MARCH 2022
This policy sets out how we use personal data including information you provide to us and data we obtain based on your choices and through our interaction with you.
We hold and use personal data to provide you with products and services, to communicate with you and to comply with our legal and regulatory obligations. We may use your personal data to develop and grow our business and improve our products and services.
We aim to be transparent on how and for what purpose we hold and use personal data. We strive to keep data safe and secure and hold it only for as long as we need it. We do not knowingly collect or process any data relating to children.
This policy also sets out your rights, how you can manage your personal data and how to contact us.
You can click specific sections which explain how we operate and use personal data.
Should you have any queries or need further information, please contact dataprotection@manoloblahnik.com
Manolo Blahnik is made up of different legal entities, details of which are set out on this page. Manolo Blahnik International Limited (company number 00971691) with registered office at 30 Welbeck Street, London, W1G 8ER (referred to as “MBIL” “we”, “us” or “our”) is a “data controller”. This means that we are responsible for and control what happens to your personal data.
MBIL related companies:
- MANOLO BLAHNIK SWITZERLAND SA
- BLAHNIK GROUP LIMITED
- MB FRANCE SAS
- MB AMERICAS LLC
This policy is issued on behalf of Manolo Blahnik International Limited (“MBIL”) and its related companies. We may share personal data between these companies, which are subject to this policy.
Our website may link to third party sites, plug-ins or applications. This policy does not apply to this external content and we do not control or monitor external sites.
We would recommend that you review policies on external websites and applications as their approach and policy will be different.
We may update this policy at any time and will post the changes online.
At this stage, there are some parts of data protection law upon which further guidance will be given by the regulators and government bodies. We may therefore need to make changes to this policy once guidance is issued.
If we make significant changes, we will notify you by email to explain these changes and post an amended policy on the website.
WHAT IS “PERSONAL DATA”? WHAT IS “PROCESSING”?
“Personal data” is any information that allows you to be identified. This does not include anonymous data where you cannot be recognised, for example financial or general sales data.
“Processing” includes the collection, storage, transfer, editing and updating of personal data. Almost every “use” of personal data is likely to be “processing”. We have categorised the different types of personal data below and explained how and why we use or “process” this data.
HOW AND WHY WE USE PERSONAL DATA
We use personal data when the law allows us to do so. There are different justifications for using personal data, known as a “lawful basis”, which include:
- compliance with the law or our legal obligations;
- performing a contract with you or a contract we may be about to enter with you;
- where necessary for our “legitimate interests” or those of a third party; and
- where you consent to processing.
A “legitimate interest” means a business or commercial reason to use your personal data. We balance this against the impact on you (positive and negative) and your legal rights. We explain the lawful basis we rely upon and use of your personal data below. In some instances, more than one lawful basis may apply.
Name, surname, website username, addresses, email address and telephone numbers.
| TYPE OF DATA / USE |
FURTHER DETAILS |
“LAWFUL BASIS” |
| New accounts and purchases. |
To create an account on our website we need details to identify you and manage your account.
We also use this information to administer your account, to process and send you an order, including where you do not create an account but order as a “guest”.
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To perform the contract between us. |
| Communicating about orders, returns and after sales service. |
When you place an order, we use your details to confirm and accept the order and to send information on delivery.
Where you request to return a product, we need to identify you, your order and may communicate with you if you have queries or request to return a product.
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To perform the contract between us.
To give effect to your legal rights and to comply with legal obligations. |
Contacting you about new products, news and events.
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We want to keep you informed about our new products and exciting news about our brand. We will only do this where you have asked us to contact you and you may ask us to stop at any time.
You can unsubscribe at any time via the link in the emails that we send to you or by contacting us at dataprotection@manoloblahnik.com
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It is in our legitimate interests to promote our brand, services and products.
We ask for your consent to contact you for marketing.
You provide this consent when you tick the box online, enter your email into our newsletter sign-up on the website or where you provide your details to a sales assistant in our boutique and request to be contacted.
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| Communicating with you when you contact us. |
If you ask us a question, raise a concern or if you get in touch with us for any reason, we need to use your details to answer your question and communicate with you.
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To perform the contract between us. |
Payment processing.
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We need personal data to process payments.
We do not have access to or store any card data. We use a third-party payment service provider to process payments.
Without your data we cannot process and receive your payment and you will not receive your order.
We also use this information when we process refunds to ensure the payment can be made and is made correctly.
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To perform the contract between us.
To comply with our legal obligations. |
| To let you know if we change our terms and policies. |
When we make significant updates to this policy, we want you to know about the changes. We will send an email to let you know what has changed and where you can review the changes and what this means for you and your data.
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To perform the contract between us.
To comply with our legal obligations. |
To prevent fraud, security breaches, legal violations and misuse of our website.
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We need to check that payments made to us are genuine and not fraudulent.
We need to protect you against fraud and criminal activity and protect our business.
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To comply with our legal obligations. |
To send you “abandoned basket” emails.
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If you are part way through our order process and the transaction is closed we may send an email to confirm whether you meant to cancel the order to give you the chance to restore the transaction.
This saves you having to go back to our site and repeat the order process.
You will only receive one email in a 7 day period. 30 days after the email is sent your email address will be anonymised on the system. |
It is in our legitimate interests to check that everything is OK with your order, to ask if you would like to complete the transaction and to help track purchases on the website.
You can unsubscribe from these emails. |
To send “back in stock” emails.
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If you ask to be notified when a product is back in stock by giving us your email, we will contact you to confirm your request and then once more should the product come back into stock.
The email will contain an option to stop tracking the product at any time and email addresses will be automatically deleted after 120 days.
Email addresses submitted via this function will not be used for marketing or any other purposes. |
To perform the contract between us and because you have asked us to do something before entering into the contract.
It is in our legitimate interests to offer this function to customers and to notify customers of stock and availability when requested.
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| TYPE OF DATA / USE |
FURTHER DETAILS |
“LAWFUL BASIS” |
| To prevent fraud, security breaches, legal violations and misuse of our website. |
We need to check that payments made to us are genuine and not fraudulent.
We need to protect you against fraud and criminal activity and protect our business.
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To comply with our legal obligations.
It is in our legitimate interest to protect our website from misuse which may not result from compliance with a legal obligation but is a breach of our website terms. |
| To recommend products to you and to understand more about you. |
We may recommend products and services to you that are of interest and better suited to you as an individual.
We also need to understand more about you and demographics, so we can offer a range and variety of products and services that you and other customers want.
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It is in our legitimate interest to understand more about you, who is buying our products and how we can improve our products and services, so they are suited to our customers and clients as a whole and to particular individuals.
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Age verification
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We need to verify the age of people using our site to ensure the website is not being used by children. |
To comply with our legal obligations. |
| HOW DO YOU USE THIS DATA? |
FURTHER DETAILS |
“LAWFUL BASIS” |
| Payment processing |
We need personal data to process payments.
Payments are made through our payment service provider.
You provide information directly to our provider, which operates a secure server to process payment details, encrypting your information and authorising payment.
Information provided is not within our control and is subject to the payment provider’s privacy policy and terms.
We do not have access to or store any card data. We use a third-party payment service provider to process payments.
Without your data cannot process and receive your payment and you will not receive your order.
We also use this information where we deal with refunds to ensure the payment can be made and is made correctly.
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To perform the contract between us.
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| To prevent fraud, security breaches, legal violations and misuse of our website. |
We need to check payments are genuine and not fraudulent.
We need to protect you against fraud and criminal activity and protect our business.
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To comply with our legal obligations.
It is in our legitimate interests to protect you and our business against fraud and criminal activity.
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To comply with our tax and accounting obligations.
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We need to keep a record of invoices we issue and payments made and received for audit and tax purposes.
We keep invoices that we send to you and information on payments received.
This may include your contact details, order details and invoice number / order number.
