May 17th 2020
Welcome to the Suite Coco website.
If you have a question that is not answered here, or if you would like more information about how we collect, use and store your personal data, you can contact us at any time by emailing email@example.com.
Who is the data controller?
What personal data do we collect?
How do we use this personal data?
What is our legal basis for processing your personal data?
Who will process your data?
Do we transfer your personal data outside of the EU?
How long do we keep your personal data?
Changes to this notice
Legislative reference and useful links
1. Who is the data controller?
Under the data protection law, the data controller is responsible for ensuring that your data is held securely, that you are given accurate information about how your data is used, and that your rights regarding your data are respected.
The Suite Coco website is owned and run by Asa Nwa Limited. For the purpose of the UK Data Protection Act 2018 and the General Data Protection Regulation 2016 (the Law), the data controllers for any personal data we hold about you is Asa Nwa Limited of United Kingdom.
SUITE COCO (referred to here as “we”, “our”, “us”) The term “our online services” refers to our mobile and tablet applications, our pages on third party social media platforms such as Instagram, Facebook, Twitter, Pinterest and Google+ and any other websites or apps we own or run from time to time. The term “our services” refers to our online services and any of our other products and services offered from time to time. If you use any of our services, we will refer to you using the terms “user”, “visitor”, “you”, “your”, “yours” in this policy.
2. What personal data do we collect?
We collect and process only the data that is required to allow us to provide our services to you. We collect the following data when you browse or shop at www.suitecoco.com:
a) We process the personal data required to complete and dispatch your purchase, including your name, billing address, delivery address, payment details, mobile number, telephone number and email address. We collect your email address in order to send you confirmation of your order; we collect your telephone number so that we can contact you if there are any issues with the order.
b) We collect your email address when you sign up to the SUITE COCO mailing list
c) If you register for a SUITE COCO account, we collect your name, email address, password, country, day and month of birth and additional information regarding your marketing preferences.
d) When you contact our Customer Care team, we may collect additional data to help us resolve any queries relating to your order, delivery, payments, marketing, the website or any other queries.
e) We collect and process data about your browsing on www.suitecoco.com, including the pages you visit and how you interact with these pages. If you have registered for an account, we collect browsing data about your access to the dedicated areas of the website.
f) If you are a customer of www.suitecoco.com, or if you have given us your consent, we collect and process your personal data for direct marketing activities.
g) If you provide us with someone else’s data – for example, if you purchase a product to be delivered to a friend or as a gift, or provide us with someone’s data as part of our refer-a-friend scheme – we will collect and process the personal data required to complete the transaction such as the name, delivery address and other contact details for your friend. If you are receiving an item as a gift, we will process your data only to fulfill the gift request and our contractual obligations.
h) When you call our Customer Care team, your call will be recorded for training and fraud prevention purposes.
3. How do we use the personal data we collect?
We collect and process your personal data for the following purposes:
a) To fulfill our contract with you, including taking payment, shipping and delivery;
b) To provide you with relevant information about our products and services via our marketing communications and advertising;
c) To help you take full advantage of our website, including placing and holding items in your shopping bag and using services such as Wish Lists;
d) To improve the performance of our website and our promotion of the website;
e) To allow our Customer Care team to help you with queries and requests;
f) To send you updates to important information such as our Terms & Conditions.
For a detailed breakdown of how we use your personal data, please view the table below.
4) What is our legal basis for processing your personal data?
Under the Law we must have a valid reason for using your personal data and we may not collect, store or use data about you that is not compatible with that reason. There are four valid reasons for our use of your personal data:
a) Most of the data we collect from you is necessary to allow us to fulfill our contract with you or to enter into a contract with you e.g. you provide a billing address and email address when you purchase an item from www.suitecoco.com so that we can process your payment and send you order confirmation.
b) In certain circumstances we will ask for your permission or consent to use your personal data e.g. if we would like to send you marketing information about items we believe may be of interest to you via email. If you have given your consent to our use of your personal data, you are entitled to withdraw this consent at any time.
c) We may also have a legitimate interest in using your personal data e.g. to ensure that the content of our website is presented to you and your device as effectively as possible, or to ensure that our marketing communications are relevant to your interests. If this is our reason for using your data, we must make sure that our interests do not override yours and you are entitled to object to this use of your data.
d) Lastly, we may be required to use your data to meet a legal obligation or to protect your interests e.g. we may exchange information with other specialist organisations for the purposes of fraud detection and credit risk reduction and we will retain financial data long term to meet our statutory obligations.
