Data protection

AURORA I-HOUSE LIMITED PRIVACY POLICY

1. Why do we need your personal data?

Owner of the web site: 

KOCHUT BRAND is represented on the UK market by the exclusive distributor AURORA I-HOUSE LIMITED.

AURORA I-HOUSE LIMITED uses information from our interactions with you and other customers as well as certain third parties to help achieve its goal of providing the highest quality products and services.


AURORA I-HOUSE LIMITED respects the privacy rights of our online visitors and recognises the importance of protecting the information collected about them. To this end, we have established procedures that ensure your personal data is processed in a responsible manner.

This privacy policy informs you about the kind of material we collect and how; the purposes for which we collect and use it; your rights about and options concerning our use of your data; how your data is processed and with whom it may be shared; and for how long we store your information etc. Please read it carefully.

Certain parts of this policy apply specifically to the collection and processing of your personal data when registering for a membership account with WWW.KOCHUT.ORG.UK (Owner of the web site and the business is AURORA I-HOUSE LIMITED who is an exclusive distributor of the Kochut brand within the UK).

DEFINITIONS:

The definition of personal data means any information relating to an identified or identifiable natural person. An identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.



When we use the term ‘processing,’ we mean any operation or set of operations performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

2. Who controls the data?

AURORA I-HOUSE LIMITED determines the purposes and means of the processing of your personal data. Carrying with it legal responsibilities, a data controller is legally responsible for the storing and use of personal information on computer or in manual files.

Contact Details:

AURORA I-HOUSE LIMITED


241 B Hither Green lane, London, SE136TH


Tel.: +44 20 3524 4947
Email: [email protected]

 

AURORA I-HOUSE LIMITED does not employ a Data Protection Officer. If you have any questions or concerns regarding privacy or if you have any enquires regarding the personal data you have given us, kindly contact AURORA I-HOUSE at any time. For details on how to contact us, please see “Contact Information” or send an email directly to our Privacy Responsible: [email protected]

3. What personal data is collected?:

All our activities are based on stringent ethical principles and legal requirements, and we are committed to protecting the privacy of all visitors to our websites and users of our (mobile) applications. For this reason, the way in which we collect and store information, including personal data, is dependent on how our website and related services are used. We do not collect any sensitive data about you.

3.1 Data collected through your interaction with us

Various technologies may be used on our websites and our (mobile) applications in order to improve them, make them more user-friendly, efficient and secure. Such technologies may lead to personal data being collected automatically by us or by third parties on our behalf. Examples of such technologies include cookies, flash cookies and web analytics.



Our site may, from time to time, contain links to and from the websites of our partner networks and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies for which we do not accept any liability. Please check these policies before you submit any personal data to their websites.

3.1.1 Click-stream data

When you visit our website, data is sent from your browser to our server. This data makes it possible for us to optimise our services and improve your experience on our websites and applications. The data is automatically collected and stored by us or by third parties on our behalf.

We may collect information about your computer for system administration purposes as well as to report aggregate information for internal marketing analysis reasons. This is data about our users' browsing actions and patterns and may include the following:

3.1.2 Cookies

We use cookies on our website. Please read our Cookie Policy to find out more about our use of cookies and the privacy policies of the parties from which we use web analysis tools or of which we have integrated plug-ins on our websites.


3.1.3 Re-targeting Technologies

Our website and (mobile) applications use re-targeting technologies. This enables us to advertise directly and personally to visitors who have already showed an interest in our products and/or shop via our partner websites.

We also work with companies who use tracking technologies to serve ads on our behalf across the Internet. These companies may collect information about your visits to our websites or (mobile) applications, as well as your interaction(s) with our communications, including advertising.



Re-targeting technologies analyse your cookies and display advertisements based on your past surfing behaviour. For further information on cookies, please refer to section 3.1.2 of this privacy policy.