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To comply with our legal obligations. |
TRACKING AND RECORDING PURCHASES
| TYPE OF DATA / USE |
FURTHER DETAILS |
“LAWFUL BASIS” |
| Storing and recording your purchases and orders. |
We do this so you can make a purchase and place your order. We need to have a record of this information to accept your order and send you your purchase.
If you open an account, you can easily see what you have purchased and your order history.
We also use this information to deal with queries and communications you might send about your purchases.
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To perform the contract between us.
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| To offer you additional products, services and benefits. |
We keep a record of the purchases you make as we may offer new or similar styles or products in future that may be of interest. This helps us to understand your interests.
For some customers and clients we may also offer access to additional benefits, sales, discounts, exclusive offers and events based on their purchase history.
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It is in our legitimate interest to offer you products and services that you want to receive and deals or benefits you might be interested in.
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To understand more about our business, products and about you.
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We use the data to understand what styles are successful and popular including region specific preferences, so we can offer customers and clients what they want and provide the best products and services as a business.
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It is in our legitimate interest to track and understand our successful products, so we can grow and improve our business. |
| TYPE OF DATA / USE |
FURTHER DETAILS |
“LAWFUL BASIS” |
| We store your contact information if you are invited to an exclusive sale or event. |
We retain details of people who attend our events, so we know who attended for similar events in the future.
In most cases you will be invited by someone you know at Manolo Blahnik or referred by a friend.
Normally you will be invited by a personal contact or because you have asked to be contacted for such events.
You can change your preference at any time by contacting us atdataprotection@manoloblahnik.com
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It is in our legitimate interest to invite our customers and contacts to events.
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| TYPE OF DATA / USE |
FURTHER DETAILS |
“LAWFUL BASIS” |
| Records of communications with you including emails, chats with customer services and notes we might make in conversations or telephone calls with you. |
We keep a record of our communications with you so we can offer you the best service, improve our standards and how we operate and to train our team.
We will use this information to handle any queries or concerns and see a complete history of our communications.
We also keep a record of this information so we can handle any similar queries or concerns from other customers and clients.
If you ask to be added to a waiting list for a particular style, we will store your email so we can contact you when the style is back in stock.
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To perform the contract between us.
It is in our legitimate interests to keep proper records of communications in our business – of course we will only keep them for as long as necessary.
It is in our legitimate interests to learn from any feedback received in emails, chats and calls, so that we can improve our business.
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| TYPE OF DATA / USE |
FURTHER DETAILS |
“LAWFUL BASIS” |
| Your username and information when you contact us via social media accounts and our conversation history. |
We use this information to communicate with you via social media who contact us with queries or concerns. We will retain the conversation history so our customer service team can see the entire interaction and to improve our responses and service.
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To perform the contract between us.
It is in our legitimate interests to keep proper records of communications in our business, however we will only keep them for as long as necessary.
It is in our legitimate interest to learn from any feedback received in emails, chats and calls, so that we can improve our business.
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| Username and likes in relation to our social media campaigns. |
We may record and store the number of likes and comments on our official account and posts on social media and may download and store all comments on a particular post or campaign.
This allows us to improve and develop our posts and service to see which styles, images and posts are positively received.
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It is in our legitimate interest to monitor and learn from our social media activities, so that we can improve their success.
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Username and information when you tag or link to us on social media or your posts.
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If you refer to, link or tag us on social media, we may repost that image along with your username on our official social media accounts. This allows us to interact with you on social media and through posts about our brand.
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It is in our legitimate interests to respond to you when you interact with us on social media, so that we can respond to you and deal with any queries or feedback. |
| TYPE OF DATA / USE |
FURTHER DETAILS |
“LAWFUL BASIS” |
| We have CCTV in our boutiques, this data is only reviewed in the event of a complaint or issue. |
We use this to prevent and detect criminal activity and to ensure your safety and employee safety.
This information is not reviewed regularly and is deleted on a rolling basis unless it needs to be retained where a specific issue has arisen.
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To comply with legal obligations.
It is in our legitimate interests to keep our employees, our customers, our products and our boutiques safe and secure.
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TECHNICAL DATA - DEVICES, LOCATION AND USE OF THE WEBSITE
Information you or your device provide when you use our website including your IP address, browser type, device type and in some cases your location.
| TYPE OF DATA / USE |
FURTHER DETAILS |
“LAWFUL BASIS” |
| To offer the correct currency, language and delivery information. |
Our website should automatically select an appropriate currency based on your location. This allows us to show you the correct currency and calculate the correct delivery costs.
This can be changed using the menu on the website.
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It is in our legitimate interest to offer regional personalisation on our website, to make your experience smoother, personalised and appropriate.
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| To improve and update our website and improve the service we offer. |
This allows us to review and improve our website including running tests, maintenance and support and reviewing hosting data to understand more about how the website functions and where we need to make changes and improvements.
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It is in our legitimate interest to learn from how users interact with our website, to make your experience smoother.
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To prevent fraud, security breaches, legal violations and misuse of our website.
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We need to protect you against fraud and criminal activity and protect our business.
We also audit the use and downloads of data from our website.
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To comply with our legal obligations.
It is in our legitimate interests to use the data obtained from our website to improve its security.
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We do not collect any “special categories” of data or data on criminal convictions or offences about you. Special categories of data include details on race, ethnicity, religious or other beliefs, sexual orientation, political opinions, trade union membership or health and genetic data. If you choose to provide these types of data to us, we will not be able to recognise this and will treat it as personal data.
IF YOU DO NOT PROVIDE YOUR PERSONAL DATA
If we need your personal data to comply with the law or to perform a contract with you and you do not provide your data, we may not be able to perform our contract. If this is the case, we will tell you.
To sell products, we need payment information and contact information to process your payment and order and to send you your purchase. As another example, if you do not wish to provide certain personal data, the functionality of the website and the quality of your experience may be impacted and you may not receive the best service.
If you do not provide your contact details, we may not be able to communicate with you about our new products, invite you to events or provide you with exclusive offers.
CHANGING THE USE OF PERSONAL DATA
We will use personal data for the purpose for which we collected it. If we consider that we need to use personal data for something else, which is compatible with the original purpose, we may use it for that new purpose. If you would like an explanation on how any new purpose is compatible with an original purpose, please contact us at dataprotection@manoloblahnik.com
Where we need to use personal data for an unrelated purpose we will inform you and explain the lawful basis that allows us to do so. We may process your personal data without your knowledge or consent in compliance with this policy, where we are required or permitted to do so by law.
We collect your personal data in a number of ways, which are summarised below.
| METHOD |
DESCRIPTION |
| Directly |
If you create an account with us, place an order, sign up to our newsletter, contact us or attend an event or sale, you provide us with your data directly.
You may provide personal details in our boutiques or online or electronically via the website, email or by phone or if you provide feedback or request after-sale support.
We may match and check personal data provided online against data from our boutiques to ensure data is accurate and up to date and that do not have duplicate records.
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| Automated technology |
When you use the website, we collect technical information (see “TECHNICAL DATA” above) about your device, browsing and in some cases your location and IP address. This is collected using cookies and similar technologies. We may also receive technical data if you visit other websites that use our cookies.
For more details on cookies see the “COOKIES” section below.
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Third Parties / Public Sources
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We may receive personal data from third parties and public sources including data from analytics providers such as Google, search information providers, providers of technical, payment and delivery services, public sources such as Companies House and the Electoral Register, or providers of contact information and databases, some of whom may be based outside of the EEA.
We use third parties to process and provide data including business partners, payment service providers, logistics companies and analytics and search information providers.
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Group members or concessions
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If you make a purchase in a store operated by another Manolo Blahnik company or through a concession or licensee and provide your personal information, we may be provided with a record of your transaction and your personal details.
Where we receive personal data from a third party, we require that they provide information in accordance with the law.
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CCTV
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We use CCTV in our boutiques which may record your visit. This is not reviewed or monitored on a regular basis and will only be accessed where necessary in the event of an issue, complaint or suspected criminal activity.
