This notice explains how Charles Tyrwhitt Shirts Limited ("We") collects personal data from you, why we collect it, how we process it and where we may disclose it to other entities.
We are committed to complying with the Data Protection Act 1998 and the EU General Data Protection Regulation for the purposes of data protection and privacy.
We use data profiling in order to make the content of our communications to you more interesting and relevant. This means that you will only receive details of our very best offers that have been tailored with you in mind. It also allows us not to waste your time by sending offers that are unlikely to be of interest.
You have the right not to be subject to a decision based solely on automated processing. This includes decisions based on profiling. If you choose to exercise this right, then you will no longer receive offers from us as we base our mailing list on our customers’ purchase history.
If you object to such automated decisions making being made based on your personal data, then please inform the Data Controller and we will ensure that is not done by either us or any organisation that processes your information on our behalf.
Information We May Collect From 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 and process the following data about you:-
Identity Data includes first name last name.
Contact Data includes delivery address, email address and telephone numbers.
Financial Data includes bank account and payment card details.
Technical Data includes internet protocol (IP) address 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.
Transaction Data includes details about payments from you and other details of products you have purchased from us.
Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect and use Aggregated Data such as statistical or demographic data for internal purposes.
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.
The Right to Rectification
You are entitled to have the information that we hold about you rectified if it is inaccurate or incomplete.
If you believe that the information that we hold about you is inaccurate, incomplete or out of date then please let the Data Controller know.
We will also inform any third parties of the rectification in order that they can update their records too.
How We Collect Your Personal Data
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Contact, Marketing and Communications Data, Profile Data and Financial Data by filling in forms at www.ctshirts.com or by corresponding with us by post, phone, live chat, email in store, or otherwise. This includes personal data you provide when you
apply for our products;
create an account on our website;
request marketing to be sent to you;
enter a competition, promotion or survey; or
give us some feedback
Use of Our Services by Children
Our website is not intended for the use of children under the age of sixteen. We ask that children do not provide personal information through our website. If we become aware that we have collected personal information from a child under the age of sixteen, then we will delete that information from our records.
Where We Store Your Personal Data
The data that we collect from you may be transferred to, and stored at, a destination outside the European Union ("EU"). It may also be processed by staff operating outside the EU who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with the appropriate EU General Data Protection Regulation Article, including Article 45 - Adequacy Decision, Article 46 - Appropriate Safeguards, Article 47 - Binding Corporate Rules, Article 49 (1) - Specific Situation Exemption or Article 49(2) - Transfer to the Data Subject.
Where we have given you (or where you have chosen) a password which enables you to access certain parts of the website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
We use physical, technological and administrative safeguards to protect your personal information against loss, misuse or alteration. All your personal information is stored securely and may only be accessed by employees with a legitimate business need to access the information. Unfortunately, the transmission of information via the internet is not completely secure and we cannot guarantee the security of your data transmitted to the website. Any transmission is at your own risk.
How We Use Your Information
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 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.
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.
How We Use Your Information
Type of data
Lawful basis for processing including basis of legitimate interest
To register you as a new customer
Necessary for our legitimate interests (to be able to create a profile for customers)
To respond to your enquiry submitted on the site, at one of our local stores or via phone, live chat, post or otherwise
Necessary for our legitimate interests (to provide customers with the products)
To process and deliver your order including:
Collect and recover money owed to us
Marketing and Communications
Performance of a contract with you
Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include:
Asking you to leave a review or take a survey
Marketing and Communications
Performance of a contract with you
Necessary to comply with a legal obligation
Necessary for our legitimate interests (to keep our records updated and to study how customers use our products)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
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)
Necessary to comply with a legal obligation
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
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)
To make suggestions and recommendations to you about our services that may be of interest to you
Marketing and Communications
Necessary for our legitimate interests (to develop our products/services and grow our business)
Direct Marketing Communications
We may use your data to enable us to send you post and emails with information about our goods and services that we believe may be of interest to you. You will receive marketing communications from us if you have requested information from us or purchased goods from us and, in each case, you have not opted out of receiving that marketing. We may permit trusted retail partners to use your data in order to provide you with information about their goods and services by post. We will do this when we believe it is in our mutual legitimate interest to do so.
