights under the law. We use your personal information to support and enhance our relationship with you. We only share your personal information in accordance with the Data Protection Act 1998 and other applicable laws. You may contact Ocean Sole UK (firstname.lastname@example.org) at any time with any privacy questions or concerns and to see the personal information you have given us and request correction. This Policy applies as between you, the User of this Website and Ocean Sole UK the owner and provider of this Website. This Policy applies to our use of any and all Data collected by us in relation to your use of the Website.
- Definitions and Interpretation In this Policy the following terms shall have the following meanings:
- “Data” – means collectively all information that you submit to Ocean Sole UK via the Website. This definition shall, where applicable, incorporate the definitions provided in the Data Protection Act 1998;
- “Cookie” – means a small text file placed on your computer by this Website when you visit certain parts of the Website and/or when you use certain features of the Website. Details of the cookies used by this Website are set out in Clause 12;
- “Ocean Sole UK” – means Ocean Sole UK, the trading name of Flip Flop I Was Ltd;
- “UK and EU Cookie Law” – means the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended by the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011;
- “personal data” – means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site. This definition shall, where applicable, incorporate the definitions provided in the [Data Protection Act 1998] OR [EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”)];
- “Website” – means the website that you are currently using (www.oceansole.co.uk) and any sub-domains of this site (e.g. subdomain. oceansole.co.uk) unless expressly excluded by their own terms and conditions.
- Scope of this Policy This Policy applies only to the actions of Ocean Sole UK and Users with respect to this Website. Our Site may contain links to other websites. Please note that We have no control over how your data is collected, stored, or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to them.
- Your Rights
3.1 As a data subject, you have the following rights under the General Data Protection Regulations (GDPR), which this Policy and our use of personal data have been designed to uphold:
3.1.1 The right to be informed about Our collection and use of personal data;
3.1.2 The right of access to the personal data We hold about you (see section 13);
3.1.3 The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us using the details in section 16);
3.1.4 The right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you (We only hold your personal data for a limited time, as explained in section 5 but if you would like Us to delete it sooner, please contact Us using the details in section 16);
3.1.5 The right to restrict (i.e. prevent) the processing of your personal data;
3.1.6 The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);
3.1.7 The right to object to Us using your personal data for particular purposes; and
3.1.8 Rights with respect to automated decision making and profiling.
3.2 If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided in section 16 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.
3.3 For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.
- Data Collected Without limitation, any of the following Data may be collected by this Website from time to time:
4.2 date of birth;
4.4 job title;
4.7 contact information such as email addresses and telephone numbers;
4.8 demographic information such as post code, preferences and interests;
4.9 financial information such as credit/debit card numbers;
4.10 IP address (automatically collected);
4.11 web browser type and version (automatically collected);
4.12 operating system (automatically collected);
4.13 a list of URLs starting with a referring site, your activity on this Website, and the site you exit to (automatically collected).
- Our Use of Data
5.1 Any personal data you submit will be retained by Ocean Sole UK.
5.2 All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the [Data Protection Act 1998] OR [GDPR] at all times. For more details on security see section 11, below.
5.3 Unless we are obliged or permitted by law to do so, and subject to Clause 6, your Data will not be disclosed to third parties. This does not include our affiliates and/or other companies within our group.
5.4 Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Website. Specifically, Data may be used by us for the following reasons:
5.4.1 internal record keeping;
5.4.2 improvement of our products/services;
5.4.3 transmission by email of promotional materials that may be of interest to you;
5.4.4 contact for market research purposes which may be done using email, telephone, fax or mail. Such information may be used to customise or update the Website.
- Third Party Websites and Services
6.1 Ocean Sole UK may, from time to time, employ the services of other parties for dealing with matters that may include, but are not limited to, payment processing, delivery of purchased items, search engine facilities, advertising and marketing. The providers of such services have access to certain personal Data provided by Users of this Website.