3.2 Data provided by you

In addition to the data collected by automated means (see 3.1), we also process data which you have provided to us. This includes but is not limited to:

We may also ask you to complete surveys that we use for research purposes, although you are not obliged to respond to them. All of this data is characterised by the fact that you have voluntarily provided it. We use this information for the purposes outlined in this privacy policy. You may at any time amend your personal data or object to its further processing (Please refer paragraph 7).

4. How is the collected data processed?

When you have registered on the WWW.KOCHUT.ORG.UK web page for the account as the returning customer, we may process your personal data in the following ways:

4.1 When you visit WWW.KOCHUT.ORG.UK website, your personal data may be processed in the following ways:

5. Legal basis

When you purchase an item in our online store, create an account with us, or enter into any other form of agreement with us, we will process your conventional personal data for that particular purpose. We may also process your conventional personal data if you e.g. have a query or similar that precedes your decision to enter into an agreement with us.



The legal basis for which we may process your personal data is stated in Article 6 1, b) of the EU Personal Data Regulation (EU) 2016/679 (GDPR), as the processing of your information is necessary for us to fulfil our agreement with you or for us to handle your inquiries and such like, ahead of concluding an agreement.



We may also process your ordinary personal data on the basis of the rules in the GDPR Article 6 1, f) unless our interests are outweighed by your privacy rights and statutory freedom. We have a legitimate interest in processing your personal data (name and email address) for both marketing and analytical purposes. Our legitimate interest is based on your preferences so that we can better customise our offerings to you—and ultimately offer products and services that better meet your needs and wishes. Additionally, we have a legitimate interest in processing your personal data for analytical purposes. 

6. Disclosure of personal data

Treating your data with the utmost care and confidentiality is one of our core values. If required by law, your data may be disclosed to third parties. We employ service providers and data processors to process data on our behalf. These services include authentication, hosting and maintenance services, analysis services, e-mail messaging services, delivery services, handling of payment transactions, solvency, address and e-mail checks. These third parties are our data processors and may only process personal data to the extent necessary in order to deliver their services. Our data processors are contractually obliged to treat such information in the strictest confidence. They are prohibited from using the data in any other way than required. Necessary steps are taken to ensure that our data processors, including service providers and other processors working on behalf of AURORA I-HOUSE LIMITED, uphold and protect the confidentiality of your data.



Some of our data processors are situated outside the EU/EAA. Consequently, we will share your personal data with countries outside the EU/EEA. However, we will only provide this information on the basis of the recipient fulfilling the applicable requirements, including: 



There may be occasions on which we disclose to our partners non-personal data in an anonymous form. Such non-personal data may include information about the number of visitors to a website or (mobile) application during a certain period of time.



Please note that any information you post or disclose through your interaction with AURORA I-HOUSE LTD (e.g. personal data contained in the photos, stories, comments and videos that you submit) will become public information and may be available to visitors to the site as well as to the general public.

We may disclose your information to the extent that we are duty-bound to disclose or share your personal data in order to comply with any legal obligation or the directions of the Court or any other body of competent jurisdiction, or in order to enforce or apply our privacy policy and other agreements; or to protect the rights, property or safety of AURORA I-HOUSE LIMITED, our employees, our customers or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.



If we choose to participate in any Alternative Dispute Resolution (ADR) procedure accessible through the ODR Platform , we may disclose your personal information to the European Commission, as operator of the ODR platform, and to any ADR provider appointed to deal with the dispute.

7. Your rights

If you provide us with personal data on our websites or other channels, this is done on an entirely voluntary basis. If you choose not to provide the requested information, various customer benefits may not be available to you. In certain cases, only those who have submitted to us the required personal data are able to order products, use certain services and in other ways avail themselves of the activities and offers available on our website and (mobile) applications. We provide numerous options, depending on the exact circumstances, in order to help you retain control over your data. These options may include displaying and editing your data online. It may also be possible to unsubscribe from services or delete user accounts or to receive information about the data held.

