PRIVACY POLICY

1. IMPORTANT INFORMATION AND WHO WE ARE

PURPOSE OF THIS PRIVACY NOTICE

This privacy notice aims to give you information on how Sorensen collects and processes your personal data through your use of our website, your use of our stores, your participation in a Sorensen event, or any data you may provide when you sign up to our newsletter, purchase a product or service or take part in a competition.

This website is not intended for children and we do not knowingly collect data relating to children.

CONTROLLER

Sorensen Crew Limited is the controller and responsible for your personal data (referred to as “Sorensen”, “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.

CONTACT DETAILS

You can contact our Data Privacy Manager at:

Post:

Sorensen Crew Limited

Camperdene House

Chipping Campden

GL55 6AT

United Kingdom

FAO: Data Privacy Manager

Email: dataprivacy@sorensenyachtwear.com

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 (www.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 1st June 2024 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 your personal data changes during your relationship with us.

THIRD-PARTY LINKS

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:

Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender, transaction ID.
Contact Data includes billing address, delivery address, email address, telephone numbers and emergency contact telephone numbers.
Financial Data includes bank account and payment card details.
Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
Technical Data includes internet protocol (IP) address, your login data (including Wi-Fi log-in data and MAC code), 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.
Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
Usage Data includes information about how you use our website, products and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences, and how you interact with our email communications.

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 treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

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 (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

3. HOW IS YOUR PERSONAL DATA COLLECTED

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity, Contact, Transaction, and Financial Data by filling in forms or by corresponding with us by post, phone, mobile messaging, email, or otherwise. This includes personal data you provide when you:
• Buy or express an interest in our products or services, in-store or on our website;
• Create an account on our website;
• Subscribe to our newsletter;
• Request that we send marketing materials to you;
• Enter a competition, promotion or survey;
• Attend a Sorensen promotional event;
• Submit a product review;
• Interact with customer services.
Automated technologies or interactions. As you interact with our website and the emails we send to you, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy for further details.
Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:
• Technical Data from analytics providers such as Google based outside the UK/EU;
• Contact, Financial and Transaction Data from franchise partners and providers of technical, payment and delivery services such as Adyen based outside of the UK, and inside and outside of the EU.
• Identity and Contact Data from data brokers such as Experian based inside and outside the EU.
• Identity and Transaction Data from affiliate networks based both inside and outside the UK/ EU.

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 perform the contract we are about to enter into or have entered into with you.
Where we have your consent.
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.

You have the right to withdraw consent to marketing at any time by unsubscribing via the link provided with each marketing email we send to your or by contacting us at dataprivacy@sorensenyachtwear.com.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity: To register you as a new customer

Type of data:

(a) Identity

(b) Contact

Lawful basis for processing including basis of legitimate interest:

(a) Performance of a contract with you

Purpose/Activity: To process and deliver your order including:

(a) Manage payments, fees and charges

(b) Ensure fulfilment by partners and franchisees

Type of data:

(a) Identity

(b) Contact

(d) Transaction

(e) Marketing and Communications

Lawful basis for processing including basis of legitimate interest:

(a) Performance of a contract with you or your employer

(b) Necessary for our legitimate interests (to recover debts due to us)

Purpose/Activity: To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy notice

Type of data:

(a) Identity

(b) Contact

(d) Marketing and Communications

Lawful basis for processing including basis of legitimate interest:

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

Purpose/Activity: To manage our relationship with you which will include:

(a) asking you to leave a review or take a survey

Type of data:

(a) Identity

(b) Contact

(d) Marketing and Communications

Lawful basis for processing including basis of legitimate interest:

(a) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

Purpose/Activity:

To manage our after sales relationship with you, including:

(a) Assisting you with warranty issues

(b) Contacting you in relation to a product recall

Type of data:

(a) Identity

(b) Contact

(d) Transaction

Lawful basis for processing including basis of legitimate interest:

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

Purpose/Activity: To manage our aftersales relationship with you, including:

(a) Assisting you with warranty issues

(b) Contacting you in relation to a product recall

Type of data:

(a) Identity

(b) Contact

(d) Transaction

Lawful basis for processing including basis of legitimate interest:

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

Purpose/Activity: To enable you to partake in a prize draw, competition or complete a survey

Type of data:

(a) Identity

(b) Contact

(d) Usage

(e) Marketing and Communications

Lawful basis for processing including basis of legitimate interest:

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

Purpose/Activity: To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

Type of data:

(a) Identity

(b) Contact

Lawful basis for processing including basis of legitimate interest:

