Last updated 10 March 2020
This policy (Policy) relates to your personal information in connection with your use of and access to the LBD Platform (as defined in the Terms)
We are committed to protecting your Information and your right to privacy. Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where information about your identity has been removed (anonymous data). If you have any questions or concerns about this Policy, or our practices with regards to your personal information, please contact us at [email protected]
When you use the LBD Platform, you trust us with your Information. We take your privacy very seriously. We seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this Policy that you do not agree with, please discontinue use of the LBD Platform.
Any capitalised terms that are not defined in this Policy are set out in our Terms.
Changes to this Policy or your personal information
We review this Policy regularly and it is your responsibility to check regularly and determine whether this Policy has changed. If you do not agree to any change to this Policy then you must immediately stop using the LBD Platform. In the event we make any significant changes to this Policy we will use our best endeavours to inform you or such changes in advance in writing.
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes for example you change your email address.
The LBD Platform are owned and operated by Fashion on the Block Limited (trading as “LBD”) a company registered in England and Wales with company number 11724731 and whose registered office is situated at 18 Fairyfield Avenue, Birmingham, United Kingdom, B43 6AG (LBD/we/us/our). LBD is the controller (also known as a data controller) and is responsible for your personal information. The term “you” refers to the user wishing to access and/or use the LBD Platform.
The LBD Platform provides a platform for you to upload and view your clothes wardrobe, share it with friends and the potential to buy and sell to or from other Members of the LBD Platform.
Information we may collect about you
Personal information you disclose to us
In Short: We collect personal information that you provide to us including information such as name, address, contact information, clothes sizing and payment card information.
We collect personal information that you voluntarily provide to us when registering to use the LBD Platform, or otherwise contacting us. The personal information that we collect depends on the context of your interactions, the choices you make and the products and features you use. When you use the LBD Platform and/or when you otherwise deal with us, we may collect the following information about you (the Information):
- Identity and Personal Data includes first name, last name, date of birth, clothes and shoe sizing, body measurements, style preferences, photographs, personal characteristics and gender.
- Contact Data means the data we use to contact you including your billing address, delivery address, work address, email address and contact numbers.
- Purchasing History means any shopping receipts which you upload to the LBD Platform (e.g. Harrods).
- Financial Data means any bank details or payment card information that you provide us. [We do not store or process your bank or card details ourselves, they are processed and stored via one of our contracted third-party service providers. We encrypt your Financial Data and securely transfer this data to our relevant third-party payment provider to process any payments.]
- Transaction Data means details about any transactions you have made in connection with the LBD Platform including the payments to and from you along with other details of Items you have purchased or sold through the LBD Platform.
- Profile Data includes your username, email address, your login data, orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use the LBD Platform. This includes your browsing patterns and information such as how long you might spend on one of our webpages on the LBD Platform and what you Items look at and for, the page that referred you to the LBD Platform and the click stream during your visit to our website, page response times and page interaction information (clicks you make on a page).
- Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
- [Social Media and Login Data. We provide you with the option to register using social media account details, like your Facebook, Twitter or other social media account. If you choose to register in this way, we will collect the Information described in the section called "How do we Handle your Social Logins" below. All Information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such Information.]
- Other information relevant to services, customer surveys and/or offers.
The LBD Platform and your Information
You are required to register as a Member and create an account and profile in order to make full use of the LBD Platform. Some of your profile information shall be visible to other Members when you interact with them including your name, gender, date of birth, telephone, email, body measurements, style preferences, billing address, delivery address and telephone number plus the contents of your Wardrobe. ]. Information which will be publicly available to Users on your profile will be your name, gender, location, rating and contents of any Wardrobe which you have shared.
Listings that are publicly visible will show any information relating to the listing (e.g. description, Item availability, Member profile picture and first name). Any content submitted by you to a public forum or social media platform may be visible to Users.
If you choose to access the LBD Platform from a shared computer or open wifi connection, we strongly recommend logging off and removing cookies and the history of the websites visited once you’ve finished.
