PRIVACY POLICY

Last date of modification: 1th of March 2019

This privacy policy (“Privacy Policy”) provides you information about how your personal details are used on www.mcgregornewyork.com (“Website”) for the purpose of informing and selling you our products and services as well as maintaining, improving and managing our products and services in order to provide you with the best experience whenever you interact with us in the digital world, as well as in the real world when you visit our stores. McGregor respects the privacy rights of its online visitors and recognises the importance of protecting the privacy of the collected personal information. For this reason, McGregor has instituted strict policies and security measures to protect your personal information.

This Privacy Policy contains the main information on the processing of your personal data carried out by McGregor Retail Netherlands B.V., with headquarters at Tesselschadestraat 20, 1054 ET Amsterdam, as data controller (McGregor or we).

Introduction

In accordance with the European General Data Protection Regulation 2016/679 (“GDPR”), this Privacy Policy aims to give you a clear view of the types of personal information we collect and how we use, share and protect your personal information. It also explains the options you have to control your information. This Privacy Policy applies when you visit and/or use the Website. By using the Website you agree and understand that we may collect, use, store and process your personal information in accordance with this Privacy Policy.

  1. Data that McGregor collects about you
  2. How does McGregor use your data?
  3. Legal basis of the processing
  4. Who will process your data?
  5. Does McGregor share your data with others?
  6. How long do we keep your data?
  7. Social networks
  8. Protection and management of your personal data
  9. Cookies
  10. Minors
  11. Your privacy rights
  12. Complaints
  13. Changes to this information
  14. Contact us

1. Data that McGregor collects about you

McGregor asks for certain personal data to provide you with the products or services you request. For example, when you make purchases, subscribe for our newsletter or create an account.

Data you provide to us

McGregor may collect and process the following:

  • Personal information– this is information we use to identify you and to make sure you are who you claim to be. This includes: name [first, last, initials], date of birth, e-mail address, unique consumer number, password & social media identifiers. 
  • Contact information– this is information we use to reach out to you in order to send you your products, provide you with promotional information and updates on McGregor (only if you have given permission for this), and answer your queries and concerns. This includes for example: phone number, shipping and billing address, e-mail address. We process these data for the performance of the contract between us.
  • Purchase information– this is information we use to process your order. This includes for example: your shopping cart, payment information (credit card number), delivery details, shipping and billing address, customer order number, purchase history with McGregor.  We process these data for the performance of the contract between us.
  • Correspondence- this is information we use for quality control purposes, and to make sure we have complied with your requests or legal requirements. This includes for example: recordings of your call to our customer service centre, notes on your feedback, related call backs, e-mail correspondence with the Customer Service. We have a legitimate interest to process these data.
  • Preference information– this is information we use to make sure you have the best experience whenever we interact. This includes for example: preferred language, Wishlist items, preferred shipping address and browsing preferences. We have a legitimate interest to process these data.

 Note that we do neither collect nor store any payment information on our servers. We do this through third parties, with which we have entered into a data processing agreement, with proper safeguards in place to secure any data or personal information obtained.

Information we get through your interaction with us

We may collect information when you visit or interact with our Website.

  • Social Media information– this is information we use to understand you better, in order to build a better relationship with you as a consumer, create products that you will like, and focus our marketing efforts on messages which you will consider helpful and interesting (based on your online behaviour), as well as optimising your social media. This includes any social media information that is publicly available such as [but not limited to]: social media handles, social media interactions and postings, your “Likes” and other reactions, your social media connections, your photos. This information is provided to us by the social media network (e.g. Facebook, Snapchat, Instagram, etc.) directly or indirectly through agencies we have agreements with. We always ask for your prior consent before we process this type of personal data. 
  • Location information- this is information we use to make sure we provide you with the most relevant information based on your geographical location. This includes for example: your residential location, current log-in location [IP address], GPS data. We always ask for your prior consent before we process this type of personal data. 
  • Device information– this is information we use to secure our network and improve our services and performances. This includes for example: IP address, date and time of the visit, how long you stayed on our Website, the referral URL (if you came to our site via a different site or an advertisement), the pages visited on our site, your browser type, device type, versions, operating system. We have a legitimate interest to process these data.
  • Behavioural/Profile information– this is information we use to make sure we communicate only information that is relevant to you, provide you with the best deals and offerings which you would be interested in, and to maximise your experience as a member. This includes for example: your shopping history, your browsing behaviour, your shopping preferences, in-store interactions. We always ask for your prior consent before we process this type of personal data. 

