Toff London respects and values the privacy of all our customers, contractors, and contacts and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
This Privacy Information explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.
About Toff London
Company: Watches2U International Limited trading as Toff London
Address: Unit 17, iO Centre, 57a Croydon Road, Croydon, CR0 4WQ
Data protection lead: To contact our DPL, please send an email to the address below.
Email address: email@example.com
Collecting Personal Information
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the "GDPR") as 'any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier'.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
We may collect some or all of the following personal data. If you do not allow us to collect this data then we may not be able to fulfil our contractual or legal requirements.
- Email address
- Telephone number
- Business name
- Job title
- Payment information
- IP address and website cookies
For more information on data collecting, please refer to our Data Protection Policy and our Data Retention Policy below.
Under the GDPR, you have the following rights, which we will always work to uphold:
- The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in "How to contact Us".
- The right to access the personal data we hold about you. Part 10 will tell you how to do this.
- The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in "How to contact Us" to find out more.
- The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in "How to contact Us" to find out more.
- The right to restrict (i.e. prevent) the processing of your personal data.
- The right to object to us using your personal data for a particular purpose or purposes.
- The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases. We do not use your personal data in this way.
- Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in "How to contact Us".
Further information about your rights can also be obtained from the Information Commissioner's Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner's Office.
Using Personal Information
We use your personal Information to provide our services to you, which includes: offering products for sale, processing payments, shipping and fulfillment of your order, and keeping you up to date on new products, services, and offers.
Under the GDPR, we must always have a lawful basis for using personal data. Our lawful basis is one or more of the following:
- Because the data is necessary for our performance of a contract with you;
- Because you have consented to our use of your personal data; or
- Because it is a legal requirement.
Your personal data may be used for one of the following purposes:
- Providing and managing your account.
- Supplying our services to you. Your personal details are required in order for us to enter into a contract with you.
- Communicating with you. This may include responding to emails or calls from you.
- Supplying you with information that you have opted-in to (you may unsubscribe or opt-out at any time by following the instructions at the bottom of every communication).
- With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email with information, news, and offers on our services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):
- If you make an enquiry but do not engage our services, we will keep your personal data for 3 months from the date of last communication.
- If you engage our services, we will keep your personal data for 7 years from the date of last communication.
We may store or transfer some or all of your personal data in countries that are not part of the European Economic Area (the “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein). These are known as “third countries” and may not have data protection laws that are as strong as those in the UK and/or the EEA. This means that we will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR as follows:
- Where we transfer your data to a third country, this is protected by the use of a data sharing agreement utilising EU approved model contract clauses.
We may need to share your Personal Information with service providers to help us provide our services and fulfill our contracts with you, as described above. For example:
- External accountant
- Couriers making deliveries on our behalf
- Contractors working on our behalf
- We use Shopify to power our online store. You can read more about how Shopify uses your Personal Information here: https://www.shopify.com/legal/privacy.
Accessing your personal data
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a "subject access request".
All subject access requests should be made in writing and sent to the email or postal addresses provided. To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible.
There is not normally any charge for a subject access request. If your request is 'manifestly unfounded or excessive' (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
Data Protection Policy
This Policy sets out the obligations of Toff London, 39-43 Monument Hill, Belgrave House, Weybridge, KT13 8RN ("the Company") regarding data protection and the rights of business contacts, customers and prospective customers ("data subjects") in respect of their personal data under EU Regulation 2016/679 General Data Protection Regulation ("GDPR").
The GDPR defines "personal data" as any information relating to an identified or identifiable natural person (a "data subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
This Policy sets the Company’s obligations regarding the collection, processing, transfer, storage, and disposal of personal data. The procedures and principles set out herein must be followed at all times by the Company, its employees, agents, contractors, or other parties working on behalf of the Company.
The Company is committed not only to the letter of the law, but also to the spirit of the law and places high importance on the correct, lawful, and fair handling of all personal data, respecting the legal rights, privacy, and trust of all individuals with whom it deals.
Data Protection Principles
This Policy aims to ensure compliance with the GDPR. The GDPR sets out the following principles with which any party handling personal data must comply. All personal data must be:
2.1 Processed lawfully, fairly, and in a transparent manner in relation to the data subject.
2.2 Collected for specified, explicit, and legitimate purposes and not further processed in a manner that is incompatible with those purposes. Further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes.
2.3 Adequate, relevant, and limited to what is necessary in relation to the purposes for which it is processed.
2.4 Accurate and, where necessary, kept up to date. Every reasonable step must be taken to ensure that personal data that is inaccurate, having regard to the purposes for which it is processed, is erased, or rectified without delay.
2.5 Kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data is processed. Personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes, subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of the data subject.
2.6 Processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction, or damage, using appropriate technical or organisational measures.