Information automatically collected
In Short: Some information – such as IP address and/or browser and device characteristics – is collected automatically when you use the LBD Platform.
We automatically collect certain information when you visit, use or navigate the LBD Platform. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use the LBD Platform and other technical information. This information is primarily needed to maintain the security and operation of the LBD Platform, and for our internal analytics and reporting purposes. Most devices allow you to manage the use of location services through your settings menu. If you would prefer not to share your location, please disable use through your device directly.
Like many businesses, we also collect information through cookies and similar technologies. You can find out more about this in our Cookies Policy.
How do we use your Information?
In Short: We process your Information for purposes based on legitimate business interests, the fulfilment of our contract with you, compliance with our legal obligations, and/or your consent.
We use your Information collected via the LBD Platform for a variety of business purposes described below. We process your Information for these purposes in reliance on our legitimate business interests (Business Purposes), in order to enter into or perform a contract with you (Contractual), with your consent (Consent), and/or for compliance with our legal obligations (Legal Obligations). We indicate the specific processing grounds we rely on next to each purpose listed below.
We may process your Information for the following purposes:
- Fulfil and manage any orders in connection with the LBD Platform and administer and manager your account (Contractual). We may use your Information or pass it onto other Members in order to enable the services you have requested through the LBD Platform including the sale of Items.
- To send administrative information to you for Business Purposes, Legal Obligations and/or possibly Contractual. We may use your Information to send you product, service and new feature information and/or information about changes to our Terms and policies.
- To send you marketing and promotional communications for Business Purposes and/or with your Consent. We and/or our third party partners may use your Information for our marketing purposes, if this is in accordance with your marketing preferences. You can opt-out of our marketing emails, see below for further details.
- To facilitate account creation and logon process with your Consent. [If you choose to link your account with us to a third party account (such as your Google or Facebook account), we use the information you allowed us to collect from those third parties to facilitate account creation and logon process. See the section below headed " How do we Handle your Social Logins" for further information.]
- Administer promotions for our Business Purposes and/or with your Consent.
- Request Feedback for our Business Purposes and/or with your Consent. We may use your Information to request feedback and to contact you about your use of the LBD Platform.
- To protect the LBD Platform for Business Purposes and/or Legal Obligations. We may use your Information as part of our efforts to keep the LBD Platform safe and secure (for example, for fraud monitoring and prevention). This includes reviewing, scanning or analysing communications between Members on the LBD Platform, either by automated or manual methods.
- To enforce our Terms and policies for Business Purposes, Legal Obligations and/or possibly Contractual.
- To respond to legal requests and prevent harm for Legal Obligations. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
- For other Business Purposes. We may use your Information for other Business Purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve the LBD Platform, products, services, marketing and your experience.
Always think carefully before disclosing your Information or other information to other Users or otherwise posting Information on the LBD Platform. It’s important that you’re aware that any data you choose to disclose on the LBD Platform may then be viewed and even used by other Users or Members. We do not control the contents of communications made between Users or Members (although you can make a complaint about a Member by contacting us using the information provided in the Contact section below).
You must respect the privacy of others and you must not disclose any personal details about other people including your family, friends, acquaintances, or other persons that may be misleading or cause them harm or offence. It is your responsibility to obtain their prior express permission in respect of any submission of their Information at any time.
Will your Information be shared with anyone?
In Short: We only share information to comply with Contractual obligations, fulfil our Business Purposes, or with your Consent.
We only share and disclose your Information in the following situations:
- Contractual: to share information with Members to enable usage of the LBD Platform including sale of Items or sharing your Wardrobe or Lookbook. You may select to make some of your Wardrobe and Lookbook information public or with other Members that you have selected [We will never share your billing or payment information with other Members.]
