Introduction

This privacy notice is relevant to anyone who uses our services and any other individuals insured under a policy. We refer to these individuals as “you/your” in this notice.

We are dedicated to being transparent and this privacy notice tells you what we do with the information that we collect about you.

We process your personal data in accordance with the relevant data protection legislation. We are the data controller for the data that we process about you and we will not collect any information from you that we do not need for the purpose of administering your insurance policy. There may be additional data controllers, such as the agent you purchased your insurance policy through or the insurer/s.

Our Contact details

We are Shades of Romeo, referred to as “we/us/our” in this notice. Our registered address is Mayfair Avenue 36, postcode IG1 3DL, London.

Anything you are not clear about


If you have any questions, or if there is anything that you are unclear about, please contact us at shadesromeo@gmail.com and we will be happy to answer any queries you may have concerning this privacy notice or the way we process your personal data.

Why is your personal data required?


The provision of your personal data is necessary for us to administer your insurance policy and meet our contractual requirements under the policy.

If you fail to provide the data, it may mean that you are unable to exercise your contractual rights, including claims under the policy. This would also hinder our ability to administer your insurance policy.

What information do we collect about you?


We may collect the following personal data about you:

-full name
-address (and previous addresses)
-date of birth
-contact numbers, and
-email address.

As a new or existing customer, as you have shopped online with us using a credit or debit card, or we have taken these details for payment authorization, we will securely collect and store this payment card information. New customers and the existing customer whose payment cards have expired, you will be asked if you would like to automatically store these details in order to speed up the payment process. If you set up a direct debit payment, we will also collect bank details from you.

WHY WE PROCESS YOUR PERSONAL DATA


Depending on the purpose for which we process your data from time to time, as explained above, we need to process one or other data, which will in general, be, depending on each case, as follows:

-your identity data (for example, your name, surname, language and country from which you interact with us, contact data, etc.);

-economic and transactions information (for example, your payment or card data, information on your purchases, orders, returns, etc.);

-connection, geolocation and/or browsing data (if you interact with us from your mobile phone, for example);

-commercial information (for example, if you have subscribed to our newsletter),

-information about your tastes and preferences.

Remember that, when we ask you to fill in your personal data to give you access to any functionality or service of the Platform, we will mark certain fields as compulsory, since this is information that we need to be able to provide the service or give you access to the functionality in question. Please take into account that, if you decide not to make such data available to us, you may be unable to complete your user registration or may not be able to enjoy those services or functionalities. Depending on how you interact with our Platform, i.e., depending on the services, products or functionalities that you wish to enjoy, we will process your personal data for the following purposes:

DO WE SHARE YOUR DATA WITH THIRD PARTIES?

To achieve the purposes mentioned in this Privacy and Cookies Policy, we must give access to your personal data to entities of the Inditex Group and to third parties that provide us with support in the services that we offer you’re, i.e.:
-financial institutions,
-anti-fraud detection and prevention entities,
-technological service providers,
-logistic, transport and delivery partners and service providers,
-providers of customer support related services,
-advertising and marketing related partners and service providers.
For service efficiency purposes, some of these providers are located in territories outside

What are my rights?

You have the right to be given the following information each time we collect information from you:

(a) our identity and contact details;(b) what we’re going to use your information for and the legal basis for processing; (c) whether you are obligated to provide the information and the consequences of failure to provide it; (d) who we will share your information with; (e) whether your information will go outside the European Economic Area and if it does what we’re doing to protect it; (f) how long we’re keeping your data for; (g) your rights in respect of our use of your data (see below); (h) if we’re collecting data with your explicit consent, the fact you have the right to withdraw consent at any time; (i) that you can contact the Information Commissioners Office (www. ico.org.uk) or your local supervisory authority for data protection matters if you have a complaint about our use of your information; and (j) if we make any automated decisions about you, the logic involved and the significance and envisaged consequences for you.

