Privacy policy

   

1.    INTRODUCTION AND SUMMARY

At Aimée Ann Lou, we are committed to protecting the personal data of the customers who use our website to purchase our unique products.

In this Privacy Policy, when we refer to “Aimée Ann Lou”, “we”, “us” or “our” we mean Aimée Ann Lou Limited and its affiliates in the United Kingdom. When we refer to “you” or “your”, we mean visitors to our website and our customers.

This Privacy Policy is important, so please read it carefully. It explains and governs:

• how and when we collect your personal data, and what information we collect;
• what we use your personal data for;
• who we share your personal data with;
• how long we hold your personal data for; and
• your rights to control your personal data.

By accessing and using our platform and services through our website, you are asked to confirm that you agree to be bound by this Privacy Policy so, if you do not, you must immediately cease use of our website and platform, and any services provided by us.

We will amend this Privacy Policy from time to time to comply with applicable laws and regulations or to meet our changing business requirements. You are encouraged to periodically review this page for the latest information on our privacy practices and amendments to our Privacy Policy.

2.    HOW AND WHEN DO WE COLLECT YOUR INFORMATION AND WHAT DO WE COLLECT

When you visit the website, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the website, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the website, and information about how you interact with the website. We refer to this automatically-collected information as “Device Information.”

We collect Device Information using the following technologies:

• “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit allaboutcookies.org.
• “Log files” track actions occurring on the website, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
• “Web beacons,” “tags,” and “pixels” are electronic files used to record information about how you browse the website.

Additionally when you make a purchase or attempt to make a purchase through the website, we collect certain information from you, including your name, surname, billing address, shipping address, payment information (including credit card numbers and any other payment types accepted such us Paypal), email address, and phone number. We refer to this information as “Order Information.”  

When we talk about “Personal Information” in this Privacy Policy, it includes Device Information and Order Information.

If you engage with us in any way, we may collect the following information about you through the methods of contact you choose to use at the point of engagement:

• information you provide through our website, including Order Information;
• information you provide through communications with us, whether in writing (including by letter or email) or on the telephone;
• information we obtain through your engagement with us on social media, including on blogs, forums and through Facebook, Instagram and Twitter; and
• information provided on your behalf by your representatives or agents (“Agents”) who engage with us on your behalf in the ways described above.

From time to time we obtain information from outside sources to help us carry out our business functions. This information, which often contains personal data, includes:

• information and reports from credit reference agencies, fraud prevention agencies, insolvency practitioners, debt advisers and tracing agents;
• commercial databases and marketing databases; and
• public records and other publicly available information sources.

If you wish to become a member of our platform you will need to provide us with the following information, which we sometimes also collect from third parties:

• your personal details (including Order Information);
• your contact information (including phone and e-mail details);
• financial information (including bank or building society account details and details of debit cards used to make transfers on the Aimée Ann Lou website / platform;
• information you provide in our registration or application process;
• information you provide in your dealings with us and through your interaction with our website / platform;
• if you are a company or a director, partner, member, shareholder, beneficial owner or guarantor of a company:

• information about your business or company, such as previous credit applications and the conduct of your accounts, and similar personal credit information;
• credit reference checks (see section 6 below for more detail);
• electoral register information;
• fraud prevention information; and
• passwords and answers to security questions.

In addition to the personal and financial information you submit or we collect as described above, we will also collect information about your computer (including, where available, your IP address, operating system and browser type), your interaction with our platform and website, and email performance data.

We also collect and retain:

• copies of our correspondence with you as well as other data we collect relating to your activities on the website / platform and your arrangements with Aimée Ann Lou;
• details about visitors to our website for the purposes of aggregating statistics or reporting purposes and to calculate referral fees (if applicable); and
• comments made on blogs and discussion forums in connection with the website / platform.

We generally do not seek to collect sensitive personal data (also known as ‘special categories of data’).

