Privacy Policy

New regulations are coming into place on 25 May 2018 around how organisations record, store and use your personal data. This legislation is the General Data Protection Regulation (GDPR), which is designed to give you full control over your personal data. Shaftesbury Carnaby PLC (“Shaftesbury”) respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you. The Company Secretary is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the Company Secretary at shaftesbury@shaftesbury.co.uk. If you would like to update your marketing preferences, please contact contact@carnaby.co.uk. This privacy notice is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice. 1. [THE DATA WE COLLECT ABOUT YOU] 2. [HOW IS YOUR PERSONAL DATA COLLECTED] 3. [HOW WE USE YOUR PERSONAL DATA] 4. [DISCLOSURES OF YOUR PERSONAL DATA] 5. [INTERNATIONAL TRANSFERS] 6. [DATA SECURITY] 7. [DATA RETENTION] 8. [IMPORTANT INFORMATION AND WHO WE ARE] 9. [YOUR LEGAL RIGHTS] 10. [GLOSSARY] CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES This version was last updated on 29 May 2018 and historic versions can be obtained by contacting us. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us. We may change this policy from time to time by updating this page so please revisit and reread it periodically. THIRD-PARTY LINKS This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and we are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit. Please note that Shaftesbury does not warrant, represent, endorse or hold responsibility over any external sites that may be linked to and from this site. 1. THE DATA WE COLLECT ABOUT YOU Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data includes first name and last name.
Contact Data includes email address and, for Neighbourhood cardholders only, company/residential address.
Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
Profile Data includesfeedback and survey responses.

Usage Data includes information about how you use our website.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice. We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. IF YOU FAIL TO PROVIDE PERSONAL DATA Where we need to collect personal data by law, or under the terms of an agreement we have with you and you fail to provide that data when requested, we may not be able to perform the agreement we have or are trying to enter into with you. In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time. 2. HOW IS YOUR PERSONAL DATA COLLECTED We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity, Contact and Marketing and Communications Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
subscribe to our newsletter;
apply to become a member of the Neighbourhood Card scheme;
request marketing to be sent to you;
enter a prize draw, ballot, promotion or survey; or
give us some feedback or ask us a question via our online contact form.

Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, pixels, server logs and other similar technologies. Please see our Cookie Policy for further details.
Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below.
Technical Data from analytics providers such as Google based outside the EU.

3. HOW WE USE YOUR PERSONAL DATA We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Where we need to perform the agreement we are about to enter into or have entered into with you.
Where we have your consent.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.

Click [here] [link to Glossary below] to find out more about the types of lawful basis that we will rely on to process your personal data. You have the right to withdraw consent at any time by contacting contact@carnaby.co.uk. PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact contact@carnaby.co.uk if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Actvity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a member of our Neighbourhood Card scheme, and inform you via email of forthcoming offers and privileges relating to membership (if applicable)	IdentityContact	Consent
To manage our relationship with you which will include: Notifying you about changes to our terms or privacy policyAsking you to take a survey	IdentityContact Profile Marketing and Communications	Necessary to comply with a legal obligation Necessary for our legitimate interests (to keep our records updated)
To respond to any queries that you submit on our website	IdentityContact	Consent
To provide a newsletter via email containing information about special offers, events, launches and other promotions	IdentityContact Marketing and Communications	Consent
To enable you to partake in a prize draw or ballot or asking you to take a survey and administering the same	IdentityContact Profile Usage Marketing and Communications	Consent
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	IdentityContact Technical	Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)Necessary to comply with a legal obligation
To use data analytics to improve our website, services, and consumer experiences	TechnicalUsage	Necessary for our legitimate interests (to keep our website updated and relevant, to develop our business and to inform our marketing strategy).

MARKETING We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. NEWSLETTER We may use your Identity and Contact Data to deliver our newsletter to you if you have provided your consent. You will receive marketing communications from us if you have requested information from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you consented to receiving that marketing. THIRD-PARTY MARKETING We will get your express opt-in consent before we share your personal data with any company outside the Shaftesbury group of companies for marketing purposes. OPTING OUT You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting contact@carnaby.co.uk at any time. COOKIES You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy. CHANGE OF PURPOSE We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact contact@carnaby.co.uk. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law. 4. DISCLOSURES OF YOUR PERSONAL DATA We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

Internal Third Parties as set out in the Glossary [Link to Glossary below].
External Third Parties as set out in the Glossary [Link to Glossary below].
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. 5. INTERNATIONAL TRANSFERS One of our external third parties is based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA. Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.

Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact contact@carnaby.co.uk if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA. 6. DATA SECURITY We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. 7. DATA RETENTION We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. 8. IMPORTANT INFORMATION AND WHO WE ARE This privacy notice aims to give you information on how Shaftesbury collects and processes your personal data through your use of this website, including any data you may provide when you sign up to our newsletter or take part in a prize draw. This website is not intended for children and we do not knowingly collect data relating to children. It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them. CONTROLLER Shaftesbury Carnaby PLC (registered company number 02038836) is the controller and responsible for your personal data (collectively referred to as “Shaftesbury”, “we”, “us” or “our” in this privacy notice. CONTACT DETAILS Our full details are: Full name of legal entity: Shaftesbury Carnaby PLC Name or title: Company Secretary Email address: shaftesbury@shaftesbury.co.uk Postal address: 22 Ganton Street, London W1F 7BY You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance. 9. YOUR LEGAL RIGHTS Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Right to withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact contact@carnaby.co.uk for further details. NO FEE USUALLY REQUIRED You will not have to pay a fee to access your personal data following 25 May 2018 (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. WHAT WE MAY NEED FROM YOU We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. TIME LIMIT TO RESPOND We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. 10. GLOSSARY LAWFUL BASIS Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us at shaftesbury@shaftesbury.co.uk. Consent means processing your data where we have your consent. Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to. THIRD PARTIES INTERNAL THIRD PARTIES Other companies in the Shaftesbury Group acting as joint controllers or processors and who are based in the United Kingdom. EXTERNAL THIRD PARTIES

Service providers acting as processors based in the United Kingdom who provide IT and system administration services.
Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors, PR advisors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance, PR and accounting services.
HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.