Introduction
Data privacy and protection is very important to us for everyone who uses our products and services, and who entrusts us with their information. We have written this privacy notice so you can better understand how we collect data, what we do with it and how we look after it. We will tell you how long we keep data and what happens when we no longer need it. We will also outline what rights you have over your data and how we protect and facilitate those rights.
Opting in and out of communications made easy
Sometimes people want to read privacy notices because a business is asking for their permission to contact them for marketing. They want to be sure that, if they agree, it will be easy for them to withdraw permission in the future. We want you to be able to opt out as easily as you opted in. Any marketing email we send you will always have an “unsubscribe” link that will take you off that relevant marketing list. Please remember that you may have subscribed from another email address; you will only be able to use the link to “unsubscribe” from the address to which the marketing email has been sent. We make it easy for you to change your preferences for postal marketing as well, giving clear instructions for opting out on all direct mail.
Contents
1. What personal data do we collect from you?
2. How do we use your personal information?
3. Legal bases for data processing – what does it mean and how do we use them?
4. Do we share your information with anyone else?
5. Do we collect information on children?
6. How long will we keep your data?
7. Profiling – what do we mean?
8. Data security and cross-border transfers
9. Link to other websites
10. Your data rights11. Notice to California Customers
12. How to contact us
13. Cookies and tracking technologies
1. What personal information do we collect from you?
We collect information:
- when you pay for any of our products or services such as magazine subscriptions or memberships access
- when you create an account with us
- when you register to receive one of our newsletters
- when you use any of our websites
- when you attend any of our events
- if you participate in any research we undertake
- if you join one of our communities or forums
- when you enter a competition
- if you contact us about a query or a complaint
BY Secrets Silk BUSINESS TEAM
We collect the following types of information:
Contact information
When you use or subscribe to one of our services, such as purchasing a print or digital subscription, purchasing a membership subscription, creating an account, signing up to an email newsletter, entering a competition, joining one of our online communities or participating in any of our research projects, we will ask you to provide information such as your name, email and address so that we can provide you with the services requested.
General personal information
When conducting surveys or running competitions, in addition to contact information, we may collect other personal information such as your gender, date of birth, marital status, etc. When creating an account with us we may ask you to provide your current location (country and city), job title and your current employer’s name, your professional and editorial interests, your portfolio.
Payment details
When you purchase a product or service from us, such as subscribing to one of our magazines, purchasing a membership, paying to access a subscription service, or attending one of our events, we will also ask you for your payment details in addition to your contact information, in order to secure payment and to authorize access to our products and services.
Online identifiers
When you visit one of our websites, we collect information about your web visit, such as how long you visited, what sites you visited or pages you looked at, your IP address and where you were when you visited, what sort of device you were using when you visited (such as a mobile phone or type of desktop PC, Mac etc). Please see Section 13 below for more information on how we use cookies and tracking technologies and click the Cookie Preference tab at the bottom of the page to access the Cookie Preference center to manage your cookie preferences.
Behavioral data
When you visit one of our websites, we collect data on your online behavior (eg time spent on website, items clicked on, etc).
When you register for a newsletter or take part in research, we may collect data about your preferences, tastes and interests.
“Special” categories of data
Sometimes, we may collect data in online surveys on what is called “special categories of data”. These could be data sets such as biometric information (including voice samples, facial recognition, etc), or political opinions, religion, race and ethnic origin, philosophical beliefs, health, sexual orientation, etc. Whenever we conduct research on these topics, it is always optional, and we will make sure we have your consent to process this data. We will remind you at the time of why and how we are processing this data and what additional safeguards are in place for using, storing and ultimately either deleting or anonymising this data.
2. How do we use your personal information?
At Secrets Silk, we collect different types of information about people for the following main reasons:
1. To provide personalized services unique to individual users.
2. To fulfill contracts for services which you have requested or purchased.
3. So we can monitor and improve the services we offer.
4. To sell advertising space on our websites. This helps us to keep our websites free for people who visit them.
5. To market products and services which we think would be relevant to you.
Newsletters, job alerts and marketing communications
When you sign up to one of our newsletters, job alert emails or other marketing communications, you are giving consent for us to use the email address provided to send you relevant content for the brands you have signed up to. You can withdraw this consent for any email communications by unsubscribing at any time or by contacting us at suppport@secretssilk.com.
Please note that even if you unsubscribe, we still may need to send you communications relating to your use of the website, such as service announcements about your purchase. We may also be required to send certain information to you under a legal, regulatory, or ethical requirement.
