This privacy notice sets out how we collect, use and manage your personal data. Where we refer to “personal data” in this privacy notice, this means data which relates to you and which personally identifies you either directly or indirectly.
Data Controllers and Data Protection Officer
A data controller is an organisation that collects and uses personal data and has responsibility for how the personal data is used and managed.
A data protection officer is the person in an organisation who has responsibility for monitoring compliance with the law and for ensuring that personal data is protected within an organisation.
MISSLIBO provides your goods and is the data controller of personal data that you provide when you order goods.
MISSLIBO also provides credit, subject to status, and is the data controller of personal data you provide when you request a credit account.
MISSLIBO is registered in the Republic of Ireland.
In the context of this privacy notice, when we use the term ‘we’ it means MISSLIBO
How We Use Your Data
We use your personal data to provide goods and services to you and to enter into and administer the credit account you have with us.
We will use your personal data in the following ways:
- To provide goods and services and to manage your retail account including administering payments, returns and responding to queries.
- To analyse your shopping preferences or how you interact with or use our website.
- For research and statistical purposes.
- To send you special offers or discounts and to tell you about our products and services. You control your preferences in respect of how your personal data is used for marketing and you can change these preferences when you log in to My Account.
- To record and monitor outbound and inbound telephone conversations with you to ensure consistent service levels, to prevent or detect fraud, to resolve queries and complaints and for performance management and training purposes.
We will collect personal data directly from you when you purchase goods or services, apply for a credit account, or change any of your details (such as your name or address) via My Account or through our Contact Centres. We require you to provide personal data in order to assess whether to enter into a contract with you or to perform our contract with you and if you do not provide the personal data we request, we will be unable to enter into or fulfil this contract.
We obtain data from third party sources such as credit reference agencies, fraud prevention agencies and publicly available information relating to you on the internet (for example on social media websites).
We may also obtain personal data from third party companies for the purposes of sending marketing communications to you. Such marketing communication may be sent by ourselves or by the third parties. These third parties must check you have given your permission for such contacts to take place.
Why We Need Your Personal Data
We need to process your personal data for a number of different reasons and these are our legal bases for processing. We also need to keep your personal data for as long as is necessary for us to operate our business and to comply with legal and regulatory obligations.
We rely on one or more of the following legal bases for processing personal data:
- To perform our contract with you or to enter into a contract with youWe need to process your personal data to fulfil our contract with you or to assess whether to enter into a contract with you, whether this is in selling and delivering goods and services to you or providing credit facilities or other financial services products to you.
- To fulfil our legitimate interests or the legitimate interests of a third partyWhen we process personal data to fulfil our legitimate interests we will use it in a way in which you would reasonably expect and which will have a minimal privacy impact. When we or third parties are relying on legitimate interests we will balance our interests against your interests and the privacy impact of the processing on you and we will process your personal data responsibly.Examples of our legitimate interests are: direct marketing, fraud prevention, preventing and investigating crime including financial crimes, assessing affordability and credit worthiness and IT security.
- To comply with legal obligations to which our business is subject.We have to comply with relevant law and regulation in order to provide retail and financial services products and we will need to process your personal data in order to comply with these legal obligations.
- ConsentIf we are relying on consent as our legal basis to process your personal data, you have the right to withdraw consent at any time.
We will keep your personal data for the purposes set out in this privacy notice and only for as long as any legal basis continues to apply. Below is a non-exhaustive list of some of the reasons we need to retain your personal data:
- Ensuring we have relevant information in the event of any queries or complaints;
- Being able to identify if you have purchased a product which is subject to a product recall;
- Being able to service any product or service guarantee you have purchased.
- To assist with the establishment, exercise or defence of legal claims.
The length of time we need to keep the personal data will vary depending on the nature of the personal data and the reason we are obliged to hold it. We will apply appropriate risk based measures to protect your personal data which may include pseudonymising or anonymising the personal data. If personal data is pseudonymised, this means it is de-identified so you are no longer identifiable, but we can re-identify you if we have a requirement to do so. If personal data is anonymised, it is de-identified, but can never be re-identified in the future.
Who We Transfer Data To
Transferring personal data to other organisations needs to take place with appropriate safeguards and you can be assured that we will only share the personal data that is needed for these organisations to be able to provide the right service to you or support us in doing so.
We may transfer your personal data to the following third parties:
- Technology service providers – our partners who provide IT and website services.
- Customer service providers – our partners who work with us to administer your account and provide you with any help you may need.
- Telephony providers – our partners who provide telephone services and functionality.
- Delivery companies – our couriers, parcel firms and mail firms who deliver your goods or services and manage any returns on our behalf.
- Distributors and manufacturers of goods – our partners who fulfil orders and deliver products to you and manage any returns on our behalf.
- Product service providers – our partners who provide products and services such as insurance or extended warranties.
- Marketing service providers – our partners who work with us to make sure we send you information about products, services and special offers that are of interest to you.
- Data pool facilitators – we may share and pool information (on an anonymous basis or otherwise) with other third party retailers or financial service providers. This may help up to improve our products and quality of service to all customers.
- Debt collectors, tracing agencies, debt purchasers or organisations providing debt support – our partners who help us to recover debts, who purchase debts or who offer debt advice and support.
- Regulators and other governmental agencies or law enforcement agencies.
- Organisations who may be interested in purchasing our business or organisations who we may be interested in purchasing – we may sell parts of our business or acquire other businesses and your personal data may be shared with such third parties as part of this process.
