1. OUR APPROACH TO PRIVACY

1.1. Sellier Limited, trading as Sellier Knightsbridge, ("Sellier", "we", "our", or "us") is committed to protecting and respecting your privacy. This privacy policy sets out how we collect, store, process, transfer, share and use data that identifies or is associated with you ("personal information") when you browse our website (www.sellierknightsbridge.com) and access our services, as well as information regarding our use of cookies and similar technologies. 

1.2 If you have any questions about this privacy policy or how we use your personal information, please contact us using the details at the end of this privacy policy.

2. WHO IS RESPONSIBLE FOR YOUR PERSONAL INFORMATION

Sellier is the data controller of the personal information we hold about you. This means that we determine and are responsible for how your personal information is used.

3. PERSONAL INFORMATION WE COLLECT ABOUT YOU AND HOW WE USE IT

3.1 We collect personal information that you voluntarily submit directly to us when you use the Sellier website. This can include information you provide to us when you place an order, correspond with us by phone, e-mail or otherwise, subscribe for our marketing communications, or use some other feature of the website.

3.2 This information will typically include your contact details. We will indicate to you if the provision of certain personal information is mandatory or optional. If you choose not to provide any personal information marked as mandatory, we may not be able to respond to your queries, provide other services to you or respond to your other requests.

3.3 The table at Annex 1 sets out in detail the categories of personal information we collect about you and how we use that information when you use the Sellier website, as well as the legal basis we rely on to process the personal information and recipients of that personal information.

4. INFORMATION WE COLLECT ABOUT YOU AUTOMATICALLY

4.1 We also automatically collect personal information indirectly about how you access and use the Sellier website, and information about the device you use to access the Sellier website, read our emails, or otherwise engage with us. We use this information to provide to you the features and functionality of the Sellier website, to monitor and improve the Sellier website and to develop new products and services. We typically collect this information through a variety of tracking technologies, including cookies, web beacons, embedded scripts, pixels, file information, and similar technologies.

4.2 The table at Annex 2 sets out in detail the categories of personal information we collect about you automatically and how we use that information. The table also lists the legal basis we rely on to process the personal information and recipients of that personal information. For more information on cookies and other tracking technologies we use, please see Section 8 below.

4.3 We may link or combine the personal information we collect about you and the information we collect automatically. This allows us to provide you with a personalised experience regardless of how you interact with us.

4.4 We may anonymise and aggregate any of the personal information we collect (so that it does not directly identify you). We may use anonymised information for purposes that include testing our IT systems, research, data analysis, improving the Sellier website and our services or developing new services and features. We may also share such anonymised and aggregated information with others. 

5. HOW LONG WE KEEP YOUR PERSONAL INFORMATION

5.1 We will store the personal information we collect for our own purposes for no longer than necessary for the purposes set out and in accordance with our legal obligations and legitimate business interests.

5.2 To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and the applicable legal requirements.

6. RECIPIENTS

6.1 As required in accordance with how we use your personal information, we may share your personal information with the following: 

a. Service providers and advisors. We may share your personal information with third party vendors and other service providers that perform services for us or on our behalf, which may include providing mailing, delivery, email or payment services, fraud prevention, web hosting, or providing analytics services. 

b. Purchasers and third parties in connection with a business transaction. Your personal information may be disclosed to third parties in connection with a transaction, such as a merger, sale of assets or shares, reorganisation, financing, change of control or acquisition of all or a portion of our business.

c. Law enforcement, regulators and other parties for legal reasons. We may share your personal information with third parties as required by law or if we reasonably believe that such action is necessary to (i) comply with the law and the reasonable requests of law enforcement; (ii) detect and investigate illegal activities and breaches of agreements; and/or (iii) exercise or protect the rights, property, or personal safety of Sellier, its users or others.

7. MARKETING AND ADVERTISING

7.1 From time to time we may contact you with information about our products and services, including sending you marketing messages and asking for your feedback on our products and services.

(i) Most marketing messages we send will be by email. For some marketing messages, we may use personal information we collect about you to help us determine the most relevant marketing information to share with you.

(ii) We will only send you marketing messages if you have given us your consent to do so. You can withdraw your consent at a later date by clicking on the unsubscribe link at the bottom of our marketing emails. We make every effort to promptly process all unsubscribe requests. You may not opt out of service-related communications (e.g., account verification, transactional communications, changes/updates to features of the Sellier service, technical and security notices).

8. COOKIES AND SIMILAR TECHNOLOGIES

8.1 The Sellier website uses cookies and similar tracking technologies to distinguish you from other users of the Sellier website. Cookies are pieces of code that we transfer to your computer's hard disk for record-keeping purposes. This helps us to provide certain functionalities of the Sellier website, to monitor and improve the Sellier website, as well as to allow our partners determine products and services that may be of interest to you and to display relevant advertising to you as you browse the Internet.