 We may obtain information by using cookies. A cookie is a small file that is sent to the browser and saved on your device when you visit our Website. Use of cookies helps us to improve our Website and deliver a more personalised experience. Some advertisements on our Website served by third party companies. Please note that these companies may also use cookies to collect information about our users.

2. How does McGregor use your data?

Your personal information is collected and processed by McGregor for purposes which are strictly connected to the use of the Website, its services and the purchase of products on the Website. We will be clear about when we collect your information, how we will use your information, and with whom we might share it. We may use the information in the following ways:

  • To set up and manage your account so you can place orders, and therefore we can:
  • provide our products and services to you;
  • make sure that the items you order are being shipped to you and arrive on time;
  • communicate with you about your orders and your account;
  • To ensure that our Website’s content is presented to you as effectively as possible, so we can:
  • update you on our latest products, news and special offers;
  • provide you with the best service if you contact our customer service;
  • conduct market research and learn about how we can improve our product offerings;
  • make products and services better and to develop new ones;
  • ask for ratings and reviews of services and products;
  • quickly process your order.

3. Legal basis of processing

We process your personal data pursuant to the following legal bases:

Contractual performance      

When we process your data for the conclusion of the purchase agreement of which you are a part, we ensure that we only use the minimum information necessary for the execution of this. This basis legitimises the processing of personal data that takes place in the following activities:

  • Conclusion and execution of a purchase agreement for the products offered on the Website;

  • Registration on the Website and use of services reserved for registered users;

  • Provision of services offered on the Website; and

  • Management of your requests by our customer service.

The provision of your personal data for these activities is a contractual obligation. You are free to communicate your data or not, but in the absence of the requested data, it will not be possible to conclude or execute the agreement and meet your requests. This means that you will not be able to purchase products and you will not be able to use our services and that we will not be able to handle your requests.

Legal obligation

We must comply with legal requirements. We may process your data if this is a requirement related to taxes, sanction legislation, debt, attachments, the prevention of money laundering, financing of terrorism, fraud and excessive lending.

Legitimate interest

We have legitimate interests to process your personal data to run our business, to improve your shopping experience and our Website.

Consent

We will carry out the following processing only if you have given us your express consent:

  • Carrying out marketing activities, such as sending newsletters;
  • Analysis of your browsing and consumption habits within the use of your account, in order to personalise your experience on our site.

If you have given your consent for us to process your personal data, you can withdraw this consent at any time.

4. Who has access to your data?

Your personal data will be processed by our internal staff who are specifically trained and authorised to process it.

In addition, your data will also be transmitted to third parties that we use to provide our services. These so-called data processors have been adequately selected and offer a guarantee of compliance with the rules on the processing of personal data. Data processors have been designated as responsible for the processing and carrying out their activities according to the instructions given by McGregor.

We may also transfer your personal data to police and judicial and administrative authorities, in accordance with the law, for the detection and prosecution of crimes, the prevention and protection from threats to public security, to allow us to ascertain, exercise or defend a right in court, as well as for other reasons related to the protection of the rights and freedoms of others. 

5. Does McGregor share your data with others?

We treat your information with care and confidentiality, and do not share, sell or trade your information with third parties other than as explicitly addressed in this Privacy Policy or when you have given your consent. We use third parties with proper safeguards in place to secure any data or personal information obtained.

To be able to carry out our business, we need to work with a number of third parties who are experts in their partial fields, such as our core service providers. We will also share your information when we are required to comply with a legal request or where we believe it is necessary to protect McGregor or its customers. For example, if McGregor is the subject of attempted fraudulent or criminal activities. We will only share your information with third parties when you have given your consent to do so.