6.2 Any Data used by such parties is used only to the extent required by them to perform the services that Ocean Sole UK requests. Any use for other purposes is strictly prohibited. Furthermore, any Data that is processed by third parties shall be processed within the terms of this Policy and in accordance with the Data Protection Act 1998.
- Links to Other Websites
- Changes of Business Ownership and Control
8.1 Ocean Sole UK may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of Ocean Sole UK. Data provided by Users will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Policy, be permitted to use the Data for the purposes for which it was originally supplied to us.
8.2 In the event that any Data submitted by Users is to be transferred in such a manner, you will not be contacted in advance and informed of the changes.
- Controlling Use of Your Data
9.1 In addition to your rights under the GDPR, set out in section 3, when you submit personal data via Our Site, you may be given options to restrict Our use of your data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details and by managing your Account).
9.2 Wherever you are required to submit Data, you will be given options to restrict our use of that Data. This may include the following:
9.2.1 use of Data for direct marketing purposes; and
9.2.2 sharing Data with third parties.
- Your Right to Withhold Information
10.1 You may access certain areas of the Website without providing any Data at all. However, to use all features and functions available on the Website you may be required to submit certain Data.
11.1 Data security is of great importance to Ocean Sole UK and to protect your Data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure Data collected via this Website.
11.2 Specifically we use the following systems:
11.2.1 Stripe – We use Stripe to collect/process transaction information’ and provide link to their security policy at https://stripe.com/docs/security/stripe
11.2.2 Paypal – We use Paypal to collect/process transaction information’ and provide link to their security policy at https://www.paypal.com/re/webapps/mpp/paypal-safety-and-security
11.3 We only keep your personal data for as long as We need to in order to use it as described above in section 5, and/or for as long as We have your permission to keep it.
11.4 Your data will only be stored in the UK.
- How Do We Share Your Data?
12.1 In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal obligations, a court order, or a governmental authority.
12.2 We may sometimes contract with third parties to supply products and services to you on Our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising, and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law.
12.2.1 We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.
- How Can You Access Your Data?
You have the right to ask for a copy of any of your personal data held by Us (where such data is held). Under the GDPR, no fee is payable and We will provide any and all information in response to your request free of charge. Please contact Us for more details at email@example.com, or using the contact details below in section 14.
14.2 By using this Website you may receive certain third party Cookies on your computer. Third party cookies are those placed by websites and/or parties other than Ocean Sole UK.
14.3 All Cookies used by this Website are used in accordance with current UK and EU Cookie Law.
14.4 Before Cookies are placed on your computer you will be presented with a prompt requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling Ocean Sole UK to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of the Website may not function fully or as intended. You will be given the opportunity to allow only first party Cookies and block third party Cookies.
14.5 Certain features of the Website depend upon Cookies to function. UK and EU Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown below. Your consent will not be sought to place these Cookies. You may still block these cookies by changing your internet browser’s settings as detailed below.
14.6 The following Cookies may be placed on your computer:
- PHPSESSID – A randomly generated code which identifies you for the duration of each visit to our site
- __cfduid – A randomly generated code which identifies you should you need to use our live chat facility
and the following third party Cookies may be placed on your computer:
- act – Facebook.com
- c_user – Facebook.com
- datr – Facebook.com
- fr – Facebook.com
- m_pixel_ratio – Facebook.com
- pl – Facebook
- presence – Facebook
- sb – Facebook
- wd – Facebook.com
- xs – Facebook.com
14.8 The analytic services used by this Website use the following Cookies:
- _ga- Google Analytics
- _gid- Google Analytics
- _psegs- Google Search
- permutive-id- Google Analytics
- permutive-session- Google
14.9 You can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser.
14.10 You can choose to delete Cookies at any time however you may lose any information that enables you to access the Website more quickly and efficiently including, but not limited to, personalisation settings.
14.11 It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your internet browser if you are unsure about adjusting your privacy settings.
- Changes to this Policy Ocean Sole UK reserves the right to change this Policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the Website and you are deemed to have accepted the terms of the Policy on your first use of the Website following the alterations.