RESKINNED RESOURCES LTD

PRIVACY NOTICE

Reskinned Resources Ltd (“Reskinned” or “we/us/our”) is committed to protecting and respecting your privacy. This Privacy and Cookie Notice sets out the basis on which the personal data that you provide to us (or that we collect from you) will be processed by us via the Reskinned Platform - which may either be accessed on the https://takeback.reskinned.clothing domain or may be embedded in a brand partner’s website (the “Reskinned Platform”) or processed by us in connection with your use of the Reskinned online marketplace, which may be accessed on the https://www.reskinned.clothing/ domain (the “Reskinned Marketplace”). Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

For the purpose of the United Kingdom version of the General Data Protection Regulation, the Data Controller is Reskinned Resources Ltd, which is registered in England and Wales under company number 12214659. Our registered office is at Unit A Forward Business Centre, North Crescent, London, England, E16 4TG.

YOUR PERSONAL INFORMATION

Information we collect from you

We collect and process some or all of the following types of information from you in the course of your use or our provision of the Reskinned Platform or Reskinned Marketplace and associated services:

• Information that you provide by registering, placing purchases or providing other information on the Reskinned Platform or Reskinned Marketplace. This will usually be your:
  • Name
  • Address
  • email address
  • phone number
  • login information
  • Information about your preferred brands
  • Information about your purchases
  • Information about items returned as part of the take-back process
• Information that you provide when requesting further information or services.
• Any feedback or information you provide to us in response to surveys
• Information you submit to confirm whether you wish to receive marketing from us or from any of our our Brand Partners.

If you contact us, we may keep a record of that correspondence.

Details of your visits to the Reskinned Platform including, but not limited to, your browsing and log data collected by Google analytics and other analytics programs, cookies, traffic data, location data, weblogs and other communication data, and the resources that you access.

The provision of e-mail address, phone number and the brand whose items you wish to return to Reskinned (each a “Brand Partner”) are required from you to enable you to use the Reskinned Platform and sign up to receive our services. We will inform you at the point of collecting information from you, whether you are required to provide any other information to us.

Information we collect from others

A courier that you select to collect any returned items will provide us with some information about the collection of those items from you.

Where you use the Reskinned Platform, we do not receive any information about you from any Brand Partner – you are directed from the Brand Partner’s website to the Reskinned Platform and provide us with your information directly.

USES MADE OF YOUR INFORMATION

Lawful basis for processing and purpose of processing

We rely on “performance of a contract with the data subject” where we collect, use and share (in accordance with this policy only) your personal data in order to provide our products and services pursuant to our agreement with you.

We rely on “legitimate interest” where:

• You are a current user of the Reskinned Platform or have recently entered into an agreement to purchase one or more items from the Reskinned Marketplace, to send you newsletters and promotional materials which we feel may be of interest to you.
• We provide information to Brand Partners for the purpose of complying with other obligations to them pursuant to our agreement with them (including but not limited to complying with audit obligations).

We rely on your consent as the lawful basis where you have agreed to participate in a survey or give us feedback, and for the processing of such personal information as has been collected through that survey or feedback process.

We obtain your “consent” before we use your information, or provide your details to Brand Partners and other third parties, for marketing purposes, unless we rely on legitimate interest, as set out above.

Purposes of processing

We use information held about you in the following ways:

• to provide you with our goods and services
• to provide you with a Credit following receipt of your Items via our takeback service. Please note that we will also share your data with the Brand Partner for this purpose (see below)
• to enable You to use the Reskinned Platform
• to enable us to provide you with an up to date, efficient and reliable service
• to learn about how the Reskinned Platform and/or Reskinned Marketplace is being used by analysing user trends and preferences, to improve the quality and design of our services, to understand which features are being used and to understand which potential new features, content, brands or campaigns are likely to interest our user base
• to contact You with news (only Your name and email address are used for this purpose)
• to notify You about Your use of the Reskinned Platform and/or Reskinned Marketplace, or to offer you additional services (only Your name and email address are used for this purpose)
• to contact You about matters requiring your attention
• to verify Your identity
• to conduct analytics on Your visit to the Reskinned Platform, including by recording and analysing user behaviour, location, audience, demographic and interest data
• to serve You advertising based on your interests and previous buying or browsing habits
• enable Our compliance with applicable laws and regulations and with any agreements we have entered into with You and the Brand Partners
• to administer and protect our websites, the Reskinned Platform and/or Reskinned Marketplace.

We may anonymise the personal data we collect (so it can no longer identify you) and then combine it with other anonymous information so it becomes aggregated data. Aggregated data helps us identify trends (e.g. what percentage of users responded to a specific survey). Data protection law does not govern the use of aggregated data and the various rights described below do not apply to it.

DISCLOSURE OF YOUR INFORMATION

We share (or may share) your personal data with:

• Our personnel: our employees (or other types of workers) who have contracts containing confidentiality and data protection obligations
• Our Brand Partners: so that they can provide us with the Credit to pass on to you and for the purpose of complying with other obligations to them pursuant to our agreement with them (including but not limited to complying with audit obligations).
• Courier services: so that they can deliver your purchased items or collect the items that you have listed to be returned to Reskinned.
• Regulatory authorities: such as HM Revenue & Customs
• Our professional advisers: such as our accountants or legal advisors where we require specialist advice to help us conduct our business
• Our supply chain: other organisations that help us provide our items, such as third party service providers, agents, subcontractors and other associated organisations for the purposes of completing tasks and providing services to you on our behalf (e.g. to host our servers). We ensure these organisations only have access to the information required to provide the support and we have a contract with them that contains confidentiality and data protection obligations

We may disclose your personal data to any member of our corporate group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006 (where applicable).