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AUTOMATED DECISION MAKING AND PROFILING
We may use personal data to carry out automated decision making or profiling. This would include identifying products or providing advertising that is tailored to you. We sometimes use systems to make automated decisions based on personal data we have or are allowed to collect from other sources about you. This allows us to make quick, fair, efficient and correct decisions using that data. These decisions can relate to products, services or features that we may offer.
We may also use personal data to detect fraud or money laundering using automated systems. Our payment service provider or third-party agencies may notify us of potential fraud and we can cease payments or activity on a specific account.
In relation to automated decisions, we do not use any systems which may have a legal or similarly significant effect on you. If we should do so in future, these will be separately highlighted. If you have any queries on these rights and these decisions, please contact us at dataprotection@manoloblahnik.com
ADVERTISING, MARKETING AND EMAILS
We want to keep you informed and up to date on our new products, exciting events and offers, however we appreciate you may not want to receive these communications. We give you the choice on how we use personal data for marketing communications.
You will receive marketing emails if you have signed up to our newsletter and have given your consent, either online or via our boutiques. You can ask us to stop sending communications to you at any time, either by clicking “unsubscribe” in the email we send to you or by emailing us at dataprotection@manoloblahnik.com.
Where you do not give or later withdraw consent to receive marketing communications we still retain personal data for transactional purposes and we rely on a different “lawful basis”.
For marketing emails, we use a third-party email marketing provider based in the United States called MailChimp. MailChimp act on our instructions and do not share your data with anyone or use it for any other purpose. MailChimp are part of Privacy Shield.
MailChimp may use data we provide to them for its legitimate business purposes including management of our account. MailChimp also uses cookies, unique identifiers, web beacons and similar tracking technologies. This allows us and MailChimp to see information about the emails we send, including how many people read, open and/or forward our emails. MailChimp may also transfer your data anywhere in the world. Please read the MailChimp Privacy Policy HERE and other information available HERE.
We may use your personal data to create an impression of what products you may be interested in or products and services that may be relevant to you. This can be used to offer you products, services and offers that are suited to you personally.
We may also advertise online and target advertisements on other websites and platforms. This is carried out with different technical networks, ad exchanges and technology, including cookies, pixels, web beacons and specific services offered by third parties. The advertising you see is based on information we hold about you and your use of our site and purchases or previous interaction with our website.
If you would like to read about how you can control which adverts you see online, see opt-out programs established by the Digital Advertising Alliance (United States) or the European Interactive Digital Advertising Alliance. We do not control cookies which are set by advertising networks.
There are also many other places where you may see advertisements for us, and not all of these are based on using your personal data. We may also bid for non-personalised advertising space on websites and social media. So even if you opt out of advertising using one of those programmes, you may still see our advertisements online and in social media.
COOKIES AND OTHER TECHNOLOGY
We use cookies and other technology and applications to collect data about your use of our website including information about your device or computer, connection information, statistics on page views, traffic, links referring to the website, Internet Protocol (“IP”) address and standard web log information.
Where you have asked us to send you marketing emails, using our email provider MailChimp, we will do so and we / MailChimp use cookies and other technology, such as pixels and web beacons, to analyse trends, and gather information about the emails we send. The data collected can tell us whether emails have been opened, allows us to measure the success of our email campaigns and improve our service to you. For more information, please see the MailChimp Privacy Policy HERE and other information available HERE.
A “cookie” is a small text file that stores information on your internet browser or hard drive when you visit a website. A cookie links your computer to information provided by you on the website (for example, linking your IP address and other information about your experience on the website to your preferences while making choices on the Website). Cookies and other automatic data collection tools are necessary for the functioning of the website and services we offer.
You can also set your browser to refuse some or all cookies or to alert you when websites set or cookies. Where you disable or refuse cookies, some parts of the website may be inaccessible or may not function correctly.
We use the following cookies on the website:
STRICTLY NECESSARY
These are essential to browse the website and provide services. Without these cookies your basket and order history will not be displayed and you may not be able to order any products.
FUNCTIONALITY COOKIES
These are not strictly necessary for the website to operate but allow the website to function more effectively. These cookies allow the website to “remember” your choices and preferences including your username, language, region etc. and offer advanced, simplified and personalised features and experience.
ANALYTICAL COOKIES
These cookies measure and analyse the use of the website including traffic, sales, pages visited most often and any error messages etc. We use these analytical cookies to improve the website and your experience.
Data collected from these cookies is anonymous and is not used to identify individuals. This information may also be shared with third parties, including our website developer and hosting provider.
TARGETING AND ADVERTISING COOKIES
These cookies personalise advertisements that are more relevant to an individual. The cookies can collect more detailed information about an individual and their browsing habits, including products accessed or put into a basket. These cookies can be used for personalised direct marketing communications, limit certain advertising or measure the impact of advertising.
These cookies also allow us, and the third-party providers we use, to track user actions on different websites and measure the impact of our marketing so that we can deliver more relevant and effective advertising to you and improve your overall experience.
Currently we do not respond to “do not track” signals or other mechanisms that provide an opt-out for collecting information across websites and services that we are involved with. In the event this changes in future, we will update this policy accordingly.
THIRD PARTY COOKIES AND SOCIAL MEDIA
If you share content through third party sites such as social media platforms or if you are logged into our website using social media information you may receive cookies from these sites. Social media activity is subject to the privacy policies of the social media website / platform.
We cannot control cookies of third parties and recommend that you review the social media platforms’ privacy policies and information on cookies. For more information about cookies please visit www.allaboutcookies.org.
COOKIES
| COOKIE NAME |
COOKIE DESCRIPTION |
THIRD PARTY |
| FORM_KEY |
Stores randomly generated key used to prevent forged requests. |
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| PHPSESSID |
Your session ID on the server. |
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| GUEST-VIEW |
Allows guests to view and edit their orders. |
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| PERSISTENT_SHOPPING_CART |
A link to information about your cart and viewing history, if you have asked for this. |
|
| STF |
Information on products you have emailed to friends. |
|
| STORE |
The store view or language you have selected. |
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| USER_ALLOWED_SAVE_COOKIE |
Indicates whether a customer allowed to use cookies. |
|
| MAGE-CACHE-SESSID |
Facilitates caching of content on the browser to make pages load faster. |
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| MAGE-CACHE-STORAGE |
Facilitates caching of content on the browser to make pages load faster. |
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| MAGE-CACHE-STORAGE-SECTION-INVALIDATION |
Facilitates caching of content on the browser to make pages load faster. |
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| MAGE-CACHE-TIMEOUT |
Facilitates caching of content on the browser to make pages load faster. |
|
| SECTION-DATA-IDS |
Facilitates caching of content on the browser to make pages load faster. |
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| PRIVATE_CONTENT_VERSION |
Facilitates caching of content on the browser to make pages load faster. |
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| X-MAGENTO-VARY |
Facilitates caching of content on the server to make pages load faster. |
|
| MAGE-TRANSLATION-FILE-VERSION |
Facilitates translation of content to other languages. |
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| MAGE-TRANSLATION-STORAGE |
Facilitates translation of content to other languages. |
|
| TOPBANNER2 |
Indicates whether a customer have read promotional banner |
|
| serverId |
To provide an improved and faster server time, the ServerID cookie remembers which server should handle the user’s requests. |
|
| recently_compared_product |
Temporary information of your session. This information is needed to optimize the speed of the website, or used to provide Shopping Basket functionality. |
|
| recently_compared_product_previous |
Temporary information of your session. This information is needed to optimize the speed of the website, or used to provide Shopping Basket functionality. |
|
| recently_viewed_product |
Temporary information of your session. This information is needed to optimize the speed of the website, or used to provide Shopping Basket functionality. |
|
| recently_viewed_product_previous |
Temporary information of your session. This information is needed to optimize the speed of the website, or used to provide Shopping Basket functionality. |
|
| searchsuiteautocomplete |
Temporary information of your session. This information is needed to optimize the speed of the website, or used to provide Shopping Basket functionality. |
|
| section_data_ids |
Stores customer-specific information related to shopper-initiated actions such as display wish list, checkout information, etc. |
|
| _ga, _gid, _utma, _utmb, _utmc, _utmt, _utmz |
Used as part of Google Analytics: _ga and _gid: used to distinguish unique users by assigning a randomly generated number as ID. _utma: records the number of visits to a website per user. _utmb and _utmc: records the amount of time a user spends on a website. _utmt: manages analytics data collected on high traffic websites. _utmz: records where a website user came from (e.g. search engine, link or via a typed in web page address) |
Google |
| APISID, CONSENT, HSID, LOGIN_INFO, PREF, SAPISID, SID, SSID, VISITOR_INFO1_LIVE, YSC |
Third party cookies. Cookies are used by a third party, YouTube, to enable our users view Video on the website. The cookies expiration date varies, some expire after the session ends, others after twenty years. |
Google/YouTube |
| TSNGUID, __qca, _gcl_au, _mkto_trk, ajs_anonymous_id, ajs_group_id, ajs_user_id, ei_client_id, intercom-id-cyym0u3i, login_idle_session_timeout, nr_growth-production, optimizelyEndUserId, JSESSIONID |
We use New Relic to measure application performance and stability, as well as provide descriptive feedback when errors occur. Information about the web page load may be collected and transmitted to the United States. |
NewRelic - https://newrelic.com/termsandconditions/cookie-policy/cookie-table |
We will never sell or transfer your data to another party for their marketing purposes.
