PRIVACY POLICY

 

Freckles — Privacy Policy — 2018

 

Patrick McGlynn Limited , Company Number 481455, trading under the style and title of Freckles having its principal office at Unit 58 ILAC Centre, Parnell Mall, Parnell Street, Dublin 1( hereinafter called “Freckles” , which expression shall where the context so admits or requires , includes it successors, and assigns) owns and operates the websites Freckles.ie and FrecklesChildrensWear.ie ( hereinafter collectively called the “Freckles websites”)

 

For the purpose of the Data Protection Acts, 1988 to 2003 ( the “Acts”) Freckles, is the Data Controller who collects, stores and uses Data collected via the Freckles.ie and FrecklesChildrensWear.ie website and via Till Receipts from sales to Customers who visit Freckles shop at Unit 58 Parnell Mall, Parnell Street, Dublin, Ireland.

The nominated representative for the purpose of the Acts is Padraig McGlynn, who can be contacted at Unit 58 Parnell Mall, ILAC Centre, Dublin 1, Ireland.

 

The combination of the Freckles Terms & Conditions of Service together with the within Freckles Privacy Policy sets out the basis on which any personal data Freckles collects from you, or that you provide to us, will be collected, stored and used by Freckles.

Collection of Personal Data and Online Privacy are important issues so please read our Privacy Policy so you can understand what information Freckles collects directly from Purchase Orders, Till Receipts, Online Forms, Emails and Social Media Posts submitted and collects indirectly from Cookies and Data Analytics.

 

Freckles welcomes you to browse our website, to view our range of Childrens Wear items and to use the general information and published  available on our website or made available through our Social Media profile of Facebook, or other digital platforms.

 

By visiting or using the Freckles websites you confirm your agreement with and acceptance of the following provisions of our Privacy Policy.

If you do not agree to be bound by this Privacy Policy then please cease to use the Freckles websites

 

1.The English Language version of this Privacy Policy dated June 2018 supersedes all previous versions and applies to all categories of User where so ever located in the world, and applies in respect of all Websites, APP`s, User Forums, Social Media Pages and Customer Databases currently operated by Freckles.

 

2) Freckles reserves the right upon giving 14 days prior notice posted on our website to update, alter or amend the provisions of this Privacy Policy or to introduce an additional new further or supplemental Privacy Policy that is specific to a new or updated product or service or delivery system.

 

3) You agree that all data collected either directly or indirectly by Freckles whether by website and other related platforms such as Online Order Form, APP, Database, Survey Forms, or other platform or service owned or operated by Freckles can be collected, stored, processed, managed by or transferred to any person or persons, company, organisation or Institution or other legal entity as Freckles may choose from time to time in its sole discretion. All Such Data may be archived, analysed, combined with data from other sources, aggregated or sorted and used by Freckles for all purposes.

 

PERSONAL INFORMATION

 

4) Personal information is information about an individual or company that can identify that person or company. To enable Freckles deliver information to you, Freckles needs to understand who you are, and in which town, city and country are you located, and what is your email address, so we ask you those questions when you register to open a Customer Account.

Customers who buy goods from or through Freckles submit their Credit Card details, billing address and name of recipient of the goods or service purchased. Freckles requires these details to process the transaction.

 

Cookies – Information Collection

 

5)Cookies are a piece of computer code that gets sent by Freckles website ( and / or sent by Technology  Providers who provide Support Services  to Freckles), to your computer and placed on your computer hard drive. Freckles and our Technology Providers use data collection technology including Cookies, Confirmation Pixel Tags and Web Beacons. These Cookies contact back to our Freckles website to enable us provide a more personalised service directly to you.

 

Freckles collects information indirectly by using Cookies. A Cookie is a piece of Code that enables your Computer link to our Freckles website and Cookies enable Freckles to collect data such as your IP Address ,Cell Phone ID , Location , page browsing , Language ,search preferences , and customer activity data log across all Freckles websites and services , so we can aggregate the Data collected both directly and indirectly to form a full profile of  your Customer preferences.

All information collected by Freckles is used to enhance the customer experience by sending targeted information, links, advertising and content, relevant to your Customer Preferences.

 

• The Browser on your computer is usually configured to accept Cookies, but you can change your browser settings to stop accepting cookies. If you disable the Cookie settings you may have difficulty accessing and using some of the interactive features of Freckles websites.

 

• By way of example the type of Cookies used by this Freckles website and their purpose are as set out below. Freckles will seek your consent to use cookies the first time you visit this website (or on subsequent occasions if the cookie that records such acceptance is deleted). Denial of the cookies used by this website may prevent parts of the website from working properly.

1. a) Header Cookie – tells the browser to store the data in a text file.
2. b) Google Analytics Cookie – shows whether or not access to the Freckles website site came via a search engine (eg Google) and it provides Freckles with information about amount of visits for each visitor to the site, how many webpages a visitor views, how long they view the Webpages, the approximate City and Country location from where the User viewed the Website..
3. c) Session Cookies – to remember your log-in for you and which Products you have selected to put into your shopping basket.
4. d) Sharing Tools – If you use social networks, such as Facebook, YouTube and Twitter, to share information from the Freckles website, you may be sent cookies from these websites. These cookies are out of our control and you should check these third-party sites for further information.

