Version 18 May 2018
SECTION 1 - WHAT DO WE DO WITH YOUR INFORMATION?
When you make a purchase or attempt to make a purchase through the Site, we collect certain information from you, including your name, billing address, shipping address, payment information (including credit/debit card numbers or PayPal), email address, and phone number. We refer to this information as “Order Information”. We use the Order Information that we collect generally to fulfil any orders placed through the Site (including processing your payment information, arranging for shipping, and providing you with invoices and/or order confirmations).
Additionally, we use this Order Information to:
- Communicate with you;
- Screen our orders for potential risk or fraud; and
- When in line with the preferences you have shared with us, provide you with information or advertising relating to our products or services.
We use the Device Information that we collect to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimise our Site (for example, by generating analytics about how our customers browse and interact with the Site, and to assess the success of our marketing and advertising campaigns).
When we talk about “Personal Information” in this Privacy Policy, we are talking both about Device Information and Order Information.
SECTION 2 - CONSENT
How do you get my consent?
When you provide us with personal information to complete a transaction, verify your credit card, place an order, arrange for a delivery or return a purchase, we asked for your expressed consent to our collecting it and using it for that specific reason only. If we ask for your personal information for a secondary reason, like marketing, we will ask you directly again for your expressed consent. In either case, we will provide you with an opportunity to say no.
How do I withdraw my consent?
If after you opt-in, you change your mind, you may withdraw your consent for us to contact you, for the continued collection, use or disclosure of your information, at anytime, by contacting us at dpo@mclear.com or mailing us at: McLear Ltd, 14-16 Great Chapel St, London, England, W1F 8FL, UK, United Kingdom
SECTION 3 - DISCLOSURE
We may disclose your personal information if we are required by law to do so or if you violate our Terms of Service.
SECTION 4 - THIRD-PARTY SERVICES
McLEAR employs the services of 3rd parties in order to supply you with our product. In general, the third-party providers used by us will only collect, use and disclose your information to the extent necessary to allow them to perform the services they provide to us. However, certain third-party service providers, such as payment gateways and other payment transaction processors, have their own privacy policies in respect to the information we are required to provide to them for your purchase-related transactions. For these providers, we have ensured that they all comply with GDPR but if you would like to read their privacy policies, so you can understand the manner in which your personal information will be handled by these providers, please contact us and we will provide their links. In particular, remember that certain providers may be located in or have facilities that are located a different jurisdiction than either you or us. So, if you elect to proceed with a transaction that involves the services of a third-party service provider, then your information may become subject to the laws of the jurisdiction(s) in which that service provider or its facilities are located. As an example, if you are located in Canada and your transaction is processed by a payment gateway located in the United States, then your personal information used in completing that transaction may be subject to disclosure under United States legislation, including the Patriot Act. Once you leave our store’s website or are redirected to a third-party website or application, you are no longer governed by this Privacy Policy or our website’s Terms of Service.
SECTION 5 - ON-LINE STORE
Our store is hosted by a 3rd Party. They provide us with the online e-commerce platform that allows us to sell our products and services to you. Your data is stored through that 3rd Party’s data storage, databases and the general shopping application. They store your data on a secure server behind a firewall. Payment: If you choose a direct payment gateway to complete your purchase, then they store your credit card data. It is encrypted through the Payment Card Industry Data Security Standard (PCI-DSS). Your purchase transaction data is stored only as long as is necessary to complete your purchase transaction. After that is complete, your purchase transaction information is deleted. All direct payment gateways adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of credit card information by the store and its service providers. Links: When you click on links on our store, they may direct you away from our site. We are not responsible for the privacy practices of other sites and encourage you to read their privacy statements. Google analytics: Our store uses Google Analytics to help us learn about who visits our site and what pages are being looked at.
SECTION 6 - SECURITY
To protect your personal information, we take reasonable precautions and follow industry best practices to make sure it is not inappropriately lost, misused, accessed, disclosed, altered or destroyed. If you provide us with your credit card information, the information is encrypted using secure socket layer technology (SSL) and stored with a AES-256 encryption. Although no method of transmission over the Internet or electronic storage is 100% secure, we follow all PCI-DSS requirements and implement additional generally accepted industry standards.
SECTION 7 - COOKIES
We use a technology called “cookies” to track patterns of behaviour of visitors to the website and to personalise content and to provide social media features. A cookie is an element of data that the website sends to your browser that is then stored on your system. This allows us to create a session with your browser and means you can choose to stay logged in whilst using the website. You can set your browser to prevent this happening. Any information collected in this way can be used to identify you unless you change your browser settings.
DO NOT TRACK Please note that we do not alter our Site’s data collection and use practices when we see a Do Not Track signal from your browser.
SECTION 8 - AGE OF CONSENT
By using this site, you represent that you are at least the age of majority in your state or province of residence, or that you are the age of majority in your state or province of residence and you have given us your consent to allow any of your minor dependents to use this site.
SECTION 9 - CHANGES TO THIS PRIVACY POLICY
We reserve the right to modify this privacy policy at any time, so please review it frequently. Changes and clarifications will take effect immediately upon their posting on the website. If we make material changes to this policy, we will notify you here that it has been updated, so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we use and/or disclose it. If our store is acquired or merged with another company, your information may be transferred to the new owners so that we may continue to sell products to you.
SECTION 10 - YOUR RIGHTS
If you are a European resident, you have the right to access personal information we hold about you and to ask that your personal information be corrected, updated, or deleted. If you would like to exercise this right, please contact us through the contact information below. Additionally, if you are a European resident, we note that we are processing your information in order to fulfil contracts we might have with you (for example if you make an order through the Site), or otherwise to pursue our legitimate business interests listed above. Additionally, please note that your information will be transferred outside of Europe, including to Canada and the United States.
SECTION 11 - DATA RETENTION
When you complete an order through the Site, we will maintain your Order Information for as long as the HMRC rules require, which are currently 6 years from the end of the financial year of the transaction.
SECTION 12 - QUESTIONS AND CONTACT INFORMATION
If you would like to: access, correct, amend or delete any personal information we have about you, register a complaint, or simply want more information contact our Privacy Compliance Officer at dpo@mclear.com or by mail at: [Re: Privacy Compliance Officer] McLear Ltd, 14-16 Great Chapel St, London, England, W1F 8FL, UK, United Kingdom