For a detailed breakdown of how we use your personal data, please view the table below.
5) Who will process your data?
Your personal data will be processed by the internal staff of Asa Nwa Limited.
Your personal data will also be transmitted to third parties that we use to provide our services. These parties have been designated as data processors and carry out their activities according to the instructions given by Asa Nwa Limited and under its control.
The third parties in question belong to the following categories: banking operators, internet providers, companies specialising in IT and telematics services; couriers; companies that carry out marketing activities, including social media organisations; companies specialising in market research and data processing; companies offering contact centre services; companies providing publishing and distribution services.
Under some circumstances we may be required to disclose or share your data without your consent, for example if we are required by the police, the courts or for other legal reasons. Your data may be transmitted to the police, judicial and administrative authorities, in accordance with the law, for the investigation and prosecution of crimes, the prevention of and protection from threats to public security, to allow Asa Nwa Limited to ascertain, exercise or defend a right in court, as well as for other reasons related to the protection of the rights and freedoms of others.
6) Data transfer outside the European Union
Some of the third parties listed in the previous paragraph ‘Who will process your data?’ may be located in countries outside the European Union that nevertheless offer an adequate level of data protection, as established by specific decisions of the European Commission (https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en)
The transfer of your personal data to countries that do not belong to the European Union and that have not been assessed as offering adequate levels of protection will be performed only:
I. after the completion between Asa Nwa Limited and said parties of specific agreements containing safeguard clauses and appropriate guarantees for the protection of your personal data (known as “standard contractual clauses” and approved by the European Commission), or
II. if the transfer is necessary for the completion and execution of a contract between you and Asa Nwa Limited (for the purchase of goods offered on our website, for registration on the website or use of services on the website), or
III. for the management of your requests.
7) How long do we keep your data?
We keep your personal data for a limited period of time in line with our data retention policy. The specific retention period will vary according to the reason for processing your personal data. After this period, your data will be permanently erased or otherwise irreversibly rendered anonymous.
Your personal data are retained in accordance with the following criteria:
When you have purchased goods from www.suitecoco.com, we will retain the billing data until the end of the relevant accounting period, normally seven years from the billing date;
When you make a payment, we will retain your payment details up to the certification of the payment and the completion of the relevant administrative-accounting formalities regarding your right of withdrawal and the terms applied for the disputing of the payment;
When you provide us with personal data in order to use the services of www.suitecoco.com, such as marketing communications subscription, we will keep your data for this purpose until the termination of the service or until you cancel your subscription to the service;
When you give us your consent to send you marketing communications, you can withdraw your consent at any time. We will consider your consent to be current for five years from your last interaction with any email that we send you or with www.suitecoco.com.
When we use your personal data and browsing history to analyse your behaviour in order to customise the website and to show you personalised sales offers, we will keep the data for analytical purposes until you ask us to delete it;
When we use personal data for market research and satisfaction surveys, we will keep the data until you ask us to stop.
When you contact our Customer Care team, we will keep any additional personal data you provide that is specific to your enquiry for as long as you remain an active customer of www.suitecoco.com.
8) Your rights
You have the right to request a copy of the data that we hold about you (and we will provide this to you free of charge once we have confirmed your identity).
If you would like a copy of some or all of your personal data, please email or write to us using the contact details in this policy.
