EcoSki respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) or when you otherwise provide personal data to us via other means (such as over the telephone) and tell you about your privacy rights and how the law protects you.
This privacy notice is provided in a layered format so that you can easily click through to the specific areas set out below.
Please also use refer to the Glossary that we have set out at the end of the Policy, if there is any terminology used in this privacy notice that you are unfamiliar with or that you don’t fully understand.
1. Important Information & Who We Are
Purpose of this privacy notice
This privacy notice aims to give you information on how EcoSki collects and processes your personal data, including any data you may provide through this website or via any other means (such as over the telephone) when you rent or enquire about or make a purchase of an item, when you sign up to our newsletter or request information or when you take part in a competition.
This website is not intended for children and there are no circumstances in which we collect data relating to children, is where??
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
EcoSki is the controller and responsible for your personal data (collectively referred to as "the Company", "we", "us" or "our" in this privacy notice).
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.
Our full details are:
Full name of legal entity:
Name or title of data privacy manager:
3 Mill Street, Oakham, Rutland, LE15 6AE
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to the privacy notice and your duty to inform us of changes
This version was last updated on 1 September 2020 and historic versions can be obtained by contacting us.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if any of the details you provide to us should change, during the course of your relationship with us.
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
2. The Data we collect about you.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
A. Identity Data
This includes data relating specifically to your identity, such as your first and last name.
B. Contact Data
This includes data relating to how you may be contacted, such as your address, email address and telephone numbers.
C. Financial Data
This includes data relating to your means and methods of payment, such as your bank account and payment card details.
D. Transaction Data
This includes data relating to the transactions you have carried out with us, such as details about payments to and from you and other details of products and services you have purchased from us.
E. Technical Data
This includes more technical data that we may obtain when you make use of our website, such as your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
F. Profile Data (Will there be an account log in for customers/preference centre or a factility for EcoSki to store data online?)
This includes the data that we receive when you create a profile on our website and make use of that policy, such as your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
G. Usage Data
This includes information about how you use our website, products and services.
H. Marketing and Communications Data
This includes your preferences in relation to whether or not you want to receive marketing from us and our third parties and also your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we will treat the combined data as personal data which will be used in accordance with this privacy notice.
If you fail to provide personal data
Where we need to collect personal data by law or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you.
In other words, where we require details from you in order to provide you with your purchases or rentals, if you do not provide us with the necessary details then we will not be able to provide the services you have requested. If we don’t have your address, or your consent to share that information with the couriers, we won’t be able to deliver your order to you.
In this case, depending upon when you fail to provide the necessary data, we may either not be able to process your purchase or we may have to cancel your purchase, in which case we will treat this as a ‘cancellation of order by you’ in accordance with our Terms and Conditions. (requires link to terms and conds). We will notify you if we are unable to process a purchase or are required to cancel a purchase for this reason.
3. How your personal data is collected
We use different methods to collect data from and about you including through:
A. Direct interactions
You may give us your Identity, Contact, Profile and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- make a purchase from us;
- use our repair services
- use our rental services
- subscribe to our newsletter or other publications;
- request marketing to be sent to you;
- enter a competition, promotion or survey;
- give us feedback;
B. Automated technologies or interactions
As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns.
C. Third parties
We may receive personal data about you from various third parties as set out below:
- Technical Data from the following parties:
- analytics providers such as Google based outside the EU;
- usage data to improve and customise your online experience with us stored within our website database based both within and outside the EU.
- advertising networks and personalisation software such as AdRoll, Google Ad Words, Facebook and Bing based inside and outside the EU;
- search information providers such as SearchNode based inside and outside the EU; and
4. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to dispatch items purchased through us directly to you
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
We may collect the following data about you, and we’ve explained the lawful basis (in brackets) and purpose for doing so in each case:
Your name, address and email address (contractual performance; legitimate interests; legal obligations; consent)
- We need to know these so that we can process the orders that you make on our website, send you email confirmations of your order, send those packages of style direct to your door, and verify your payment details (contractual performance).
- From time to time we’ll send you catalogues, special offers and promotions by post and email (legitimate interests).
- We also use your data for fraud prevention purposes, to verify you are a real customer (legitimate interests).
- We need this information so that we can respond to your queries and or a complaint in the case that one arises (contractual performance; legitimate interests).
- We may also keep a record of these to inform any future communication with us, to demonstrate how we communicated with you throughout, to ensure that we provide you with the best possible service.
- We also use this data to send you survey and feedback requests to help improve our services. It helps make our products or services more relevant to you (legitimate interests).
- Sometimes, we may need these details to send you communications that are required by law or necessary to inform you about our changes to the services we provide you (legal obligations; contractual performance).
- When you leave a product review for us on our website you’re given the option to provide your email address which we use to verify your review (legitimate interests).
- If you participate in our research activities (for example, customer WhatsApp groups, Customer focus groups), we’ll use your name in order to administer the group (consent).
Your payment card (contractual performance; legitimate interests)
- We use this data to process your order, or to process refunds to you (contractual performance).
- In addition, we may use this data for fraud prevention and detection purposes. Don’t worry we process and store your card details securely in line with industry best practice, using techniques including encryption and tokenisation to keep you safe when shopping with us (legitimate interests).
Your date of birth (legitimate interests; legal obligation)
- We always need to confirm that you’re over 18 so that we can legally enter into a contract with you (legal obligation).
- We may use this data for fraud prevention and detection purposes (legitimate interests).
Your phone number (contractual performance; consent)
- We ask for this so that we can call or text you about your orders, although it’s optional. It’s handy when the courier can’t find your address, for example, or if there is a problem with your order (contractual performance).