Access

You have the right to ask us the following about our use of your information: (a) the purpose of our use; (b) what type of information is used; © who we share your information with; (d) how long we keep your information; (e) what rights you have in relation the information we hold; (f) whether you have a right to lodge a complaint with the Information Commissioner’s Office or other supervisory authority; (g) if we have collected your information from another person, who that person is; (h) whether we make any decisions about you automatically (g) whether your information goes outside the European Economic Area. You can also ask us for a copy of the data we have.

Rectification

You can ask us to correct any details you think we have which are incorrect

Erasure

You can ask us to delete information about you if any of the following apply: (a) it is no longer required by us for the purpose for which we collected it from you; (b) if we collected it with your explicit consent, when you withdraw that consent; (c) if you have grounds to object to us using it (see below) and we do not have any overriding legitimate grounds for using it; (d) if we have unlawfully used your information; (e) if you need us to delete it so that you can comply with a legal obligation. Please note that we may need to keep certain information to comply with our legal obligation or for claims purposes.

Restriction

You can ask us to stop using your information if any of the following apply, (a) you don’t think we have the correct details for you; (b) our use is unlawful and you do not want us to delete your information; © when you object to processing (see below); (d) we no longer require the information for the purpose for which we collected it; (e) where we collected the information with your explicit consent (f) if you object to our use (see below) and we do do not have any overriding legitimate grounds for using it; (g) if you need us to delete it so that you can comply with a legal obligation. Please, not when you make a request we can still store your information and use it for claims purposes or if it is necessary to protect another person.

Portability

You have the right to ask us to send your information to you or another person where we originally collected your information with your explicit consent. We must provide this in a structured, commonly used and machine-readable format. Please note this does not include information which we have inferred or derived, for example, the information we have collected about you to understand your shopping habits with Shades of Romeo in order to give you good customer experience.

Objection

You have the right to ask us to stop using your information where we have told you the legal purpose for which we are processing your information is for “legitimate interests” (see above) and you have grounds relating to your personal situation which requires us to stop using your information or where we have collected your information for direct marketing and you want us to stop using it for direct marketing purposes.

Automated Decision Making

You have the right to object to automated decision-making based on your personal data, and to request human intervention in any such decision.

Cookie Notice

This notice is designed to help you understand what cookies are, how Next uses them, and the choices you have regarding their use.

By continuing to use Shades of Romeo the “Site”, you are agreeing to our use of cookies in the manner described in this notice.

What are cookies?

Cookies are small text files that are stored on your browser or the hard drive of your computer or another device when you visit the Site, this allows the Site to recognize you as a user either for the duration of your visit (using a ‘session cookie’) or for repeat visits ( a ‘persistent cookie’). They are not harmful and do not contain any information such as your home address, date of birth or credit card details.

The cookies we use fall into four broad types:

Strictly Necessary Cookies

These cookies are essential in helping you to move around our Site and use its features, such as accessing secure areas of the website. Without these cookies, services you have asked for, such as setting up an account cannot be provided. These cookies do not gather information about you that could be used for marketing or remembering where you’ve been on the internet

Analytical/Performance Cookies

In order to keep the Site, its services and products relevant, easy to use and up-to-date, we use web analytics services to help us understand how people use our Site. For example, we can see which parts of the Site and products are most popular, identify when errors occur, and test different versions of a page or feature to see which one works best.

Functionality Cookies

These cookies allow websites and applications to remember choices you make (such as your user name, language, or the region you are in) and provide enhanced, more personal features. The information these cookies collect is usually anonymized which means we can’t identify you personally. They do not gather any information about you that could be used for selling advertising or remembering where you’ve been on the internet but do help with serving to advertise.

Targeting Cookies

We also use cookies to assist in targeted advertising. Although these cookies can track your visits around the web they don’t know who you are. Even if you sign in to your Shades of Romeo account, the data is not linked to your profile. Without these cookies, online advertisements you encounter will be less relevant to you and your interests. We also use them to measure the effectiveness of our marketing communications, for example by telling us if you have opened a marketing email that we have sent you.