Your information and where it goes

Your privacy is important to us:

At City Of Clouds we take your privacy very seriously and are committed to protecting the privacy and security of our customers. We fully appreciate and respect the importance of data protection and online security. This Privacy Policy (the “Policy”) outlines how your personal information is treated and forms part of our terms and conditions. This Policy explains: What information we collect when you use the City Of Clouds website (the “Site”), when you communicate with us, or when you visit one of our stores (as the case may be);

• How we use your information;
• How we share your information;
• How long we keep your information and how it is stored;
• Our approach to sensitive personal information;
• What options you have to control your information;
• The rights you may have in relation to your personal information; and
• How we communicate changes to this Policy.

Please contact our Customer Services team if you would like to discuss this with us or have any questions, comments or suggestions relating to this Policy.

About us:

This Site is run by Powered By Unicorns Limited Trading As City Of Clouds(“City Of Clouds”/”we”/”us”/”our”)  For the purposes of applicable data protection laws, including the EU General Data Protection Regulation (“GDPR”) (as amended or superseded) City Of Clouds is the “controller” of the personal information collected through the Site, by phone, e-mail or other communication, with our Customer Services team, or in any City Of Clouds store. This means that City Of Clouds decides why and how
your personal information is processed.

1. WHEN AND HOW DO WE COLLECT PERSONAL INFORMATION?

Our Website is free for you to browse through and read. We will only collect personal information that you provide to us when you:

• Create an account on our Site
• Place an order through our Site
• Fill in forms on our site, for example to leave feedback, enter a Prize Draw or Competition, or respond to a survey
• Contact us, send us an email or offer feedback
• Subscribe to our mailing list

Any personal information you provide to us in the ways listed above is voluntary. However, if you do not provide this information to us, we may be unable to provide products and services to you or interact or communicate with you effectively.

If you are a child under 16 and want to receive City Of Cloud’s news, we ask that a parent or guardian register. By this we mean that a parent or guardian can register on your behalf using their details. We ask this so that as a child, your personal details are protected, and also to ensure that you have parental consent to take part. City Of Clouds does not ask a person under 16 for more personal information as a condition of participation than is necessary for a given promotion.

We will also collect certain information automatically when you visit our Site, in particular: When you access our Site, we use “cookies” to make it easier for you to use our Site. These cookies record data about the pages you browse and the activities you carried out during your visit. Further details about our use of cookies is set out in our Cookie Policy

below;

We record details of the resources that you access to visit our Site (for example, URL addresses, traffic data etc.); and We record information about the type of device you have used to visit our Site, your device settings, and the cause of any system errors. Your device manufacturer or operating system provider will have further details on what information your device makes available.

Information we collect when you contact us:

We will collect personal information about you when you contact us by telephone, e-mail, online chat function or via social media. We may monitor, record and store such communication with you as needed and, in particular, for training and/or quality purposes.

Information we collect if you apply for a job with us:

You may be able to apply for a job with us through our Site or through third-party websites such as LinkedIn. The personal information we collect about you may include your name, contact details, employment history, and any information set out in your CV.

2. HOW WE STORE YOUR INFORMATION AND FOR HOW LONG?

Your information may be processed by our staff or by the staff of our suppliers to the extent necessary to fulfil your order. By submitting your personal information to us, you agree to the transfer of your personal information, its storage and processing.

We will keep the data which we collect from you on a secure server. Any information you give us relating to credit card details is handled by a PCI DSS compliant third party and encrypted using secure server technology. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access and require our suppliers to do the same.

Where we have given you a password (or where you have chosen one) to access certain parts of this Site, you are responsible for keeping this password confidential. We ask that you do not share a password with anyone.

How long we keep your information:

We retain the information you provide for the following periods;

For as long as you are subscribed to receive marketing information and, afterwards, indefinitely in our suppression lists to ensure that you do not receive such information; For as long as your account is being used and for a period of three years after the date you cease to use your account, after which period we will anonymise the personal information on file by deleting the personal information and allocating a personally unidentifiable unique reference ID and store the remaining information for a period of five years (“Data Retention Period”). After this time it will be permanently deleted from all systems and back-ups. If you wish to set up an account after this period this will be treated as a new account and your transaction history will not be available; and In the case of any contact you may have with our Customer Care team, for as long as is necessary to provide support-related reports and trend analysis. 

Our Data Retention Period has been determined to cover contractual and legal requirements, credit risk, fraud detection and customer service periods, as well as to cover regulatory requirements, and the resolution of disputes or fraud prevention.

Sensitive personal information:

We do not seek to collect sensitive personal information (i.e. information relating to race or ethnic origin, political opinions, religious or other beliefs, trade union membership, physical or mental health, sexual orientation or criminal records). We ask that you do not provide such information to us.

