PRIVACY POLICY 

1. WHO ARE WE 

1.1 Watters Designs, Inc,WToo Partners L.P. and Watters Design Europe Ltd (collectively referred to herein as “Watters” or “we”) are the Data Controller of personal information we may collect from you when you do business with us, or that you may provide when you visit our websites at www.watters.com, www.wtoo.com and www.willowby.com (referred to herein as our “Websites”).

1.2 You can contact us at any stage:

1.2.1 By writing to us at:

Watters Design Europe Ltd
Unit 3 West Court
Buntsford Park Road
Buntsford Business Park
Bromsgrove
B60 3DX

1.2.2 By emailing us at:

UKSales@watters.com

1.2.3 By telephone on:

(0)1527 832373

1.3 We respect your privacy and are committed to protecting it through our compliance with this privacy policy (referred to herein as the “Policy”). 

1.4 This Policy also describes our practices for collecting, using, maintaining, protecting and disclosing your personal information.

 

2. This Policy applies to information we collect:

2.1 in provision of our goods and services; 

2.2 on our Websites;

2.3 in e-mail, text and other electronic messages between you and our Websites; and

2.4 when you interact with our advertising and applications on third-party websites and services. 

 

3. Information We Collect About You and How We Collect It

3.1 We collect personal information from and about users of our Websites, our suppliers, our customers and prospective customers including:

3.1.1 your name, postal address, and e-mail address; 

3.1.2 information about your computer hardware and software, such as your IP address, browser type, domain names, access times and referring website addresses;

3.1.3 Payment information if you are a supplier to enable us to pay you, or if you are a customer to enable us to collect payment from you;

3.1.4 Information to assist us with managing our relationship with you;

3.2 The ways that we collect this information are:

3.2.1 from you when you contact us;

3.2.2 from you when you input information into our Websites, for example information provided at the time of registering to use our Websites, subscribing to our services, posting material or requesting further services

3.2.3 From your computer equipment as you navigate through our Websites. Information collected from your computer equipment is automatically collected and may include usage details, IP addresses and information collected through cookies and other tracking technologies;

3.2.4 From Retailers when you order a product or service from us to enable us to provide the product or service, for example your size, occasion date etc;

 

4. Information You Provide to Us

The information we collect from you may include:

4.1 Information that you provide by filling in forms on our Websites. This includes information provided at the time of registering to use our Websites, subscribing to our services, posting material or requesting further services. 

4.2 We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with our Websites.

4.3 Records and copies of your correspondence (including e-mail addresses), if you contact us.

4.4 Your search queries on our Websites.

4.5 You also may provide information to be published or displayed (hereinafter, "posted") on public areas of our Websites, or transmitted to other users of our Websites or third parties (collectively, "User Contributions"). Your User Contributions are posted on and transmitted to others at your own risk. We cannot control the actions of other users of our Websites with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

 

5. Information We Collect through Automatic Data Collection Technologies 

5.1 As you navigate through and interact with our Websites, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including:

5.1.1 details of your visits to our Websites, including traffic data, location data, logs and other communication data and the resources that you access and use on our Websites; and

5.1.2 information about your computer and internet connection, including your IP address, operating system and browser type.

5.2 The information we collect automatically is statistical data and may not include personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Websites and to deliver a better and more personalized service, including by enabling us to:

5.2.1 estimate our audience size and usage patterns;

5.2.2 store information about your preferences, allowing us to customize our Websites according to your individual interests;

5.2.3 speed up your searches; and

5.2.4 recognize you when you return to our Websites.

5.3 The technologies we use for this automatic data collection may include Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website. Please see the section entitled “Cookies” below for more information.

5.4 We encourage you to review the privacy statements of websites you choose to link to from our Websites so that you can understand how those websites collect, use and share your information. We are not responsible for the privacy statements or other content on websites outside of our Websites.

 

6. Use of your Information 

6.1 We use information that we collect about you or that you provide to us, including any personal information:

6.1.1 to perform the contract for goods or services we have with you. We cannot perform our contract with you without your personal data;

6.1.2 to provide you with quotes and/or information about our business. It is necessary to collect personal data about you in order to take these steps to enter into a contract with you and we cannot enter into a contract with you without your personal data;

6.1.3 to enable you to liaise with our approved retailers to book appointments on your behalf. We process this personal data about you on the basis of your consent which can be withdrawn at any time. If you withdraw your consent for us to process your personal data in this way, we will not be in a position to assist you with arranging an appointment with our retailers.;

6.1.4 to operate our Websites. We process your personal data on this basis because it is in our legitimate interests to maintain and operate our Websites. We balance this against any risk to your rights at freedoms. ;

6.1.5 to produce analytical data pertaining to our Websites We process your personal data on this basis because it is in our legitimate interests to obtain and analyse data relating to user trends and other business information. We balance this against any risk to your rights at freedoms;

6.1.6 to inform you of other products or services available from Watters and its affiliates. We process your personal data on this basis because it is in our legitimate interests in growing and developing our business. We balance this against any risk to your rights at freedoms and you can object to this processing at any time and we will cease to do so. Please see paragraph 14 for information on how you can object;

6.1.7 to contact you via surveys to conduct research about your opinion of current products and services, or of potential new products and services that may be offered We process your personal data on this basis because it is in our legitimate interests to understand our customers and website users and to grow and develop our business. We balance this against any risk to your rights at freedoms;

6.1.8 to notify you about changes to our Websites or any products or services we offer. We do this because it is in our legitimate business interests to do so. We balance this against any risk to your rights and freedoms. ;

6.1.9 to allow you to participate in interactive features on our Website;

6.1.10 We may also keep track of the websites and pages our users visit within our Websites, in order to determine what Watters services and products are the most popular. This data is used to deliver customized content and advertising within our Websites to customers whose behavior indicates that they are interested in a particular subject area.

