Welcome to the Strings Universal’ privacy notice.
Strings Universal respects your privacy and is committed to protecting your personal information. We want our customers to be able to use our services confident in the knowledge that we are serious about protecting personal information. Therefore we are updating our processes and policies to meet the EU’s new data privacy rules (the GDPR).
And tell you about your privacy rights and how the law protects you.
1. Important information and who we are
Strings Universal is committed to protecting the privacy and security of your personal information.
This Privacy Statement describes and aims to give you information on how Strings Universal collects and processes your personal information in accordance with the EU General Data Protection Regulation ("GDPR"), through your use of this website, our mobile app, or when you provide information, including any data you may provide through these channels when you sign up to our newsletter or purchase a product or service or take part in a competition. This website is not intended for children and we do not knowingly collect data relating to children.
Strings Universal INC is the controller and responsible for your personal information (collectively referred to as “Strings Universal”, “we”, “us” or “our” in this privacy statement).
We have appointed a GDPR team who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy statement, please contact the GDPR team using the details set out below. If you would like to exercise any of your legal rights please complete the relevant form included at the "Your legal rights" section of this Privacy Statement and send this to us at the details included on the form. Our GDPR team will be happy to help with any questions that you may have.
Our full details are:
Legal entity: Strings Universal INC
Contact: GDPR Team
Email address: firstname.lastname@example.org
Postal address: Strings Universal Inc,19W 34th ST STE 1018 New York 10001, United States.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the U.S supervisory authority for data protection issues. We would,
however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to the privacy notice and your duty to inform us of changes
This version was last updated on 22nd April 2019 and historic versions are archived here.
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us. You can update your information at any time by amending your personal information within your details section of Sign in at stringsuniversal.com or alternatively by clicking here for more options Contact us.
This website may include links to third-party websites, 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 notice of every website you visit.
Data protection principles
we will comply with data protection law. This says that the personal information we hold about you must be:
2. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). There are "special categories" of more sensitive personal data which require a higher level of protection. We may collect, use, store and transfer different kinds of personal information about you which we have grouped together follows:
Identity Data includes first name, maiden name, last name, username or similar identifier, gender, marital status, title, date of birth, email address.
Personal Data includes details such as name, title, addresses, telephone numbers, and personal email addresses.
Contact Data includes billing address, delivery address, email address and telephone number.
Financial Data includes bank account and card payment details. (But excludes Credit Card numbers and PIN or passwords for that card used for making any payments, which are not stored by us)
Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
Technical Data includes Internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, cookie ID’s, web log information, device identifiers and other technology on the devices you use to access this website.
Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
Usage Data includes information about how you use our website, products and services, your browsing activity including intended purchases and aborted baskets, completion of surveys, wish-lists, connection information and statistics on your visits to site and page views, the links you click and other actions you take on our services, within our advertising or e-mail content and participation in promotional activity Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal information but is not considered personal information in law as this data does 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 information so that it can directly or indirectly identify you, we treat the combined data as personal information which will be used in accordance with this privacy notice.
We do not collect any Special Categories of Personal information about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
We may also collect, store and use the following "special categories" of more sensitive personal information:
Information about your health, including but not limited to any medical conditions, food allergies.
We do process some Special Categories of Personal Information about you based on the confidential information which you provide to Strings Universal for this purpose. We process this information which you have provided to us with your consent only Special Categories of Personal Information which may be processed about you include details about your race or ethnicity, philosophical beliefs, sex life and information about your health.
IF YOU FAIL TO PROVIDE PERSONAL INFORMATION
Where we need to collect personal information 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.
3. When and how we collect your personal data
We capture, process and retain personal information from you and any devices you may use when you navigate to a stringsuniversal.com web, by transacting, by registering an account and otherwise interacting with us.
We may capture customer information, purchase data and browsing behaviour as part of the rewards for life loyalty programme. This is so we can optimise and personalise your experience with stringsuniversal.com
Some more examples of the different methods by which we collect information from and about you include through:
Direct interactions: You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal information you provide when you
Automated technologies or interactions: As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal information by using cookies, server logs and other similar technologies. These machine learning algorithms generate content which they apply to personalising your experience and select more specifically the items you have an interest in as well as supporting general service optimisation including bid/ markdown automation. We may also receive Technical Data about you if you visit other websites employing our cookies.