If we do hold data about you we will:
give you a description of it
tell you why we are holding it
tell you who it could be shared with
tell you how long we will keep the data
if the data was not provided by you, we will give you any available information such as the source of the data
tell you if the data has been used for automated decision making
tell you if the data is stored outside of the European Economic Area, and if so what safeguards are in place to protect your personal data
let you have a concise and clear copy of the data
You have the right to ask us to correct any inaccuracies in the personal data we hold about you and to stop us using your data until it has been corrected. We want to make sure that your personal data is accurate and up to date and we will be happy to correct or remove data you think is inaccurate.
You have the right to withdraw your consent to marketing at any time by contacting our Customer Care team, clicking “unsubscribe” on a marketing email or replying STOP to a text message. You may receive a small number of further communications immediately after unsubscribing but we will implement your request as quickly as possible.
You have the right at any time to oppose our processing of your personal data on the basis of our legitimate interest. You will need to explain the reasons behind your request and allow us to consider your request and respond.
You have the right to request the deletion of your personal data. After receiving and reviewing your request, if legitimate it will be our responsibility to cease processing promptly and to delete your personal data.
You have the right to receive a copy of your data that we process based on your consent or on the basis of a contract with you in a standard format. If you wish, where technically possible, we can transfer your data directly to a third party indicated by you.
To exercise any of these rights contact our Customer Care team at firstname.lastname@example.org
To ensure that the data of our users are not subject to breaches or illegitimate use by third parties, we will ask you to confirm your identity before carrying out your request.
If you believe that Asa Nwa Limited is processing your personal data in contravention of the Law, you can file a complaint with the supervisory authority responsible for compliance with the rules on personal data protection.
In the UK, the complaint can be presented to the ICO. More information on how to complain is available on the ICO’s website at https://ico.org.uk/.
11) Changes to this notice
12) Legislative references and useful links.
The processing of your personal data is carried out by ASA NWA LIMITED in compliance with the Regulation (EU) 2016/679 general regulation on data protection, UK Data Protection Act 2018 and rules on the processing of personal data (https://ico.org.uk/).
Our use of your data
Our legal basis for processing
When you purchase a product from www.suitecoco.com we ask you for the personal data necessary to allow us to fulfill our contract with you including taking payment, completing any related anti-fraud checks if you choose to pay by credit/debit card, billing, shipping and delivery of the product and possible handling of the return.1. The provision of your personal data for these activities is a contractual obligation. You are free to communicate your data or not, but in the absence of the requested data it will not be possible to finalise or execute the contract and your requests. This means that while you will continue to be able to browse www.suitecoco.com, you will not be able to purchase products and you will not be able to use the services of our website
2. When you make a purchase at www.suitecoco.com, we are required to process your personal data to meet our legal obligations in accordance with the tax provisions and other statutory rules which apply.
You are free to decide whether or not to purchase from us, but if you do make a purchase this use of your data will be necessary to meet our legal obligations.
3. When you make a purchase at www.suitecoco.com, we will use some of your personal data to carry out anti-fraud activities: we have a legitimate interest in carrying out this activity to prevent and prosecute any fraudulent activity.
When you visit www.suitecoco.com, we will collect the personal data necessary to allow us to provide you with the services of the website, such as placing and holding items in your shopping bag.Our use of your data is necessary for our legitimate interest in ensuring that the service we provide to you is managed correctly.
This website is owned and run by ASA NWA LIMITED (“we”, “our”, “us”), The term “our online services” refers to Suite Coco and any other websites or apps we own or run from time to time. If you use any of our online services, we will refer to you using the terms “user”, “visitor”, “you”, “your”, “yours” in this policy.
The cookies used on our online services
Advertising cookies used on our business partners’ websites
How to reject or opt out of receiving cookies
The tracking technology we use in our Apps
THE COOKIES USED ON OUR ONLINE SERVICES
The cookies we use on our online services can be grouped into the following categories:
Essential cookies: Some of the cookies on our online services are essential for us to be able to provide you with a service you have requested. An example of this would be a cookie that enables you to log into your account on the website, or one which allows communication between your browser and the website. You may not be able to use our website without these cookies.
Website functionality cookies: These cookies enable you to browse our online services and use features such as shopping baskets and wish lists.