6. How long do we keep your data?

We keep your personal data for a limited period of time, depending on the type of activity that is involved with the processing of your personal data. We retain your personal data after you remove your own account, to the extent necessary to comply with our legal and regulatory obligations, and for the purpose of fraud monitoring, detection and prevention. We also retain your data  to comply with our tax, accounting, and financial reporting obligations. Where we retain data, we do so in accordance with any limitation periods and records retention obligations that are imposed by applicable law.

After this period, your data will be permanently erased or otherwise rendered anonymous in an irreversible way.

7. Social networks

On our Website you may find social plug-ins from various social networks. If you choose to interact with a social network, your activity on our Website will also be made available to social networks such as Facebook, Twitter and Instagram. If you are logged in on one of these social networks during your visit to our Website, the social network might add this information to your profile on this network. We are not responsible for their use of data. Please check the privacy statement for each social network for further information.

8. Protection of your personal information

We have taken appropriate technical and organisational measures to protect your information against any loss, alteration, access or misuse. In particular, we have the following measures in place:

Encryption and security

McGregor has implemented a variety of security measures to maintain the safety of your personal information. All payment information provided by you is transmitted via Secure Socket Layer (SSL) technology, which encrypts your information before it is sent to us to protect the information from unauthorised use. Besides SSL encryption, we use MasterCard SecureCode which represents an extra level of security for you when placing an order. It protects you against misuse of your card number. All payment details are processed through a gateway provider and are not stored or processed on our servers. Although we will do our best to protect your personal information, security cannot be guaranteed.

Third party links

Our Website may include links to external websites operated by other companies. These third party links may collect personal data from visitors to their website. McGregor has no responsibility or liability for the content and activities of these linked websites.

Email subscription

You can sign up for our McGregor newsletter by submitting your email address in the newsletter module found at the bottom of any page on the Website. We do not send the newsletter to online (or registered) visitors unless you have chosen to receive this. All of our email communication contains an unsubscribe button, so at any time you can easily opt out from receiving future emails. You may also contact us to exercise your rights via our contact details.

9. Cookies

When you visit our Website, unique cookies are placed to distinguish your browser from all other browsers that visit our site. For more information you can see our cookie policy.

10. Minors

If you are under the age of 18, we require that you inform and obtain parental or guardian consent before you provide us with your personal information.

11. What rights can you exercise in relation to your personal data?

Rights with respect to the processing of personal data

You have the right to view and change the personal data that we have collected from you. You have the right to object to the processing of your personal data. In certain cases, you can also ask us to limit the processing of your personal data, erase your data, transfer your data to another data controller or have it deleted. If you wish to do any of these, please send a request to our Customer Service via support@mcgregornewyork.com and indicate that it concerns a personal data request.

Please enclose a copy of your identity document so that we can be sure that you are the person submitting the request. Make sure that you black out your passport photograph and your citizen service number. This is to protect your privacy. Also provide your private address. You will receive an overview of your data or a response to your request within one month of your request.

12. Complaints

We hope that you would not need to, but if you do want to complain about our use of your personal data, please send an email with the details of your complaint to support@mcgregornewyork.com. We will look into it and respond to any complaints we receive.  

If you believe that the processing of your personal data has been carried out unlawfully, you can file a complaint with the supervisory authority responsible for compliance with the data protection rules. In the Netherlands, the complaint can be presented to the Data Protection Authority (in Dutch: Autoriteit Persoonsgegevens) via www.autoriteitpersoonsgegevens.nl. If you are not happy with how the complaint is resolved, you can lodge an appeal with the courts.

13. Changes to this information

McGregor reserves the right to make changes to this Privacy Policy without prior notice. Changes will be posted on our Website, with indication of the date of its last update. If you continue visiting the Website you will be automatically bound by the amended Privacy Policy. We therefore advise to check this Privacy Policy on a regular basis. 

14. Contact us

If you have any questions about our use of your information, how to exercise your rights, or about our Policies, you are welcome to contact us using the information below.

Telephone: +31 (0) 20 280 78 90  (Monday through Friday 9:00 a.m. – 5:00 p.m. CET)
Email: support@mcgregornewyork.com