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PRIVACY POLICY

 

LEGAL INFORMATION

This Privacy Policy informs how The Thrifty Gentleman (hereinafter also –” Controller”,” Owner”,” we”, “us” or “our”) processes information and personal data on the website https://www.thrifty-gentleman.com/ as well as any other media form, media channel, mobile website related, linked, or otherwise connected thereto (hereinafter – Website).

We strive to protect all personal information that we receive or generate. This Privacy Policy (“Privacy Policy” or “Policy”) explains our data protection practices for our visitors. This Privacy Policy also explains the nature of the personal information we collect, the means by which we collect it, the purposes for which we collect it, and how we use, process, protect, and share it.

Please read this entire Privacy Policy before submitting information to this Website. By accessing or using this Website for any purpose and by submitting any of your personal information to us, you are consenting to the terms and conditions of this Policy. If you disagree with any part of this Privacy Policy, please do not use this Website or any of our other services and do not share any personal information with us.

Data controller: The Thrifty Gentleman, address: PO Box 815, Winchester, SO23 3UA.

Contact information: e-mail address: contact@thrifty-gentleman.com

 

DEFINITIONS AND LEGAL REFERENCES

 

Personal Data (or Data) - Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.

Usage Data - Information collected automatically through this Website (or third-party services employed in this Website), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Website, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Website) and the details about the path followed within the Website with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.

User - The individual using this Website who, unless otherwise specified, coincides with the Data Subject.

Data Subject - The natural person to whom the Personal Data refers.

Data Processor (or Data Supervisor) - The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.

Data Controller (or Owner) - The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Website. The Data Controller, unless otherwise specified, is the Owner of this Website.

GDPR - the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data.

 

COLLECTING OF DATA

This section explains generally the sources from which, and the means by which, we collect and process personal information.

 

  • Register an account

If you register an account, your information will be used for user profile creation.

  • Order our Products

When you order our products, your shipping address, contact information, payment information, identification information will be used to process your order and deliver our products.

  • Join our mailing list

When you subscribe to our mailing list, your e-mail address will be used to send updates, news and other commercial information.

 

  • Contact us

If you contact us in relation to any of the Services (via email), We may collect and retain your contact details and your communication for the purpose of handling your query and keeping records of communications.

  • Other Means of Collection

We collect personal information by a variety of means and methods, including the following:

  1. When you submit personal information to us voluntarily, communicate with us, pay for our services which may appear on our Website, or use any of our Services;

  2. When you visit our Website, we may collect location and other information from the internet browser you are using;

  3. When your communications with us provide us with certain technical formation, such as internet protocol (IP) address, browser type, time zone setting and location, device operating system, and other technologies you may use to access our Website or otherwise communicate with us;

  4. From third parties and public sources, including from data analytics providers for our own social media pages, like Facebook, Twitter, Instagram.

COLLECTED DATA

The personal information we collect varies by user, transaction, and purpose, but our primary purpose is the efficient and satisfactory conduct of our business and for related legal purposes.

Users are responsible for any third-party Personal Data obtained, published or shared through this Website and confirm that they have the third party's consent to provide the Data to the Owner.

The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as contacting the User and sending emails using mailing list. Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.

Generally, we collect the following data:

  • Information User provides when communicating using our Website, register an account or order our products;

  • Information we obtain from a third party, such as a site or website provider, about use of our Website on third-party websites or devices;

  • Location information, including location information provided by a mobile or other device interacting with our Website (including through beacon technologies), or associated with your IP address, where we are permitted by law to process this information;

  • Activity information about your use, and the use by any person(s) you authorize through your account on our Website, such as the services you provide, how often you use our services, and your preferences; and

  • Usage, viewing, technical, and device data when you visit our Website on third-party sites or websites, or open emails we send, including your browser or device type, unique device identifier, and IP address.

We collect the following categories of Personal data for the following activities:

Visiting the Website

- Browsing data
- Device information

Contacting our support teams

- Identification data.
- Contact data (e-mail address).
- Content of your request.


