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Who are we? 

The data controller who processes and has responsibility for your personal data is Finlay & Co. Ltd  of 61 Broadwick Street, Soho, London, W1F 9QT  (collectively referred to as: “Company”, “We”, “Us” or “Our” in this Policy). 

By visiting our website and sharing personal data with us, you accept and consent to the provisions of this Privacy Policy. If you live in the European Economic Area or you are a EU citizen, you can contact the Information commissioner’s office at any stage with a complaint. We would ask you to get in touch with us first in case any query can be resolved by us initially. Personal data that we store or process about you is managed in compliance with the European General Data Protection Regulation - Regulation (EU) 2016/679 - GDPR.


What information is collected? 

When you create an account with us, you will provide a name, email address, and password. If you make a purchase, we request information from you to facilitate the transaction and deliver the products to you. You may also provide us with information when you book an eye test online or visit us in-store. This information may include your name, email address, phone number, home address, date of birth and eye test prescription information - including previous prescriptions, medical history and information about your vision. 

For virtual try on function on the website, we may ask you to submit (or we may ask your permission to take) a photo, facial scan, or other image of you.

As you make a purchase, we ask you to provide payment information, which may include payment card information such as credit card number and expiration date, billing address and shipping address. Our payment processor, which is required by credit card issuers to meet specific security requirements, will collect, store, and process your credit card and other payment information on our behalf using industry-standard security measures. We do not store any payment card information.

We automatically collect web logs and usage information. We record certain information and store it in log files when you interact with us. This information may include device and browser information, internet protocol address, URLs of referring, landing and exit pages, and search terms or phrases. 

Like most websites, our processes may include technology such as pixel tags and cookies that enable us and our service providers to collect information about your behaviour and interactions whilst on the website.. Cookies are small files that web servers may place on your computer when you visit a website. For example, cookie-related techniques are the use of fingerprints and scripts such as Google Analytics. Cookies allow personal data to be stored or consulted so that you can be recognised if you visit the website again. You may be able to set your web browser to reject cookies entirely or require that it request permission before accepting new cookies. You can delete cookies from your web browser once you leave a website. 

We may also collect information about you if you visit our stores. Like most retailers, we have in-store video surveillance for security, fraud, and loss prevention purposes. 


How we collect your information 

We collect information about individuals in various ways. We receive information about you when you create an account, purchase products or services from Finlay or subscribe to our mailing list. By filling in forms or by corresponding with us by post, phone, email or other means, you may be communicating your identity, contact details and financial information. When you visit our website, we may automatically collect data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may receive personal data about you from various third parties including Google Analytics and others. We work with Verisure Services Limited who provide our instore CCTV monitoring service.


How we use your information 

We typically use your information to provide and enhance our services and the experience for you. Here are some of the ways we may use your information:

  • to provide, personalise, and improve our products and service
  • to facilitate the sale and delivery of your purchases and home try-on
  • to confirm, reschedule, or provide other services related to eye tests
  • to communicate with you and to send you updates about your order
  • to provide information and recommendations about our products and services
  • for our other internal business purposes

We may use your prescription information to determine the vision correction that you need.

Location. We may use location information collected from your mobile device to enhance your shopping experience and to provide you with location-based services, such as advertising, search results, and other personalized content, as well as to assist us with foot traffic measurement and service improvements in our stores.

When you submit (or grant us permission to take) a photo, facial scan, or other image of you, we don’t share those photos, scans, or images, or any facial data captured in the facial scans, with any third parties, but we may use them as described below:

  • to measure your pupillary distance and gather other optical information
  • to map and measure your facial features
  • to address certain problems or concerns you may have with your glasses
  • to help better understand how our frames fit our customers and provide frame recommendations

How we share your information 

We may provide your information to our contractors and service providers as necessary to enable them to perform certain services for us, including but not limited to: order fulfillment, delivery services, payment processing, marketing services and data analytics.

Our third-party advertising partners may use cookies to collect information about your online activities on our services and across other online services in order to deliver more relevant advertising. One of the third party services that we use to track your activity on our Services is Google Analytics. If you do not want Google Analytics to collect and use information about your use of our Services, then you can install an opt-out in your web browser  - https://tools.google.com/dlpage/gaoptout. You also may opt-out from Google Analytics for Display Advertising or the Google Display Network by using Google’s Ads Settings located at https://www.google.com/settings/ads.


Access to your information and your choices  

We may use the information we hold about you to help inform what we think you may be interested to receive from us. This is partly how we decide which products, services and offers will be communicated with you. We may also share your personal data with the third parties and logistics partners such as DHL and Shipbob for delivery purposes. 

If you engage, or we reasonably suspect that you are engaging in any illegal activity, we may disclose your personal information, to the extent we determine in our sole discretion is necessary to cooperate with appropriate authorities. 

If you decide you don’t want to receive marketing emails from us, you can opt out of marketing emails in your account settings, click the “Unsubscribe” link in our emails. Where you opt out of receiving these marketing communications, this will not apply to personal data provided to us as a result of a product/service purchase. 

 

Protecting your information 

Any personal information we collect, store or process is considered confidential. We therefore take appropriate measures to protect personal data against any accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access or against any other unlawful or unauthorised processing of such personal data. These measures guarantee an appropriate level of security given the risks related to processing and the nature of the data.

At any time, you can make a reasonable request to access any personal data that we store about you. Please contact us through our customer care team on email. You can also ask us to make changes if data we hold about you is incorrect. You can withdraw consent for us to hold your information at any stage, although this can result in a prevention for us to provide goods and services effectively to you. Any requests for access to information can take up to a month to respond to. We retain information from sight tests undertaken for 10 years as per instruction from the College of Optometrists.


Use by minors 

We don’t intentionally collect information about children, however, we will store sight test information of customers under 18 years of age if they have had a sight test with us in store.


Regional variations 

Under law for the US state of California, customers who are residents of California may request certain information about our disclosure of personal information during the prior calendar year to third parties for their direct marketing purposes. If you would like to get in touch, please contact our customer care team.


Changes to this Policy 

Our Privacy Policy might be revised occasionally with revised Privacy Policies being published on our website, where the most up-to-date version is available. We recommend checking our website and the privacy policy on a regular basis. If we make a material change that would reduce your rights, we will either honour our prior privacy policy or request for your consent to the change. The last revision was made in July 2020.


Contact Us 

If you have questions about this Privacy Policy or updating your information, please contact us at care@finlayandco.com