If you provide information about other people (for example, if you represent a company and you provide information about directors, partners, members, shareholders or beneficial owners other than yourself) then you must:

• provide a copy of this Privacy Policy to those persons and ensure that they are aware of and understand its contents; and
• when providing information about other people, ensure that you have all relevant permissions and authority: (i) to make all those disclosures; (ii) to act on their behalf; and (iii) in relation to partners, members, shareholders or beneficial owners of companies, to allow us to make credit checks at credit reference agencies in respect of those persons.

3.    USING YOUR INFORMATION

We collect, store and use your personal data:

• to fulfill any orders placed through the website (including processing your payment information, arranging for shipping and providing you with invoices and/or order confirmations);
• to inform you of website / platform developments and activity and of changes to our products and services;
• to develop and improve our services, products and business, including analysing and improving our customer service offering;
• if you are a company (or a director, partner, member, shareholder, beneficial owner or guarantor of a company):

• to ascertain your needs; and
• if you miss any repayment of your invoices, to trace your whereabouts and recover debts or enforce an invoice and to verify any payment plan you have proposed or income and expenditure form you have submitted;

• to transfer money;
• to carry out mandatory or other regulatory checks;
• to comply with our legal and regulatory obligations;
• to carry out statistical analysis and market research and testing;
• to contact you (including by SMS and e-mail) with products and services which Aimée Ann Lou think may interest you (at all times taking into consideration your rights at law including your right to opt-out from receiving marketing from us);
• for targeted advertising through digital platforms, social media and television (this may entail profiling, data enrichment and audience segmentation);
• to open membership accounts with us and to manage and maintain those membership accounts;
• to verify your identity and the other information you have provided to us, including your bank account information and (if relevant) the identity of your business associates;
• to update the records we hold about you from time to time;
• to provide and administer the marketplace and our related services; and
• for the prevention and detection of fraud, money laundering, or other illegal or criminal activity.

Where relevant, we will hold and process your sensitive personal data to allow us to make decisions about you and your accounts with us or with which you are connected. This may involve us sharing your sensitive personal data with your Agents. We will process sensitive personal data only in accordance with our legal rights and obligations. If this processing is carried out with your consent, at the point of collection you will be informed of your right to withdraw that consent at any time, and the process for doing so.

We continually review the legal basis for us using your personal data in the ways described above. In most instances it is in our legitimate interests to use your information in the manner described above to provide you with the services we offer as an online platform. We consider this data processing to be proportionate and not prejudicial or detrimental to you. In some, specific circumstances, the processing is necessary for the performance of a contract to which you are a party, necessary for compliance with a legal obligation to which we are subject, or necessary in order to protect your vital interests or the vital interests of other customers. We sometimes rely on consent, and in those instances we have processes in place to ensure that we obtain your freely-given and informed consent to use your personal data for agreed, specific purposes.

We use the information we collect about your computer for: (i) our legitimate purposes; (ii) marketing; platform administration; and (iii) service improvement.

4.    SHARING AND DISCLOSING YOUR INFORMATION

We may disclose your personal data to other registered members of our website / platform, including:

• to provide transactional and performance information;
• to provide updates; and
• if required to enforce (or make preparations to enforce) any invoice or debt that remains unpaid.

If you, as a registered member of our platform, receive information about another registered member, then you must only use that information to communicate with us about your contract with that member. You acknowledge that we are not responsible for misuse of transactional or other information by other members but you must inform us promptly if you are the victim of any misuse of that information.

We may disclose your personal data:

• to companies in our group and our affiliates;
• to our suppliers, sub-contractors and third party data processors (including, if relevant, card payment and direct debit payment processors, marketing and data analytics service providers (for example, Google Analytics), collection agents, tracing agents, insolvency practitioners, professional advisers and persons who provide us with the following services from time to time: identification and fraud check; marketing; technology; platform support; and back-up and business continuity);
• with any third party you have asked us to share your personal data with, including social media sites if you have asked us to connect with your social media account;
• to credit reference and fraud prevention agencies (see sections 7 and 8 below for more information on this);
• to a third party if it acquires all or part of our business or assets in connection with the acquisition, or to a successor in interest in the unlikely event of our insolvency, winding up or liquidation;
• if we are required to do so by applicable law and regulation or by any governmental, tax, regulatory body or law enforcement agency;
• if you are represented by an Agent, to your Agent; and
• to any other person with your prior consent to do so.

