Privacy Policy

Introduction

Welcome to the CoverCouch privacy notice.

CoverCouch Ltd. respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you. We are obliged to inform you about according to applicable personal data protection regulation incl. the EU Regulation No. 2016/679 the General Data Protection Regulation (“GDPR”).

Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.

This Privacy notice may be supplemented by other information received from us and other terms and conditions applicable to this website, or which you have agreed to as part of interacting with us.

Your comments and feedback are always welcome.

1. IMPORTANT INFORMATION AND WHO WE ARE

Purpose of this privacy notice

This privacy notice aims to give you information on how CoverCouch collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter, purchase a product or service, order free fabric samples or take part in a competition.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Controller

CoverCouch Ltd is the controller and responsible for your personal data (collectively referred to as "CoverCouch", "we", "us" or "our" in this privacy notice). We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

Contact details

Full name of legal entity: CoverCouch Ltd.
Name: Tomas Paplauskas
Email address: [email protected]
Postal address: 59 Devons Road, E3 3DW, London, United Kingdom

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy notice or to your personal data

This version was last updated on 23 June 2020.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

2. THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

  1. Identity Data includes first name, last name, username or similar identifier.
  2. Contact Data includes billing address, delivery address, email address and telephone numbers.
  3. Financial Data includes payment card details.
  4. Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
  5. Technical Data includes internet protocol (IP) addresses, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
  6. Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses. 
  7. Usage Data includes information about how you use our website, products and services.
  8. Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

3. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity, Contact Data by filling in forms or by corresponding with us via our website, or by post, phone, email or otherwise. This includes personal data you provide when you:

  1. apply for our products or services;
  2. create an account on our website;
  3. subscribe to our service or publications;
  4. order free fabric samples from us;
  5. request marketing to be sent to you;
  6. enter a competition, promotion or survey; or
  7. give us feedback.

Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.  Please see our cookie policy below for further details.

Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:

  1. Technical Data from analytics providers or search information providers.
  2. Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
  3. Identity and Contact Data from data brokers or aggregators.
4. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

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

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a list format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the list below.

Purpose/Activity - To register you as a new customer.
Type of data - (a) Identity; (b) Contact.
Lawful basis for processing including basis of legitimate interest - Performance of a contract with you.

Purpose/Activity - To process and deliver your order including: (a) Manage payments, fees and charges; (b) Collect and recover money owed to us.
Type of data - (a) Identity; (b) Contact; (c) Financial; (d) Transaction; (e) Marketing and Communications.
Lawful basis for processing including basis of legitimate interest – (a) Performance of a contract with you; (b) Necessary for our legitimate interests (to recover debts due to us).

Purpose/Activity - To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy; (b) Asking you to leave a review or take a survey.
Type of data - (a) Identity; (b) Contact; (c) Profile; (d) Marketing and Communications.
Lawful basis for processing including basis of legitimate interest - (a) Performance of a contract with you; (b) Necessary to comply with a legal obligation; (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services).

Purpose/Activity - To enable you to partake in a prize draw, competition or complete a survey.
Type of data - (a) Identity; (b) Contact; (c) Profile; (d) Usage; (e) Marketing and Communications.
Lawful basis for processing including basis of legitimate interest - (a) Performance of a contract with you; (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business).

Purpose/Activity - To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).
Type of data - (a) Identity; (b) Contact; (c) Technical.
Lawful basis for processing including basis of legitimate interest - (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise); (b) Necessary to comply with a legal obligation.

Purpose/Activity - To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.
Type of data - (a) Identity; (b) Contact; (c) Profile; (d) Usage; (e) Marketing and Communications; (f) Technical.
Lawful basis for processing including basis of legitimate interest - Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy).

Purpose/Activity - To use data analytics to improve our website, products/services, marketing, customer relationships and experiences.
Type of data - (a) Technical; (b) Usage.
Lawful basis for processing including basis of legitimate interest - Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy).

Purpose/Activity - To make suggestions and recommendations to you about goods or services that may be of interest to you.
Type of data - (a) Identity; (b) Contact; (c) Technical; (d) Usage; (e) Profile.
Lawful basis for processing including basis of legitimate interest - Necessary for our legitimate interests (to develop our products/services and grow our business).

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods from us or ordered free fabric samples from us or if you provided us with your details when you entered a competition or registered for a promotion, and, in each case, you have not opted out of receiving that marketing.

Our marketing may take place by email, by ads and communication on our site, or by ads and communication on social media sites and other third party sites (retargeting). The communication may be tailored to your marketing preferences and to our assumptions on your interests based on information we have about you (profiling), unless you have told us that you rather prefer general, non-personalized marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any other company for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see below.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below for the purposes set out in the list in paragraph 4 above.

