Last updated 28 February 2022 

1. Introduction 

The purpose of this policy is to explain to you how Boucleme processes, uses and protects  the information we collect about you including procedures that we have in place to safeguard your privacy. The policy applies to our US website, https://boucleme.us (along with any of their sub-domains, extensions and associated domains), and any products and services offered and supplied by us.

By using our websites, you are accepting the practices described in this policy. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

In protecting your privacy Boucleme also ensures it complies with relevant Federal and State legislation including The Telephone Consumer Protection Act (TCPA) and CAN-SPAM Act relating to SMS messaging and the California Privacy Rights Act 2020.

This policy (together with our Terms & Conditions and any other documents referred to in it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.

"Personal data" means any information relating to you that can identify you, directly or indirectly, in particular by reference to an identifier such as a name, email address, an identification number, location data, or an online identifier.

If you have any questions about this privacy policy including any requests to exercise your legal rights, you can contact us via our support page stating that your query is about “data protection”.

Please note that when you provide information to us on a third-party site or platform (for example, via our applications), the information you provide may be separately collected by the third-party site or platform. The information we collect is covered by this privacy policy, and the information the third-party site or platform collects is subject to the third-party site or platform’s privacy practices.

 

2. Your Data

All the information we collect is used to operate and improve the service we offer you. We are committed to using your personal information only for:

• Processing your order
• Planning and managing our business activities, including analysis of customers' shopping habits, product and style preferences.
• To verify details of your payment method or credit card account.

We will not rent or sell your name, address, email address, payment card information or personal information to any third party. If you have purchased goods from Bouclème, subscribed to our newsletter, entered any of our competitions, or advised us of your postal address and phone number we may occasionally update you on news and special opportunities via your preferred communication channels (email, post and phone)

Information you give us

You may give us information about yourself via forms or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you register, visit or use the Website, place an order on the Website, subscribe to the newsletter, or contact Customer Services. The information you give us may include your name, address, e-mail address and phone number, personal description, photograph, and which products you have purchased from us. In limited circumstances, you may provide us with your card or bank account details.

Information we collect about you

Information we get from your use of our Website.

With regard to each of your visits to the Website we may automatically collect the following information:

— technical information, including the Internet protocol (IP) address used to connect your computer to the Internet; your login information; browser type and version; time zone setting; session length; browser plug-in types and versions; hostname; operating system and platform and computer specifications;

— information about your visit and use of our Website, including the use of certain features or content on our Website; the full Uniform Resource Locators (URL) clickstream to, through and from our Website (including date and time); products you viewed or searched for; page response times, length of engagement with web pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number;

— items you put into your shopping cart including when you have abandoned your cart and this information is used to determine when to send cart reminder messages via SMS or email.

We collect this personal data by using Cookies, in-app analytics tools, and other similar technologies. Please see our Cookie Policy for further details.

Information we receive from other sources.

We work closely with third parties — including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers (such as Google Analytics ) search information providers, and credit reference agencies. We may receive information about you from such third parties.

How we use information we collect

We will use the information you give us:

— to improve customer service and help us respond to your support needs more effectively.

— to meet our obligations arising from any contract entered into between you and us and to provide you with the information, products and services that you request from us;

— to provide you with information about other goods and services we offer that are closely related to those that you have already purchased or enquired about;

— To provide you with service related messages; these may include order updates, account alerts, etc.

— to provide you with information about goods or services we feel may interest you. If you are an existing customer, we will contact you by electronic means (e-mail or SMS) only to provide information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you, and you will be given an option to unsubscribe with each communication. If you have not purchased a product, we will contact you by electronic means only if you have consented to this;

— to notify you about changes to our service and products;

— to provide you with learning and support content to help you make the most of your products;

— to ensure that content from our Website is presented in the most appropriate manner for you and for your computer.

 

We will use the information we collect about you for the reasons above, and also:

— to understand how you use our services and products and further personalise your experience.

— for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;

— as part of our efforts to keep our website safe and secure;

— to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;

— to make suggestions and recommendations to you and other users of our Website about goods or services that may interest you or them.

We may combine information we receive from other sources with information you give to us and information we collect about you. We will use this information and the combined information only for the purposes set out above (depending on the types of information we receive).

 

3. Cookies

Our Website uses cookies to distinguish you from other users of our Website. Cookies are files downloaded from a web server to the PC of a visitor to our website. They provide the owner of a website with personal details about the purchase made from the site and information viewed. This helps us to provide you with a good experience when you browse our Website and also allows us to improve. For detailed information on the cookies we use, the purposes for which we use them, and how to change your Cookie settings, please see Cookie Policy.

 

4. Data Protection

Bouclème may transfer and store your personal information with third parties in locations around the world for the purposes described in this privacy policy. Wherever your personal information is transferred, stored or processed by us, we will take reasonable steps to safeguard the privacy of your personal information. These steps may include implementing standard contractual clauses where recognized by law, obtaining your consent, or other lawful means of transferring personal information. It may also be processed by staff operating outside the Territory who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the fulfilment of your order, the processing of your payment details, and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing.

We take all steps reasonably necessary to ensure that your data is treated securely, with adequate protections, and in accordance with this privacy policy.

Unfortunately, the transmission of information via the internet is not completely secure. We will do our best to protect your personal data, meet our obligation to employ best practices, and avoid unnecessary storage or transfer of your data. However, we cannot guarantee the absolute security of your data transmitted to our Website. Bouclème will have no liability for disclosure of information due to errors in transmission or unauthorised acts of third parties. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

You can check the information that we hold about you by sending us an email at infoUS@boucleme.co.uk. If you find any inaccuracies we will delete or correct them promptly. The personal information that we hold about you will be held securely in accordance with our internal security policy and the law.