By trusted retail partners, we mean organisations operating in the following categories:-
Food and Wine
Gadgets and Entertainment
Health and Beauty
Holidays and Leisure
You have the right to withdraw from or amend the receipt of direct marketing communications. If you would like to do this then simply contact the Data Controller and let us know. If you do decide to do this then you will miss out on news of the fantastic offers that we would like to make you aware of.
Disclosure of Your Information
We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006 or one of our connected companies.
We may disclose your personal information to third parties:-
In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets
If Charles Tyrwhitt Shirts Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets
In addition to the information that we share in order to comply with our legal obligations, we also may share or disclose the information:-
To third parties that process data on our behalf
To our trusted retail partners via data pooling
To any other party with your prior consent
Data pools are groups of retailers who share information on what their customers buy. This pooled information is analysed to understand consumer's wider buying patterns. From this information, customers are sent tailored communications containing suitable offers that should be of interest to them based on what they like to buy. We do not share email addresses for the purposes of data pooling.
We may also exchange your information with other companies and organisations for the purposes of fraud protection and credit risk reduction. Where false information or fraud is suspected, we may pass this information to fraud prevention and law enforcement agencies.
Retention of Data
We retain your information for as long as you hold an account with us. This enables us to maintain an ongoing relationship with you and allows us to service the orders that you place with us. We follow a data retention schedule; this has been put in place to ensure that we retain the minimum amount of personal data about you.
We ask that you not send or disclose any sensitive personal information to us either through our website, post, email, text message, live chat, telephone call or by any other method. For clarity, sensitive personal information means information related to racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background or trade union membership.
In the unlikely event that information that you have supplied us is compromised then we shall notify both the UK Information Commissioner’s Office and you that this is the case. This notification will be made without due delay.
Changes to This Privacy Notice
We review this notice at least annually or after any significant change to our website, processes, systems or because of government regulations. Any changes we may make to our privacy notice in the future will be posted on this page and, where appropriate, notified to you by e-mail. We recommend that you visit this page from time to time to view any changes that we may have made.
Date of Last Review: 3rd April 2018
Date of Next Review: 24th May 2018
The Data Controller
Our Data Controller may be contacted in writing at:-
The Data Controller, Charles Tyrwhitt Shirts LTD, Cottons Centre, Cottons Lane, London. SE1 2QG
Or by email at email@example.com
The Data Protection Officer
Our Data Protection Officer may be contacted in writing at:-
The Data Protection Officer, Charles Tyrwhitt Shirts LTD, Cottons Centre, Cottons Lane,
London, SE1 2QG
Or by email at DPO@ctshirts.co.uk
If you have a complaint relating to our data protection or data privacy then please email the Data Protection Officer.
If you are unhappy with the final response that you receive from us in relation to a complaint, then you have the right to complain to our supervisory authority – the UK Information Commissioner’s Office. For further information, please visit https://ico.org.uk/concerns/
As from the 25th of May 2018, the EU General Data Protection Regulation replaces the Data Protection Act 1998. This gives you new rights in relation to the privacy of your personal information. As treating customers fairly is part of our culture, we are not going to wait until May to do this and we have provided a brief explanation below of how you can use those rights.
In the case of any request involving one of your rights, we will respond to your request without delay and at most within one month of receipt of your request. We are permitted to extend this time period by up to two additional months if your request is particularly complex.
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correctionof the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Legitimate Interestmeans the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contractmeans processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
The information contained herein is the property of Charles Tyrwhitt and may not be copied, used or disclosed in whole or in part except with the prior written permission of the Chief Information Officer.