Rights you may have:

You may have certain rights in relation to personal information that we hold about you. These include the right to request access to your personal information, to request that it is erased, that its processing is restricted, or that any inaccurate personal information is rectified. You may also have the right to object to the processing of your personal information, or in some circumstances to obtain a copy of the personal information in a machine readable format and will always have a right at any time to withdraw any consent you have given to us.

In particular, you have the right to object or withdraw your consent (as applicable) to any use we make of your personal information for direct marketing purposes. You have the option to unsubscribe from our e-mails through a link at the bottom of every e-mail we send to you.

If you want to change the details that you have registered with us, or would like to amend your marketing preferences or unsubscribe altogether, this can be changed in the “My Account” section of our Site or by contacting our Customer Services team.

3. HOW WE SHARE YOUR INFORMATION

We share your information with our core service providers and third party platforms as required for our business to function; for example, picking, .packaging and processing orders, fulfilling deliveries, customer support, fraud detection, credit risk reduction checks, IT systems support, and internal audits.

If you choose to provide feedback on your transaction, we will share your information with TrustPilot, a third party feedback site who will capture your feedback on transactions which we use to enhance our customer service.

Your information may be processed by a third party in order to test, enhance or maintain the functionality of our Site.

We also use services offered by Google, Facebook, Instagram and other similar social media platforms to better tailor our marketing communications and for targeted advertising. As part of this process, some personal information, such as your e-mail address, is provided to the relevant third party, however for security purposes this data is “hashed” prior to being shared. Hashing is a process of identity masking or “pseudonymisation” which means we do not disclose your e-mail but still enables linking between your social media presence and our Site. Your personal information will be transmitted to countries outside of the EEA, including the United States. If you would like more information about how your personal information may be transmitted, and the safeguards applied, please contact [email protected]. You may have the right to object to your personal information being used in this way (see “Rights you may have” below).

We receive insights from Facebook about the effectiveness of our advertising campaigns which you experience on our Site and social channels. This helps to better target our advertising. Every external company we work with adheres to our same expectations and requirements in handling personal

information and obligates them to meet these standards and those contained in the GDPR.

4. HOW TO UNSUBSCRIBE

Our policy is to allow users to unsubscribe from our regular emails and SMS at any time. You can do this by clicking the link at the bottom of every email and SMS, sending an e-mail to [email protected] requesting your information be removed from the mailing list.

If you have asked us to stop sending emails, and this hasn’t happened, it may be because the email address to which we are sending them is not the same as the address you sent your request from. Please check the address we are using and include this information in your request. The easiest way to do this is to return to us the whole of the unwanted email. The address we are sending to is included within the message.

5. HOW WE USE YOUR INFORMATION

City Of Clouds (and those people or companies employed by City Of Clouds who help make this Website, its content and certain affiliated companies) will
process the information you tell us in order to respond to your feedback – like responding to problems, improving our services and gearing what we do to suit your requirements further.

Data protection laws require us to have a specific legal reason (also known as a ‘lawful basis’) and purpose to use your personal information.

The ways we use your personal information and the legal reasons which we have for doing so are as follows:

• For the performance of a contract between you and us;
• To provide you with an account on our Site, if you choose to sign up for one;
• To fulfil any order that you place with us;
• To collect payment from you;
• To provide personal styling advice, if so requested;
• To administer any competitions you have entered;
• To provide you with a receipt, if you ask us to send this to you electronically; and
• To protect and defend our legal rights and interests.
• Where we have a legitimate interest in using your personal information: Processing necessary for us to promote our business, brands and products and services 
• To contact you by e-mail with marketing about our products and services after we presented you with an option on our Site to opt-out (e.g. using a tick box when placing an order or making a sales enquiry) which you declined to take. This marketing will relate only to products and services similar to those you are purchasing or enquiring after;
• To deliver tailored advertising (including via social media);
• To tailor and personalise our marketing communications based on your attributes and preferences; and To administer and monitor our Site, including to ensure that content is presented in the most effective manner for you and for your device, and to allow you to participate in interactive features when you choose to.
• Processing necessary for us to respond to changing market conditions and the needs of our visitors and customers
• To analyse any feedback that you provide on our services, and to improve our services; and8
• Processing necessary to conduct recruitment activities and staff our business
• To review and assess any job application that you submit to us.
• To contact you by post following completion of an online order. And to contact you by e-mail or text message or WhatsApp message with marketing communications about our products, services, events and promotions where you opted-in to receiving these (e.g. by actively ticking a box). This includes marketing information that we send to you in our e-mail newsletter to which you have signed up by inserting your e-mail address;
• To contact you by e-mail or text message to refresh your marketing preferences; and To use non-essential cookies and similar technologies in the ways described in our Cookie Policy and to collect personal information about you using them.

Where the processing is required for us to comply with our legal obligations:

To comply with a request from you in connection with the exercise of your data protection rights (for example where you have asked us not to contact you for marketing purposes or your subscription has expired, we will keep a record of this on our suppression lists in order to be able to comply with our legal
obligations); and To keep a record of the data protection rights that you have exercised and which relate to our processing of your personal information.