- Compliance with Legal Obligations. We may disclose your Information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
- Vital Interests. We may disclose your Information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
- Third-Party Service Providers. We may share your Information with third-party vendors, service providers, contractors or agents who perform services and require access to such information to do that work. Examples include: payment card providers, data analysis, email delivery, hosting services, customer service, search information providers, delivery services, analytic providers, credit reference agencies and marketing agencies. They will only have access to your Information to the extent that they need to perform those services. They are required to keep your Information confidential and may not use it other than as we ask them to and always in accordance with this Policy. The third parties we use include ViSenze, Pinterest, Shopify, Google Analytics, Instagram and Facebook. In some cases, the Information provided to us varies and is controlled by the specific service or as authorised by you via your privacy settings for that service. For more information on how these companies handle your personal data, please refer to their privacy policies.
- Business Transfers. We may share or transfer your Information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
- Business Partners. Provided you have given us Consent to do so we may share your Information with our business partners to offer you certain products, services or promotions.
- With your Consent. We may disclose your Information for any other purpose with your Consent.
We may disclose aggregated, anonymous information (i.e. information from which you cannot be personally identified), or insights based on such anonymous information, to selected third parties, including (without limitation) analytics and search engine providers to assist us in the improvement and optimisation of the LBD Platform. In such circumstances we do not disclose any information which can identify you personally.
Information collected from other Sources
In Short: We may collect limited data from public databases, marketing partners, social media platforms, and other outside sources.
We may obtain Information about you from other sources, such as public databases, joint marketing partners, social media platforms (such as Facebook), as well as from other third parties. Examples of the information we receive from other sources include: social media profile information (your name, due date, gender, birthday, email, current city, state and country, user identification numbers for your contacts, profile picture URL and any other information that you choose to make public); marketing leads and search results and links, including paid listings (such as sponsored links). The information provided to us varies and is controlled by the specific service or as authorised by you via your privacy settings for that service.
Is your Information transferred internationally?
In Short: We may transfer, store, and process your Information in countries other than your own but will take all reasonable steps to ensure it is protected.
Whenever we transfer your Information outside of the UK, we will take all reasonable measures that we can to protect your Information in accordance with this Policy and applicable law. To the extent that any transfer requires approved safeguards are in place (for example if transferring outside of the European Economic Area that the EU model contract clauses will be in place or if to the USA that the entity it is transferred to is EU/US Privacy Shield registered).
In Short: We are not responsible for the safety of any information that you share with third-party providers who feature or advertise, but are not affiliated with, the LBD Platform.
The LBD Platform features links to third-party websites or contain advertisements from third parties that are not affiliated with us and which may link to other websites, online services or mobile applications. We cannot guarantee the safety and privacy of data you provide to any third parties. Any data collected by third parties is not covered by this Policy. We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services or applications that may be linked to or from the LBD Platform. You should review the policies of such third parties and contact them directly to respond to your questions. Anything you share on the publicly available part of the LBD Platform will also be catalogued by third party search engines. We are not responsible for their use of your information or the accuracy of it.
How long do we keep your Information?
In Short: We keep your Information for as long as necessary to fulfil the purposes outlined in this Policy unless otherwise required by law.
We will only keep your Information for as long as it is necessary for the purposes set out in this Policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements).
When we have no ongoing Business Purpose to process your Information, we will either delete or anonymise it, or, if this is not possible (for example, because your Information has been stored in backup archives), then we will securely store your Information and isolate it from any further processing until deletion is possible.
How do we keep your Information safe?
In Short: We aim to protect your Information through a system of organisational and technical security measures.
We have implemented appropriate technical and organisational security measures designed to protect the security of any Information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your Information, transmission of Information to and from the LBD Platform is at your own risk. You should only access our services within a secure environment. All of your payment information is encrypted using SSL technology.
It is explicitly prohibited to use our Member-to-Member communication system to send content that violates our Terms or spam of any kind. We reserve the right to scan internal messages to check for spam, phishing, viruses and other malicious, prohibited or illegal behaviours or content. Please note, the messages sent through internal systems are not stored indefinitely and you must not rely on the storage of those messages.
[How do we handle your Social Logins?
In Short: If you choose to register or log in to our websites using a social media account, we may have access to certain Information about you.