We share data with companies as part of managing and running our business and providing products and services to you.
We share data with the following categories of recipients:
GROUP AND RELATED COMPANIES
- This allows us to consolidate data across our business.
DELIVERY AND LOGISTICS
- We share your data with companies that store, pack and deliver products to physically send products or contact you to provide you with your order.
PROFESSIONAL SERVICES
- We share your data with hosting companies that administer and host our website, IT service providers who manage our internal systems and technology, finance software and audit providers, payment service providers, database software services that help us manage our business and products, event planners and coordinators and our other professional advisors and agents such as law firms, accountants and insurers.
GOVERNMENT AND REGULATORY BODIES
- We may need to share data with law enforcement, tax authorities, fraud agencies and other governmental and public bodies where required by law or to prevent crime and fraud and to comply with our legal obligations.
COMPANIES YOU ASK US TO SHARE DATA WITH
- Insofar as we are able, we will share your data with any third party that you may request.
EMAIL MARKETING
- We use MailChimp to send out our emails for marketing. MailChimp may not use our email data for their own purposes and only act on our instructions. For the MailChimp Privacy Policy please click HERE and for other information please click HERE.
We may provide anonymised data to third parties relating to sales, business performance and analytics and to manage and improve our website. We will take steps to remove any personal data from this information prior to this analysis.
If we were to sell, transfer, or merge any part of our business or assets or acquire another business we may need to share data with a third party for that transaction.
If a change happens to our business, any new owner or company may continue to use your personal data as set out in this privacy notice.
We share personal data within our group of companies and related companies which may involve transferring your data outside of the European Economic Area (EEA).
Some of our service providers are based outside the European Economic Area (EEA) so when we share data with them and they provide us with the services we have requested this will involve processing data outside of the EEA.
We and our processors may transfer your data anywhere in the world.
Whenever we transfer personal data outside of the EEA, we take steps to ensure similar protection as in the EEA by ensuring at least one of the following safeguards is implemented:
- we transfer personal data to countries that have been deemed to provide adequate protection for personal data by the European Commission;
- - we use specific contracts approved by the European Commission giving personal data the same protection as in Europe; and/or
- - we may transfer data to the United States as part of the Privacy Shield which requires third parties to provide similar protection for data shared between the Europe and the United States.
Please Contact us at dataprotection@manoloblahnik.com if you would like further information on transfers of personal data outside of the EEA.
PROTECTING DATA AND SECURITY
We require third parties to respect security of personal data we share with them and to treat it in accordance with the law. We do not allow third-party service providers to use personal data for their own purposes and we only permit processing of personal data for specified purposes, in accordance with our instructions and the in compliance with the law. Third parties we share data with are also subject to a duty of confidentiality.
We have security, technical and organisational measures to prevent personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Some examples safeguards we have implemented include firewalls and data encryption, physical access controls and information access controls. We limit access to personal data to employees, agents, contractors and third parties who need to know or need to access that data. We have put in place procedures to deal with data breaches and will notify you and any applicable regulator of a breach where we are required to do so.
Where you have a password for the website, you must keep this confidential and not share this with anyone.
We retain personal data for as long as necessary to fulfil the purposes for which we collected it, including satisfying any legal, accounting or reporting requirements for our business.
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 applicable legal requirements.
For tax and accounting purposes we have to keep some information about our customers for at least six years after a purchase.
In some circumstances you can ask us to delete your data (see “YOUR RIGHTS” below for further information).
In some circumstances we may also anonymise your personal data (so you can no longer be identified) for research or statistical purposes whereupon we may use this information indefinitely.
Where we offer goods to customers in the European Union, such customers have the right to make a complaint to a supervisory authority or regulator in the EU (outside of the UK).
MB France is the designated representative of MBIL in the EU. MB France can be contacted at dataprotection@manoloblahnik.com or via post at 11-12 Galerie de Montpensier, Palais Royal, Paris 75001.
You have the following rights:
REQUEST ACCESS TO YOUR PERSONAL DATA
You can request a copy of personal data we hold about you and you can check that we are processing lawfully.
REQUEST CORRECTION OF YOUR PERSONAL DATA
You can request that incomplete or inaccurate data we hold about you is corrected. We may need to verify the accuracy of the new data you provide and your identity.
REQUEST ERASURE OF YOUR PERSONAL DATA
You can ask us to delete or remove your personal data where
- there is no good reason for us continuing to process it;
- where you successfully exercise your right to object to processing (see below); or
- we have processed information unlawfully or where required under local law.
We may not always be able to comply with your request for specific legal reasons which will be notified to you, if applicable.
OBJECT TO PROCESSING OF YOUR PERSONAL DATA
You may object to processing your personal data where we rely on legitimate interests and believe the processing impacts your fundamental rights and freedoms. We may demonstrate that we have overriding legitimate grounds to process your information which override your rights and freedoms.
REQUEST RESTRICTION OF PROCESSING
You may request restriction of processing of your personal data. This enables you to ask us to suspend processing:
- if you want us to establish the data's accuracy;
- where use of the data is unlawful, but you do not want us to erase it;
- 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
- you have obejcted to our use of the data, but we need to verify whether we have overriding legitimate grounds to use it.
REQUEST TRANSFER OF YOUR PERSONAL DATA
You may request we transfer your personal data to you or 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.
WITHDRAWING CONSENT
Where we rely upon consent, you may withdraw your consent at any time. If you withdraw consent, we may not be able to provide certain products or services to you.
If you wish to exercise your rights, please contact us at dataprotection@manoloblahnik.com .
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is unfounded, repetitive or excessive. Alternatively, we may refuse to comply in such cases.
We may need to request specific information to confirm your identity and ensure your right to access the personal data or to exercise a specific right. This is a security measure to ensure personal data is not disclosed to the incorrect person.
We may also contact you to ask you for further information in relation to your request to improve our response and response time.
We will try to respond to legitimate requests within one month, however on occasion it may take us longer where your request is particularly complex or you have made multiple requests.
You have the right to complain to the Information Commissioner's Office (ICO), the UK’s supervisory authority for data protection (www.ico.org.uk). If you have a concern or complaint, we would appreciate the opportunity to try to resolve this with you directly, so please consider contacting us in the first instance at dataprotection@manoloblahnik.com
NOVEMBER 2018
This policy sets out how we use personal data including information you provide to us and data we obtain based on
your choices and through our interaction with you.
