Issued: 9th April 2024
Our Policy
- We take your privacy and security very seriously and this Privacy Policy (Privacy Policy) sets out how any personal information you provide when you use/access our website (thebiascut.com) (the BC Website) or otherwise use/access/interact with us (including Ageism Is Never In Style (AINIS), a registered trade mark and a trading name of ours) is used and protected.
- Appropriate physical, electronic and managerial procedures are in place to safeguard and secure the information we collect online. But no data transmission over the Internet or electronic storage can be entirely secure, so we cannot guarantee the security of your personal information and/or use of the BC Website or other use of, or interaction with, us or our services.
- We need your personal information in order to provide services to you. If you do not wish us to collect or process your personal information you should not use our services.
- We may update the Privacy Policy at any time we consider appropriate. The amended Privacy Policy will become effective once posted on the BC Website.
- We also refer you to the privacy policies of Shopify and third parties we work with to provide products and services to you. The Schedule to this Privacy Policy (the Schedule) provides links to these and a summary of what we use these organisations for.
- In this Privacy Policy the term EEA means the European Economic Area. Other expressions used have the meaning given them in our Terms of Use. Headings used in the Privacy Policy are only to assist you in finding your way around it.
Shopify
- The BC Website is hosted by Shopify which provides the e-commerce platform that enables us to provide products and services to you.
- When you visit the BC Website, place an order, sign up for a BC Website account or use the BC Website’s other services or features, Shopify collects personal information about you, such as your name, email address, shipping and billing addresses, payment details, company name, phone number, IP address and device data. If you submit a message on the BC Website Shopify will collect that personal information. Shopify may also collect any other information you provide.
- Shopify collects your personal information directly or by cookies, widgets or other means. When you visit or browse the BC Website Shopify collects information about the device and browser you use, your network connection, your IP address and information about cookies installed on your device (see our Cookies Policy for further information on the use of cookies and how to delete or disable them).
- Shopify needs this information to enable us to provide products and services to you, including supporting and processing orders, and for authentication and processing payments. It also uses this information to improve its services.
- Shopify may transmit and/or process your personal data outside the EEA. If you are located in the EEA your personal information is processed by Shopify’s Irish affiliate, Shopify International Ltd. As part of Shopify’s service it may transfer your personal information to other regions, including to Canada and the United States (U.S.) and may store your personal data in the U.S.
- Shopify follows industry standards on information security management to safeguard your personal information and has protections in place at every step of its data flows. To protect your information when its transferred out of the EEA Shopify relies on the EU-U.S. Privacy Shield Framework as well as inter-company agreements between Shopify’s affiliates that may process your information for Shopify International Ltd. Shopify has certified that it adheres to the Privacy Shield Principles of notice, choice, accountability for onward transfers, security, data integrity and purpose limitation, access, recourse, enforcement and liability. You can find this certification statement at https://www.privacyshield.gov. Data transferred to Canada is protected under The Personal Information Protection and Electronic Documents Act of Canada.
- Shopify is also applying for approval of Binding Corporate Rules (BCRs) by the Irish Data Protection Commissioner and, once they are approved, will rely on these BCRs to protect personal data transferred between Shopify’s corporate entities worldwide. But no method of transmission over the Internet or method of electronic storage is 100 per cent secure, so neither we nor Shopify can guarantee the absolute security of your personal information.
- Shopify works with sub-processors and other third –parties to help us provide services to you. Shopify shares your personal information with such third- parties and they may, collect, use, retain and disclose your personal information in accordance with their privacy policies. Shopify remains responsible for any personal information transferred to a sub-processor or other third- party abroad for processing or to support its efforts.
- Any personal information transferred to a sub-processor for data processing is subject by law to a comparable level of protection as provided by Shopify. In certain circumstances Shopify may be required by law to share information with third parties or may share it to investigate or take action regarding illegal activities, potential fraud or physical threats. It may provide personal data, where permitted, to prevent, investigate or respond to violations of any agreements with Shopify. You also agree to Shopify sharing personal information with any company that acquires the Shopify business.
- If you use a direct payment gateway to make payment for a purchase from us Shopify will store your credit or debit card data but for only as long as is necessary to complete your purchase transaction. After your purchase transaction is completed your purchase transaction information is deleted other than the type of payment card used and the last four digits of your card..
- Your purchase transaction data is encrypted through the Payment Card Industry Data Security Standard (PCI-DSS). All direct payment gateways adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council. Shopify is certified as a PCI DSS Level 1 compliant service provider, which is the highest level of compliance available, and its platform is audited annually by a third party qualified security assessor. However no transmission of information over the Internet or method of electronic storage is 100% secure.
- When processing a request for erasure of personal information Shopify will anonymise the personal data and keep non-personal data such as revenue information and order detail (such as the payment gateway used, time of sale, amount paid). If we stop using Shopify it will purge all personal data within 90 days of our doing so.