 

Using Cookies makes it possible for Freckles to:

6.1) Know you are a regular customer, let you login fast and to present your Account profile data page to you when you login.

6.2) Save your information to your Account and let you use interactive features

6.3) Log individual User patterns such as IP Address, Page Clicks, Search preferences, Date , time spent reading page, location and compare this against wider user database.

6.4) If we understand more about you we can send you relevant Product or Service details and relevant Newsletters , Special Offers  and Emails, but you can decline to accept the Emails and Newsletters by clicking on the unsubscribe link at end of the email.

6.5) We collect Click-Through Data if you click on a banner.

6.6)Pixel tags tell us if a message that we send to a Customer has been opened.

 

Use of Information Collected

 

7) The main reasons why Freckles collects information are:

 

7.1)To enable us prioritise the Content that we have available and to display content that is directly relevant to you.

7.2) Freckles generates sales revenues primarily by selling Childrens Wear but we also sell advertising services on our website, so we use the information to target advertising.

7.3) Freckles uses the Credit Card details to validate the Card and to deliver the goods or services to the nominated consumer of the goods or services purchased.

7.4) Freckles may send Special Offers to existing Customers or display special offers to website Viewers and/or  send them notification that time periods to avail of Special Offers  are due to expire and send them reminder.

7.5) Freckles may use the information to send you Service Updates , Product Updates , new features, Special Offers and to warn you of any expiration of relevant time deadlines.

7.6) The information collected helps Freckles develop new Services , new Products, new features and to understand our Customers needs by conducting Surveys.

7.7) To protect legal rights of Freckles, and the rights of our Product Suppliers and Service Providers and to prevent fraud.

7.8) To answer Queries and to assist in resolving disputes.

• Freckles generally contacts our Customer Base via Email, Newsletter , targeted Advertising on screen and targeted contact via Freckles Social Media Community on Facebook ,
• Some Customers provide Freckles with details of mobile phone number and Freckles may send text message with details of Special Offers, details of Order Conformation or Order Shipment, but the Customer can unsubscribe at any time and decline to receive text message from Freckles.

 

Sharing of Information

 

• Freckles makes a great effort to ensure your personal details are stored securely and not hacked or accessed by unauthorised persons.

Freckles uses Secure Sockets Layer (SSL) encryption on all website pages on which Personal Data is gathered.

 

Freckles Employees have signed non-disclosure agreements and are trained to implement data governance procedures.

Freckles will not share or disclose your Personally Identifiable information details with any other third party except as authorised by you, and you confirm that you authorise Freckles to share and disclose the said information as follows:

 

8.1) If you access the Freckles Social Media on Facebook or any other public platform where Freckles has a User Profile, you may choose to display some identifiable information such as Name, Photos, Location and comments. Alternatively you can choose a User ID and Avatar. So please choose you Privacy Setting carefully and be careful about what User ID Name you choose and what Pictures and content you upload because all of the information which you upload on public forums, is automatically accessible to Search Engines and publicly viewable by all users of social media platforms.

 

8.2) If you click on a Banner Advertisement, Email Link or Newsletter that contains an advertisement for a third party supplier you may choose to send information to that Advertiser. Organisations that advertise on Freckles website, are separate legal entities and each will have its own Privacy Policy and Terms of Service and Freckles has no control over or liability for the acts or omissions of other organisations and their Privacy Policy.

 

8.3) Freckles may disclose information to any Bank, any relevant Payment Processing Service Providers including PayPal, Stripe or Realex,  and /or any Debit or Credit Card Processing company to enable transaction be cleared or processed and if there is any suspicion of misuse of a Debit Card or a Credit Card we may report the matter to law enforcement authorities and to any Bank, Payment Processing Service Provider, Debit Card issuer or Credit Card issuer.

 

8.4) All products  sold by Freckles are intended for use by one individual and if a Customer seeks to resell any products sold by Freckles on a commercial basis or to rent out or share such products on a commercial basis with multiple users, Freckles reserves the right to suspend or close your account and to report the matter to the appropriate authorities and to use the information to take legal proceedings.

 

8.5) Freckles shares information with our Service Providers such as our Global Partners , Local Auditing companies, Customer Order Fulfilment  companies, Data Processing companies, Translation Companies, Training Providers, Mobile Phone Device Companies and phone service Carriers, Delivery company or other local service providers from time contracted by Freckles to assist us in delivery of our Products and Services.

 

8.6) Some Freckles products and services may be sold through agents and third parties such as Amazon, eBay, or other online marketplace or other intermediary and it may be necessary to share information with that intermediary to enable Freckles to deliver the Products or Service and to monitor payment collection and shipment of the Products.

 

8.7) In the event of a Sale, partial Sale of a business unit, Merger or reorganisation Freckles may sell, licence, transfer or assign part or all the intellectual property that comprises our database and all information contained therein, to the relevant Buyer or Third Party.