Data Retention Policy
This Policy sets out the obligations of Toff London, of 39-43 Monument Hill, Belgrave House, Weybridge, KT13 8RN ("the Company") regarding retention of personal data collected, held, and processed by the Company in accordance with EU Regulation 2016/679 General Data Protection Regulation ("GDPR").
The GDPR defines "personal data" as any information relating to an identified or identifiable natural person (a "data subject"). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
The GDPR also addresses "special category" personal data (also known as "sensitive" personal data). Such data includes, but is not necessarily limited to, data concerning the data subject’s race, ethnicity, politics, religion, trade union membership, genetics, biometrics (if used for ID purposes), health, sex life, or sexual orientation.
Under the GDPR, personal data shall be kept in a form which permits the identification of data subjects for no longer than is necessary for the purposes for which the personal data is processed. In certain cases, personal data may be stored for longer periods where that data is to be processed for archiving purposes that are in the public interest, for scientific or historical research, or for statistical purposes (subject to the implementation of the appropriate technical and organisational measures required by the GDPR to protect that data).
In addition, the GDPR includes the right to erasure or "the right to be forgotten". Data subjects have the right to have their personal data erased (and to prevent the processing of that personal data) in the following circumstances:
- Where the personal data is no longer required for the purpose for which it was originally collected or processed (see above);
- When the data subject withdraws their consent;
- When the data subject objects to the processing of their personal data and the Company has no overriding legitimate interest;
- When the personal data is processed unlawfully (i.e. in breach of the GDPR);
- When the personal data has to be erased to comply with a legal obligation; or
- Where the personal data is processed for the provision of information society services to a child.
This Policy sets out the type(s) of personal data held by the Company, the period(s) for which that personal data is to be retained, and when and how it is to be deleted or otherwise disposed of.
For further information on other aspects of data protection and compliance with the GDPR, please refer to the Company’s Data Protection Policy.
A cookie is a small amount of information that’s downloaded to your computer or device when you visit our Site. We use a number of different cookies, including functional, performance, advertising, and social media or content cookies. Cookies make your browsing experience better by allowing the website to remember your actions and preferences (such as login and region selection). This means you don’t have to re-enter this information each time you return to the site or browse from one page to another. Cookies also provide information on how people use the website, for instance whether it’s their first time visiting or if they are a frequent visitor.
We use the following cookies to optimize your experience on our Site and to provide our services.
|"Cookie"||means a small file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site;|
|"Cookie Law"||means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 and of EU Regulation 2016/679 General Data Protection Regulation ("GDPR");|
|"personal data"||means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data, as defined by EU Regulation 2016/679 General Data Protection Regulation ("GDPR"); and|
|"Us", "We", "Toff London"||Toff London, of 39-43 Monument Hill, Belgrave House, Weybridge, KT13 8RN.|
- By using Our Site, you may also receive certain third party Cookies on your computer or device. Third party Cookies are those placed by websites, services, and/or parties other than Us. Third party Cookies are used on Our Site to collect information about how visitors use our site and to provide social media links. For more details, please refer to section 4 below.
- All Cookies used by and on Our Site are used in accordance with current Cookie Law. We may use some or all of the following types of Cookie:
- Strictly Necessary Cookies: A Cookie falls into this category if it is essential to the operation of Our Site, supporting functions such as logging in, your shopping basket, and payment transactions.
- Analytics Cookies: It is important for Us to understand how you use Our Site, for example, how efficiently you are able to navigate around it, and what features you use. Analytics Cookies enable us to gather this information, helping Us to improve Our Site and your experience of it.
- Functionality Cookies: Functionality Cookies enable Us to provide additional functions to you on Our Site such as personalisation and remembering your saved preferences. Some functionality Cookies may also be strictly necessary Cookies, but not all necessarily fall into that category.
- Targeting Cookies: It is important for Us to know when and how often you visit Our Site, and which parts of it you have used (including which pages you have visited and which links you have visited). As with analytics Cookies, this information helps us to better understand you and, in turn, to make Our Site and advertising more relevant to your interests.
- Third Party Cookies: Third party Cookies are not placed by Us; instead, they are placed by third parties that provide services to Us and/or to you. Third party Cookies may be used by advertising services to serve up tailored advertising to you on Our Site, or by third parties providing analytics services to Us (these Cookies will work in the same way as analytics Cookies described above).
- Persistent Cookies: Any of the above types of Cookie may be a persistent Cookie. Persistent Cookies are those which remain on your computer or device for a predetermined period and are activated each time you visit Our Site.
- Session Cookies: Any of the above types of Cookie may be a session Cookie. Session Cookies are temporary and only remain on your computer or device from the point at which you visit Our Site until you close your browser. Session Cookies are deleted when you close your browser.
- Cookies on Our Site are not permanent and will expire.
For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please go to the Contact Us page to email us or by mail using the details provided below:
PO Box 2041
Croydon, United Kingdom
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.
Any changes will be made available in the latest version of this document, which is always available from our website.
Posted on: version 1, 07.12.2020
Last updated: 04.06.2021