We hold and use personal data to provide you with products and services, to communicate with you and to comply
with our legal and regulatory obligations. We may use your personal data to develop and grow our business and
improve our products and services.
We aim to be transparent on how and for what purpose we hold and use personal data. We strive to keep data safe
and secure and hold it only for as long as we need it. We do not knowingly collect or process any data relating
to children.
This policy also sets out your rights, how you can manage your personal data and how to contact us.
You can click specific sections which explain how we operate and use personal data.
Should you have any queries or need further information, please contact dataprotection@manoloblahnik.com
Manolo Blahnik is made up of different legal entities, details of which are set out on this page. Manolo Blahnik
International Limited (company number 00971691) with registered office at 30 Welbeck Street, London, W1G 8ER
(referred to as “MBIL” “we”, “us” or “our”)
is a “data controller”. This means that we are responsible for and control what happens to your personal data.
MBIL related companies:
- MANOLO BLAHNIK SWITZERLAND SA
- BLAHNIK GROUP LIMITED
- MB France SAS
This policy is issued on behalf of Manolo Blahnik International Limited (“MBIL”) and its related
companies. We may share personal data between these companies, which are subject to this policy.
Our website may link to third party sites, plug-ins or applications. This policy does not apply to this external
content and we do not control or monitor external sites.
We would recommend that you review policies on external websites and applications as their approach and policy
will be different.
We may update this policy at any time and will post the changes online.
At this stage, there are some parts of data protection law upon which further guidance will be given by the
regulators and government bodies. We may therefore need to make changes to this policy once guidance is
issued.
If we make significant changes, we will notify you by email to explain these changes and post an amended policy
on the website.
“Personal data” is any information that allows you to be identified. This does not include
anonymous data where you cannot be recognised, for example financial or general sales data.
“Processing” includes the collection, storage, transfer, editing and updating of personal data.
Almost every “use” of personal data is likely to be “processing”. We have categorised the different types of
personal data below and explained how and why we use or “process” this data.
We use personal data when the law allows us to do so. There are different justifications for using personal data,
known as a “lawful basis”, which include:
- compliance with the law or our legal obligations;
- performing a contract with you or a contract we may be about to enter with you;
- where necessary for our “legitimate interests” or those of a third party; and
- where you consent to processing.
A “legitimate interest” means a business or commercial reason to use your personal data. We balance this against
the impact on you (positive and negative) and your legal rights. We explain the lawful basis we rely upon
and use of your personal data below. In some instances, more than one lawful basis may apply.
Name, surname, website username, addresses, email address and telephone numbers.
| TYPE OF DATA / USE |
FURTHER DETAILS |
“LAWFUL BASIS” |
| New accounts and purchases. |
To create an account on our website we need details to identify you and manage your account.
We
also use this information to administer your account, to process and send you an order, including where
you do not create an account but order as a “guest”.
|
To perform the contract between us. |
| Communicating about orders, returns and after sales service. |
When you place an order, we use your details to confirm and accept the order and to send information on
delivery.
Where you request to return a product, we need to identify you, your order and may
communicate with you if you have queries or request to return a product.
|
To perform the contract between us.
To give effect to your legal rights and to comply with
legal obligations.
|
Contacting you about new products, news and events.
|
We want to keep you informed about our new products and exciting news about our brand. We will only do
this where you have asked us to contact you and you may ask us to stop at any time.
You can
unsubscribe at any time via the link in the emails that we send to you or by contacting us at dataprotection@manoloblahnik.com
|
It is in our legitimate interests to promote our brand, services and products.
We ask for your
consent to contact you for marketing.
You provide this consent when you tick the box online,
enter your email into our newsletter sign-up on the website or where you provide your details to a sales
assistant in our boutique and request to be contacted.
|
| Communicating with you when you contact us. |
If you ask us a question, raise a concern or if you get in touch with us for any reason, we need to use
your details to answer your question and communicate with you.
|
To perform the contract between us. |
Payment processing.
|
We need personal data to process payments.
We do not have access to or store any card data. We
use a third-party payment service provider to process payments.
Without your data we cannot
process and receive your payment and you will not receive your order.
We also use this
information when we process refunds to ensure the payment can be made and is made correctly.
|
To perform the contract between us.
To comply with our legal obligations. |
| To let you know if we change our terms and policies. |
When we make significant updates to this policy, we want you to know about the changes. We will send an
email to let you know what has changed and where you can review the changes and what this means for you
and your data.
|
To perform the contract between us.
To comply with our legal obligations. |
To prevent fraud, security breaches, legal violations and misuse of our website.
|
We need to check that payments made to us are genuine and not fraudulent.
We need to protect
you against fraud and criminal activity and protect our business.
|
To comply with our legal obligations. |
To send you “abandoned basket” emails.
|
If you are part way through our order process and the transaction is closed we may send an email to
confirm whether you meant to cancel the order to give you the chance to restore the transaction.
This saves you having to go back to our site and repeat the order process.
You will only receive
one email in a 7 day period. 30 days after the email is sent your email address will be anonymised on
the system.
|
It is in our legitimate interests to check that everything is OK with your order, to ask if you would
like to complete the transaction and to help track purchases on the website.
You can unsubscribe
from these emails.
|
To send “back in stock” emails.
|
If you ask to be notified when a product is back in stock by giving us your email, we will contact you
to confirm your request and then once more should the product come back into stock.
The email
will contain an option to stop tracking the product at any time and email addresses will be
automatically deleted after 120 days.
Email addresses submitted via this function will not be
used for marketing or any other purposes.
|
To perform the contract between us and because you have asked us to do something before entering into
the contract.
It is in our legitimate interests to offer this function to customers and
to notify customers of stock and availability when requested.
|
| TYPE OF DATA / USE |
FURTHER DETAILS |
“LAWFUL BASIS” |
| To prevent fraud, security breaches, legal violations and misuse of our website. |
We need to check that payments made to us are genuine and not fraudulent.
We need to protect
you against fraud and criminal activity and protect our business.
|
To comply with our legal obligations.
It is in our legitimate interest to protect our website
from misuse which may not result from compliance with a legal obligation but is a breach of our website
terms.
|
| To recommend products to you and to understand more about you. |
We may recommend products and services to you that are of interest and better suited to you as an
individual.
We also need to understand more about you and demographics, so we can offer a range
and variety of products and services that you and other customers want.
|
It is in our legitimate interest to understand more about you, who is buying our products and how we can
improve our products and services, so they are suited to our customers and clients as a whole and to
particular individuals.
|
Age verification
|
We need to verify the age of people using our site to ensure the website is not being used by
children.
|
To comply with our legal obligations. |
| HOW DO YOU USE THIS DATA? |
FURTHER DETAILS |
“LAWFUL BASIS” |
| Payment processing |
We need personal data to process payments.
Payments are made through our payment service
provider.
You provide information directly to our provider, which operates a secure server to
process payment details, encrypting your information and authorising payment.
Information
provided is not within our control and is subject to the payment provider’s privacy policy and terms.
We do not have access to or store any card data. We use a third-party payment service provider
to process payments.
Without your data cannot process and receive your payment and you will not
receive your order.
We also use this information where we deal with refunds to ensure the
payment can be made and is made correctly.
|
To perform the contract between us.
|
| To prevent fraud, security breaches, legal violations and misuse of our website. |
We need to check payments are genuine and not fraudulent.
We need to protect you against fraud
and criminal activity and protect our business.
|
To comply with our legal obligations.
It is in our legitimate interests to protect you and our
business against fraud and criminal activity.
|
To comply with our tax and accounting obligations.
|
We need to keep a record of invoices we issue and payments made and received for audit and tax purposes.
We keep invoices that we send to you and information on payments received.