The LBD Platform offers you the ability to register and login using your third party social media account details (like your Facebook or Twitter logins). Where you choose to do this, we will receive certain Information from your social media provider. The Information we receive may vary depending on the social media provider concerned, but will often include your name, e-mail address, friends list, profile picture as well as other information you choose to make public. If you login using Facebook, we may also request access to other permissions related to your account, such as friends, check-ins, and likes, and you may choose to grant or deny us access to each individual permission.The Information that you post, transmit, or otherwise make available on the social media platform may be viewed and/or used by other Users of those networks and we have no control over such viewing and use and cannot prevent further use of such information by third parties.
In the event you choose to link your LBD profile with a social media account, information you provide to us in the process may be included on your LBD profile. Additionally, your contacts on the social media platform(s) (“Friends”) may be able to see your activity on the LBD Platform. A link to your public profile on the social media site may be added to your LBD profile and other Users may be able to see any Friends or links (e.g. friends of friends) via that social network you may have in common with them.
When you interact with us through social media networks, you acknowledge that we may access your Information that is held by that account, solely in accordance with your social media privacy settings. Any links to social media are not under our control and remain solely your responsibility. You acknowledge that any information posted via social media through our Platform, or any third party you allow to access your content, is done entirely at your own risk and that by posting to a public platform you make that information visible to third parties who can use that information at their discretion.
Do we collect information from minors?
In Short: We take steps to ensure that the LBD Platform are only used by those over 16 years of age and we do not knowingly collect data from or market to children under 16 years of age.
We do not knowingly solicit data from or market to children under 16 years of age. By using the LBD Platform, you represent that you are at least 16 years of age. If we learn that Information from users less than 16 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age 16, please contact us at [email protected]
Your Consent to processing
You will be required to give Consent to certain processing activities before we can process your Information. Where applicable, we will seek Consent from you when you first submit Information to or through the LBD Platform.
If you have previously given your Consent you may freely withdraw such Consent at any time. You can do this by emailing [email protected].
If you withdraw your Consent, and if we do not have another legal basis for processing your Information, then we will stop processing your Information. If we do have another legal basis for processing your Information, then we may continue to do so subject to your legal rights.
Please note that if we need to process your Information in order for you to use the LBD Platform and you object or do not provide Consent to us processing your Information, the LBD Platform will not be available to you.
Marketing and opting out
If you have given Consent to marketing we may contact you about our products, services, promotions and special offers. If you no longer wish to receive such information you can withdraw your Consent at any time by sending an email to [email protected] or unsubscribing from the communications.
If you have given Consent, we may share your Information with carefully selected third-party organisations and business partners and they may contact you directly. If you prefer not to receive direct marketing communications from the third-party please contact them directly to withdraw the Consent.
Need to make changes to your info?
You may at any time review or change the information in your LBD account by logging into the LBD Platform and going to the “my profile” section where you can review or change your information. You can update your details, change your shipping, preferences and also delete and amend your bank account details. Please contact us on [email protected] if you need any help. .
If you wish to terminate your LBD account please contact us via [email protected] and we can arrange this for you. Some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms and/or comply with legal requirements.
What are your privacy rights?
In Short: You have certain rights in respect of your Information.
You have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your Information, (ii) to request rectification or erasure of your Information; (iii) to restrict the processing of your Information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your Information. To make any requests, please contact us at [email protected] We will consider and act upon any request in accordance with applicable data protection laws.
We may need to request specific information from you to help confirm your identity and ensure your right to access your Information (or to exercise any of your other rights). This is a security measure to ensure that your Information is not disclosed to a person who does not have the right to receive it. We may also contact you to ask you for further information in relation to your request to speed up your response.
If we are relying on Consent to process your Information, you have the right to withdraw your Consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal.
We welcome your feedback and questions on this Policy. If you wish to contact us about this Policy, about our Information or any other questions, please email us at [email protected]
You have the right to make a complaint at any time to the Information Commissioner’s Office (the ICO), the UK supervisory authority for data protection issues (https://ico.org.uk/concerns/). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.