Protecting your privacy
Shimitu Ltd
Contents of this Privacy Notice
1. Introduction.
2. Who is Shimitu Ltd?
3. Explaining the legal bases we rely on.
4. When do we collect your personal data?
5. What sort of personal data do we collect?
6. How and why do we use your personal data?
7. Combining your data for personalised direct marketing.
8. How we protect your personal data?
9. How long will we keep your personal data?
10. Who do we share your personal data with?
11. Where your personal data may be processed?
12. What are your rights over your personal data?
13. How can you stop the use of your personal data for direct marketing?
14. If you live outside the UK.
15. Any questions?
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1. Introduction
This Privacy Notice 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 know that there’s a lot of information here, but we want you to be fully informed about your rights, and how Shimitu Ltd uses your data.
We hope the following sections will answer any questions you have but if not, please do get in touch with us.
It’s likely that we’ll need to update this Privacy Notice from time to time. We’ll notify you of any significant changes via email, but you’re welcome to come back and check it whenever you wish.
When you are using the Shimitu websites, Shimitu Ltd is the data controller. Shimitu Ltd is a UK based company and therefore, when visiting our website, personal data that we may collect through cookies or online forms will leave the EU for the UK.
2. Who is Shimitu Ltd?
● Shimitu Ltd – The main company
● Shimitu Music
● ShimiCard
For simplicity throughout this notice, ‘we’ and ‘us’ means Shimitu Ltd and its brands.
3. Explaining the legal bases we rely on
The law on data protection sets out several different reasons for which a company may collect and process your personal data, including:
Consent
In specific situations, we can collect and process your data with your consent.
For example, when you tick a box to receive email newsletters.
When collecting your personal data, we’ll always make clear which data is necessary in connection with a particular service.
Contractual obligations
In certain circumstances, we need your personal data to comply with our contractual obligations.
For example, if you order an item from us for home delivery, we’ll collect your
address details to deliver your purchase and pass them to our courier.
Legal compliance
If the law requires us to, we may need to collect and process your data.
For example, we can pass on details of people involved in fraud or other criminal activity affecting us to law enforcement.
Legitimate interest
In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business, and which does not materially impact your rights, freedom or interests.
For example, we will use your purchase history to send you or make available personalised offers.
We also combine the shopping history of many customers to identify trends and ensure we can keep up with demand or develop new products/services.
We may also use your address details to send you direct marketing information by post, telling you about products and services that we think might interest you.
4. When do we collect your personal data?
● When you visit any of our websites, and use your account to buy products and services, or redeem vouchers on the phone or online.
● When you make an online purchase and check out as a guest (in which case we just collect transaction-based data).
● When you create an account with us.
● When you purchase a product or service in store or by phone but don’t have (or don’t use) an account.
● When you engage with us on social media.
● When you contact us by any means with queries, complaints etc.
● When you ask one of our Partners to email you information about a product or service.
● When you enter prize draws or competitions.
● When you book any kind of appointment with us or book to attend an event.
● When you’ve given a third-party permission to share with us the information they hold about you.
5. What sort of personal data do we collect?
● If you have a web account with us: your name, gender, date of birth, billing/delivery address, orders and receipts, email and telephone number. For your security, we’ll also keep an encrypted record of your login password.
● Details of your interactions with us.
For example, we collect notes from our conversations with you, details of any complaints or comments you make, details of purchases you made, items viewed or added to your basket, gift list and wish list choices, voucher redemptions, bands you show interest in, web pages you visit and how and when you contact us.
● Copies of documents you provide to prove your age or identity where the law requires this. (including your passport and driver's licence). This will include details of your full name, address, date of birth and facial image. If you provide a passport, the data will also include your place of birth, gender and nationality.
● Details of your visits to our websites or apps, and which site you came from to ours.
● Information gathered using cookies in your web browser. Learn more about how we use cookies and similar technologies.
● Personal details which help us to recommend items of interest.
We’ll only ask for and use your personal data collected for recommending items of interest and to tailor your shopping experience with us. Of course, it’s always your choice whether you share such details with us.
● Payment card information.
● Your comments and product reviews.
● To deliver the best possible web experience, we collect technical information about your internet connection and browser as well as the country and telephone code where your computer is located, the web pages viewed during your visit, the advertisements you clicked on, and any search terms you entered.
● Your social media username, if you interact with us through those channels, to help us respond to your comments, questions or feedback.