We will only transfer your personal data to third parties who adhere to appropriate data security standards and controls. From time to time we may need to transfer your personal data to other countries. Where this is the case, we will ensure that the transfer is subject to appropriate safeguards to protect your personal data and complies with applicable law which may include having standard contractual clauses in place with the third party. For further information on how data can be transferred to other countries, please find enclosed a link to the European Commission website: https://ec.europa.eu/info/law/law-topic/data-protection_en
You have certain rights in respect of your personal data and we have processes to enable you to exercise these rights.
Right of Access
This is known as a Subject Access Request. If you want to know if we are processing personal data relating to you and to have access to any such personal data you can contact our Customer Services Team at firstname.lastname@example.org. In order to supply you with your personal data that we hold we will need to verify your identify.
Right to Rectification
If you believe that we hold inaccurate personal data about you, then you can either update this information directly by logging in to My Account and updating the relevant details or you can request that we carry out a review by contacting our Customer Services Team at email@example.com. Depending on the type of personal data you believe is inaccurate, we may ask you for further proof to ensure that the personal data is being corrected properly. If we are satisfied that the personal data is inaccurate we will make the necessary changes.
Right to Erasure
You have a right to ask for your personal data to be erased in certain circumstances. However, this right does not apply where we have to comply with a legal obligation or where we need personal data for the establishment, exercise or defence of legal claims. Therefore we cannot comply with an erasure request where you have a retail shopping account, owe money on a credit facility or have otherwise bought products and services for which we must keep records. In addition, if you opt out of marketing communications or have previously opted out of marketing communications, we have to keep a record or such opt out to ensure that we don’t contact you in the future.
Right to Restriction
You have a right to request that processing of personal data is restricted in certain circumstances. However, we shall still continue to process the personal data for storage purposes, for the establishment, exercise or defence of legal claims or with your consent.
Right to Object
Where we are relying on legitimate interests as a legal basis to process your data, you have a right to object to such processing on grounds relating to your particular situation.
If you object to our use of your personal data for marketing purposes, we will opt you out of marketing. You can do this by contacting our Customer Services Team at firstname.lastname@example.org. You may also object to other processing when we rely on our legitimate interests as the basis for processing, but we do not have to stop the processing if we can demonstrate compelling legitimate grounds for the processing (taking into account our processing activities, the nature of our business and our legitimate interests) and that these grounds override your interests, rights and freedoms or in the event that we need the personal data for the establishment, exercise or defence of legal claims. To enable us to consider any objection we will need to know what specific interests, rights or freedoms relating to your particular situation you believe will potentially be put at risk by our processing. If we do stop processing your personal data (apart from for direct marketing purposes), this may affect our ability to trade with you.
From time to time, in deciding whether to enter into a contract with you, or during the ongoing performance of a contract, we take decisions based on automated processing which produces legal affects or similarly significantly affects you, for example assessing a fraud risk.
There are a number of consequences of such automated processing:
- we may conduct a further review or request additional information from you in relation to your request to purchase goods and services if our fraud decisioning highlights any issues.
We also use automated processing in relation to the information we hold about you to make recommendations of products and services we think you would be interested in and to improve your experience when you visit our website by making it relevant and tailored to you.
Right to Portability
In certain circumstances, you can request that we provide to you your personal data in a commonly used format. If you wish to make such a request, you can contact our Customer Services Team at email@example.com
Right to Complain to the Data Protection Commissioner
You have the right to lodge a complaint with the Data Protection Commissioner and more details can be found on their website www.dataprotection.ie .
Before we provide services, goods or financing to you, we undertake checks for the purposes of preventing fraud and money laundering, and to verify your identity. These checks require us to process personal data about you.
What we process and share
The personal data you have provided, we have collected from you, or we have received from third parties may include your:
- date of birth
- residential address and address history
- contact details such as email address and telephone numbers
- financial information
- employment details
- identifiers assigned to your computer or other internet connected device including your Internet Protocol (IP) address
When we and fraud prevention agencies process your personal data, we do so on the basis that we have a legitimate interest in preventing fraud and money laundering, and to verify identity, in order to protect our business and to comply with laws that apply to us. Such processing is also necessary to enable us to enter into and perform our contracts with you.
We, and fraud prevention agencies, may also enable law enforcement agencies to access and use your personal data to detect, investigate and prevent crime.
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.
As part of the processing of your personal data, decisions may be made by automated means. This means we may automatically decide that you pose a fraud or money laundering risk if:
- our processing reveals your behaviour to be consistent with money laundering or known fraudulent conduct; or is inconsistent with your previous submissions; or
- you appear to have deliberately hidden your identity.
Consequences of Processing
If we, or a fraud prevention agency, determine that you pose a fraud or money laundering risk, we may refuse to provide the services and financing 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. If you have any questions about this, please contact us on the details above.
Whenever fraud prevention agencies transfer your personal data outside of 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 secure data sharing.
Your personal data is protected by legal rights, which include your rights to:
- object to our processing of your personal data;
- request that your personal data is erased or corrected;
- request access to your personal data.
For more information or to exercise your data protection rights, please contact us using the contact details above.
Please make sure that you have read and understood our Privacy Notice which explains how we safeguard any data which you provide to us and the basis for which we process your data in order for us to fulfil your online orders.
MISSLIBO, 75A MEATH STREET, THE LIBERTIES, DUBLIN, 8
If you have any queries about how we use your information or on data protection generally please contact us on firstname.lastname@example.org