Allowing the visitors and Users to exercise their data protection rights

- Identification data.
- Contact data.
- Content of the request.
- Data necessary to reply to the request.


Complying with legal requests or manage litigation

- Data necessary to prove our compliance to its obligations and/or manage legal proceedings.


Create an account

- Identification information.

- Contact information.


Connect your accounts

- Personal data from connected accounts (e.g., Facebook account, Google account, etc.).


Order our products

- Identification information.

- Payment information.

- Contact information.

- Shipping address.

 

Subscribe to receive commercial e-mails

- E-mail address.

PURPOSE OF DATA COLLECTION

We use the personal information that we collect or receive from our Users for the purposes described in this Policy and for other business purposes allowed by law, including the development, delivery, and performance of our services, sharing with our affiliates for related business purposes, and as follows:

  • To contact you: To contact you by email, telephone calls or other equivalent forms of electronic communication.

  • To provide services and process your orders.

  • To manage your requests: To attend and manage your requests to us.

  • To respond to your requests and questions, resolve disputes, investigate and address your concerns, and monitor and improve our responses;

  • For testing, research, analysis, and a product and service development, including to improve our Website and services;

  • For facilitating and processing your transactions with us and with our third party affiliates and business partners, if we choose to provide these services;

  • To respond to law enforcement requests and as required by applicable laws, court orders, or governmental regulations;

  • For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, marketing and your experience.

 

METHODS OF DATA PROCESSING

The Thrifty Gentleman takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.

The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to The Thrifty Gentleman, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Website (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by The Thrifty Gentleman. The updated list of these parties may be requested from the Owner at any time.


TRANSFERS AND SHARING OF DATA

Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own.  If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with The Thrifty Gentleman using the information provided in the contact section.

The Thrifty Gentleman may store, process your personal data outside the European Union (EU)/European Economic Area (EEA). In this case, your personal data is processed in UK.

We may share your personal data with following recipients:

 

  • Internal recipients – your Personal data will only be disclosed to authorize employees that require an access to fulfil their obligations (e.g. support teams, developers, etc.). Our employees are specifically trained and made aware of the sensitivity of your Personal data and the requirements necessary to ensure the protection of your right to privacy.

  • Processors – in order to provide the Services, The Thrifty Gentleman may communicate your Personal data to other entities acting as data processors. 

  • Partners and third parties – in order to provide the Services, The Thrifty Gentleman may communicate your Personal data to third party service providers.

  • Judicial, administrative and other public authoritiesThe Thrifty Gentleman may have to share or disclose some of your Personal data if it is required to do so by the law, by a request meaning from a competent authority., to comply with a court order, to obtain legal remedies or defend The Thrifty Gentleman’s rights, to contribute with investigations (e.g. fraud, identity theft, etc.). 

 

RETENTION TIME

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for. Therefore:

  • Personal Data collected for the purposes of a Contract between The Thrifty Gentleman and User shall be retained as long as there is a Contract between the parties.

  • Personal data collected for the purposes of the Consent of the User will be retain for as long as User has given Consent.

  • Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfil such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.

The Thrifty Gentleman may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

 

RIGHTS UNDER GDPR

Users may exercise certain rights regarding their Data processed by The Thrifty Gentleman. In particular, Users have the right to do the following:

  • Withdraw consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.

  • Object to processing of Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.

  • Access Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.

  • Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.

  • Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.

  • Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.

  • Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User's consent, on a contract which the User is part of or on pre-contractual obligations thereof.

  • Lodge a complaint. If you have unresolved concerns, you have the right to complain to the data protection authority – Information Commissioners Office (ICO).

 

Any requests to exercise User rights can be directed to The Thrifty Gentleman through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.

 

If user has any issues regarding data processing done by The Thrifty Gentleman, user can send request to the national supervisory authority.


CHANGES TO THIS PRIVACY POLICY

 

The Thrifty Gentleman reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within this Website and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to The Thrifty Gentleman. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

 

Should the changes affect processing activities on the basis of the User’s consent, The Thrifty Gentleman shall collect new consent from the User, where required.


Latest update: July 21st, 2023
 

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