You can access and amend your personal data at any time by logging on to your account on www.pandora.net and entering your account profile details. Click on ‘-> ‘ at the top right corner and choosing ”Returning customer” to gain access to your personal details.



If any of the information that you have provided us with has changed, e.g. if you change your email address or other contact details, or if you wish to cancel your registration with us, please let us know by editing your details on the "My Profile" (”Returning customer” pages or by sending an email outlining the changes to: “[email protected]

In general, you have the following rights:

7.1 The right to request access to your personal data

You are entitled to gain access to some of the personal data you provide to AURORA I-HOUSE LIMITED By filling in this online form you may request details of the information about you that we hold and process, including the purposes for which it is used.

You can also access your personal details by logging on to your AURORA I-HOUSE LIMITED  account on www.kochut.org.uk and entering you account profile details. Click on “->” (top right corner) to gain access to your personal details.

7.2 The right to amend and/or delete your personal data

You have the right to request correction, appendage, deletion or blockage of your stored personal data. To do so, send your request to using the email addres: [email protected] . Without undue delay of receipt of your request, we will comply to the required extent. If, for any reason, we cannot comply with your request, we will contact you. 

7.3 The right to restrict the processing of your personal data

In special circumstances, you have the right to restrict the processing of your personal data. To request restriction, kindly contact us using the email address: [email protected] .

7.4 The right to data portability

You have the right to receive your personal data (concerning you only) in a structured, commonly used and machine-readable format (“data portability”), and have the right to transit this data to another data controller. To request data portability, kindly contact us on email: [email protected]

7.5 The right to object to the processing of your personal data and to unsubscribe

You have the right to ask us not to process your personal data when processing is based on a legitimate interest pursued by AURORA I-HOUSE LIMITED, e.g. for marketing purposes. We will inform you in this privacy policy if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to object at any time by contacting us on email – [email protected] or in writing to the postal address included at the end of this document.



Emails sent to you by containing newsletter or marketing content include the option to unsubscribe by following the instructions set out in the email. If you do not wish to receive emails from us, you can simply click on the unsubscribe hyperlink and we will stop sending you emails.

For all other types of messages you may receive from us, such as maintenance announcements or administrational notifications, the receipt of such can only be terminated by deleting your account. These messages are a mandatory part of user accounts and the related use of our websites and (mobile) applications. Contact us using this online email on [email protected]

7.6 The right to withdraw your consent at any time

You are at any time entitled to withdraw your consent to our processing of your personal data. The withdrawal of consent shall, however, not affect the lawfulness of processing based on consent before its withdrawal. Contact us using this online on email [email protected].

If you wish to withdraw your consent to receiving promotional information and offers in general, including by postal services, email, text message, telephone or any other electronic means, you may do so at any time in writing to AURORA I-HOUSE LTD , Data Protection, or by sending a request using email address [email protected]. Should we have misgivings regarding your identity, we may ask you to provide identification. 

7.7 Conditions and/or limitations on your rights

There may be conditions to or limitations on your aforementioned rights. We are therefore unable to guarantee your right to data portability, as it is dependent on the specific circumstances of the processing activity.

8. Retention of your personal datas

AURORA I-HOUSE LIMITED will not retain your personal data for longer than necessary for the purposes for which it is processed within the following processing activities:

Returning customers

- Has membership

- Can have Account

- Can have signed up for Newsletter prior to joining the Club

How do we define an inactive Member?

An inactive member is someone who have not engaged with us by: logging in to the Returning customer, made a purchase either on a AURORA I-HOUSE owned website or instore/showroom, opened and clicked an email for a time period of up to 5 years from the last engagement.

What Personal data will be Erased if  Member is inactive?

All Personal data, such as: Name, email address, address, zip code, anniversaries, Gender, Phone number, day of birth, wish list, My sizes, purchase data (if not in breach with local mandatory law) etc. Full Erasure.

When will Personal data be Erased?