Website analytics cookies: We use these cookies to measure and analyse how our customers use our online services. An example is counting the number of different people visiting our website or using a particular feature, rather than the total number of times the site or feature is used. This allows us to continuously improve our online services and your shopping experience.
Customer preference cookies: When browsing or shopping online, our online services will remember preferences you make (for example your user name, language or location). This improves your experience and makes your browsing simpler, easier and more personal to you.
Social sharing cookies: When browsing or shopping online, our online services will remember preferences you make (for example your user name, language or location). This improves your experience and makes your browsing simpler, easier and more personal to you.
When you visit www.suitecoco.com, we will use some data about your use of the website to help us improve the website and our promotion of the website. This will include data about how you came to the website; the date and time of your visit; products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction data (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.Our use of your data is necessary for our legitimate interest in ensuring that the service we provide to you is managed correctly.
When you register on www.suitecoco.com,we will collect the data necessary to ensure that we can recognize you on return visits and provide you with the services registration offers, such as creating a wish list or subscribing to emails about stock updates and/or new releases. If you would prefer not to continue receiving these emails, you can unsubscribe at any time using the link on the bottom of the email, or by contacting our Customer Care team. The provision of your personal data for these activities is a contractual obligation. You are free to communicate your data or not, but in the absence of the requested data it will not be possible to finalise or execute the contract and your requests. This means that while you will continue to be able to browse www.suitecoco.com, you will not be able to use the services of our website such as the Wish List or stock alerts
When you sign up for our marketing communications, we will ask you for your email address to enable delivery of the marketing communications. If you would prefer not to receive these emails, you can unsubscribe at any time using the link on the bottom of the email, or by contacting our Customer Care team.You have given your consent and asked us to send you our marketing communications.
If you have purchased from www.suitecoco.com, we will use the personal data we hold about you, including your purchase history, to contact you regarding products and services that may be of interest to you. This contact will normally be via email, but in certain circumstances we may contact you via other methods e.g. we may call you if an item you have been eager to purchase comes back into stock. If you would prefer not to be contacted in this way, you can unsubscribe from emails at any time using the link on the bottom of the email, or by contacting our Customer Care team.Our use of your data is necessary for our legitimate interest in ensuring that you receive information about goods and services that may be of interest to you.
We analyse contact data, purchase histories, web browsing data and lifestyle data to tailor our marketing communications, web site presentation and internet advertising to meet your preferences. For example, if you have been browsing or have previously purchased a particular dress, we may send you an email to tell you that this item is now on sale or display similar products to you on our own website or as part of our advertising on other websites.Our use of your data is necessary for our legitimate interest in ensuring that you receive information about goods and services that may be of interest to you.
When you contact our Customer Care team, we will use the personal data you provide and that we have collected to respond to your requests for help or information.The provision of your personal data for these activities is a contractual obligation. You are free to communicate your data or not, but in the absence of the requested data it will not be possible to finalise or execute the contract and your requests.
You have the option to provide us with your birth day and month and to subscribe to our marketing communications and those from our partners.
When you call our Customer Care team, your call will be recorded for training and fraud prevention purposes.Our use of your data is necessary for our legitimate interest in ensuring that our employees receive adequate training and for fraud prevention.
To improve our marketing communications, we use a similar technology to cookies to confirm whether you have opened a marketing email or clicked on a link in the email. This information helps us to measure the value of our communications and to provide you with relevant content.This processing constitutes profiling under the GDPR. We process your personal data in this way as it is in our legitimate interest to offer you a personalised experience on our sites and to provide you with personalised advertising and marketing.
If you have given us your email address or mobile phone number, we may supply this data to digital advertising or social media companies who work on our behalf, such as Facebook and Google. This is so we can show you advertising via these sites that is tailored to your interests and your purchase history. At our request, Facebook and Google may also use this data to identify individuals with similar characteristics to our customers and then serve our advertising to these individuals. The data we provide to these organisations is limited to email address or mobile phone number and is always provided in an encrypted format. If you would prefer not to see targeted advertising from us on social media, please refer to the instructions provided by the website or app, for example on Facebook, Twitter, Instagram, and Google. This processing constitutes profiling under the GDPR. We process your personal data in this way as it is in our legitimate interest to offer you a personalised experience on our sites and to provide you with personalised advertising and marketing.