 

7. Disclosure of Your Information

7.1 Watters does not sell, rent or lease its customer lists to third parties.

7.2 Watters may disclose your information:

7.2.1 if required to do so by law.

7.2.2 to allow contractors, service providers and other third parties we use to support our business. For example, we may provide our analytical data to contractors to provide us with analysis of that data.

7.2.3 to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of Watters’ assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by Watters is among the assets transferred.

7.2.4 to fulfill the purpose for which you provide it. For example, if you give us an e-mail address to use an "e-mail a friend" feature of our Website, we will transmit the contents of that e-mail and your e-mail address to the recipients.

7.2.5 for any other purpose disclosed by us when you provide the information or any other purpose with your consent.

 

8. Transfer of your information out of the EEA

8.1 We may transfer your personal information to our affiliated companies with Watters Design Europe Limited, being Watters Designs Inc and WToo Partners LLP, to the United States of America (the "USA") which is located outside the European Economic Area (EEA).

8.2 The USA do not have the same data protection laws as the United Kingdom and EEA.

8.3 Whilst the European Commission has not given a formal decision that the USA provide an adequate level of data protection similar to those which apply in the United Kingdom and EEA, any transfer of your personal information will be subject to a European Commission approved contract (as permitted under Article 46(5), of the General Data Protection Regulation that are designed to help safeguard your privacy rights and give you remedies in the unlikely event of a misuse of your personal information.  

8.4 If you would like further information please contact us. 

 

9. Use of Cookies

9.1 The Websites may use "cookies" to help you personalize your online experience. A cookie is a text file that is placed on your hard disk by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you.

9.2 One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to tell the Web server that you have returned to a specific page. For example, if you personalize a page on our Websites, or register with our Websites or services, a cookie helps Watters to recall your specific information on subsequent visits. When you return to our Websites, the information you previously provided can be retrieved, so you can easily use the features that you customized.

9.3 You have the ability to accept or decline cookies. Most Web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of our Websites.

 

10. Security of your Personal Information

10.1 Watters secures your personal information from unauthorized access, use or disclosure. When personal information is transmitted to other websites, it is protected through the use of encryption, such as the Secure Sockets Layer (SSL) protocol.

10.2 The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Websites, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

10.3 Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of any personal information transmitted to our Websites. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Websites.

 

11. Children Under Thirteen

11.1 Our Websites are not intended for children under thirteen years of age. No one under age thirteen may provide any personal information to or on our Websites. Watters does not knowingly collect personal information from children under the age of thirteen. If you are under the age of thirteen, you may not access our Websites without supervision of a parent or guardian. If we learn we have collected or received personal information from a child under 13, we will delete that information. If you believe we might have information from or about a child under age 13, please contact us at media@watters.com.

 

12. Opt-Out & Unsubscribe

12.1 We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

12.1.1 Tracking Technologies. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent.

12.1.2 Announcements and Promotional Offers. We respect your privacy and give you an opportunity to opt-out of receiving announcements of certain information. Users may opt-out of receiving any or all communications from Watters https://www.watters.com/account.

12.2 We do not control third parties' collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative ("NAI") on the NAI's website.

 

13. Retention of information

13.1 We are only allowed to keep your information if we need it for one of the reasons we describe above. 

13.2 If we collect your personal data in order to perform a contract for goods and services, we will keep it for up to 7 years from your last contact with us.

13.3 If we collect your personal data on the basis of our legitimate interests, we will keep it indefinitely from your last contact with us.

 

14. Your Rights

14.1 Under European Data Protection Laws, if you are an European Union citizen you have a number of important rights free of charge. In summary, those include rights to:

14.1.1 access to your personal information and to certain other supplementary information that this Privacy Notice is already designed to address

14.1.2 require us to correct any mistakes in your information which we hold

14.1.3 seek the erasure of personal information concerning you in certain situations

14.1.4 ask to the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations;

14.1.5 object at any time to processing of personal information concerning you for direct marketing and we will cease processing;

14.1.6 object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you;

14.1.7 object in certain other situations to our continued processing of your personal information, for example where we are processing on the basis of our legitimate interests;

14.1.8 otherwise restrict our processing of your personal information in certain circumstances

14.2 For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation.

14.3 you would like to exercise any of those rights, please:

14.3.1 email, call or write to us;

14.3.2 let us have enough information to identify you;

14.3.3 let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill), and

14.3.4 let us know the information to which your request relates [, including any account or reference numbers, if you have them]

14.4 You also have the right to complain about how we treat your Personal Data and Sensitive Personal Data to the Information Commissioner's Office (ICO). The ICO can be contacted at:

https://ico.org.uk/global/contact-us/

 

15. Changes to Our Privacy Policy

15.1 Watters will occasionally update this Policy to reflect Company and customer feedback. Watters encourages you to periodically review this Policy to be informed of how Watters is protecting your information.

15.2 It is our policy to identify any changes we make to this Policy by placing a notice at the top of this Policy for at least a period of one month after the change.

15.3 The date the privacy policy was last revised is identified at the bottom of the page. You are responsible for periodically visiting our Websites and this Policy to check for any changes.

 

Effective as of September 30, 2014

Last Modified: [ ] September 2018