- If you participate in our research activities (we’ll use your phone number for administering the group (consent).
Your communication history with us (contractual performance; legitimate interests)
- We keep records of the live chats, telephone calls, emails and postal correspondence from you so we can provide you with the great customer service and support we’re known for (contractual performance). We may also use this data when training our staff, to make sure we continuously improve that customer service (we set our goal at ‘incredible’) (legitimate interests).
Information about your device and how you use our website (including your IP address, device type) (legitimate interests)
- We use this data to continuously improve our website, to set default options for you, and to show you the correct content (for example language and currency). We may also use it to develop, test and improve the systems, services and products we provide to you by say, recording your browser’s Session ID to help us understand more when you leave us online feedback about any problems you’re having. This data is also used to prevent and detect fraud.
Your responses to surveys, competitions and promotions (legitimate interests; contractual performance)
- This allows us to run all of these things. If we don’t use this data, you can’t win competitions or use promotions.
- If you share your photographs with EcoSki these may be published on our website.
Your social media username (legitimate interests)
- If you interact with us on social media, we use this data to help us respond to your comments, questions or feedback.
Your Internet Protocol (IP) address (legitimate interests)
- We collect information about your location through your IP address which helps us to show you content that is most relevant to you.
Any of your personal data (legal obligation)
- There may be situations where we are legally required to share your personal data, for example, when a court order is submitted to share it with law enforcement agencies or a court of law.
- If you don’t want to give us your data, you don’t have to. However, if you don’t, you may not be able to buy products from our website and catalogue, and you are unlikely to receive our best customer service. It’s your call.
Data Retention Period
For all the purposes for which we will use your personal data outlined in the table above, we will retain your personal data until you request for it to be deleted, or anonymise your contact record after 36 months of inactivity with EcoSki. For customers who complete an order with us, we will retain your data for accounting purposes for a period of 7 years.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
We have established the following personal data control mechanisms:
- When signed up to our newsletter, you have the opportunity to unsubscribe using the link at the bottom of email newsletters sent to you, or by contacting us directly.
- In most instances an online account is created on our website for customers to track their order, and allowing you to update your personal information at any time. (will we have this facility?)
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us only when you have given us your specific consent to receive such communications.
It is not our usual policy to share your personal information with any company outside the EcoSki group of companies for marketing purposes, but if we did we would only do so with your express opt-in consent.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data that you have provided to us as a result of a purchase of travel services or other such transactions.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. How we disclose your personal data
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
- External Third Parties as set out in the Glossary.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
There are circumstances where we may share some of your data with others:
- Delivery Companies / Couriers (contractual performance / legitimate interests) so that we can deliver your purchases. After your purchases have been delivered, the delivery company / courier may contact you by email you to check that you are happy with the service that you have received from them.
- Payment and Credit Agencies (contractual performance). We use reliable, very trustworthy companies to process the orders you place with us or help us in the services we provide to you. We only give them the data they need.
- Marketing Agencies (legitimate interests) - We also share your name, address, IP addresses, email address and transaction history with data selection analysts, data segmentation and ranking agencies, and email marketing agencies. It sounds very complicated but these organisations help us to analyse our customer base and to identify potential new customers, to target our marketing in a way that is most relevant for you, and show you the content that is relevant to you (based on your location). In all instances, we provide them with only the data they need to perform their function.
- Upon sale of business assets (legal obligation) - In the unlikely event that our business assets are sold or purchased by another company, our data records will be sold too as part of our business.
- Research Companies (legitimate interests) - We care what you think so we might ask outside research companies to contact you directly for opinions on our products and services (we only give them the data they need to get this done).
6. How we secure your data
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
7.How long we retain your data for
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Details of retention periods for different aspects of your personal data are shown in section 4
In addition to the above, by law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for seven years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see Request erasure below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
8. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us
Performance of Contract
means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation
means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
YOUR LEGAL RIGHTS
You have the right to:
to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing
of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing
of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- if you want us to establish the data's accuracy;
- where our use of the data is unlawful but you do not want us to erase it;
- where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
- you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
· Request the transfer
of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time
where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Cookies are small text files that websites send to your computer, and can be thought of as Internet users’ identification cards. They let the website know when the user has returned, which enables the site to bring up information relevant to that user– name and past orders, for example.
Just to reassure you, cookies aren’t computer programs, and can't read other information saved on your hard drive. They can’t be used to disseminate viruses or, for example, get hold of a user's email address. They only contain and transfer to the website as much information as the users themselves have disclosed to that website. Please note that cookies are computer-specific, so if you log on to any site from a different computer, the cookie settings on that computer will apply.
For further information about managing and disabling cookies on your computer see www.allaboutcookies.org/manage-cookies .
When you visit our sites, cookies are either served directly by us, or by our business partners. These are the different kinds of cookies we use:
- Essential cookies: These cookies allow you to use the basic functionality of our website. For example, browsing our products, ordering and paying for items, checking your account information and viewing your order history.
- Performance cookies: These cookies allow us to get to know how you use our website. They’re used to analyse visitor information such as usage and visitor numbers, so they help us to see how effective our advertising is and understand what you like. We also use this information to help improve our website, make our marketing more relevant and improve your experience. The data used for these cookies is aggregated and anonymised, which means that we can’t identify you as an individual. In other words, your personal data is not used for these cookies.
- Functionality cookies: These ones allow us to provide additional functionalities to the website, and will retain some settings information. While they’re not essential for the functionality of our site, they do enable extra features that should make your shopping experience even better.