LoveCrafts / WEBS Group Privacy Policy
Published on September 5, 2022Welcome to the LoveCrafts / WEBS Group privacy policy. We are a group of companies that operate various crafting websites and platforms, including www.lovecrafts.com, www.yarn.com and www.stringyarns.com. We respect your privacy and are committed to protecting your personal data. This privacy policy explains how we look after your personal data when you visit our websites (regardless of where in the world you visit it from) and tells you about your privacy rights and how the law protects you.
Important information and who we are
Purpose of this privacy policy
This privacy policy explains how the LoveCrafts and WEBS group of companies (the LoveCrafts Group) process your personal data through your use of our website(s) www.lovecrafts.com, www.yarn.com and www.stringyarns.com, including any data you may provide through our website(s) when you sign up to our online communities, browse our websites, make a purchase or share any of our content on social media, or any data that you may provide when you speak with our Smiles team.
Although we offer products and crafts aimed at families, our websites are not directed at children under the age of 13, and we do not knowingly or intentionally collect personal data from children under the age of 13.
It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them. If you are a California resident, our California Resident Privacy Notice provides more information about your California privacy rights and explains how you can exercise those rights.
Data Controller
If you visit, register with or are a customer of our German or UK website, www.lovecrafts.com, then LoveCrafts Group Limited and LoveCrafts Makers Ltd are joint data controllers and are responsible for your personal data. If you register with or are a customer of our US website, www.lovecrafts.com/us, then Lovecrafts Group Limited and LoveCrafts, Inc are joint data controllers and are responsible for your personal data. If you register with or are a customer of our US websites www.yarn.com, or www.stringyarns.com, then Lovecrafts Group Limited and Valley Fibers Corporation are joint data controllers and are responsible for your personal data. All companies in the LoveCrafts Group are collectively referred to as “LoveCrafts” "we", "us" or "our" in this privacy policy.
We have appointed a data protection coordinator who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights in relation to your personal data, please contact the data protection coordinator using the details set out below.
If you are a LoveCrafts customer, please use the following contact details:
Email address: info@lovecrafts.com
Postal address:
LoveCrafts Group Ltd, Aviation House, 125 Kingsway, London, WC2B 6NH
If you are a WEBS or String Yarns customer, please use the following contact details:
Email address: info@yarn.com
Postal address:
Valley Fibers Corp, 75 Service Center Road, Northampton, MA 01060
You have the right to make a complaint at any time with a supervisory authority. The authority responsible for us is the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the opportunity to deal with your concerns before you approach the ICO so please do contact us in the first instance.
Individuals and data protection supervisory authorities in the EU may contact our data protection representative in accordance with Article 27 GDPR: DP-Dock GmbH, Attn: Lovecrafts, Ballindamm 39, 20095 Hamburg, Germany, www.dp-dock.com, lovecrafts@gdpr-rep.com.
Changes to the privacy policy and updates to your information
We keep our privacy policy under regular review. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third-party links
This website may include links to third-party websites (such as our suppliers), plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
The data we collect about you
Personal data means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (de-identified data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, last name, username or similar identifier, address, email address, phone number, date of birth, gender and social media handle.
- Contact Data includes billing address, delivery address, email address and telephone numbers.
- Financial Data includes last four digits of your payment card, your PayPal ID and your Ravelry ID (if you have connected with those services through our website).
- Transaction Data includes details about payments to and from you and other details of your order history and products you have purchased from us, details of your shopping cart history and details of your interactions with our customer service team.
- Technical Data includes information about your IP address, your login data, browser type and other technology on the devices you use to access your websites.
- Profile Data includes purchases or orders made by you, your interests and preferences.
- Usage Data includes information about how you use our website, products and services, including content that you click on and how you have moved around our website.
- Employment Data. Includes information you provide or make available to us when you apply for a job with us, including your contact information, education, and employment experience. If you apply for a job with us through a third-party platform (such as Indeed), we will collect the personal data you make available to us through such third-party platform.
- Marketing and Communications Data includes your preferences in receiving marketing from us.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
We do not collect any Special Categories of Personal Data about you and we do not collect any information about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
How is your personal data collected?
We use different methods to collect personal data from and about you including through:
- Direct interactions. You may give us, or we may obtain, your Identity, Contact, Transaction, Usage, Profile, Marketing and Financial Data by filling in forms or by corresponding with us by post, phone or email or by browsing our website(s). We record calls with our Smiles team for quality and training purposes.
- Automated technologies and indirect interactions. As you interact with our website, we will automatically collect Technical Data. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy for further details.