6. How and why do we use your personal data?
We want to give you the best possible customer experience. One way to achieve that is to get the richest picture we can of who you are by combining the data we have about you.
We then use this to offer you promotions, products and services that are most likely to interest you. In the case of loyalty scheme members, we’ll also offer you relevant rewards.
The data privacy law allows this as part of our legitimate interest in understanding our customers and providing the highest levels of service.
Of course, if you wish to change how we use your data, you’ll find details in the ‘What are my rights?’ section below.
Remember, if you choose not to share your personal data with us, or refuse certain contact permissions, we might not be able to provide some services you’ve asked for.
For example, if you’ve asked us to let you know when an item comes back into stock, we can’t do that if you’ve withdrawn your general consent to hear from us.
Here’s how we’ll use your personal data and why:
● To process any orders that you make by using our websites, apps or by phone. If we don’t collect your personal data during checkout, we won’t be able to process your order and comply with our 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 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 sent 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 based on 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 protect our business and your account from fraud and other illegal activities. This includes using your personal data to maintain, update and safeguard your account. We’ll also monitor your browsing activity with us to quickly identify and resolve any problems and protect the integrity of our websites. We’ll do all of this as part of our legitimate interest.
For example, by checking your password when you login and using automated monitoring of IP addresses to identify possible fraudulent logins from unexpected locations.
● To process payments and to prevent fraudulent transactions. We do this based on our legitimate business interests. This also helps to protect our customers from fraud.
● If we discover any criminal activity or alleged criminal activity through our use
of fraud monitoring and suspicious transaction monitoring, we will process this data for the purposes of preventing or detecting unlawful acts. We aim to protect the individuals we interact with from criminal activities.
● With your consent, we will use your personal data, preferences and details of your transactions to keep you informed by email, web, text, telephone and through our contact centres about relevant products and services including tailored special offers, discounts, promotions, events, competitions and so on. This is only applicable within the UK.
Of course, you are free to opt out of hearing from us at any time.
● To send you communications required by law, or which are necessary to inform you about our changes to the services we provide you. For example, updates to this Privacy Notice, product recall notices, and legally required information relating to your orders. These service messages will not include any promotional content and do not require prior consent when sent by email or text message. If we do not use your personal data for these purposes, we would be unable to comply with our legal obligations.
● To display the most interesting content to you on our websites or apps, we’ll use data we hold about your favourite bands or products and so on. We do so based on your consent to receive app notifications and / or for our website to place cookies or similar technology on your device.
For example, we might display a list of items you’ve recently looked at or offer you recommendations based on your purchase history and any other data you’ve shared with us.
● To administer any of our prize draws or competitions which you enter, based on your consent given at the time of entering.
● To develop, test and improve the systems, services and products we provide to you. We’ll do this based on our legitimate business interests.
For example, we’ll record your browser’s Session ID to help us understand more when you leave us online feedback about any problems you’re having.
● 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 or services more relevant to you.
● To process your booking/appointment requests.
Sometimes, we’ll need to share your details with a third party who is providing a service (such as delivery couriers). We do so to maintain our appointment with you. Without sharing your personal data, we’d be unable to fulfil your request.
7. Combining your data for personalised direct marketing
We want to bring you offers and promotions that are most relevant to your interests at times. To help us form a better, overall understanding of you as a customer, we combine your personal data gathered across our websites as described above.
8. How we protect your personal data
We know how much data security matters to all our customers. We will treat your data with the utmost care and take all appropriate steps to protect it.
We secure access to all transactional areas of our websites and apps using ‘https’ technology.
Access to your personal data is password-protected, and sensitive data such as payment card information is secured and encrypted to ensure it is protected.
We regularly monitor our system for possible vulnerabilities and attacks, and we carry out penetration testing to identify ways to further strengthen security.
9. How long will we keep your personal data?
Whenever we collect or process your personal data, we’ll only keep it for as long as is necessary for the purpose for which it was collected.
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. Who do we share your personal data with?
We sometimes share your personal data with trusted third parties.
For example, delivery couriers, for fraud management, to handle complaints and to help us personalise our offers to you and so on.
Here’s the policy we apply to those organisations to keep your data safe and protect your privacy:
● We provide only the information they need to perform their specific services.
● They may only use your data for the exact purposes we specify in our contract with them.
● We work closely with them to ensure that your privacy is respected and always protected.
● If we stop using their services, any of your data held by them will either be deleted or rendered anonymous.
Examples of the kind of third parties we work with are:
● IT companies who support our website and other business systems.