Working with Third-Parties
- We also use Apps to provide products, services and other activities and/or opportunities to you and these are listed in the Schedule with links to their privacy policies.
- We work with third-parties to help provide services to you.
- You agree to us providing your personal information to those third-parties to support these efforts, and to such third-parties collecting, using, retaining and disclosing your personal information. This may involve your personal data being transferred, stored and processed outside the EEA. The privacy policies of the third parties listed in the Schedule give information about this and how they protect your data.
- So as to offer you Klarna’s “Pay in 3” option, we will pass to Klarna certain of your personal information, such as contact and order details, in order for Klarna to assess whether you qualify for this payment option. Your personal data is handled in accordance with applicable data protection law and in accordance with the information in Klarna’s privacy policy. There is a link to their privacy policy in the Schedule.
- In general third-party providers used by us will only collect, retain, use and disclose your information to the extent necessary to allow them to perform the services they provide. For more information you can find links to third party privacy policies in the Schedule. For example, certain third-party service providers, such as payment gateways, and other payment transaction processors, have their own privacy policies in respect of the information we are required to provide to them for your purchase-related transactions. We recommend you read their privacy policies to understand how your personal information will be handled by them.
Other Times Data is Received
- When you create a BC Website account, submit an order on the BC Website, subscribe to its ‘Style Club’, complete the Ageism Is Never In Style Share Your Story Form on the BC Website or otherwise use our services or interact with us (such as applying to or via us in response to a modelling call out), you provide the personal information we ask for.
- We also receive information about you when you browse the BC Website. We use web analytical tools, such as Google Analytics, to help us learn about the traffic our site receives and how it is used, such as who visits it, when and where from and what pages are being viewed. This data is general and does not identify the individual to whom it relates.
- We/Shopify/third -parties we use to provide services may also receive personal information about you from the computer, mobile phone or other device you use to access the BC Website or BC Blog or to otherwise interact with us.
- If you access the BC Website using an application programming interface (API) with a third- party website this may involve a third-party website transferring information about you to us/Shopify/third-parties we use to provide services, and us/Shopify/third-parties we use to provide services transferring information about you to that website. Your agreement with that website will determine how it uses, stores and transfers your personal information.
- We cannot be responsible for the privacy and security of any information you provide a third-party website or application and you should read its terms and conditions and privacy policy.
Cookies
- The BC Website/Shopify/third- parties we use to provide services use cookies and similar technologies. Our Cookies Policy tells you more about what cookies are, what cookies are used with the BC Website and how they are used. It also tells you where to get more information on how to delete cookies on your device or disable future ones.
Our Style Club
- The BC Website has a facility to subscribe to its Style Club. When you apply to join the Style Club we ask for certain personal information, including your name and email address, to enable us to provide the service to you. We share this information with MailChimp and Klayvio, email services we use to assist us in managing the Style Club more efficiently, sending you emails about the Club and information about our products and services, and to conduct market research to enable us to improve our services and the BC Website. MailChimp or Klayvio may share your personal information with third-party sub-processors to help them deliver services to you. Those sub-processors/we/Mailchimp/Klayvio may also receive personal information about you from the computer, mobile phone or other device you use to join the Style Club or, after subscribing to the Style Club, access the BC Website or BC Blog or otherwise interact with us.
- If you subscribe to the Style Club you agree to MailChimp and Klayvio and their sub-processors receiving and processing your personal data (in accordance with their privacy policies) and sending communications to you on our behalf and to your personal data being transferred to, stored and processed in the United States to enable MailChimp and Klayvio and their sub-processors to provide services for us. MailChimp and Klayvio have self-certified their compliance with the EU-U.S. privacy shield and agrees to protect such personal data in accordance with the requirements of the Privacy Shield Principles (see https://www.privacyshield.gov.)
- MailChimp and Klayvio will retain your personal data for as long as needed to provide services to you. It may also retain and use your information to comply with its legal obligations, resolve disputes, prevent abuse and enforce its agreements.
- While you are a member of the Style Club we may use your personal information to;
- send you promotional emails about special offers, new posts to the BC Blog or other information we think you may find interesting; and
- contact you for market research purpose.
If after subscribing to the Style Club you decide you do not wish us to contact you in this way, you can remove yourself from the Style Club via an ‘unsubscribe’ link on any Style Club email or email us at contact@thebiascut.com or write to us at The Bias Cut Limited, 22 Belmont Hill, London, SE13 5BD
Using and Sharing your Data
- We may use your personal information:
- for our internal record keeping; and
- to improve our products and services.
We shall not disclose your cardholder data to any third-party other than in connection with processing a card payment transaction you have requested.
