Hat Couture (“HC”) is committed to complying with the General Data Protection Regulation and the Data Protection Act 2018, once enacted. Looking after the personal information you share with us is very important, and we want you to be confident that your personal data is kept safely and securely and to understand how we use it to offer you a better and more personalised shopping experience.
We have published this notice to help you understand
how and why HC collect information from you;
who we share your information with, why and on what basis; and
what your rights are.
If we make changes to this notice we will notify you by updating it on our website. Next will be what is known as the ‘Data Controller’ of the personal data you provide to us, and we will sometimes refer to ourselves in this notice as “we” or “us”. By Data Controller, this means Next determines the purposes and way in which any personal data are, or will be, processed.
Should you need to contact us please write to: Data Protection Officer Hat Couture, The Willows, Main Street, Poundon, Bicester UK OX27 9BB or via email@example.com quoting Security and Privacy Enquiry. This privacy notice was last updated on 20th November 2019.
What information we collect when you register and why?
When you buy goods from us, you are entering into a contract with us. You do not need to set up an account with us but should you choose to do so before ordering from us; so we can set this up we will ask you to provide some personal information such as:
address (and previous addresses)
date of birth
contact numbers, and
All credit/debit card payments are taken via third party service providers including Square and PayPal. We do not therefore hold any of your financial data on our system.
When you apply for a credit account, we get information about you from credit reference
How do we use your information?
Data Protection says that we are allowed to use and share your personal data only where we have a proper reason to do so. The law says we must have one or more of these reasons and these are:
Contract - your personal information is processed in order to fulfil a contractual arrangement e.g. in order to send you your product samples special offers etc.
Consent – where you agree to us using your information in this way e.g. contacting you with special membership offers etc.
Legitimate Interests - this means the interests of HC in managing our business to allow us to provide you with the best products and service in the most secure and appropriate way e.g. to transfer your data to certain Third Party’s such as delivery partners.
Legal Obligation – where there is statutory or other legal requirement to share the information e.g. when we have to share your information for law enforcement purposes.
Who we share your information with and why
HC works with a number of trusted suppliers, agencies and businesses in order to provide you the high quality goods and services you expect from us such as delivery companies, fraud prevention agencies and market research companies amongst others. Some examples of the categories of third parties with whom we share your data are:
HC works with a number of trusted partners who supply products and services on our behalf. All partners are subject to thorough security checks, and will only hold the minimum amount of personal information needed in order to fulfil the orders you place or provide a service on our behalf.
In order for you to receive your goods, HC works with a number of delivery partners. Again, we only pass limited information to them in order to ensure delivery of your items.
HC works with business who support our website and other business systems.
Marketing Companies and Online Advertising
We work with marketing companies who help us manage our electronic communications with you or carry out surveys and product reviews on our behalf. We use technologies such as cookies within digital marketing networks, ad exchanges and social media networks such as Facebook’s Custom Audience to get relevant marketing messages across to you. These messages may appear when you are on other websites or apps. HC online advertising is intended to help you find what you are looking for and keep you up to date with news of products and services, including store events, offers and promotions by HC. The online advertising you see will be based on any information we may have about you and your visit to the HC website or app such as products you have looked at, search history or ads you have previously clicked on
HC works with trusted third party payment processing providers in order to securely take and manage payments.
Your personal data is protected by legal rights, which include your rights to object to our processing of your personal data; request that your personal data is erased or corrected; request access to your personal data.
For more information or to exercise your data protection rights, please contact us using the contact details above. You also have a right to complain to the Information Commissioner’s Office, which regulates the processing of personal data.
Transfers to third countries
Some of the information you provide to us may be transferred outside the European Economic Area such as India and the US. This is a transfer to a third country. HC has a business relationship with Capita India who provides us with IT support, customer and supplier account administration services. Although the data is held in UK data centres colleagues in India may access it, for them to undertake the activities described above.
If you place an order with us and you are outside of the UK we will transfer the data that we hold on you to Hat Couture in the UK. To find out more please contact us at firstname.lastname@example.org
HC also works with suppliers and partners who may make use of Cloud and/or hosted technologies, we undertake data security due diligence on our partners, ensure that suitable contracts are in place and that these partners conform to appropriate accreditations.
Wherever these transfers take place Next will have an appropriate contract in place and there are strict rules regarding the confidentiality and security of your information in place to safeguard it.
Keeping in touch with you
We want to keep you up to date with information about new ranges, special offers and improvements to our website. When you set your account up, we will ask you if you want to receive this type of marketing information.
HC will not share your information with companies outside of Hat Couture for their marketing purposes.
If you decide you do not want to receive this marketing information you can request that we stop by writing to the Data Protection Officer at the address provided above, emailing email@example.com via My Account online or the unsubscribe link within the email.
You may continue to receive mailings for a short period while your request is dealt with.
How long we keep your information
If we collect your personal information, the length of time we retain it is determined by several factors including the purpose for which we use that information and our obligations under other laws.
We may need your personal information to establish, bring or defend legal claims. For this purpose, we will always retain your personal information for 7 years after the date it is no longer needed by us for any of the purposes listed under How we use your information above. The only exceptions to this are where:
the law requires us to hold your personal information for a longer period, or delete it sooner;
you exercise your right to have the information erased (where it applies) and we do not need to hold it in connection with any of the reasons permitted or required under the law;
we bring or defend a legal claim or other proceedings during the period we retain your personal information, in which case we will retain your personal information until those proceedings have concluded and no further appeals are possible; or
in limited cases, existing or future law or a court or regulator requires us to keep your personal information for a longer or shorter period.
