iWEAR PRIVACY POLICY
This privacy policy (“Policy”) describes the personal data collected or generated when you use our website (https://www.iwear.ltd). Our Policy also describes how your personal data is used, shared, processed and protected. Our policy also sets out the choices you have relating to your personal data and how you can contact us.
A. Who is Responsible for the Processing of Your Personal Data?
For the purposes of UK and EU data protection laws, the data controller is Big Smart Ideas Ltd trading as iWear. Our Address is Unit 9 The Centurion Centre Castlegate Business Park Old Sarum SALISBURY SP4 6QX UK
B. The Personal Data We Collect and when we collect it
We ask you for certain personal data to enable us to provide you with the products or services you request. For example, when you make purchases, request to receive communications, create an account, participate in our events, contests or competitions, or interact with our site. This personal data includes your:
•Contact details including name, email, telephone number and address;
•Login and account information, including screen name, password and user ID if applicable;
•Payment or credit card information (collected by our payment processor but not stored by us);
•Images, photos and videos (if you choose to upload them);
•Optical prescription information (if you order prescription lenses); and
•Personal preferences including your marketing and cookie preferences.
We use additional personal data to enable us to activate features within our site.
When using our site data is automatically collected and shared with iWEAR by the technology platforms providing the website.
Your web browser or mobile device, for example, may share certain data with iWEAR as you interact with the iWEAR site. More information about these practices is included in the Cookies and Pixel Tags section below. The shared data may include:
• Device IDs, call state, network access, storage information and battery information
• Cookies, IP addresses, referrer headers, data identifying your web browser and version, and web beacons and tags
C. Tools to Manage What We Collect
In many cases, your web browser or mobile device platform will provide additional tools to allow you to control when your device collects or shares specific categories of information. For example, your mobile device or web browser may offer tools to allow you to manage cookie usage or location sharing. We encourage you to familiarize yourself with and use the tools available on your devices.
D. How and why we use your Personal Data
We use the personal data we collect from you in the following ways:
To Process your Orders
We gather this information to allow us to process your registration, process any orders you may make, provide the products requested and deliver them to you. The relevant information is then used by us, our agents and sub-contractors to communicate with you on any matter relating to the conduct of your account and the provision of the goods or services in general. Our legal basis for processing this data is to perform the contract with you.
To Conduct Data Checks
When you send us your order, we (or our agents and sub-contractors) may run some checks on it before it is fulfilled. These checks may include verifying your address and fraud checks, some of which are partly automated checks on all purchases to filter out unusual or suspect transactions, or transactions which can be identified as susceptible to fraud. Suspected fraud on the site will be investigated and if necessary prosecuted. Processing this data is necessary for the purposes of our legitimate interest in preventing non-payment or fraud.
To Provide the Features of the Site, Apps, and Services You Request
When you use our site, we will use your data to provide the product or service you have selected. For example, if you make a purchase on https://www.iwear.ltd, or participate in an event or promotion, we will use the contact information you give us to communicate with you about the purchase, event or promotion. Your consent provides the legal basis for processing this data. If you use our Apps, we will collect the data you provide and store it so that you can review it in the App. We may use this data to calculate further information, so that the calculated information can be provided to you as part of the functionality of the App. Your consent is the legal basis for processing this data in this way.
In many cases, to use features within our site, Apps, and services you may need to provide us with additional data and/or additional consent to use particular data in a certain way. For example, to share content on social media, you may be required to provide your social media account credentials.
You can withdraw your consent to the processing of your information in any of these ways through the App settings at any time.
To Communicate Information about our Products, Services, Events and for Other Promotional Purposes
When you create an iWEAR user account, we may use the information you provide, as well as information from other iWEAR sources, such as your use of iWEAR’s site and Apps and your participation in iWEAR events and competitions (possibly through other iWEAR affiliates), to send you personalized communications on products and services that may be interesting for you.
You can withdraw your consent to receiving these communications at any time through your account settings.
To Operate, Improve and Maintain our Business, Products and Services
When you make a purchase, we may use that information for accounting, auditing and other internal functions. We may also use data about how you use our products and services to enhance your user experience and to help us diagnose technical and service problems and administer our site and Apps. If you add product reviews to our site, we may use that information to improve our products and the customer experience. Our legal basis for processing this data is that it is necessary for the purposes of our legitimate business interests as described above.
To Protect Our or Others' Rights, Property or Safety
We may also use data about how you use our site and Apps to prevent or detect fraud, abuse, illegal uses and violations of our Terms of Use (where necessary for the purposes of our legitimate interests) and to comply with court orders, governmental request or applicable law.
For General Research and Analysis Purposes
We use data about how our visitors use our site, Apps and Services to understand customer behaviour or preferences. For example, we may use information about how visitors to https://www.iwear.ltd search for and find products, to better understand the best ways to organize and present product offerings in our site. We use Google Analytics for this, and the customer data is anonymised.