6. COOKIES POLICY

At City Of Clouds we take your privacy very seriously. We fully appreciate and respect the importance of data privacy and security on the Internet. This
website uses cookies and similar technologies for various purposes, including to distinguish you from other users of the website.

Cookies and similar technologies we use on this website:

A cookie is a small text file placed on your computer by websites you visit.7 The cookies we use are unique to your City Of Clouds account. Cookies don’t
tell us who you are, however they do allow us to recognise your device and remember your preferences or actions.

This website also uses technologies such as web beacons and pixels. These are other technologies that store information in your browser or device, using local shared objects or local storage.

Why we use cookies and similar technologies:

• When you access the City Of Clouds website, we use cookies in order to create an enjoyable and easy online shopping experience for you. These are the main types of cookies that we use and why we use them:
• Strictly Necessary Cookies – these cookies are required for the operation of our website. They will, for example, allow you to navigate the site, add items to your shopping basket and purchase hem.
• Site Analytics – to measure and analyse how customers use our website and respond to marketing, to improve your shopping experience and to improve the overall functionality of our website.
• Customer Preference – to improve your shopping experience by saving you time when making a purchase. For example, we may use cookies to store your language or country so you don‘t have to set them up every time you visit our website.
• Targeting Or Advertising – these cookies are used to enhance your City Of Clouds online experience and to deliver relevant content to you as set out in our Privacy Policy here e.g. adverts or abandoned basket emails/SMS. Such cookies also help us measure the effectiveness of our marketing campaigns. These cookies may be placed by us, or by third parties (see “Advertising cookies and similar technologies” below).

You can opt out of targeted advertising by: Facebook: https://www.facebook.com/settings/?tab=ads
Google: https://www.google.com/settings/ads/anonymous

Deleting or blocking cookies and other technologies:

The cookies described above may be either “session cookies”, which means they are temporary and are automatically deleted from your computer or device when you close your browser, or they may be “persistent cookies”, which last until their expiry date or until you or your browser delete them. By law, we are required to ask your permission before storing non-essential cookies on your computer. If you choose to block or delete cookies or similar technologies used on our website, it may prevent the website from functioning properly or at all. 

You may refuse to accept cookies by altering the settings on your internet browser. Generally, this can be done by visiting the “Settings” menu in your browser. You can also visit the EU-based Your Online Choices website, which will show you the cookies and similar technologies currently in use on your browser, and allow you to opt-out of these. By continuing to use our site and our cookies policy, you agree to the cookies outlined being placed on your device.

Analytics cookies:

Our website uses cookies provided by Google Analytics. These cookies allow us to collect information in an anonymous form about engagement with our website. They tell us, for example, the number of visitors to our website, how visitors have come to our website, and the pages they visited. You can find out more about Google Analytics by visiting https://www.google.com/policies/privacy/partners/, and you can opt-out of the use of these cookies by visiting https://tools.google.com/dlpage/gaoptout.

Advertising cookies and similar technologies:

We work with third parties including Facebook who may use cookies, web beacons and other storage technologies to collect and receive information from our website and elsewhere on the internet, and use it to provide measurement services and targeted adverts. The use of these tools can tell us when you
visited our website, the pages you visited, and the links you followed. This information will be used to make advertising more relevant to your interests. The parties that place these cookies may use the information collected in accordance with their own privacy policies. Please note that if you do block
these third party tools, you will still see advertisements, but these will not be tailored to your interests.

Changes to cookies policy:

We may change this Cookies Policy from time to time. In some cases, we may provide you with additional notice such as adding a statement to the homepage of the website or sending you an email with the update. Please check this Cookies Policy regularly to stay informed about our information practices and the ways you can help protect your privacy.

7. WHAT DO WE DO TO SAFEGUARD PERSONAL INFORMATION?

We will use our best efforts to be sure that third parties who work with us as our agents to make this Website and its contents available to you, and to fulfil your orders and requests, agree to protect personal information that they must access in order to serve our Website and our visitors. We limit access to personal information about you to employees who we believe reasonably need to come into contact with that information to provide products or services to you or in order to do their jobs.

8. LINKS TO OTHER WEBSITES

We may offer links to other websites we use and recommend. However, we are not responsible for the content or information collection policies of websites operated by other companies. If you visit another website, we advise you to review their privacy and other policies.

9. CHANGES TO OUR PRIVACY POLICY

Any changes to the Privacy Policy will be posted here. If City Of Clouds wishes to make material changes to the way we use your personal information we will ask for your consent before we do so.

10. ANYTHING ELSE I SHOULD KNOW?

If you want to change the details that you have registered with us, or would like to amend your marketing preferences or unsubscribe altogether, this can be changed in the “My Account” section of our Site or by contacting our Customer Services team.

You also have the right to complain about the use of your personal information to the Information Commissioner’s Office.

If you have any questions about this privacy Policy and practices of this site you can contact us at [email protected].