What are your rights
You are entitled to request the following from HC, these are called your Data Subject Rights and there is more information on these on the Information Commissioners website www.ico.org.uk
Right of access –to request access to your personal information and information about how we process it
Right to rectification –to have your personal information corrected if it is inaccurate and to have incomplete personal information completed
Right to erasure (also known as the Right to be Forgotten) – to have your personal information erased. Contact London Office: 0333 330 3213
Right to restriction of processing – to restrict processing of your personal information
Right to data portability - to electronically move, copy or transfer your personal information in a standard form
Right to object - to object to processing of your personal information
Rights with regards to automated individual decision making, including profiling –rights relating to automated decision making, including profiling
If you have any general questions about your rights or want to exercise your rights please contact firstname.lastname@example.org
You have the right to lodge a complaint with a data protection regulator in Europe, in particular in a country you work or live or where your legal rights have been infringed. The contact details for the Information Commissioner’s Office (ICO), the data protection regulator in the UK, are available on the ICO website www.ico.org.uk where your personal information has or is being used in a way that you believe does not comply with data, however, we encourage you to contact us before making any complaint and we will seek to resolve any issues or concerns you may have.
This notice is designed to help you understand what cookies are, how HC uses them and the choices you have regarding their use.
What are cookies?
Cookies are small text files that are stored on your browser or the hard drive of your computer or other device when you visit the Site, this allows the Site to recognise you as a user either for the duration of your visit (using a ‘session cookie’) or for repeat visits ( a ‘persistent cookie’). They are not harmful and do not contain any information such as your home address, date of birth or credit card details.
The cookies we use fall into four broad types:
Strictly Necessary Cookies
These cookies are essential in helping you to move around our Site and use its features, such as accessing secure areas of the website. Without these cookies, services you have asked for, such as setting up an account cannot be provided. These cookies do not gather information about you that could be used for marketing or remembering where you've been on the internet.
In order to keep the Site, its services and products relevant, easy to use and up-to-date, we use web analytics services to help us understand how people use our Site. For example, we can see which parts of the Site and products are most popular, identify when errors occur, and test different versions of a page or feature to see which one works best.
These cookies allow websites and applications to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. The information these cookies collect is usually anonymised which means we can't identify you personally. They do not gather any information about you that could be used for selling advertising or remembering where you've been on the internet, but do help with serving advertising.
If you would like more information on any of these types of Cookies, including how to opt-out, please visit www.youronlinechoices.com
They enable you to transact whilst other non-essential cookies enable us to give you and enhanced, personalised web experience and determine relevant products to show you.
To personalise and improve your customer experience.
To allow you to securely sign in to your Hat Couture Account so that you can use "My Account" features such as order information.
To recognise the device that you are using.
To store the content of your online shopping bag whilst you browse the site and to complete an order.
To record the areas of the Site that you have visited, products you have viewed and time spent browsing, as well as the products you purchased. HC uses this information to help make the website more user friendly, develop our Site design and to continuously improve the quality of the service we provide.
To distribute visitors to our Site evenly across platforms to ensure the content is served at the fastest possible speed.
For re-marketing purposes to determine relevant related products to show you when you're browsing on other selected websites. These cookies can be associated with services provided by a third party such as an advertising network.
Cookies are an essential part of how our Site works, as they remember certain information about a visitor.
HC uses its own 1st party cookies these are placed there and used solely by HC. We use the Facebook Pixel, which uses both 1st Party and 3rd party cookies, as well as other Third-Party cookies (these are placed there by the third parties we work with, listed below).
Are cookies safe?
Yes. The information stored in cookies is safe and anonymous to any external third party, and your account security is never compromised. You can find more information about cookies at http://www.allaboutcookies.org/ and www.youronlinechoices.com/. For a video about cookies visit https://www.google.com/intl/en-GB/policies/technologies/cookies/
Can I turn off cookies?
To change your cookie settings, or if you want to be notified each time a cookie is about to be used, you should amend the settings provided in your web browser to prevent us from storing cookies on your computer hard drive.
For information on how to disable cookies, please consult the "Help" tab of your browser via the menu bar. For further information on non-essential cookies used for targeting and banner advertising please see below.
Details of our Third Party Cookies
HC allows selected Third Parties who participate with us in marketing programs to place cookies when you visit our site. These cookies enable us to monitor which adverts you see and click on to get to our site.
For details of the Third Party cookies we use please see the table below. HC is not responsible for the content or privacy policies of Third Parties or other websites, and we advise that you check these yourself.
The following Cookies are all used for Analytical and Targeting purposes.
Google Tag Manager
Yahoo DOT Tag
Facebook Custom Audiences
Facebook Pixel *
The Facebook Pixel uses both 1st party and 3rd party cookies and further details of our use of online advertising can be found in the Privacy Notice.
Website visitors who don’t want their data used by Google Analytics can install the Google Analytics opt-out browser add-on. To opt-out of Analytics for the web, visit the Google Analytics opt-out page and install the add-on for your browser. Learn more about the opt-out and how to properly install the browser add-on here.
Visitors can also opt-out of Google Analytics for Display Advertising and customize Google Display Network ads using the Ads Settings
This Cookie Notice was last updated on 20th November 2019 and further changes will be communicated by updating this notice.
Should you need to contact us please write to:
Data Protection Officer Hat Couture, The Willows, Main Street, Poundon, Bicester OX27 9BB
or via email@example.com quoting Security and Privacy Enquiry.