RegulationUpdated May 2022
Keeping your data safe
Who are we?
Located in Parnell, Auckland, Lucy Ralston is an international couturière elegant and contemporary dresses. She has established herself as a bespoke evening dressmaker and wedding designer that elevates the feminine image of beauty in all shapes and forms. Lucy’s creations have built an exceptional list of private clients based on her high standards of craftsmanship, refined style and originality.
1 Who’s in control?
1.1 It is important that you understand who is responsible for keeping your data safe. We are the “controller” of all personal data collected and used. This means that we are responsible for deciding how and why your data is used and for ensuring that your data is handled legally and safely.
2 What data do we collect and where from?
2.1 We collect some data directly from you when you engage with Lucy Ralston. This is information about you that you give us by filling in forms on our site lucyralston.com or by corresponding with us by telephone, email, social media platforms or in person. It includes information you provide when you register to use our site, subscribe to our service, place an order, purchase a garment or accessory, participate in discussion boards or other social media functions, enter a competition, promotion or survey and when you report a problem with our site.
This data could include some or all of the following:
2.1.1 your full name;
2.1.2 your email address;
2.1.3 your telephone numbers, home and mobile;
2.1.4 your postcode and address (if you choose to provide them);
2.1.5 your billing contact name (family or guardian);
2.1.6 your billing contact email address, postal address and phone numbers (family or guardian);
2.1.7 photographic images of you throughout your purchase, order, and fittings process, consisting of approx. 8 fittings in total;
2.1.8 images of you on your wedding day (if you chose to share them);
2.1.9 your credit card information (this is not held on file);
2.1.10 your body measurements;
2.1.11 personal notes about your fittings and personal body information;
2.1.12 personal family information and details of your wedding;
3 What do we use your data for?
3.1 It is important that you understand how and why we use the personal data that we collect about you. This section sets out the different purposes for which we process personal data and which types of personal data we need for each purpose.
3.2 Managing your personal Account Data and providing you with our services, we manage confidentially all the data you have provided us with as listed in section
2.1.1 Your data will stay in our computer system unless you request otherwise. The team at Lucy Ralston Ltd. have all signed strict confidentiality agreements and are very aware of client confidentiality throughout all our processes.
3.2.1 We use a password protected internal computer program, which is backed up to our internal server and in turn backed up externally to manage and administer your purchase order, for the avoidance of doubt this may be a consultation, sample purchase, accessory purchase or a bespoke garment order. We use this to search your account and to provide you with Lucy Ralston services that you have requested from us. We also store personal data in our online diary system. This would be name and contact details and information in connection with your appointments with us.
3.2.2 we use your Voluntary Data to enable us to make appointments, respond to queries, complaints or comments that you have and to make sure that these are appropriately dealt with.
3.4 Improving our services
3.4.1 we use Account Data, Behavioural Data, Voluntary Data and Survey Data to help us monitor, analyse and improve Lucy Ralston Ltd services and procedures. We use this data to help us understand which products, content and services are most suitable to our clients and to help us identify errors and test features. This helps us to make sure that we are providing you with the best possible products and services. This also
(a) enable us to assess our performance and to improve our products and services including advertising;
(b) inform our marketing and promotional activities;
(c) inform and support our advertising partners;
3.5 We periodically review the data that we keep in our archive and we will delete or anonymise your data held in the archive where we consider it is no longer of value or interest.
4 What is our legal basis for using your data?
4.1 Data protection law says that we have to tell you the legal basis that we rely on to process your personal data for the purposes that we have notified to you. This section tells you what that legal basis is in relation to each of the purposes set out above.
4.2 With the exception of email marketing, we process your personal data for all of the purposes identified under What do we use your data for? and How do we use your data for marketing and advertising purposes? on the basis that it is in our legitimate interests, or the legitimate interests of third parties with whom we share your data, to carry out these activities. Further information about what those interests are is set out below.
Purpose: AdvertisingLegitimate interests: To provide advertising that is relevant to you to ensure that you have the best experience possible.
4.4 In respect of the use of your email address for email marketing purposes, we process this on the basis that we have your consent to do so. You can withdraw your consent at any time by requesting this via email to us.
5 Who do we share your data with?
5.1 We do need to share your personal data with some third parties in some circumstances. This includes where we use third party suppliers to perform various services for us. The third party suppliers we share your personal data with are as follows:
5.1.1 third party service providers who help us to manage our customer database and registration process; IT / PR and marketing providers. Website creators and advisors.
5.1.2 other service providers such as information security service providers who help us to manage our IT systems and ensure that they are secure
6.2 Any Voluntary Data you submit to our team will be retained for a minimum period of ten years from submission, after which it may be anonymised.
6.3 It is helpful to keep purchase orders on file for reference for crossover with future clients. We often search past client’s orders for fear of a friend having a similar garment.
6.4 In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
6.5 If Lucy Ralston Ltd. or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
6.6 If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or terms and conditions of supply and other agreements; or to protect the rights, property, or safety of Lucy Ralston Ltd, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
7 What rights do you have?
7.1 You have a number of rights under data protection law. These rights and how you can exercise them are set out in this section. We will normally need to ask you for proof of your identity before we can respond to a request to exercise any of the rights in this section and we may need to ask you for more information, for example to help us to locate the personal data that your request relates to.
7.2 We will respond to any requests to exercise your rights as soon as we can and in any event within one month of receiving your request and any necessary proof of identity or further information. If your request is particularly difficult or complex, or if you have made a large volume of requests, we may take up to three months to respond. If this is the case we will let you know as soon as we can and explain why we need to take longer to respond.
7.3 A right to access your information
7.3.1 You can access all of your Account Data through requesting this directly via email to firstname.lastname@example.org
7.3.2 You also have a right to ask us to send you a copy of your Account Data and all other personal data that we hold about you (subject to some exceptions). A request to exercise this right is called a “subject access request” and must be made in writing to: email@example.com
7.4 A right to object to us processing your information
7.4.2 If we have compelling legitimate grounds to carry on processing your personal data, we will be able to continue to do so. Otherwise, we will cease processing your personal data.
7.4.3 You can exercise this right by emailing firstname.lastname@example.org.
7.4.4 Remember that you can always delete your account at any time through emailing email@example.com.
7.5 A right to have inaccurate data corrected
7.5.1 You have a right to ask us to correct inaccurate data that we hold about you. If we are satisfied that the new data you have provided is accurate, we will correct your personal data as soon as possible.
7.6 A right to have your data erased
8 How can you contact us?
9 What if you have a complaint?
9.1 You have a right to complain to the Information Commissioner’s Officer (ICO),
10 What if this policy changes?