Advertising
We advertise on our site and in our newsletters to help keep most of the content free. We use cookies and similar technologies and work with trusted partners so that we can show you advertisements we believe might interest you, to control the number of times you see an ad and to measure the effectiveness of a campaign. Where required by law we obtain your consent to use cookies. Please see our Cookies Preference Center which is accessible at the bottom of this page and across our websites to manage your cookie preferences and see section 13 below for more information on how we use cookies across our websites.
Social Media Advertising
We work with social media networks such as Facebook Pixel and Twitter Pixel to show you interest-based marketing content from our brands and selected advertisers if you have viewed a Secrets Silk website. Data collected by the Facebook Pixel and Twitter Pixel may also be anonymised and used in aggregate to help improve the quality and effectiveness of our websites and marketing efforts.
You can limit the kind of tracking and profiling that Facebook and Twitter undertakes by going to your Facebook and Twitter account settings. You can also control your cookie preferences by accessing the Cookie Preference center at the bottom of our websites.
Research & Insight
We run various user communities, forums and reader panels. We send out research invitations to our research communities, to people who pay for our products and services and to people who have opted in to receive communications from us.
Delivery of goods and services / Customer account management
We will use the information you have provided for the provision of goods and/or services that you have requested or purchased and subsequently communicating with you about those products and services.
Please note too, that when you buy something from us – such as a subscription, membership or a ticket to an event – we may contact you about your registration details, to manage any account or subscription you have with us, or to provide customer service. This will be the case even if you have opted-out of, or declined to consent to, receiving promotional emails.
Competitions
When you enter one of our online competitions, we will process your information for the purposes of picking a winner. If you have opted-in to receiving information from us about our products and services (eg receiving subscriptions offers, event invitations, signing up for editorial newsletters etc) then we will use the information you provide to make sure we offer you relevant products and services (based on where you live, your age, gender, tastes, preferences etc). If you have opted-in to receive news and offers from any competition sponsors, we will share your information with them.
Further details about this are outlined in the “who do we share information with” with section.
Partnership programmes
We work with our partners from the world of luxury goods, fashion, travel and retail so that we can present you with some outstanding offers and opportunities by either email or post. You will only ever receive partner messages from us if you have actively given permission. We won’t disclose your personal information to anyone, the messages will come from us and you can unsubscribe at any time from these messages.
Customer queries and complaints
We process any information you provide when dealing with any complaints or enquirers made by you or legally on your behalf
3. Legal bases for data processing – what does it mean and how do we use them?
The law on data protection sets out several different reasons why a company may collect and process your personal data and it is one of our duties to make sure you understand which of these lawful bases we are using to process your data.
Consent
In specific situations, we can collect and process your data with your consent. For example, when you tick a box to receive email newsletters or when you enter your email address to subscribe to a newsletter.
Contractual obligations
In certain circumstances, we need your personal data to comply with our contractual obligations.
For example, when you purchase a print subscription to a magazine, or purchase membership access, we will keep your personal information to perform a contract or service with you.
Legal compliance
If the law requires us to, we may need to collect and process your data.
For example, we can pass on details of people involved in fraud or other criminal activity affecting us to law enforcement.
Legitimate interest
In specific situations, we require your data to pursue our or a third party’s legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests. Where we rely on our legitimate interests we ensure that the rights and freedoms of individuals are not outweighed by our own interests.
We will also use your address details to send you direct marketing information by post, telling you about products and services that we think might interest you
4. Do we share your information with anyone else?
Service providers
We work with service providers to perform some tasks on our behalf. This might include: analysis, payments, marketing, etc, and we may share your personal data with these providers to perform the necessary tasks. However, they are obliged not to disclose or use it for any other purposes. Any third-party processing of your data on our behalf will be subject to security and confidentiality obligations consistent with this privacy notice and
Customer research & insight
We may disclose de-personalized data (such as aggregated statistics) about the audience of our products and services and/or research participants to describe our sales, customers, traffic patterns and other information to prospective partners, advertisers, investors and other reputable third parties, and for other lawful purposes. These statistics will never include identifiable personal information.
Law enforcement organizations
Under certain circumstances we may occasionally be required by law, court order or governmental authority to disclose certain types of personal information and we reserve the right to comply with any such legally binding request.
Marketing partners
With your explicit permission, we may share your information with other companies we are working with, such as competition sponsors. Whenever we share your information with another company, we will always ask for your permission, will name the company and will always be clear that your information will be shared with another organization.
5. Collecting data on children
We do not knowingly collect and process information from children (anyone under the age of 13). The products and services we offer are generally aimed at people aged 18 and over.
If you are under the age of 13, we ask that you do not give us any information about you or use our websites.