This may
include your contact details, order details and invoice number / order number.
|
To comply with our legal obligations. |
| TYPE OF DATA / USE |
FURTHER DETAILS |
“LAWFUL BASIS” |
| Storing and recording your purchases and orders. |
We do this so you can make a purchase and place your order. We need to have a record of this information
to accept your order and send you your purchase.
If you open an account, you can easily see
what you have purchased and your order history.
We also use this information to deal with
queries and communications you might send about your purchases.
|
To perform the contract between us.
|
| To offer you additional products, services and benefits. |
We keep a record of the purchases you make as we may offer new or similar styles or products in future
that may be of interest. This helps us to understand your interests.
For some customers and
clients we may also offer access to additional benefits, sales, discounts, exclusive offers and events
based on their purchase history.
|
It is in our legitimate interest to offer you products and services that you want to receive and deals
or benefits you might be interested in.
|
To understand more about our business, products and about you.
|
We use the data to understand what styles are successful and popular including region specific
preferences, so we can offer customers and clients what they want and provide the best products and
services as a business.
|
It is in our legitimate interest to track and understand our successful products, so we can grow and
improve our business.
|
| TYPE OF DATA / USE |
FURTHER DETAILS |
“LAWFUL BASIS” |
| We store your contact information if you are invited to an exclusive sale or event. |
We retain details of people who attend our events, so we know who attended for similar events in the
future.
In most cases you will be invited by someone you know at Manolo Blahnik or referred by
a friend.
Normally you will be invited by a personal contact or because you have asked to be
contacted for such events.
You can change your preference at any time by contacting us atdataprotection@manoloblahnik.com
|
It is in our legitimate interest to invite our customers and contacts to events.
|
| TYPE OF DATA / USE |
FURTHER DETAILS |
“LAWFUL BASIS” |
| Records of communications with you including emails, chats with customer services and notes we might
make in conversations or telephone calls with you.
|
We keep a record of our communications with you so we can offer you the best service, improve our
standards and how we operate and to train our team.
We will use this information to handle any
queries or concerns and see a complete history of our communications.
We also keep a record of
this information so we can handle any similar queries or concerns from other customers and clients.
If you ask to be added to a waiting list for a particular style, we will store your email so we can
contact you when the style is back in stock.
|
To perform the contract between us.
It is in our legitimate interests to keep proper records of
communications in our business – of course we will only keep them for as long as necessary.
It
is in our legitimate interests to learn from any feedback received in emails, chats and calls, so that
we can improve our business.
|
| TYPE OF DATA / USE |
FURTHER DETAILS |
“LAWFUL BASIS” |
| Your username and information when you contact us via social media accounts and our conversation
history.
|
We use this information to communicate with you via social media who contact us with queries or
concerns. We will retain the conversation history so our customer service team can see the entire
interaction and to improve our responses and service.
|
To perform the contract between us.
It is in our legitimate interests to keep proper records of
communications in our business, however we will only keep them for as long as necessary.
It is
in our legitimate interest to learn from any feedback received in emails, chats and calls, so that we
can improve our business.
|
| Username and likes in relation to our social media campaigns. |
We may record and store the number of likes and comments on our official account and posts on social
media and may download and store all comments on a particular post or campaign.
This
allows us to improve and develop our posts and service to see which styles, images and posts are
positively received.
|
It is in our legitimate interest to monitor and learn from our social media activities, so that we can
improve their success.
|
Username and information when you tag or link to us on social media or your posts.
|
If you refer to, link or tag us on social media, we may repost that image along with your username on
our official social media accounts. This allows us to interact with you on social media and through
posts about our brand.
|
It is in our legitimate interests to respond to you when you interact with us on social media, so that
we can respond to you and deal with any queries or feedback.
|
| TYPE OF DATA / USE |
FURTHER DETAILS |
“LAWFUL BASIS” |
| We have CCTV in our boutiques, this data is only reviewed in the event of a complaint or issue. |
We use this to prevent and detect criminal activity and to ensure your safety and employee safety.
This information is not reviewed regularly and is deleted on a rolling basis unless it
needs to be retained where a specific issue has arisen.
|
To comply with legal obligations.
It is in our legitimate interests to keep our employees, our
customers, our products and our boutiques safe and secure.
|
Information you or your device provide when you use our website including your IP address, browser type, device
type and in some cases your location.
| TYPE OF DATA / USE |
FURTHER DETAILS |
“LAWFUL BASIS” |
| To offer the correct currency, language and delivery information. |
Our website should automatically select an appropriate currency based on your location. This allows us
to show you the correct currency and calculate the correct delivery costs.
This can be changed
using the menu on the website.
|
It is in our legitimate interest to offer regional personalisation on our website, to make your
experience smoother, personalised and appropriate.
|
| To improve and update our website and improve the service we offer. |
This allows us to review and improve our website including running tests, maintenance and support and
reviewing hosting data to understand more about how the website functions and where we need to make
changes and improvements.
|
It is in our legitimate interest to learn from how users interact with our website, to make your
experience smoother.
|
To prevent fraud, security breaches, legal violations and misuse of our website.
|
We need to protect you against fraud and criminal activity and protect our business.
We also
audit the use and downloads of data from our website.
|
To comply with our legal obligations.
It is in our legitimate interests to use the data
obtained from our website to improve its security.
|
We do not collect any “special categories” of data or data on criminal convictions or offences about you. Special
categories of data include details on race, ethnicity, religious or other beliefs, sexual orientation, political
opinions, trade union membership or health and genetic data. If you choose to provide these types of data
to us, we will not be able to recognise this and will treat it as personal data.
If we need your personal data to comply with the law or to perform a contract with you and you do not provide
your data, we may not be able to perform our contract. If this is the case, we will tell you.
To sell
products, we need payment information and contact information to process your payment and order and to send you
your purchase. As another example, if you do not wish to provide certain personal data, the functionality of the
website and the quality of your experience may be impacted and you may not receive the best service.
If
you do not provide your contact details, we may not be able to communicate with you about our new products,
invite you to events or provide you with exclusive offers.
We will use personal data for the purpose for which we collected it. If we consider that we need to use personal
data for something else, which is compatible with the original purpose, we may use it for that new purpose. If
you would like an explanation on how any new purpose is compatible with an original purpose, please contact us
at dataprotection@manoloblahnik.com
Where we need
to use personal data for an unrelated purpose we will inform you and explain the lawful basis that allows us to
do so. We may process your personal data without your knowledge or consent in compliance with this policy, where
we are required or permitted to do so by law.
We collect your personal data in a number of ways, which are summarised below.
| METHOD |
DESCRIPTION |
| Directly |
If you create an account with us, place an order, sign up to our newsletter, contact us or attend an
event or sale, you provide us with your data directly.
You may provide personal details in our
boutiques or online or electronically via the website, email or by phone or if you provide feedback or
request after-sale support.
We may match and check personal data provided online against data
from our boutiques to ensure data is accurate and up to date and that do not have duplicate records.
|
| Automated technology |
When you use the website, we collect technical information (see “TECHNICAL DATA” above) about your
device, browsing and in some cases your location and IP address. This is collected using cookies and
similar technologies. We may also receive technical data if you visit other websites that use our
cookies.
For more details on cookies see the “COOKIES” section below.
|
Third Parties / Public Sources
|
We may receive personal data from third parties and public sources including data from analytics
providers such as Google, search information providers, providers of technical, payment and delivery
services, public sources such as Companies House and the Electoral Register, or providers of contact
information and databases, some of whom may be based outside of the EEA.
We use third parties
to process and provide data including business partners, payment service providers, logistics companies
and analytics and search information providers.
|
Group members or concessions
|
If you make a purchase in a store operated by another Manolo Blahnik company or through a concession or
licensee and provide your personal information, we may be provided with a record of your transaction and
your personal details.