● Operational companies such as delivery couriers to contact you about your order delivery and occasionally service review messages.
Sharing your data with third parties for their own purposes:
We will only do this in very specific circumstances, for example:
● With your consent, given at the time you supply your personal data, we may pass that data to a third party for their purposes.
● For fraud management, we may share information about fraudulent or potentially fraudulent activity. This may include sharing data about individuals with law enforcement bodies.
● We may also be required to disclose your personal data to the police or other enforcement, regulatory or Government body, in your country of origin or elsewhere, upon a valid request to do so. These requests are assessed on a case-by-case basis and take the privacy of our customers into consideration.
11. Where your personal data may be processed
Shimitu is a UK based company and so we will transfer your data to the UK, which is outside of the EU. We also have offices in other countries so we may transfer your data to other countries (for example the USA). We may also need to share your personal data with third parties and suppliers outside the European Economic Area (EEA)
Protecting your data outside the UK
The EEA includes all EU Member countries as well as Iceland, Liechtenstein and Norway.
We may transfer personal data that we collect from you to third-party data processors in countries that are outside the UK.
For example, this might be required to fulfil your order, process your payment details or provide support services.
If we do this, we have procedures in place to ensure your data receives the same protection as if it were being processed in the UK. For example, our contracts with third parties stipulate the standards they must always follow. If you wish for more information about this, please contact our Data Protection Officer.
Any transfer of your personal data will follow applicable laws and we will treat the information under the guiding principles of this Privacy Notice.
12. What are your rights over your personal data?
An overview of your different rights
You have the right to request:
● Access to the personal data we hold about you, free of charge in most cases.
● The correction of your personal data when incorrect, out of date or incomplete.
● The deletion of the data we hold about you, in specific circumstances. For example, when you withdraw consent, or object and we have no legitimate overriding interest, or once the purpose for which we hold the data has come to an end.
● Restriction of the use of your personal data, in specific circumstances, generally whilst we are deciding on an objection you have made.
● That we stop processing your personal data, in specific circumstances. For example, when you have withdrawn consent, or object for reasons related to your individual circumstances.
● That we stop using your personal data for direct marketing (either through specific channels, or all channels).
● That we stop any consent-based processing of your personal data after you withdraw that consent.
Your right to withdraw consent.
Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent.
Where we rely on our legitimate interest
In cases where we are processing your personal data based on 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.
Direct marketing
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.
Checking your identity
To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Notice.
If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.
13. How can you stop the use of your personal data for direct marketing?
There are several ways you can stop direct marketing communications from us:
● Click the ‘unsubscribe’ link in any email communication that we send you. We
will then stop any further emails from that division.
● If you have an account, log in into your account, visit and change your preferences.
14. If you live outside the UK
For all non-UK customers
This Privacy Notice shall be provided in English only.
When placing an order with the us, browsing our website, including for analytics and website usage research, and/or agreeing to receive direct marketing electronic communications as described in this Privacy Notice and our Cookies.
Notice, your personal data will be processed by us or on our behalf. Of course, you still have the right to ask us not to process your data in these ways, and if you do so, we will respect your wishes.
Sometimes we will need to transfer your personal data between countries to enable us to supply the goods or services you have requested. In the ordinary course of business, we will transfer your personal data to the UK and may also transfer your personal data to third parties located in the UK to your country of residence.
We shall endeavour to ensure that reasonable steps are taken to procure that all such third parties outside of your country of residence shall not use your personal data other than for the services they provide and for which they need the personal data, and to adequately protect the confidentiality and privacy of your personal data.
We will ensure that any third parties only process your personal data in accordance with their legitimate interests. These third parties may be subject to laws that differ from the laws which apply in the country where you reside. We do not actively take steps to ensure that any overseas recipient of your personal data complies with the laws which apply in your country.
If you have any questions, please contact our Data Protection Officer, and we will respond within your local timeframe response requirements. To complain about an alleged breach of this Privacy Notice or our privacy obligations at law, please provide us with as much detail as possible in relation to your complaint. We will take any privacy complaint seriously and any complaint will be assessed with the aim of resolving any issue in a timely and efficient manner.
15. Any questions?
We hope this Privacy Notice has been helpful in setting out the way we handle your personal data and your rights to control it.
If you have any questions that haven’t been covered, please contact our Data Protection Officer who will be pleased to help you:
Email us on DataProtect@shimitu.com
This notice was last updated on June 1st, 2024.