We may also disclose your personal data to third parties:

• in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets; or
• if we or substantially all of our assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets; or
• if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms and Conditions and other agreements; or
• to protect Our rights, property, or safety or that of our affiliated entities and our users and any third party we interact with the to provide the Reskinned Platform; or
• in relation to selected third parties only, only to the extent that you have consented to such selected third parties notifying you about certain goods or services, which may be if interest to you.

Other than as set out above, and save insofar as is necessary in order for us to carry out our obligations arising from any contracts entered into between you and us, we will not share your data with third parties unless we have procured your express consent to do so.

STORING YOUR PERSONAL DATA

Security

We take appropriate measures to ensure that any personal data are kept secure, including security measures to prevent personal data from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal data to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the Reskinned Platform; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

The Reskinned Platform may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and terms of use and that we do not accept any responsibility or liability for these policies and terms of use. Please check these policies before you submit any personal data to these websites.

Keeping your personal data up to date

If your personal details change you may update them by accessing the relevant page of the website, or by contacting us using the contact details below. If you have any questions about how we use data collected which relates to you, please contact us by sending a request by email to the contact details below.

We will endeavour to update your personal data within seven (7) working days of any new or updated personal data being provided to us, in order to ensure that the personal data we hold about you is as accurate and up to date as possible.

How long we keep your personal data

We will hold the data set out above for a reasonable time having regard to the nature of the personal data and the purpose for which it was collected. In particular:

• Where we hold your personal data in connection with the performance of a contract with one of our customers or suppliers, we will hold your data, and in particular any communications between you and us in relation to the negotiation or performance of the contract by either party for so long as that contract is in force and for a period of at least 7 years after;
• Where we hold your data in connection with the marketing or promotion of our business, we will hold your data for up to 2 years, or for up to 2 years after you last communicated with us, if later.
• In respect of website usage data, we hold your data for 5 years from the date of collection.

Where we store your personal data

All information we hold about you is stored on secure servers within the United Kingdom and/or the European Economic Area.

YOUR RIGHTS

Under the General Data Protection Regulation you have a number of important rights free of charge. In summary, those include rights to:

• access to your personal data and to certain other supplementary information that this Policy is already designed to address
• require us to correct any mistakes in your information which we hold
• require the erasure of personal data concerning you in certain situations
• receive the personal data concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
• object at any time to processing of personal data concerning you for direct marketing
• object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
• object in certain other situations to our continued processing of your personal data
• otherwise restrict our processing of your personal data in certain circumstances
• claim compensation for damages caused by our breach of any data protection laws.

For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation.

If you would like to exercise any of those rights, please:

• email, call or write to us
• let us have enough information to identify you (email address),
• let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill), and
• let us know the information to which your request relates

HOW TO COMPLAIN

We hope that we can resolve any query or concern you raise about our use of your information.

The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone: 0303 123 1113.

CHANGES TO OUR PRIVACY POLICY

We reserve the right to modify this Policy at any time. Any changes we may make to our Policy in the future will be notified and made available to you using the Reskinned Platform. Your continued use of the services and the Reskinned Platform shall be deemed your acceptance of the varied privacy policy.

INFORMATION ABOUT OUR USE OF COOKIES AND IP ADDRESSES

We may collect information about your mobile phone, computer or other device from which you access the Reskinned Platform including where available your IP address, operating system and browser type, for systems administration and to report aggregate information to third parties affiliates. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual. we may, however, use such information in conjunction with the data we have about you in order to track your usage of our services.

Our Reskinned Platform and Reskinned Marketplace use cookies to distinguish you from other users. This helps us to provide you with a good experience when you browse the Reskinned Platform and/or Reskinned Marketplace and also allows us to improve the Reskinned Platform and Reskinned Marketplace.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.

The cookies we use include:

“Analytical” cookies. They allow us to recognise and count the number of visitors and to see how visitors move around the Reskinned Platform when they are using it. This helps us to improve the way the Reskinned Platform works, for example, by ensuring that users are finding what they are looking for easily.

“Strictly necessary” cookies. These are cookies that are required for the operation of the Reskinned Platform. They include, for example, cookies that enable you to log into secure areas of the Reskinned Platform, use a shopping cart or make use of e-billing services.

“Functionality” cookies. These are used to recognise you when you return to the Reskinned Platform. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

“Targeting” cookies. These cookies record your visit to the Reskinned Platform, the pages you have visited and the links you have followed to our affiliates’ websites. We will use this information to make the Reskinned Platform, offers e-mailed to you and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

Please note that third parties’ affiliates may also use cookies, over which we have no control.

We can only use cookies with your permission (you will be prompted by a message when you first visit our website, the Reskinned Platform and/or the Reskinned Marketplace, also known as a cookie banner, where you can choose to accept or decline our cookies). You can update your settings on our website, the Reskinned Platform and/or the Reskinned Marketplace.

You may block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of the Reskinned Platform and Reskinned Marketplace.

CONTACT

All questions, comments and requests regarding this Privacy and Cookies Policy should be addressed to privacy@reskinned.clothing