Personal data will be Erased, if the Club Member has been inactive for up to five years.

What Personal data will be kept after the 5 year inactive period?

No Personal data will be kept unless required by local mandatory law.

How do we Erase Personal data?

Global IT will on a quarterly basis manually Erase Personal data. Personal data will be Erased in all IT systems.






Newsletter

- No membership

- No Account

- Signed-up for Newsletter (e.g. through online channels Guest check out, Retail Uploads, etc.)

How do we define an inactive Newsletter sign up?

An inactive Newsletter Sign up is a person that has not opened and clicked an email for a period of up to 24 months. If a newsletter sign up, makes a purchase either instore or online or signs up to the Club, he/she is automatically transferred to the new status of a Purchaser, see below, and therefore follows the inactive definition of this new status.

What Personal data will be Erased if a Newsletter sign up is inactive?

All Personal data, such as: Name, gender, email address and product preference will be Erased. Full Erasure.

When will Personal data be Erased?

Personal data will be Erased, if the Newsletter Sign up has been inactive for up to 24 months.

What Personal data will be kept after the 3 year inactive period?

No Personal data will be kept unless required by local mandatory law.

How do we Erase Personal data?

Global IT will on a quarterly basis manually Erase Personal data. Personal Data will be Erased in all IT systems.

Account with Club membership

Someone who actively have created an account online with Club membership. Having an account does not mean that they have made a purchase.

How do we define an inactive Newsletter sign up?

Someone who actively have created an account online with Club membership. Having an account does not mean that they have made a purchase.

How do we define an inactive account holder?

An inactive account is someone who have not engaged with us by either making a purchase either instore/showroom or online on a AURORA I-HOUSE LIMITED owned website while creating an account, logged into the account, opened and clicked an email for a time period of up to 5 years from the last engagement.

What Personal data will be Erased if an account holder is inactive?

All Personal data, such as: Name, email address, address, zip code, gender, phone number, anniversaries, day of birth, wish list, purchase. This means full Erasure.

When will Personal data be Erased?

Personal data will be Erased, if the account holder has been inactive for up to five years.

What Personal data will be kept after the 5 year inactive period?

No Personal data will be kept unless required by local mandatory law.

How do we Erase Personal data?

Global IT will on a quarterly basis manually Erase Personal data. Personal Data will be Erased in all IT systems.


Purchase – no account/guest check out

Someone who has made a purchase either online or offline without creating an account

How do we define an inactive customer?

An inactive customer is someone who have not engaged with us by: making a purchase either instore or online on AURORA I-HOUSE  owned website while creating an account, logged into the account, opened and clicked an email for a time period of up to 5 years from the last engagement.

What Personal data will be Erased if a customer is inactive?

All Personal data, such as: name, email address, address, zip code, gender, phone number, day of birth, purchase. This means full Erasure.

When will Personal data be Erased?

Personal data will be Erased, if the customer has been inactive for up to five years.

What Personal data will be kept after the 5 year inactive period?

No Personal data will be kept unless required by local mandatory law.

How do we Erase Personal data?

Global IT will on a quarterly basis manually Erase Personal data. Personal Data will be Erased in all IT systems.


Web visitors – IP address

Someone who has visited our website.

How do we define an inactive visitors?

An inactive visitor is someone who has not visited our website for 24 months.

What Personal data will be Erased if a customer is inactive?

All data that we have collected in regard to the visit on our website. Such as:

-Content, A/B testing & product browsing analytics

- Traffic source analytics

- Internal search analytics

- Purchase analytics

- Device analytics

- Marketing retargeting

When will Personal data be Erased?

Personal data will be Erased 25 month after collected.

What Personal data will be kept after the 25 month inactive period?

No Personal data will be kept unless required by local mandatory law.

How do we Erase Personal data?

The data will automatically be Erased after 25 months.