Where we receive personal data from a third party, we require that they
provide information in accordance with the law.
|
CCTV
|
We use CCTV in our boutiques which may record your visit. This is not reviewed or monitored on a regular
basis and will only be accessed where necessary in the event of an issue, complaint or suspected
criminal activity.
|
We may use personal data to carry out automated decision making or profiling. This would include identifying
products or providing advertising that is tailored to you. We sometimes use systems to make automated decisions
based on personal data we have or are allowed to collect from other sources about you. This allows us to make
quick, fair, efficient and correct decisions using that data. These decisions can relate to products, services
or features that we may offer.
We may also use personal data to detect fraud or money laundering using
automated systems. Our payment service provider or third-party agencies may notify us of potential fraud and we
can cease payments or activity on a specific account.
In relation to automated decisions, we do not use
any systems which may have a legal or similarly significant effect on you. If we should do so in future,
these will be separately highlighted. If you have any queries on these rights and these decisions, please
contact us at dataprotection@manoloblahnik.com
We want to keep you informed and up to date on our new products, exciting events and offers, however we
appreciate you may not want to receive these communications. We give you the choice on how we use personal data
for marketing communications.
You will receive marketing emails if you have signed up to our newsletter
and have given your consent, either online or via our boutiques. You can ask us to stop sending
communications to you at any time, either by clicking “unsubscribe” in the email we send to you or by emailing
us at dataprotection@manoloblahnik.com.
Where you do not give or later withdraw consent to receive marketing communications we still retain personal
data for transactional purposes and we rely on a different “lawful basis”.
For marketing emails, we use
a third-party email marketing provider based in the United States called MailChimp. MailChimp act on our
instructions and do not share your data with anyone or use it for any other purpose. MailChimp are part of
Privacy Shield.
MailChimp may use data we provide to them for its legitimate business purposes
including management of our account. MailChimp also uses cookies, unique identifiers, web beacons and similar
tracking technologies. This allows us and MailChimp to see information about the emails we send, including how
many people read, open and/or forward our emails. MailChimp may also transfer your data anywhere in the world.
Please read the MailChimp Privacy Policy HERE and
other information available HERE.
We may use your
personal data to create an impression of what products you may be interested in or products and services that
may be relevant to you. This can be used to offer you products, services and offers that are suited to you
personally.
We may also advertise online and target advertisements on other websites and platforms.
This is carried out with different technical networks, ad exchanges and technology, including cookies, pixels,
web beacons and specific services offered by third parties. The advertising you see is based on information we
hold about you and your use of our site and purchases or previous interaction with our website.
If you
would like to read about how you can control which adverts you see online, see opt-out programs established by
the Digital Advertising Alliance (United States) or the European Interactive Digital Advertising Alliance. We do not
control cookies which are set by advertising networks.
There are also many other places where you may
see advertisements for us, and not all of these are based on using your personal data. We may also bid for
non-personalised advertising space on websites and social media. So even if you opt out of advertising using one
of those programmes, you may still see our advertisements online and in social media.
We use cookies and other technology and applications to collect data about your use of our website including
information about your device or computer, connection information, statistics on page views, traffic, links
referring to the website, Internet Protocol (“IP”) address and standard web log information.
Where you
have asked us to send you marketing emails, using our email provider MailChimp, we will do so and we / MailChimp
use cookies and other technology, such as pixels and web beacons, to analyse trends, and gather information
about the emails we send. The data collected can tell us whether emails have been opened, allows us to measure
the success of our email campaigns and improve our service to you. For more information, please see the MailChimp
Privacy Policy HERE and other information available HERE.
A “cookie” is a small text file that stores
information on your internet browser or hard drive when you visit a website. A cookie links your computer to
information provided by you on the website (for example, linking your IP address and other information about
your experience on the website to your preferences while making choices on the Website). Cookies and other
automatic data collection tools are necessary for the functioning of the website and services we offer.
You can also set your browser to refuse some or all cookies or to alert you when websites set or cookies. Where
you disable or refuse cookies, some parts of the website may be inaccessible or may not function correctly.
We use the following cookies on the website:
STRICTLY NECESSARY
These are essential to browse
the website and provide services. Without these cookies your basket and order history will not be displayed and
you may not be able to order any products.
FUNCTIONALITY COOKIES
These are not strictly
necessary for the website to operate but allow the website to function more effectively. These cookies allow the
website to “remember” your choices and preferences including your username, language, region etc. and offer
advanced, simplified and personalised features and experience.
ANALYTICAL COOKIES
These
cookies measure and analyse the use of the website including traffic, sales, pages visited most often and any
error messages etc. We use these analytical cookies to improve the website and your experience.
Data
collected from these cookies is anonymous and is not used to identify individuals. This information may also be
shared with third parties, including our website developer and hosting provider.
TARGETING AND
ADVERTISING COOKIES
These cookies personalise advertisements that are more relevant to an individual.
The cookies can collect more detailed information about an individual and their browsing habits, including
products accessed or put into a basket. These cookies can be used for personalised direct marketing
communications, limit certain advertising or measure the impact of advertising.
These cookies also
allow us, and the third-party providers we use, to track user actions on different websites and measure the
impact of our marketing so that we can deliver more relevant and effective advertising to you and improve your
overall experience.
Currently we do not respond to “do not track” signals or other mechanisms that
provide an opt-out for collecting information across websites and services that we are involved with. In the
event this changes in future, we will update this policy accordingly.
THIRD PARTY COOKIES AND SOCIAL
MEDIA
If you share content through third party sites such as social media platforms or if you are
logged into our website using social media information you may receive cookies from these sites. Social media
activity is subject to the privacy policies of the social media website / platform.
We cannot control
cookies of third parties and recommend that you review the social media platforms’ privacy policies and
information on cookies. For more information about cookies please visit www.allaboutcookies.org.
COOKIES
| COOKIE NAME |
COOKIE DESCRIPTION |
THIRD PARTY |
| FORM_KEY |
Stores randomly generated key used to prevent forged requests. |
|
| PHPSESSID |
Your session ID on the server. |
|
| GUEST-VIEW |
Allows guests to view and edit their orders. |
|
| PERSISTENT_SHOPPING_CART |
A link to information about your cart and viewing history, if you have asked for this. |
|
| STF |
Information on products you have emailed to friends. |
|
| STORE |
The store view or language you have selected. |
|
| USER_ALLOWED_SAVE_COOKIE |
Indicates whether a customer allowed to use cookies. |
|
| MAGE-CACHE-SESSID |
Facilitates caching of content on the browser to make pages load faster. |
|
| MAGE-CACHE-STORAGE |
Facilitates caching of content on the browser to make pages load faster. |
|
| MAGE-CACHE-STORAGE-SECTION-INVALIDATION |
Facilitates caching of content on the browser to make pages load faster. |
|
| MAGE-CACHE-TIMEOUT |
Facilitates caching of content on the browser to make pages load faster. |
|
| SECTION-DATA-IDS |
Facilitates caching of content on the browser to make pages load faster. |
|
| PRIVATE_CONTENT_VERSION |
Facilitates caching of content on the browser to make pages load faster. |
|
| X-MAGENTO-VARY |
Facilitates caching of content on the server to make pages load faster. |
|
| MAGE-TRANSLATION-FILE-VERSION |
Facilitates translation of content to other languages. |
|
| MAGE-TRANSLATION-STORAGE |
Facilitates translation of content to other languages. |
|
| TOPBANNER2 |
Indicates whether a customer have read promotional banner |
|
| serverId |
To provide an improved and faster server time, the ServerID cookie remembers which server should handle
the user’s requests.
|
|
| recently_compared_product |
Temporary information of your session. This information is needed to optimize the speed of the website,
or used to provide Shopping Basket functionality.
|
|
| recently_compared_product_previous |
Temporary information of your session. This information is needed to optimize the speed of the website,
or used to provide Shopping Basket functionality.
|
|
| recently_viewed_product |
Temporary information of your session. This information is needed to optimize the speed of the website,
or used to provide Shopping Basket functionality.