8.2 We use the following types of cookies:

i. Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of payment services.

ii. Analytical/performance cookies. They allow us to recognise and count the number of visitors, to see how visitors move around the Sellier website when they are using it and to monitor the performance of certain features on the Sellier website. This helps us to improve the way the Sellier website works, for example, by ensuring that users are finding what they are looking for easily and to test the rollout of new features. 

iii. Functionality cookies. These are used to recognise you as you move around the Sellier website and to remember information that you enter when you use the Sellier website, such as when you fill in a form.

iv. Third party cookies. Please be aware that advertisers and other third parties may use their own cookies tags or other technologies when you click on an advertisement or link to or on our website. These third parties are responsible for setting out their own cookie and privacy policies.

8.3 Annex 3 contains more information about the cookies we use and how long they remain on your device. 

8.4 If you do not wish to receive cookies, most browsers allow you to change your cookie settings. Please note that if you choose to refuse cookies you may not be able to use the full functionality of the Sellier website. These settings will typically be found in the "options" or "preferences" menu of your browser. 

9. STORING AND TRANSFERRING YOUR PERSONAL INFORMATION

9.1 Security. We implement appropriate technical and organisational measures to protect your personal information against accidental or unlawful destruction, loss, change or damage. All personal information we collect will be stored on our secure servers. We will never send you unsolicited emails or contact you by phone requesting your account ID, password, credit or debit card information or national identification numbers.

9.2 International transfers of your personal information. The personal information we collect may be transferred to and stored in countries outside of the jurisdiction you are in where we and our third party service providers have operations. If you are located in the UK or European Economic Area ("EEA"), your personal information may be processed outside of the UK or EEA; these international transfers of your personal information will be made pursuant to appropriate safeguards, including:

a. ensuring that the personal information is transferred to countries recognised by the European Commission or the UK Secretary of State (as applicable) as offering an equivalent level of protection; or

b. ensuring that such transfer is to a third party that is a member of a compliance scheme recognised as offering adequate protection for the rights and freedoms of data subjects, as determined by the European Commission or the UK Secretary of State (as applicable).

9.3 We will take appropriate steps to ensure that your personal information is treated securely and in accordance with applicable law and this privacy policy regardless of where it is processed.

9.4 If you wish to enquire further about the safeguards we use, please contact us using the details set out at the end of this privacy policy. 

10. YOUR RIGHTS IN RESPECT OF YOUR PERSONAL INFORMATION

10.1 In accordance with applicable privacy law you have the following rights in respect of your personal information that we hold:

(a) Right of access. You have the right to obtain:

(i) confirmation of whether, and where, we are processing your personal information;

(ii) information about the categories of personal information we are processing, the purposes for which we process your personal information and information as to how we determine applicable retention periods;

(iii) information about the categories of recipients with whom we may share your personal information; and

(iv). a copy of the personal information we hold about you.

(b) Right of portability. You have the right, in certain circumstances, to receive a copy of the personal information you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal information to another person.

(c) Right to rectification. You have the right to obtain rectification of any inaccurate or incomplete personal information we hold about you without undue delay. 

(d) Right to erasure. You have the right, in some circumstances, to require us to erase your personal information without undue delay if the continued processing of that personal information is not justified. 

(e) Right to restriction. You have the right, in some circumstances, to require us to limit the purposes for which we process your personal information if the continued processing of the personal information in this way is not justified, such as where the accuracy of the personal information is contested by you.

10.2 You have a right to object to any processing based on our legitimate interests. There may, depending on the particular circumstances, be compelling reasons for continuing to process your personal information despite your objection, and we will assess and inform you if that is the case. You can object to marketing activities for any reason.

10.3 If you wish to exercise one of these rights, please contact us using the contact details at the end of this privacy policy. 

10.4 You also have the right to lodge a complaint to your local data protection authority. If you are based in the European Union, information about how to contact your local data protection authority is available here. If you are based in the UK, information about how to contact your local data protection authority is available here.

11. LINKS TO THIRD PARTY SITES

The Sellier website may, from time to time, contain links to and from third party websites, including those of our partners, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. Please check the individual policies before you submit any information to those websites.

12. OUR POLICY TOWARDS CHILDREN

The Sellier website is not directed at persons under 18 and we do not knowingly collect personal information from children under 18. If you become aware that your child has provided us with personal information, without your consent, then please contact us using the details below so that we can take steps to remove such information as quickly as possible.

13. CHANGES TO THIS POLICY

We may update this privacy policy from time to time and so you should review this page periodically. When we change this privacy policy in a material way, we will update the "last modified" date at the end of this privacy policy. Changes to this privacy policy are effective when they are posted on this page.

14. NOTICE TO YOU

If we need to provide you with information about something, whether for legal, marketing or other business related purposes, we will select what we believe is the best way to get in contact with you. We will usually do this through email or by placing a notice on the Sellier website. 

15. CONTACTING US

15.1 Please contact shop@sellierknightsbridge.com if you have any questions, comments and requests regarding this privacy policy. 

15.2 This privacy policy was last modified on 14 June 2022.

ANNEX 2 – PERSONAL INFORMATION COLLECTED AUTOMATICALLY

ANNEX 3 – COOKIES