If you are a parent or guardian of a child under 13 and you if you think that your child has used our websites or subscribed to a newsletter or provided their information to us without your consent, please contact us at support@secretssilk.com and we will delete and/or stop processing your child’s personal information within a reasonable time.
If you are aged between 13 and 18, we request that you seek your parent or guardian’s permission before providing us with your information or using our websites or apps.
6. How long will we keep data?
We will retain your personal information for as long as necessary to provide the individual service/s you have requested while taking into account any legal requirements and tax and accounting rules.
Where you sign up to receive email marketing from us we will retain your e-mail address after you ‘opt-out’ of receiving emails to ensure that we continue to honour and respect that request. To unsubscribe from our newsletters or marketing emails at any time, please click on the unsubscribe link at the bottom of any newsletter or marketing email and update your account preferences.
In some circumstances you can ask us to delete your data: see ‘Your rights’ below for further information.
In some circumstances, we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
7. Profiling
We may sometimes use the data you share with us, and that we collect about you when browsing our websites and products, to personalise our services and to tailor marketing content. For example, we may use information you have provided to send you information about products we think you may be interested in. If you do not want to receive this material, you can unsubscribe at any point.
8. Cross-border transfers and security
We make sure that we have appropriate security measures to protect your information and make sure that, when we ask another organisation to provide a service for us, they have appropriate security measures and follow the same high standards of security and data protection as we do.
If we or our service providers transfer any information out of the European Economic Area (EEA) or the UK, it will only be done with the relevant protection (stated under EEA or UK law) being in place.
9. Links to other websites
Our website may contain links to other websites run by other organisations. This privacy policy applies only to Secrets Silk websites‚ so we encourage you to read the privacy statements on any other websites you visit. We cannot be responsible for the privacy policies and practices of other sites even if you have accessed them using links from our websites.
10. Your rights
As a consumer, you have rights when it comes to your data:
1. The right to be informed. At every point where we are collecting your data, we will inform you of why it is being collected and how it is being processed.
2. The right of access. If you wish to see what information we hold on you, you may send us what is called a Subject Access request. We will require photocopies of two pieces of identification. We will respond within 30 days of receipt of your request. There is no cost to you in requesting to see your data, but please note that we reserve the right to charge you if you make subsequent requests. You can use the contact details below for a Subject Access Request.
3. The right to rectification. We offer the opportunity to amend your personal information by contacting us using the details below.
4. The right to erasure. If you wish to cancel all communications with us, we can anonymise or de-identify your data. Please contact us using the details below. Please make sure you inform us of all email accounts, profiles, names etc that you may have used with us that you wish to erase.
5. The right to restrict processing. You can opt-out or restrict the processing of your data by:
- Amending your cookie settings in your browser
- Contacting support@secretssilk.com
If you are unhappy with the way we have collected and are using your personal data please do not hesitate to contact us, using the contact details below.
11. Notice to California Customers – Your Privacy Rights
A. Consumer Privacy. The California Consumer Privacy Act, Cal. Civ. Code §1798.100 et. seq. (“CCPA”), grants residents of California certain rights with respect to their Personal Information and requires us to provide such individuals with certain information, described in this Section 11.
(1) California residents may exercise the following rights by contacting our Privacy Policy Coordinator by email or phone, as described in the How to Contact Us section below
• Know the ways in which we acquire, use, share, disclose and otherwise process your personal information;
• Know the specific pieces of your personal information that we hold;
• Request the deletion of your personal information, subject to several exceptions; and
• Not to be denied goods or services for exercising these rights.
(2) California residents also have the right to opt-out of the “sale” of their personal information. We put “sale” in quotation marks because the CCPA considers some transfers of personal information to third parties in exchange for value as “sales,” even if no money changes hands, such as when online identifiers, Device IDs, and other information is shared with Third Party Businesses to further their own commercial purposes such as generating profiles about individuals.
California residents can exercise this right here: Do Not Sell My Personal Information. If we have actual knowledge that a California resident is younger than 16, we will request opt-in consent before selling their personal information. Note that we can still share personal information with third parties if those transfers aren’t “sales,” such as with our Service Providers.
(3) Depending on the circumstances and which Service you use, we have disclosed the following categories of your personal information for a “business purpose” (as defined in the CCPA) in the preceding twelve (12) months:
- Identifiers
- Protected characteristics
- Commercial information
- Geolocation data
- Internet or other electronic network activity information
- Financial, medical, or health insurance information
- Audio, electronic, visual, thermal, olfactory, or similar information
- Professional information
- Education information
- Inferences drawn from any of the above information categories.