|
|
| recently_viewed_product_previous |
Temporary information of your session. This information is needed to optimize the speed of the website,
or used to provide Shopping Basket functionality.
|
|
| searchsuiteautocomplete |
Temporary information of your session. This information is needed to optimize the speed of the website,
or used to provide Shopping Basket functionality.
|
|
| section_data_ids |
Stores customer-specific information related to shopper-initiated actions such as display wish list,
checkout information, etc.
|
|
| _ga, _gid, _utma, _utmb, _utmc, _utmt, _utmz |
Used as part of Google Analytics: _ga and _gid: used to distinguish unique users by assigning a randomly
generated number as ID. _utma: records the number of visits to a website per user. _utmb and _utmc:
records the amount of time a user spends on a website. _utmt: manages analytics data collected on high
traffic websites. _utmz: records where a website user came from (e.g. search engine, link or via a typed
in web page address)
|
Google |
| APISID, CONSENT, HSID, LOGIN_INFO, PREF, SAPISID, SID, SSID, VISITOR_INFO1_LIVE, YSC |
Third party cookies. Cookies are used by a third party, YouTube, to enable our users view Video on the
website. The cookies expiration date varies, some expire after the session ends, others after twenty
years.
|
Google/YouTube |
| TSNGUID, __qca, _gcl_au, _mkto_trk, ajs_anonymous_id, ajs_group_id, ajs_user_id, ei_client_id,
intercom-id-cyym0u3i, login_idle_session_timeout, nr_growth-production, optimizelyEndUserId, JSESSIONID
|
We use New Relic to measure application performance and stability, as well as provide descriptive
feedback when errors occur. Information about the web page load may be collected and transmitted to the
United States.
|
NewRelic - https://newrelic.com/termsandconditions/cookie-policy/cookie-table
|
We will never sell or transfer your data to another party for their marketing purposes.
We share data
with companies as part of managing and running our business and providing products and services to you.
We share data with the following categories of recipients:
GROUP AND RELATED COMPANIES
- This allows us to consolidate data across our business.
DELIVERY AND
LOGISTICS
- We share your data with companies that store, pack and deliver products to
physically send products or contact you to provide you with your order.
PROFESSIONAL
SERVICES
- We share your data with hosting companies that administer and host our website,
IT service providers who manage our internal systems and technology, finance software and audit providers,
payment service providers, database software services that help us manage our business and products, event
planners and coordinators and our other professional advisors and agents such as law firms, accountants and
insurers.
GOVERNMENT AND REGULATORY BODIES
- We may need to share data with
law enforcement, tax authorities, fraud agencies and other governmental and public bodies where required by law
or to prevent crime and fraud and to comply with our legal obligations.
COMPANIES YOU ASK US TO
SHARE DATA WITH
- Insofar as we are able, we will share your data with any third party
that you may request.
EMAIL MARKETING
- We use MailChimp to send out our
emails for marketing. MailChimp may not use our email data for their own purposes and only act on our
instructions. For the MailChimp Privacy Policy please click HERE and
for other information please click HERE.
We may provide
anonymised data to third parties relating to sales, business performance and analytics and to manage and improve
our website. We will take steps to remove any personal data from this information prior to this analysis.
If we were to sell, transfer, or merge any part of our business or assets or acquire another business
we may need to share data with a third party for that transaction.
If a change happens to our business,
any new owner or company may continue to use your personal data as set out in this privacy notice.
We share personal data within our group of companies and related companies which may involve transferring your
data outside of the European Economic Area (EEA).
Some of our service providers are based outside the
European Economic Area (EEA) so when we share data with them and they provide us with the services we have
requested this will involve processing data outside of the EEA.
We and our processors may transfer your
data anywhere in the world.
Whenever we transfer personal data outside of the EEA, we take steps to
ensure similar protection as in the EEA by ensuring at least one of the following safeguards is implemented:
- we transfer personal data to countries that have been deemed to provide adequate protection for personal
data by the European Commission;
- - we use specific contracts approved by the European Commission giving personal data the same protection as
in Europe; and/or
- - we may transfer data to the United States as part of the Privacy Shield which requires third parties to
provide similar protection for data shared between the Europe and the United States.
Please Contact us at dataprotection@manoloblahnik.com if
you would like further information on transfers of personal data outside of the EEA.
We require third parties to respect security of personal data we share with them and to treat it in accordance
with the law. We do not allow third-party service providers to use personal data for their own purposes and we
only permit processing of personal data for specified purposes, in accordance with our instructions and the in
compliance with the law. Third parties we share data with are also subject to a duty of confidentiality.
We have security, technical and organisational measures to prevent personal data from being
accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Some examples safeguards we
have implemented include firewalls and data encryption, physical access controls and information access
controls. We limit access to personal data to employees, agents, contractors and third parties who need to know
or need to access that data. We have put in place procedures to deal with data breaches and will notify you and
any applicable regulator of a breach where we are required to do so.
Where you have a password for the
website, you must keep this confidential and not share this with anyone.
We retain personal data for as long as necessary to fulfil the purposes for which we collected it, including
satisfying any legal, accounting or reporting requirements for our business.
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 applicable
legal requirements.
For tax and accounting purposes we have to keep some information about our
customers for at least six years after a purchase.
In some circumstances you can ask us to delete your
data (see “YOUR RIGHTS” below for further information).
In some circumstances we may also anonymise
your personal data (so you can no longer be identified) for research or statistical purposes whereupon we may
use this information indefinitely.
You have the following rights:
REQUEST ACCESS TO YOUR PERSONAL DATA
You can
request a copy of personal data we hold about you and you can check that we are processing lawfully.
REQUEST CORRECTION OF YOUR PERSONAL DATA
You can request that incomplete or inaccurate
data we hold about you is corrected. We may need to verify the accuracy of the new data you provide and your
identity.
REQUEST ERASURE OF YOUR PERSONAL DATA
You can ask us to delete or
remove your personal data where
- there is no good reason for us continuing to process it;
- where you successfully exercise your right to object to processing (see below); or
- we have processed information unlawfully or where required under local law.
We may not always be able to comply with your request for specific legal reasons which will be notified to you,
if applicable.
OBJECT TO PROCESSING OF YOUR PERSONAL DATA
You may object to
processing your personal data where we rely on legitimate interests and believe the processing impacts your
fundamental rights and freedoms. We may demonstrate that we have overriding legitimate grounds to process your
information which override your rights and freedoms.
REQUEST RESTRICTION OF PROCESSING
You may request restriction of processing of your personal data. This enables you to ask us to suspend
processing:
- if you want us to establish the data's accuracy;
- where use of the data is unlawful, but you do not want us to erase it;
- 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
- you have obejcted to our use of the data, but we need to verify whether we have overriding legitimate
grounds to use it.
REQUEST TRANSFER OF YOUR PERSONAL DATA
You may request we transfer your personal data to
you or 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.
WITHDRAWING CONSENT
Where we rely upon consent, you may withdraw your
consent at any time. If you withdraw consent, we may not be able to provide certain products or services to you.
If you wish to exercise your rights, please contact us at dataprotection@manoloblahnik.com.
You will not have
to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a
reasonable fee if your request is unfounded, repetitive or excessive. Alternatively, we may refuse to comply in
such cases.
We may need to request specific information to confirm your identity and ensure your right
to access the personal data or to exercise a specific right. This is a security measure to ensure personal data
is not disclosed to the incorrect person.
We may also contact you to ask you for further information in
relation to your request to improve our response and response time.
We will try to respond to
legitimate requests within one month, however on occasion it may take us longer where your request is
particularly complex or you have made multiple requests.
You have the right to complain to the
Information Commissioner's Office (ICO), the UK’s supervisory authority for data protection (www.ico.org.uk). If you have a concern or complaint, we would appreciate the
opportunity to try to resolve this with you directly, so please consider contacting us in the first instance at dataprotection@manoloblahnik.com