How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where you have provided consent.
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal obligation.
The section below contains information about the lawful basis that we will rely on to process your personal data.
Generally, we do not rely on consent as our primary legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
We have set out below a description of all the ways we process your personal data, and which of the legal bases we rely on to do so.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
---|---|---|
To register you as a new customer and as a member of our community | (a) Identity (b) Contact | Performance of a contract with you |
To process, fulfil and deliver your order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us (c) Providing any associated customer services required in relation to your order | (a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications | (a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover any debts due to us) |
To operate and facilitate our community platform | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications | (a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) |
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey | (a) Identity (b) Contact (c) Profile (d) Marketing and Communications | (a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) (d) Based on your consent. |
To enable you to partake in a prize draw, competition or complete a survey, and to fulfil any orders for competition prizes | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications | (a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) |
To administer and protect our business and this website, and to report to our Board and investors | (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile | (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation, listing or group restructuring exercise) (b) Necessary to comply with a legal obligation |
To deliver relevant website content and postal or electronic marketing to you and measure or understand the effectiveness of the marketing we serve to you, including to target advertising to you on our website and third party websites that is relevant to your interests | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical | Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) |
To process your job application | (a) Employment data | Necessary for our legitimate interests (to conduct our internal recruitment processes) |
To enhance our website and user experience | (a) Technical (b) Usage | Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
To make suggestions and recommendations to you about goods or services that may be of interest to you | (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications | Necessary for our legitimate interests (to develop our products/services and grow our business) |
To allow you to provide goods or services to us, or to assess your suitability to provide good or services to us | (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile | (a) Necessary for our legitimate interests (to develop and grow our business) (b) Performance of a contract with you |
To comply with legal, audit or financial obligations | (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile | (a) Necessary for our legitimate interests (to manage, develop and grow our business) (b) Necessary to comply with a legal obligation |
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We will only send you marketing communications where we have obtained your consent to do so or where we are otherwise legally allowed to do so. You can ask us to stop processing your personal data for this purpose at any time, for example, by clicking an unsubscribe link in an email that we send.
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you and we may market to you on this basis.
You may receive marketing communications from us if you have requested information from us or purchased goods from us and you have not opted out of receiving that marketing. We also send marketing by post from time to time unless you have asked us not to do so.
Third-party marketing
We do not currently share your personal data with any third parties for direct marketing purposes, and if this changes in the future, we will get your express opt-in consent before doing so.
Cookies
For more information about the cookies we use, please see our cookie policy.
Change of purpose We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to have an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Disclosures of your personal data
When required for the purposes stated above, we may share your personal data with:
- Other companies in the LoveCrafts Group (including as a result of a reorganisation or restructure of the LoveCrafts Group) who act as joint data controllers or processors and who may be based internationally.
- Our business partners, customers, suppliers, service providers and sub-contractors who provide us with various services required to run our business, such as payment processors, delivery companies and email providers.
- Professional advisers including lawyers, bankers, auditors and insurers who provide us with professional services.
- Credit or other similar reference agencies for the purpose of assessing your suitability or ability where this is in the context of us entering (or proposing to enter) into a contract with you or the company you work for.
- HM Revenue & Customs, regulators and other authorities based in the United Kingdom and in other jurisdictions, when required.
- Analytics and search engine providers that assist us in the improvement and optimisation of our site.
- Our advertisers and advertising networks that require the data to select and serve relevant adverts to you and others.
We may disclose and transfer your personal data to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell, liquidate, or transfer all or a portion of our business or assets. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
International transfers
We share your personal data within the LoveCrafts Group. This will involve transferring your data outside the UK if you are in the UK, or outside the EU if you are in the EU.
Many of our external third parties are based outside the UK or the EU so their processing of your personal data will involve a transfer of data outside the UK or the EU.
Whenever we transfer your personal data out of the UK or the EU, we ensure a similar degree of protection is afforded to it by ensuring appropriate contractual safeguards are in place.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK or the EU.
Data security
We make reasonable efforts to protect your personal data by using physical and electronic safeguards designed to improve the security of the personal data we maintain. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. However, as no electronic transmission or storage of personal data can be entirely secure, we can make no guarantees as to the security or privacy of your personal data.
We have established procedures to address suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
In some circumstances we will de-identify your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These rights are described in detail below.
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the personal data's accuracy.
- Where our use of the personal data is unlawful, but you do not want us to erase it.
- Where you need us to hold the personal data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your personal data, but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
California Residents
If you are a California resident, you can review our California Resident Privacy Notice for information about your privacy rights and choices under California law.