Use (Processing) of Prescription or other Medical Data
If you order prescription lenses, we will collect and use your prescription in order to fulfill your order. As this information is considered sensitive personal data in the EU and certain other jurisdictions, we need your explicit consent to use it for this purpose, and we take appropriate measures to protect it. The company which operates the site will collect the prescription on our behalf and will send it and your order number to the manufacturer of prescription lenses. We will not disclose your prescription data to any other party.
Other Purposes
If we want to use your personal data in other ways, we will provide specific notice at the time of collection and obtain your consent where the law requires us to do so.
E. SHARING of Your Personal Data
We share your personal data with:
• Members of our Big Smart Ideas Ltd group
• Our payment processors, Amazon Payments, Shopify Payments, Paypal and Opayo (formerly Sagepay).
• Our financial service providers, such as banks;
• Third party service providers processing personal data on iWEAR’s behalf, for example to operate the site, process credit cards and payments, arrange shipping and deliveries, manage and service our data, distribute emails, carry out research and analysis, manage brand and product promotions as well as administering certain services and features;
• The laboratory which manufactures prescription lenses if you order them; and
• Other third parties to the extent necessary to: (i) comply with a government request, a court order or applicable law; (ii) prevent illegal uses of our site and Apps or violations of our site’s and the Apps’ Terms of Use and our policies; (iii) defend ourselves against third party claims; and (iv) assist in fraud prevention or investigation (e.g., counterfeiting).
We may also transfer personal data we have about you in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, spin-off, dissolution or liquidation), to our advisers and any prospective purchasers and their advisers and to the new owners of the business or assets.
F. PROTECTION and MANAGEMENT of your Personal Data
• Encryption & Security: We use a variety of security measures, including encryption and authentication tools, to maintain the safety of your personal data. Your personal data is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, except that we share your name, telephone number and physical address with our shipping and delivery companies for the purpose of making that delivery, and that data would not be encrypted by them. Also, the security of information transmitted via the Internet cannot be guaranteed.
• International data transfers: The personal data we collect or generate in the context of our site and Apps will be stored and processed in the UK, EU and Switzerland. Switzerland are deemed by the European Commission to provide an adequate level of protection to personal data.
• Retention of your data: We retain your personal data for as long as necessary to fulfil the purposes for which we collect it, except if you request us to delete it or if required otherwise by law.
o Prescription data will be retained for thirty six (36) months in order to respond to any queries or complaints about the lenses supplied;
o Payment or credit card data will be retained long enough to enable us to process refunds or chargebacks and to demonstrate compliance with relevant laws (usually a period of two (2) to seven (7) years);
o Login, account information and cookie preferences will be retained for thirty-six (36) months/years after your last visit to our site or App (as applicable);
o Contact details will be retained for thirty-six (36) months/years after your last visit to our site or your last order;
o Any marketing preference data that records your request not to receive marketing from us will be retained as long for as we have your contact details.
• Your rights related to your personal data: You have the right to:
o withdraw your consent to our use of your personal data at any time;
o access your personal data free of charge (subject to certain legal limitations);
o request rectification of data which is inaccurate or incomplete;
o to request us to erase your data, in certain circumstances including where you withdraw your consent and there is no other legal ground for processing your data;
o restrict our processing of your data, in certain circumstances;
o .object to the processing of your data where there is no overriding legitimate interest for continuing to process your data;
o object to our processing of your data for direct marketing purposes; and
o obtain and reuse your personal data for your own purposes across different services.
To modify your (email or sms) subscriptions or to opt-out of receiving iWEAR communication, or to exercise any of the above rights, please email us at sales@iwear.ltd, log into you account preferences or use the unsubscribe link which will be at the bottom of any marketing emails sent.
G. USING iWEAR Site and Apps with Third-Party Services
Our site and Apps allow you to interact with a wide variety of other digital services. For example, our site and Apps can integrate with third-party social networks and other digital services.
If you choose to connect your iWEAR account with a third-party account, your privacy rights on third-party platforms will be governed by their respective policies. For example, if you choose to share your iWEAR activity on third-party social media platforms, the policies of those platforms govern the data that resides there.
Our site and Apps may provide links to other (third-party) websites and apps for your convenience or information. Linked sites and apps have their own privacy notices or policies, which we strongly encourage you to review. To the extent any linked websites or apps are not owned or controlled by us, we are not responsible for their content, any use of the websites or apps, or the privacy practices of the websites or apps.
H. CHANGES to our Privacy Policy
Applicable law and our practices change over time. If we decide to update our Policy, we will post the changes on our site and Apps. We strongly encourage you to read our Policy and regularly check for any changes. This Policy was last modified in May 2018. For updates which change or affect our practices in relation to personal data, you may be asked to confirm your consent.
I. SUPERVISORY AUTHORITY
The UK Information Commissioner’s Office (‘ICO’) is the designated Supervisory Authority of iWEAR.
If you feel your data has been processed unlawfully or you wish to make a complaint in relation to the processing of your personal data, please contact the ICO on 0303 123 1113 or visit https://ico.org.uk/concerns/handling/.
J. QUESTIONS and Feedback
We welcome questions, comments, and concerns about our Policy and privacy practices. If you wish to provide any feedback or if you have questions or concerns, please contact Consumer Services/Privacy at sales@iwear.ltd