- We may use or share general, demographic or statistical data we receive via BC's websites, and/or BC's and/or AINIS' social media platforms and/or services for internal operations, consultancy and/or marketing case study purposes, statistical analysis, troubleshooting and otherwise improving the BC Website.
- We may share general, demographic or aggregated statistical information with third-parties about the BC Website’s, and/or BC's and/or AINIS's social media user base. We may share statistical data about you alone only with your permission (after giving notice of our intention to do so and removing any identifying information) or as otherwise permitted under this Privacy Policy.
- We shall not give your personal information to a third-party without your express approval except as:
- reasonably necessary to fulfil any service request or process an application to or via us (such as in response to a modelling call out) or customer support (such as performing credit or other security checks or arranging for you to be sent a product you have ordered), or
- we reasonably believe is required or permitted to comply with any tax or other applicable law or regulation, or
- necessary to protect or enforce the rights, property or safety of the BC Website, its users and/or the public, or
- is otherwise permitted under this Privacy Policy.
Your Personal Data and Your Rights
- If you place an order with us our lawful basis for processing your personal data is the contract we enter into with you to fulfil that order. If you subscribe to the Style Club, and/or complete the Ageism Is Never In Style Share Your Story Form on the BC Website and/or submit an application to or via us or via AINIS social media platform in response to a modelling call out and/or accept our cookies we rely on consent as the basis of lawful processing of your personal data. You have the right to withdraw consent at any time but this will not affect the lawfulness of processing based on consent before its withdrawal.
- We retain your personal information for only as long as we need to in order to provide a service to you and others or if retention is reasonably necessary to comply with our legal or regulatory obligations or is otherwise permitted under the Terms.
- If you wish us to no longer collect, use, process, retain or disclose your personal data at any time you can:
- if you have completed the Ageism Is never In Style Share Your Story Form on the BC Web site and wish to withdraw any consent you have given under it, email us at ageismisneverinstyle@thebiascut.com.
- in any other case, email us at contact@thebiascut.comor write to us at The Bias Cut Limited, 22 Belmont Hill, London, SE13 5BD
Personal data cannot be erased from Shopify if it’s associated with a pending order or an order made less than 180 days prior to the request for it to be deleted.
- You may contact us at contact@thebiascut.com to request a copy of the personal information we hold for you; to obtain confirmation whether your personal data are being processed; or to be provided with additional information about the processing. We shall comply with your request within one month and may require proof of identity before doing so. We do not charge for a copy of your personal data undergoing processing but may charge an administration fee of £10 for each additional copy requested.
- If you believe we are holding information about you which is incorrect or incomplete, please amend your account details accordingly on the BC website or contact us as soon as possible at contact@thebiascut.comWe shall correct any incorrect information as promptly as possible.
- If you believe your personal information has been used in a manner not consistent with this Privacy Policy please contact us at contact@thebiascut.com or write to The Bias Cut Limited,
The Bias Cut Limited, Wilmington House, High Street, East Grinstead RH19 3AU. If your complaint or dispute remains unresolved you have the right to take it to the Information Commissioner’s Office at https://ico.org.uk
Schedule
Below is a list of third-parties we work with to provide you with a better service; detailing when they might apply, their purpose, and links to their privacy policies.
General Usage Of Website
Name |
Purpose |
Privacy Policy |
Shopify |
Ecommerce platform that runs thebiascut.com |
https://www.shopify.com/legal/privacy |
Siteground |
Domains Host & Security |
https://www.siteground.co.uk/terms.htm |
Google Adwords, Merchant Centre & Shopping |
Online advertising and remarketing through Google and affiliated partners |
https://policies.google.com/privacy/update#intro |
Facebook Ads |
Facebook advertising & remarketing |
https://www.facebook.com/about/privacy/update |
Instagram Ads |
Instagram advertising & remarketing |
https://help.instagram.com/519522125107875?helpref=page_content |
Pinterest Ads |
Facebook advertising & remarketing |
https://policy.pinterest.com/en-gb/privacy-policy |
Gmail |
The Bias Cut email service |
https://policies.google.com/privacy/update#intro |
Google Business |
Lists The Bias Cut business information on Google |
https://policies.google.com/privacy/update#intro |
Bing Ads |
Online advertising and remarketing through Bing and affiliated partners |
https://privacy.microsoft.com/en-gb/privacystatement |
Compass App |
App that analyses visitor and customer activity |
https://www.compass.co/privacy |
Other Forms
Name |
Purpose |
Privacy Policy |
Jotforms |
Sign ups for activities & surveys and storage of completed forms Ageism Is Never In style Share Your Story Form Ageism Is Never In Style modelling casting calls and modelling opportunities, and partnership modelling casting calls and modelling opportunities |
https://www.jotform.com/privacy/ |
Legal representation: Ceruelan Law