9. The security of information and data integrity

We take the appropriate technical and organisational measures to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised use, disclosure or access, in particular where processing involves the transmission of data over a network, and against all other unlawful forms of processing and misuse.


The exclusive distributor and representative of the Kochut brand within the UK is AURORA I-HOUSE LIMITED, which uses third party data processors to collect and process your personal data. Any data processors commissioned by AURORA I-HOUSE LIMITED will only process your personal data in accordance with AURORA’S I-HOUSE instructions, and are legally obliged to adhere to strict security procedures when handling personal data.

9.1 Keeping information secure

AURORA I-HOUSE LIMITED may employ third parties to collect personal information on its behalf. In such cases, these third parties are be subject to confidentiality and data processing agreements and will be instructed by AURORA I-HOUSE LIMITED to comply fully with the AURORA I-HOUSE Privacy Policy.



Where we have provided you with, or where you have chosen, a password that enables you to access certain parts of our site, you are responsible for ensuring this password remains confidential. We ask you not to share your password with anyone.



Unfortunately, transmission of information via the Internet is not wholly secure. Although we do our utmost to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is done so at your own risk. Once we have received your information, we employ strict procedures and rigid security measures to try to prevent unauthorised access.

9.2 Social Networks

Our website and (mobile) applications provide you with social plug-ins from various social networks. If you choose to interact with a social network, your activity on our website or (mobile) applications will also be made available to social networks such as Facebook and Twitter.



If you have logged in to one of these social network sites during your visit to one of our websites or (mobile) applications, the social network site may add this information to your profile. If you are interacting with one of the social plug-ins, this information will be transferred to the social network site. If you do not want this data transfer, please log out of your social network site before entering one of our websites or (mobile) applications. We cannot prevent this data collection and social plug-in information transfer. Please read carefully the privacy policies of your social networks for detailed information about their collection and transfer of personal data, your rights, and how you can achieve satisfactory privacy settings.



Additionally, to improve your user and brand experience, your data may be passed to a third party (e.g. Facebook,Istagram) for processing in accordance with data protection and privacy regulations.



Facebook: http://www.facebook.com/about/privacy/
Twitter: http://twitter.com/privacy

Google +: http://www.google.com/intl/en/policies/privacy/ 
Istagram: https://help.instagram.com/519522125107875/?helpref=hc_fnav&bc[0]=368390626577968&bc[1]=285881641526716

9.3 Geolocation Services

Location-enabled services may be employed within some of our (mobile) applications. Should you use these (mobile) applications, they may receive information about your actual location, such as GPS signals sent by a mobile device or information that can be used to approximate a location. You can enable or disable your location services in your device or browser settings.



For further Information on Google Maps and their privacy policy, please see: http://www.google.com/intl/en/policies/privacy/ 


For further information on Baidu Maps and their privacy policy please see: https://map.baidu.com/zt/client/service/index.html 

10. Consequences of non-disclosure of personal data

It is not possible to create an account on WWW.KOCHUT.ORG.UK web site with AURORA I-HOUSE LIMITED to gain the membership and make a purchase on the website if you are unable to provide us with the required information.

11. Contact Information

Should you have any questions about our privacy policy or the processing of your personal data, please feel free to contact us.

Data Controller:



AURORA I-HOUSE LIMITED


241 B Hither Green lane, London, SE136TH


Tel.: +44 20 3524 4947


Email: [email protected]

12. Complaints

Complaints should be submitted directly to the UK data protection supervisory authority:

https://ico.org.uk/

13. Changes to this policy

AURORA I-HOUSE LIMITED has pledged to adhere to the fundamental principles of privacy and data protection. We therefore regularly review our privacy policy in order to keep it up to date and compliant with privacy and data protection principles. This privacy policy may be changed from time to time in order to keep pace with new developments and opportunities relating to the Internet and to stay in line with prevailing legislation. Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, may be notified to you by email.

To submit a data request, please use email address: [email protected]


Last updated:  January 2019