 

5. Marketing Preferences and SMS “Opt in” 

When you create an account we will ask you which marketing channels you prefer to be contacted through – email, SMS messaging or by post 

SMS Messaging Consent 

Bouclème respects your right not to receive unsolicited marketing communications via SMS.

We will only send you messages if you have explicitly opted in to receive them, whether on setting up an account or through other interactions with the webstore or marketing platforms. We will record that consent. We specifically do not use 3rd party lists.

Our website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies. We cannot accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

 

6. Opt Out

If you no longer wish to receive marketing messages by email, post or SMS you can remove that consent by contacting us at the email address below and asking to be removed from our list. To unsubscribe from email notifications, you can simply click the “Unsubscribe” link in the footer of any email. We will no longer contact you by those means. 

For SMS you can also opt out from receiving marketing communications by replying STOP to a message you have received.

Please note that from time to time short codes and  telephone numbers we used to operate the Service may be changed. We will notify of such changes.

 

7. Third Party Processors

Any personal data that you disclose directly to third party data processors (summarised below) are subject to such processor’s privacy policy. We take all reasonable steps to ensure that your data is treated securely, with adequate protections when engaging processors on our behalf.

• Payment providers — We use payment providers to process your payment transactions, such as Klarna, Afterpay and PayPal. When you select Klarna as your payment option we will pass to Klarna certain aspects of your personal information, such as contact and order details, in order for Klarna to assess whether you qualify for their payment options and to tailor the payment options for you. General information on Klarna you can find here. Your personal data is handled in accordance with applicable data protection law and in accordance with the information in Klarna’s privacy policy. When you select Klarna as your payment option we will pass to Klarna certain aspects of your personal information, such as contact and order details, in order for Klarna to assess whether you qualify for their payment options and to tailor the payment options for you. General information on Klarna you can find here. Your personal data is handled in accordance with applicable data protection law and in accordance with the information in Klarna’s privacy policy
• Cloud storage providers — We use cloud computing platforms that securely store all of our data, including customer details.
• Email service providers — in order to send you marketing content and transactional emails, we share your details with our email service providers.
• SMS service providers – to send you marketing messages by SMS you phone number is processed by a 3rd party system
• Social Media Platforms — We may make your name and email address available to companies in order to advertise and market our services to you through other platforms on the internet (e.g. Instagram, TikTok, Facebook). See the ‘Marketing’ section of this Privacy Policy above.
• Analytics tools — We use analytics tools to understand the way that users interact with our website. We also collect, use and share aggregated and/or anonymised data (“Aggregated Data”) such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity.
• Stockists and delivery providers — In order to package and mail your orders to you, it is necessary to share your information with stockists and delivery providers.
• Marketing and insights providers — Marketing and insights tools allow us to understand our customers better so that we may continually improve our website, products and customer service experience. We may share anonymised information about our customers to facilitate this process.
• Customer service platforms — When you interact with our Support team, your details are shared with our customer service platform providers.

Feedback forms — when you make a purchase, we engage a third party to request and collate your feedback on our behalf.

 

8. Compliance and cooperation with regulatory authorities

We regularly review our compliance with our Privacy Policy and our statutory duties. When we receive formal written complaints, we will contact the person who made the complaint to follow up. We are willing to work with the appropriate regulatory authorities, including data protection authorities, to resolve any complaints regarding the transfer of personal data that we cannot resolve with our users directly. Please see ‘complaints’ under section 11.

 

9. Your rights 

The rights below are legally are legal requirements for California residents. As we respect your privacy rights we will honour these for all of our customers, irrespective of where they reside. Please note we will need to verify your identity to respond to your request.

• Right of Access – you can ask what information we collect including what information we collect, why we collect it, which category of third parties we share information with and the specific information is held.

• Right to delete – you can request that personal information we hold about you is erased e.g. if the information is no longer necessary for the purposes for which it was collected or processed or our processing of the information is based on your consent and is no longer reasonably necessary to retain it 

• Right of Correction or Completion. If personal information we hold about you is not accurate or is out of date and requires amendment or correction, you have a right to have the data rectified or completed. This can usually be done by via our website

• Consumers’ Right to Limit Use and Disclosure of Sensitive Personal Information - in certain circumstances, you can object to our processing of your personal information or to restrict our use of your personal information.

• Right to know what information sold and shared and to whom.

You can exercise these rights by contacting us using the details in the 'Contact' section below.

10. Children (U16)

Bouclème does not knowingly collect information from any person Under 16. If a child has provided us with personally identifiable information, a parent or guardian of that child may contact us if they would like this information deleted from our records. We will use reasonable efforts to delete the child's information from our databases.

11. Complaints

If you are unhappy about our use of your information, you can contact our data protection team or contact us using the details in the Contact section below.

12. Changes to our privacy policy

Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our Privacy Policy. We will not reduce your rights under this Privacy Policy without your explicit consent. We will also keep prior versions of this Privacy Policy in an archive for your review.

13. Contact

If you wish to exercise any of your rights (Section 10 and 12 above), to ask questions, or have comments regarding this privacy policy please email them to infoUS@boucleme.co.uk.

Bouclème is the trading name of Boucleme LLC, a company incorporated in Delaware and, registered in Illinois.