Online retargeting is a form of online advertising that allows us and some of our advertising partners to show you advertising based on your browsing patterns and interactions with our websites. For example, when you have visited our website then moved to another site, you may start seeing our adverts displaying special offers or reminding you of the products you were browsing on our website. The technology behind these adverts is based on cookies. We process your personal data in this way as it is in our legitimate interest to offer you a personalised experience on our sites and to provide you with personalised advertising and marketing.
This website is owned and run by ASA NWA LIMITED (“we”, “our”, “us). The term “our online services” refers to SUITE COCO, our pages on third party social media platforms such as Instagram, Facebook, Twitter, Pinterest and Google+ and any other websites or apps we own or run from time to time. The term “our services” refers to our online services and any of our other products and services, offered from time to time. If you use any of our services, we will refer to you using the terms “user”, “visitor”, “you”, “your”, “yours” in this policy.
What personal information do we collect from you and how?
What about cookies? What are cookies?
How this information may be used
Who we will share your personal information with
Where we process your personal information
Marketing opt-in and opt-out provisions
How you can access your personal information and keep it up to date
Safeguarding your personal information
Why we link to other websites
How we can make changes to this policy
Where and how to ask questions or contact us about this policy
WHAT PERSONAL INFORMATION DO WE COLLECT FROM YOU AND HOW?
We collect personal information about you when you register or subscribe for one of our services, place an order, buy a gift voucher, use our online services, interact with us in any other way, such as via social media, click on an advert that we put on our or someone else’s website, use our Personal Shopping services, ask for information or assistance, give us a testimonial or other feedback, comment on any blogs or articles featured in our services, attend an event that we run or sponsor, enter competitions or special promotions, sign up for our special offers or other updates, participate in research panels or fill in surveys. By registering, subscribing or using our services, you consent to the use of your personal data in line with this policy. We may also receive information about you from third parties, with whom we have a business relationship.
The information we collect and hold about you may include your name, email address, phone and mobile phone numbers, home address, shipping and payment card billing address, payment card details, IP address, search criteria, shopping history, shopping preferences, sizings, responses to research panels and surveys, the type of browser you use (a browser is the program you use to look at websites, such as Internet Explorer, Firefox or Safari), the times when you access the site and for how long, your referring URL (the site you come from to reach our website), cell IDs (these are the unique identifiers of the telecommunications towers being used by your mobile phone when you use our locations-based services on your mobile phone or tablet) and other location information (for example, GPS measurements), photographs and other content you share with us when you use our services, date of birth, password details, answers to security questions and any other information you may give us.
We may record or monitor calls that you receive from us or make to us. We do this for security and training purposes, and to improve the services we provide to you.
WHAT ABOUT COOKIES? WHAT ARE COOKIES?
HOW THIS INFORMATION MAY BE USED
Whenever you give us your personal information we will use it in accordance with applicable privacy laws and for the purposes set out in this policy, on the data entry forms you complete, in any relevant terms and conditions and on pages or emails which link to the data entry forms.
When you use our services: If you use any of our services, register for or attend one of our events, set up, look at or change your account details or contact your personal shopper or a member of our Customer Care team, we will record your personal details. Your information will be used in the first place to provide the products, services or information you have asked for and to provide you with a personalized shopping experience. We keep the information you provide and may use it for several purposes, including: (i) accounting, billing, reporting and audit; (ii) credit checking or screening; (iii) authentication and identity checks; (iv) credit, debit or other payment card verification and screening; (v) debt collection; (vi) safety, security, health, training, administrative and legal purposes; (vii) data matching and dedupe, statistical and market analysis, and marketing information; (viii) advertising and marketing for us, and third parties; (ix) developing, testing and maintaining systems; (x) studies, research and development; (xi) customer surveys; (xii) customer care and to help us in any future dealings with you, for example by identifying your requirements and preferences; (xiii) where required by law or in connection with legal proceeding or disputes; and (iv) any other uses set out in the terms and conditions for use of our services. For these purposes we may disclose your information to one or more of the other organisations listed in the section called “who we will share your personal information with”.