We may use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s educational page at networkadvertising.org/understanding-online-advertising/how-does-it-work. You can opt out of targeting advertising by visiting: https://about.ads.microsoft.com/en-us/resources/policies/personalized-ads or by visiting the Digital Advertising Alliance’s opt-out portal. 

Third parties who process your personal data on our behalf are only permitted to process your personal data in accordance with our instructions and we take steps to ensure that the transfer and any on-going processing by those third parties is carried out securely and in accordance with applicable privacy laws.

Save as expressly provided above, or otherwise without your consent, we will not share your personal data with any third party.

5.    DATA RETENTION

We will not keep your personal data for longer than is necessary for the purposes for which it was collected and is processed and for the purposes of satisfying our legal, accounting or regulatory reporting requirements. These requirements generally permit us to retain our customer files for a period of six years after the end of the relationship (i.e. the date on which we no longer provide services to you as a customer). We may retain data for longer than this in certain circumstances, for example in the event of an ongoing dispute.

6.    OVERSEAS TRANSFERS

In order to support our business in the most efficient manner possible, we share infrastructure and functions across our business internationally. This means that we may transfer your personal data to, or your personal data may be accessible in, any location in which we do business, or in which our directors, shareholders, or affiliates reside. If your information is transferred to or accessible in a country which is not considered by the European Union to adequately protect personal data (such as the USA), we will always take steps to ensure that your information is protected and that those transfers comply with applicable privacy laws.

We may transfer your information to other countries, including those outside the European Economic Area, either for storage purposes or if we engage suppliers, sub-contractors or third party data processors who are based or have operations overseas. We will always take steps to ensure that your information is protected and that those transfers comply with applicable privacy laws.

7.    CREDIT REFERENCE AGENCIES (“CRAs”)

From time to time we may undertake credit reference checks against customers (and against directors, partners, members, shareholders and beneficial owners of companies) and Agents:

• as part of the application process, if applicable, to assess creditworthiness and product suitability;
• for general credit management, account management and identity/know-your-customer (KYC) checks during the term of our relationship;
• to trace and recover debts if there are late repayments or default; and
• to prevent criminal activity.

In order to do this, we will supply your personal information to CRAs and they will give us information about you, such as about your financial history. We may request the following from CRAs:

• Enquiry against the credit file of the individual or company (enquiries are not visible to other organisations);
• Commercial Credit Report relating to the credit file of a company, whether or not your application for membership is successful (this type of request for information may be visible to other organisations);
• Quotation Search against the personal credit file of the directors, partners, members, beneficial owners and shareholders of any business customer (a Quotation Search is not visible to other organisations); and
• Consumer Credit Search against the personal credit file of any customer, or the directors, partners, members, beneficial owners and shareholders of a company (this type of request for information may be visible to other organisations).

When CRAs receive a request for information from us they may:

• link together the previous and subsequent names advised by you of anyone that is a party to the account; and
• create a record of the name and address (if there is not one already).

We will give details of all purchases taken through our website / platform and how they are managed to the CRAs. If you purchase and do not repay in full and on time, the CRAs will record the outstanding debt and, in some cases, the length of time that the debt remains outstanding; other organisations may see these updates and this affect your ability to obtain credit in the future.

We will also continue to exchange information about you with CRAs on an ongoing basis about your settled accounts and any debts not fully repaid on time. CRAs will share this information with other organisations.

Any records shared with CRAs will remain on file for six years after your account is closed, whether any outstanding sums have been settled by you or following a default. You can contact the CRAs currently operating in the UK. The information they hold may not be the same so you may consider contacting them all. They will charge you a small statutory fee.

The identities of the CRAs, and the ways in which they use and share personal information, are explained in more detail at:

• TransUnion Credit Reference Agency Notice (TransUnion CRAIN)
• Equifax Credit Reference Agency Notice (Equifax CRAIN); and
• Experian Credit Reference Agency Notice (Experian CRAIN).