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

Purpose/Activity: To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

Type of data:

(a) Identity

(b) Contact

(d) Usage

(e) Marketing and Communications

(f) Technical

Lawful basis for processing including basis of legitimate interest:

(a) Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

Purpose/Activity: To share with data analytics providers such as Facebook and Google to generate advertising to potential customers with similar profiles

Type of data:

(a) Identity

(b) Contact

(d) Usage

(e) Marketing and Communications

Lawful basis for processing including basis of legitimate interest:

(a) Necessary for our legitimate interests (to grow our business and to inform our marketing strategy)

Purpose/Activity: To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

Type of data:

(a) Technical

(b) Usage

Lawful basis for processing including basis of legitimate interest:

(a) Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

Purpose/Activity: To make suggestions and recommendations to you about goods or services that may be of interest to you

Type of data:

(a) Identity

(b) Contact

(d) Usage

(e) Profile

(f) Marketing and Communications

Lawful basis for processing including basis of legitimate interest:

(a) Necessary for our legitimate interests (to develop our products/services and grow our business); or

(b) Consent

MARKETING AND OPTING OUT

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You can update your marketing preferences by logging on to your account and selecting the opt-out option. Alternatively, if you would like to continue to receive marketing communications but want to change some features, please contact us at dataprivacy@sorensenyachtwear.com. You may also click ‘unsubscribe’ in any of the marketing emails we send to you.

Opting out of marketing messages will not prevent you receiving non-marketing messages from us, for example relating to products ordered from us, responses to customer service queries etc.

PROMOTIONAL OFFERS FROM US

We may use your Identity, Contact, Technical, Transaction, 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 (this is “marketing”).

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and, in each case, you have not opted out of receiving that marketing. You will also receive marketing communications from us if you have provided us with your details when you entered a competition or registered for a promotion and gave us your consent as part of that process.

THIRD-PARTY MARKETING

We will get your express opt-in consent before we share your personal data with any other company for marketing purposes. However, we may release your personal information to our authorised direct marketing agents who will be sending information to you on our behalf, unless you tell us that you do not wish this to happen.

Your browser is where your cookie information is stored. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. Each browser has a different method for you to delete cookies or edit your privacy settings. The following resource offers you simple guides on how to remove cookies from each browser. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please cookie policy.

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. DISCLOSURES OF 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.

6. INTERNATIONAL TRANSFERS

Some of our external third parties are based outside of the UK so their processing of your personal data will involve a transfer of data outside the UK.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the UK authorities and/or the European Commission. For further details, see https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en

Where we use certain service providers, we may use specific contracts approved by the UK/European Commission which give personal data the same protection it has in Europe. For further details, see https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

7. DATA SECURITY

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.

8. DATA RETENTION

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

We keep your personal data for a limited period of time in line with our data retention policy. The specific retention period will vary according to the reason for processing your personal data. After this period, your data will be permanently erased or otherwise irreversibly rendered anonymous.

9. YOUR LEGAL RIGHTS

You have the following rights under data protection law:

The right to request a copy of the personal data that we hold about you.The right to ask us to correct any inaccuracies in the personal data we hold about you.
The right to withdraw your consent to marketing.
The right to object to our processing of your personal data on the basis of our legitimate interest.
The right to request the deletion of your personal data in certain circumstances.
The right to data portability to transfer your data to another entity.
The right related to automated decision making including profiling. We use profiling to make relevant and tailored recommendations to you. Profiling is the automated processing of personal data to evaluate certain things about an individual, for example, people who are interested in particular designers or products. We do not use automated decision-making processes that would have a potentially damaging effect on you. But if we did, you have the right to obtain human intervention, express your point of view, obtain an explanation of the decision and challenge it.

To exercise any of these rights, you can sign in to your account, contact our team at dataprivacy@sorensenyachtwear.com.

If you believe that Sorensen Crew Limited are processing your data illegally, you have the right to lodge a complaint with the relevant Supervisory Authority. In the UK, this is the ICO.

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.

10. SECURITY

We are committed to taking appropriate technical, physical and organisational measures to protect personal information against unauthorised access, unlawful processing, accidental loss or damage, and unauthorised destruction.

In particular, we use security measures that employ pseudonymisation or encryption of your data to ensure the confidentiality, integrity, and availability of your data as well as the resilience of the systems and services that process them. We have the ability to restore the availability and access to personal data in the event of a physical or technical incident. Furthermore, Sorensen Crew Limited undertakes to test, verify and regularly evaluate the effectiveness of technical and organizational measures in order to ensure continuous improvement in the safety of processing data.