SESSI PRIVACY POLICY

This Privacy Policy explains in detail the types of personal data we may collect about you when you interact with us. It also explains how we’ll store and handle that data and keep it safe.

We want to make sure you’re fully informed about your rights and how SESSI uses your data. We hope the following notice will answer any questions you have but, if not, please do contact us.

1. PURPOSE OF THIS PRIVACY POLICY

1.1 This privacy policy aims to give you information on how SESSI collects and processes your personal data through your use of our website. This includes any data you may provide through our website when you purchase a product, sign up for our newsletter or contact us by email. It is important that you read this privacy policy so that you are fully aware of how and why we are using your data. 

2. CONTROLLER

The sessilondon.com website and any other means of collecting personal data are controlled by SESSI London Ltd, referred to as “we”, “us” or “our” throughout this Privacy Policy. We are the primary data controller for the purposes of this website and a company registered in England company number 14865451. Our registered office is 54 Queen Street, Henley-On-Thames, England, RG9 1AP, United Kingdom.

3. CHANGES TO OUR PRIVACY POLICY

3.1 This version was created on 16.11.23. 

We may amend this Privacy Policy at any time by posting the amended terms herein. All amended terms automatically take effect 30 days after they are posted. We will announce any material changes to this Privacy Policy via email.

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.

4. WHEN DO WE COLLECT PERSONAL DATA FROM YOU

4.1 We may collect and process the following data about you:

• When you make an online purchase.
• When you sign up to receive our newsletter. 
• When you open an email from us and any links in those messages are clicked. 
• When you engage with us on social media.
• When you contact us by any means.
• When you enter prize draws or competitions.
• When you complete any surveys we send you.
• When you comment on or review our products and services.
• When you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions, patterns and the website that referred you to sessilondon.com. We collect this personal data by using cookies, server logs and other similar technologies. Technical Data is collected from the following parties: analytics and search information providers (such as Google), marketing platforms (such as Facebook) and advertising networks (such as AdRoll). 
• When you've given a third party permission to share with us information they hold about you.
• We collect data from publicly-available sources when you have given consent to share information or where the information is made public as a matter of law.

5. PERSONAL DATA WE MAY COLLECT FROM YOU

5.1 We capture customer data, purchase data and browsing behaviour so we can fulfil any orders placed, optimise and personalise your experience and tailor any emails we may send you if you consent.

The personal information we collect includes the following:

• Personal information including payment related information you give us when you register or purchase through the site;
• Content that you generate when interacting with our customer services team including details we require to contact you and verify your identity;
• Device identifiers such as IP addresses, cookie IDs, IDFAs and other device identifiers, as well as geo location information, IoT technologies and connection information such as statistics on your page views, traffic to and from the sites, referral URL, ad data, your browsing history, hashed email addresses, and your web log information.

If you give us personal data about someone else, you must do so only with their explicit and prior consent.

We use cookies to collect information about the pages you view, the links you click and other actions you take on our Services or e-mail content. Cookies are text files stored on your computer when you visit web pages. To make full use of the online shopping and personalised features on sessilondon.com, your computer, tablet or mobile phone will need to accept cookies, as we can only provide you with certain personalised features of this website by using them.

Most web browsers have cookies enabled; should you need to turn them on, consult the help guide for your browser. If you’d prefer to restrict, block or delete cookies from sessilondon.com, or any other website, you can use your browser to do this. Each browser is different, so check the Help menu of your particular browser to learn how to change your cookie preferences. 

6. HOW AND WHY WE USE YOUR PERSONAL DATA

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

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

6.2 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.

Examples of how we use information held about you include:

• To process any orders that you make on our website or in store. If we don't collect your personal data during checkout, we won't be able to process and deliver your order and comply with legal obligations. For example, your details may need to be passed to a third party to supply or deliver the product or service that you ordered, and we may keep your details for a reasonable period afterwards in order to fulfil any contractual obligations such as refunds, guarantees and so on.
• To respond to your queries, refund requests and complaints. Handling the information you send enables us to respond. We may also keep a record of these to inform any future communication with us and to demonstrate how we communicated with you throughout. We do this on the basis of our contractual obligations to you, our legal obligations and our legitimate interests in providing you with the best service and understanding how we can improve our service based on your experience.
• To process payments and to prevent fraudulent transactions. We do this on the basis of our legitimate business interests. This also helps to protect our customers from fraud.
• To administer any of our prize draws or competitions which you enter
• To develop, test and improve the systems, services and products we provide to you. We'll do this on the basis of our legitimate business interests.
• To comply with our contractual or legal obligations to share data with law enforcement.
• To send you survey and feedback requests to help improve our services. These messages will not include any promotional content and do not require prior consent when sent by email or text message. We have a legitimate interest to do so as this helps make our products more relevant to you.

7. WHO DO WE SHARE YOUR DATA WITH?

7.1 We protect your information using measures that reduce the risks of loss, misuse, unauthorised access, disclosure and alteration. We minimise the amount of personal information we disclose to what is directly relevant and necessary to accomplish the specified purpose.

In so doing we may disclose your personal information to authorised third party service providers who help us to provide our services such as:

• Payment providers to facilitate purchases
• Fulfilment providers to facilitate order management, packaging and delivery
• Marketing and advertising providers in order to personalise your experience

We do not disclose your personal information to third parties for marketing purposes.

Where legally compelling grounds exist, we may also disclose your personal information to governmental and law enforcement agencies, and otherwise in the defence of legal claims.

We protect your information using measures that reduce the risks of loss, misuse, unauthorised access, disclosure and alteration. 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.

8. HOW WE PROTECT YOUR DATA

8.1 The security of your personal data is very important to us and we are committed to treating it with the utmost care, taking all appropriate steps to protect it.

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. Access to your personal data is password-protected, and sensitive data (such as payment card information) is secured and tokenised to ensure it is protected.

We secure access to all transactional areas of our websites and apps using 'https' technology.

We regularly monitor our system for possible vulnerabilities and attacks, and we carry out penetration testing to identify ways to further strengthen security.

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.

9. HOW LONG WILL YOU KEEP MY DATA FOR?

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

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. For example, if your order included a product guarantee, the associated personal data will be kept until the end of the guarantee period.

At the end of that retention period, your data will either be deleted completely or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning.

10. WHAT ARE YOUR RIGHTS OVER YOUR PERSONAL DATA?

10.1 Under certain circumstances, you have rights under data protection laws in relation to your personal data.

You have the right to:

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

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

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

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

Request restriction of processing 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.

In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.

You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We must always comply with your request.

If you wish to exercise any of the rights set out above, please contact email hello@sessilondon.com.

To opt out from email marketing please click on the unsubscribe link featured at the bottom of each marketing email we send.

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.

www.sessilondon.com is a site operated by SESSI London LTD. We are registered in England and Wales under company number 14865451 and our registered office is at 54 Queen Street, Henley-On-Thames, England, RG9 1AP, United Kingdom (the "Assignee").