 

• Freckles may disclose information if we receive Warrants , Legal Proceedings , requests for Legal Discovery of records , Subpoenas or if we are subject to lawful Government Inspection .

 

Unauthorised Use of Information

9) If any User or Customer or other person using a Freckles Social Media pages,  seeks to misbehave by sending spam, rude or offensive content, nuisance messages, unauthorised or inappropriate content to other members or to any third parties, Freckles can investigate, suspend or delete your customer account and report the matter to the Authorities.

 

Freckles will never ask you for your password details and you should never reply to any Phising style email that purports to ask you for your personal password.

If you feel that you password has been compromised then you should change your password.

If as a result of your actions or omissions you allow somebody else to use your login password and they cause loss or harm, you may leave yourself open to legal liability, so be careful not to share your login password.

 

Please take care to protect the confidentiality of your login password as other third parties, perhaps using spyware, malware , Phising emails or Trojans may seek to unlawfully intercept your Private Information from your computer while it is being transmitted to us, or to misuse the public information such as your photo or identity that you have publicly posted on Freckles Social Media pages.

Please inform Freckles of any such complaint and Freckles reserves the right to share information that with any Persons or Authorities relevant to resolving any complaint received.

 

10) As a Customer of Freckles you personally agree that you will respect the Privacy of other Customers and comply with all laws and regulations in your home country regarding copyright, privacy and use of Content.

 

Data Analytics

11) To enable Freckles to understand Consumer patterns and preferences Freckles may collate data from across the website and across our range of products and services to enable us improve our products, plan our Stock Levels of Products, plan our allocation of resources and for marketing purposes to increase future sales. To enable Freckles work with our user audience , Customers and commercial business partners, Freckles may from time to time compile reports and share or sell the results of the general market Data Analytics Reports without specifying results that are specific to any one single Customer.

 

Status Report on your Personal Information

• Upon receving a Data Subject Access Request in writing and upon payment of the fee of €5.00 plus 23% VAT, total €6.15, Freckles may furnish you with a copy of your personal data that you submitted to our website and any personal data relating to you, which Freckles has stored in Paper Files or other Media Format.

Before Freckles can accede to any such request Freckles may ask for formal proof of identity so that you to fully identify yourself and if you wish to obtain such copies of your personal information, you must send a letter by registered post to Freckles at Unit 58 Parnell Mall, ILAC Centre, Parnell Street, Dublin 1, Republic of Ireland, together with a Bank Draft payable to Freckles in the sum of €6.15. Please note that to assist Freckles to trace and compile a record of all your relevant personal information, you should include within your Letter full details of any personal identifiers which you supplied previously supplied to Freckles via the website (e.g. Name; address; phone number; e-mail address, Customer Account Number, Order Number, Shipping Address, name of Credit Card Holder ).

Freckles will endeavor to comply with and to process all reasonable Data Subject Access Requests within 20 working days.

If you believe that Freckles holds any inaccurate information about you, you can request Freckles to correct that information. Such a request must be in writing by registered post to Freckles at Unit 58 Parnell Mall, ILAC Centre, Parnell Street, Dublin 1, Ireland.

In certain circumstance, you may also request that data which you have supplied via the website be deleted.If you wish to request a deletion, you would generally be expected to identify some contravention of data protection law as to the manner in which Freckles stores or uses the specified data.

Freckles may decline to process requests in cases where the request may destroy accounting or financial Records, or is repetitious or would involve unjustified effort and expense or could prejudice the privacy of others.

Freckles Contacting You

13) Customers who register their names hereby authorise and give their conent and permission for Freckles to contact them by sending general Notifications, Emails , Special Offers, Discout Vouchers, Coupons, Loyalty Bonus and Newsletters, and Customers who fill in a Contact Request Form, authorise and consent to Freckles contacting them by Email, SMS Text, Letter, or Phone call. If you wish to unsubscribe from Emails, Newsletter or to cancel any Contact Form, please email Freckles via Contact Form on website and we can action your request.

Procedures to Prevent Unauthorized Data Access, Loss or Misuse

14) All Data is stored and processed by Freckles on secure servers. To ensure global high speed access to our website and interactive features we use mirror hosting of our website in several locations.  Freckles has trained its staff and we carry out regular internal reviews to check our security procedures, technology and monitoring and control systems are up to date. As internet data transmission may involve access through Third Party websites access via WiFi and / or third party Internet Carriers, and all persons contacting Freckles acknowledge and confirm that they access the features and use the services of third party providers at their sole risk.

• Freckles is registered as Data Controller with the Office of the Data Protection Commissioner in Ireland DataProtection.ie and our policy is to seek to resolve any complaints by corresponding directly with the person or company affected. In the event of any unresolved complaint concerning transfer of Personal Data it is open to you to report the matter to the Data Protection Commissioner in Ireland which enforces standards set down by EU Directives that are similar to US Safe Harbor Standards.

Contact

16) If you wish to contact us please email us via Contact Form on Freckles website or write to us by registered post at Unit 58 Parnell Mall, ILAC Centre, Parnell Street, Dublin 1, Republic of Ireland.

Freckles  — June 2018