(4) Depending on the circumstances and which Service you use, we have “sold” (as defined in the CCPA) the following categories of your personal information in the preceding twelve (12) months:
- Identifiers
- Protected characteristics
- Commercial information
- Geolocation data
- Internet or other electronic network activity information Inferences drawn from any of the above information categories, along with the following categories: (i) financial, medical, or health insurance information; (ii) audio, electronic, visual, thermal, olfactory, or similar information; (iii) professional information, and (iv) education information.
B. Shine the Light. California’s “Shine the Light” law, Civil Code Section 1798.83, gives California customers the right to prevent our disclosure of their personal information to third parties for those third parties’ direct marketing purposes, and requires certain businesses to respond to requests from California customers asking about the business’ practices related to disclosing personal information to third parties for the third parties’ direct marketing purposes. Alternately, such businesses may have in place a policy not to disclose personal information of customers to third parties for the third parties’ direct marketing purposes if the customer has exercised an option to opt-out of such information-sharing. We have such a policy in place. As discussed above in Section X(A)(2), California residents can exercise their right to opt-out here: Do Not Sell My Personal Information.
C. Online Erasure. California’s “Online Erasure” law, Business and Professions Code Sections 22580-22582, requires operators of certain websites and online services to allow registered users who are under the age of 18 and residents of California to request removal of Content they post. If you fit that description and posted Content on a section of our Service that is directed to minors, you may request removal of the Content by contacting our Privacy Policy Coordinator by email or as described in the How to Contact Us section below. In response to your request, we may elect to make the Content invisible to other users and the public (rather than deleting it entirely), in which case the Content may remain on servers we control and/or may be publicly available elsewhere if a third party copied and reposted the Content.
12. How to contact us
Thank you for reading our Privacy Policy. If you would like to contact us to understand more about our privacy policy or wish to contact us concerning any matter relating to individual rights and your personal information, then please email or write to us at:
Email: support@secretssilk.com
To contact the Data Protection Officer, please e-mail: support@secretssilk.com
If you are a California Resident and would like to contact us to understand more about our privacy policy or wish to contact us concerning any matter relating to individual rights or your personal information, then please email or write to us at:
Privacy Policy Coordinator
13. Cookie and tracking technologies
This Section outlines what cookies and similar tracking technologies our websites use, how we use them and information on how to opt out of these cookies if you wish to do so. Please see our Cookie Preference centre which can be found at the bottom of our websites to change your cookie preferences and learn more about which vendors we work with and what types of cookies we use on our websites. .
What are Cookies?
Cookies and similar tracking technologies, such as tags, scripts and beacons, are small pieces of code (referred to as cookies hereafter) that are stored on a device (computer, mobile phone, tablet etc) and enable a website to “personalise” itself to users by remembering information about the user’s visit to the website. We also use cookies within emails we may send.
Cookies are used to collect information, where available, about your device, your IP address, operating system and browser type and how you have interacted with our websites.
Cookies can be used to identify users and devices and collect information such as IP addresses and device IDs.
Why do we use them?
Our websites use cookies to:
- Store any preferences you have made and display content to you in a more personalised way
- Evaluate our websites’ advertising and promotional effectiveness
- Gain insight into the nature of our audience so we can tailor our content accordingly
- Provide interest-based advertising on our websites and on other websites which are tailored to your interests and preferences
Where required by law we obtain your consent to use cookies so that we can show you adverts we believe you might be interested in, to control the number of times you see an advert and to measure the effectiveness of a campaign. We advertise on our site and in our newsletters to help keep the content free for our audiences.
We will always make sure our websites contain clear and easy to find information about our cookies.
What types of cookies do we use?
- Per-Session Cookies: We only use these while you are visiting our website and they are deleted when you leave. They remember you as you move between pages, for example recording the items you add to an online shopping basket. They also help maintain security.
- Persistent cookies: These cookies stay on your computer until they expire or are deleted. We set automatic deletion dates so that we don’t keep your information for longer than we need to.
- First and third-party cookies: Whether a cookie is ‘first’ or ‘third’ party refers to the website or domain placing the cookie. First party cookies in basic terms are cookies set by a website visited by the user – the website displayed in the URL window. Third party cookies are cookies that are set by a domain other than the one being visited by the user. If a user visits a website and a separate company sets a cookie through that website this would be a third-party cookie.\
For an up to date list of first and third-party cookies that we use and to manage your cookie choices please visit the Cooke Preference link at the bottom of our websites.
Opting out of Cookies
We provide you with choice over the use of cookies as described in this policy via the Cooke Preference centre.
Please note that our websites may not work correctly if you change certain preferences, such as disabling all cookies.
Please also note that after applying these settings, you will continue to receive advertising, although it may not be tailored to your likely interests using information collected from cookies and similar technologies on your device.