8.    FALSE INFORMATION AND FRAUD PREVENTION AGENCIES (“FPAs”)

If we suspect or identify fraud we may record this and may also pass this information to FPAs (such as CIFAS) and other organisations involved in crime and fraud prevention including law enforcement agencies. We and fraud prevention agencies may also enable law enforcement agencies to access and use your personal data to detect, investigate and prevent crime.

We and fraud prevention agencies process your personal data on the basis that we have a legitimate interest in preventing fraud and money laundering, and to verify your identity in order to comply with our legal and regulatory obligations and to protect us and users of our platform and services.

We and other organisations may access and use this information in order to prevent fraud, money laundering or other criminal activity. We also use FPAs to screen job applicants and employees.

Fraud prevention agencies can hold your personal data for different periods of time, and if you are considered to pose a fraud or money laundering risk, your data can be held for up to six years.

If we, or a fraud prevention agency, determine that you pose a fraud or money laundering risk, we may refuse to provide the services you have requested, or we may stop providing existing services to you.

A record of any fraud or money laundering risk will be retained by the fraud prevention agencies, and may result in others refusing to provide services, financing or employment to you.

Whenever fraud prevention agencies transfer your personal data outside the European Economic Area, they impose contractual obligations on the recipients of that data to protect your personal data to the standard required in the European Economic Area. They may also require the recipient to subscribe to “international frameworks” intended to enable data sharing.

9.    YOUR RIGHTS

You may, at any time:

• exercise your right to request access to certain personal data records we hold about you (a subject access request), by emailing assistance@aimeeannlou.com with the subject line “subject access request”;
• request that we update and correct any out-of-date or inaccurate personal data we hold about you by emailing us at assistance@aimeeannlou.com with the subject line “data update request”, and also log-in to your Aimée Ann Lou account and make changes yourself;
• contact us to register your preferences for how we contact you at assistance@aimeeannlou.com;
• opt out of any marketing communications that Aimée Ann Lou may send you by emailing us at assistance@aimeeannlou.com, or by following the link on any email marketing you have received or by following the appropriate opt-out procedures that we include on all marketing materials; and
• exercise your right to object to our continued processing or your right of erasure, neither of which is a guaranteed or absolute right. We will consider all requests of this nature and take into account any compelling legitimate grounds to continue processing, for example our need to continue to process your personal data in connection with any legal or regulatory requirements to which we are subject.

When you contact us, we will need you to provide us with adequate information to identify yourself to enable us to assist you in fulfilling your request. We will deal with your request as soon as possible.

You may also request that the CRAs we use provide you with information that they hold about you. You must contact them directly to do this.

10.   SECURITY AND OTHER THIRD PARTIES

Aimée Ann Lou takes appropriate technical and organisational measures to safeguard the personal data that you provide to us, but we accept no liability if communications are intercepted by third parties or incorrectly delivered or not delivered.

If we transfer your information to third parties, we will take steps to ensure that the transfer and any on-going processing by those third parties is carried out securely and in accordance with applicable privacy laws.

The website and marketplace contain links to other websites operated by third parties. This Privacy Policy applies only to the personal data that Aimée Ann Lou collects and we are not responsible for personal data that third parties may collect, store and use through other websites.

You also have a responsibility to ensure that your information is kept secure. If you are a member of our platform, you must:

• keep your login details secret;
• log out of your account when not using it;
• maintain good internet security (for example, be careful when using public Wi-Fi or shared access internet connections); and
• tell us immediately if you think your account has been compromised.

11. CONTACT DETAILS

If you have any questions or concerns about this Privacy Policy, how we process your personal data, or if you wish to exercise any of your rights as a data subject, you can contact us at assistance@aimeeannlou.com.

If you have concerns about how we manage your personal data, you can make a complaint to the UK Data Protection Authority, the Information Commissioner’s Office. You can find their contact details here: https://ico.org.uk/global/contact-us/.

12.   ABOUT AIMÉE ANN LOU

Aimée Ann Lou Limited is a company incorporated in England and Wales, with registered number 13097641 and registered office at 21 Ellis Street, Knightsbridge, London, SW1X 9AL.