External Third Parties. These include:

  1. PayPal, who provide us with payment services.
  2. HSBC, who provide us with payment services.
  3. UPS, who provide us with order fulfilment services.
  4. Royal Mail, who provide us with order fulfilment services.
  5. LT Post, who provide us with order fulfilment services.
  6. Prestashop, who provide us with website management services.
  7. Web Solutions, who provide us with website management services.
  8. Omnisend, who provide us with marketing services.
  9. Yotpo, who provide us with marketing services.
  10. Tawk.to, who provide us with marketing services.
  11. Freshdesk, who provide us with customer care services.
  12. Push!, who provide us with marketing services.
  13. Google Analytics, who provide us with reporting services.
  14. Google Suite, who provide us with performance, security and mail services.
  15. Cloudflare, who provide us with performance services.
  16. Hosty, who maintain our IT network and systems.
  17. Professional advisers including lawyers, bankers, auditors and insurers who provide various professional services to us.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

International transfers

We do not transfer your personal data outside the European Economic Area (EEA).  However, it is possible that if we change our service providers, or engage a new service provider then thay may be based outside of the EEA.  In this case we will ensure that they must provide a similar degree of protection to your personal data by ensuring at least one of the following safeguards is implemented:

  1. We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
  2. Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries. 
  3. Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

6. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site. Any transmission is at your own risk.

7. DATA RETENTION

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

We retain data to the extent required by law (such as tax/bookkeeping laws).

We retain data such as contact data, order data and communication data to the extent relevant for limitation periods for potential claims (typically no less than five years after date of a purchase or until you ask us to ‘deregister’ and delete it).

We retain data such as contact data, order data, marketing data, location data and preference data as long as you have consented to receive marketing communication from us.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.

In some circumstances you can ask us to delete your data: see Request erasure below for further information.

In some circumstances we may anonymize 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. 

8. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. For more information about these rights please email us at [email protected].

  1. Request access to your personal data.
  2. Request correction of your personal data.
  3. Request erasure of your personal data.
  4. Object to processing of your personal data.
  5. Request restriction of processing your personal data.
  6. Request transfer of your personal data.
  7. Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us. 

No fee usually required

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 clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

9. GLOSSARY

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

YOUR LEGAL RIGHTS

You have the right to:

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

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

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

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

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

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

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

10. COOKIES

Our cookies policy

We use cookies on this site to enable certain parts of the site to function and to distinguish you from other users of our website. This helps us to improve our visitors' experience.

By continuing to browse our website, you are agreeing to our use of cookies.

What is a cookie? A cookie is a small file of letters and numbers that is stored on your browser or hard drive if you agree. They cannot harm your computer and do not contain any information that identifies you personally. We will never collect any personal information about you, or anyone using your device, such as name, address or financial details, using our website cookies.

Some features used on this website may involve a cookie being sent to your computer by a third party. For example, if you view or listen to any embedded audio or video content you may be sent cookies from the site where the embedded content is hosted. Likewise, if you share any content on this website through social networks you may be sent cookies from these websites. We have no control over third party cookies so please check the websites of these third parties for more information about their cookies and how to manage them.

To be able to access parts of our site, for example online shopping, your device must be set to accept cookies. You can block cookies at any point by changing your browser settings. Every browser has a different way to turn cookies off so it’s best to check in your browser’s help section.

You can find out more information about the individual cookies we use and the purposes for which we use them in the next section below:

What cookies do we use

Cookie nameCookie Description
CART The association with your shopping cart.
CATEGORY_INFO Stores the category info on the page, that allows to display pages more quickly.
COMPARE The item that you have in the Compare Products list.
CURRENCY Your preferred currency
CUSTOMER An encrypted version of your customer ID with the store.
CUSTOMER_AUTH An indicator if you are currently logged into the store.
CUSTOMER_INFO An encrypted version of the customer group you belong to.
CUSTOMER_SEGMENT_IDS Stores the customer segment ID
EXTERNAL_NO_CACHE A flag, which indicates whether caching is disabled or not.
FRONTEND Your session ID on the server.
GUEST-VIEW Allows guests to edit their orders.
LAST_CATEGORY The last category you visited.
LAST_PRODUCT The most recent product you have viewed.
NEWMESSAGE Indicates whether a new message has been received.
NO_CACHE Indicates whether it is allowed to use cache.
PERSISTENT_SHOPPING_CART A link to information about your cart and viewing history if you have asked the site.
POLL The ID of any polls you have recently voted in.
POLLN Information on what polls you have voted on.
RECENTLYCOMPARED The items that you have recently compared.
STF Information on products you have recently emailed to friends.
STORE The store view or language you have selected.
USER_ALLOWED_SAVE_COOKIE Indicates whether a customer allowed to use cookies.
VIEWED_PRODUCT_IDS The products you have recently viewed.
WISHLIST An encrypted list of products added to your Wishlist.
WISHLIST_CTN The number of items in your Wishlist.
_UTMA, _UTMV,_UTMB,_UTMC,_UTMZ, _ga, _gat,_gid Google Analytics, which is a web analytics service from Google, uses these cookies to help us see how our website is used.
__cfduid Cloudflare, which is a secure CDN network for website performance, speed and security.
__tawkuuid Tawk.to, customer care service for live chatting and customer care service online.
fbm_ Facebook, which helps users to connect through their Facebook account.
omnisendAnonymousID, omnisendCartProducts, omnisendContactID, omnisendEmailID, omnisendSessionID, soundest-recovery, soundest-views, soundestID Omnisend, an indicator what products user has purchased, viewed or added to cart.

if you would like to discuss cookies with us in more detail, please write to us at:

Full name of legal entity: CoverCouch Ltd.
Email address: [email protected]
Postal address: 59 Devons Road, E3 3DW, London, United Kingdom

This Privacy Notice may change from time to time. We will notify you by appropriate means if we make any changes of significance to you. You will always find the latest version of this Privacy Notice on our Site.