Saved payment card details will only be shared with our payment partner and not with any other third parties and will only be used to process your order, using our payment partner’s systems.
We may also use your personal information to send you marketing updates, as detailed in the next section.
Testimonials: If you give us feedback, we may use it to improve our services and we may publish it online or offline to promote our business and our services. We will ask for your permission before we publish it.
Comments and reviews submitted to our online services: If you wish to submit a comment or feedback on a blog or article featured on our services, we may (but are not obliged to) publish your comment online or offline to promote our business and our services. We will collect your name or username which will be displayed next to your comment and e-mail address, which will not be published, but which we may use to contact you in relation to your comment.
WHO WE WILL SHARE YOUR PERSONAL INFORMATION WITH
From time to time, we may engage third party business partners to provide information about you or to collect personal information on our behalf. We may also share or match your data with third party business partners to provide you with the products, services or information you ask for or for interest-based advertising. We may pass your information onto one or more of the following organisations: (i) data processing companies, mailing houses and other third party suppliers working on our behalf; (ii) ad-serving agencies and other advertising intermediaries; (iii) credit reference or fraud prevention agencies, which may keep a record of that information; (iv) research students, universities and other research and development organisations; (v) regulatory bodies, government and enforcement agencies, such as the police.
We may receive requests for information from government departments, the police and other enforcement agencies. If this happens, and there is a proper legal basis for providing your personal information, we will provide it to the organisation asking for it.
We collate information about site traffic, sales, wish lists, and other commercial information which we may pass onto third parties, but this information does not include any details which can identify you personally.
WHERE WE PROCESS YOUR PERSONAL INFORMATION
When we use your information as described in this policy, this may involve sending your information outside the European Economic Area (EEA). When we do this, we make sure that appropriate steps are taken to protect your personal information and your rights. By providing us with your personal information, you agree that we may transfer, store and process your information outside the EEA. Governments in certain countries such as the USA have broad powers to access data for security, crime prevention and detection and law enforcement purposes.
MARKETING OPT-IN AND OPT-OUT PROVISION
From time to time we may offer you the chance to receive news updates which, depending on your preferences, we will discuss with you by phone or live chat or send to you via email, SMS and/or direct mail. These include alerts for new products, features, enhancements, special offers, upgrade opportunities, contests, events of interest, and one-off marketing promotions. You can opt-out of receiving these updates, if you wish.
We, or our third party business partners, may also ask you if you want to receive marketing if you enter a promotion or attend an event thrown or sponsored by us.
Marketing communications you subscribe to will only be sent by SUITE COCO.
You have the right to ask us not to use your personal information for marketing. At all times, we will offer you the opportunity to unsubscribe from any service or update to which you have subscribed, if you change your mind. Whenever you receive direct marketing from us, we will tell you how to unsubscribe. To opt out of direct mail, please contact our Customer Care team:
email at email@example.com
If you tell us that you do not want to receive direct marketing, we will still contact you in order to provide you with products and services you request and for administration purposes.
HOW YOU CAN ACCESS YOUR PERSONAL INFORMATION AND KEEP IT UP TO DATE
You have the right to see information we hold about you, with some exceptions which are described in the privacy laws. If you would like a copy of your personal information, please contact our privacy officer at firstname.lastname@example.org. You will need to pay a processing fee.
WHY WE LINK TO OTHER WEBSITES
Our online services may from time to time contain hyperlinks to websites that are owned and operated by other organisations. These websites have their own privacy and cookie policies, and we urge you to read them. They control how your personal information is used when you give it to these other organisations or they collect it with cookies. We do not approve any other websites and we are not responsible for any information, material, products or services that are on or accessible through those websites or for the privacy practices of websites run by other organisations. If you use these other websites you do so at your own risk.
HOW WE CAN MAKE CHANGES TO THIS POLICY