We may allow you to share information with social media sites, or use social media sites to create your account or to connect your account with the respective social media site. Those social media sites may give us automatic access to certain personal information retained by them about you (e.g., content viewed by you, content liked by you and information about the advertisements you have been shown or may have clicked on). Where this information is received by us, we will use this information to further personalise your experience with www.stringsuniversal.com.
Third parties or publicly available sources. We may receive personal information about you from various third parties as set out below:
Technical Data from the following parties:
(a) Analytics providers such as Google Analytics and Google DoubleClick based outside the EU;
(b) Advertising networks such as Amnet based inside the EU and Google Display Network based outside the EU;
(c) Social Network providers such as Facebook based outside the EU;
Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as PayPal based outside the EU;
Identity and Contact Data from data brokers or aggregators such as Experian based inside the EU;
Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.
We may have to share your data with third parties, including third-party service providers.
We require appointed third parties to respect the security of your data and to treat it in accordance with the law.
We may transfer your personal information outside of the EU.
If we do, you can expect the same degree of protection in respect of your personal information.
We will share your personal information with third parties where required by law, or where we have another legitimate interest in doing so, or when we have your explicit consent.
"Third parties" includes third-party service providers (including contractors and designated agents) and other entities associated with Strings Universal
All our third-party service providers and other entities within Strings Universal are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
We may share your personal information within Strings Universal as part of our regular reporting activities on company performance, in the context of system maintenance, support and hosting of data.
We may share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal information with a regulator or to otherwise comply with the law.
We will transfer the personal information we collect about you to service provider in India in order to perform our contract with you, or with your explicit consent.
There is no an adequacy decision by the European Commission in respect of that country. This means that the country to which we transfer your data is not deemed to provide an adequate level of protection for your personal information. To ensure that your personal information does receive an adequate level of protection we have put in place the strong inter country security measures to ensure that your personal information is treated by those third parties in a way that is consistent with and which respects the EU and US laws on data protection:
4. How we use your personal data
We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
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.
Business management and planning, including accounting and auditing.
Making decisions about grievances.
Dealing with legal disputes
Complying with health and safety obligations.
To prevent fraud.
To monitor your use of our information and communication systems to ensure compliance with our Global IT policy and laws of the land.
To ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution.
To conduct data analytics studies to review and better understand customer satisfaction and needs.
Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.
Please see point 5 below (Purposes for which we will use your personal information) to find out more about the types of lawful basis that we will rely on to process your personal information.
Generally, we do not rely on consent as a legal basis for processing your personal information other than in relation to sending third party direct marketing communications to you via email. You have the right to withdraw consent to marketing at any time by e-mailing or contacting our Customer Services team. For more information about these and other options click here - Contact us.
If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you (such as providing a benefit), or we may be prevented from complying with our legal obligations (such as to ensure the health and safety).
We will only use your personal information 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 we need to use your personal information 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 information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Principles of GDPR
We will use your personal data only in-line with the following principles:
This is the only principle that deals explicitly with security. The GDPR states that personal data must be “processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures”.
The GDPR is deliberately vague about what measures organisations should take, because technological and organisational best practices are constantly changing.
Currently, organisations should encrypt personal data wherever possible, but they should also consider whatever other options are suitable.
We do not need your consent if we use special categories of your personal information in accordance with our written policy to carry out our legal obligations or exercise specific rights. In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us.
Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention.
We do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes.
5. Purposes for which we will use your information
We have set out below, in a table format, a description of all the ways we plan to use your personal information, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
In general terms, we use the personal information we collect to help Strings Universal better understand you and to enable us to personalise your experience with Strings Universal, including offers, promotions and services to meet your needs. We use your information to:
personalise our services, offers and promotions to you and provide you with a personalised experience on our sites.
operate your online account and your rewards for life account.
process your telephone or online orders / purchases.
offer you site content that includes items that you might like and to keep track of your basket.
contact you about your account and tell you about important changes to Strings Universal.
provide, develop and improve our products and services.
provide you customer service.
manage promotions, competitions, customer surveys and questionnaire.
check and verify your identity, and prevent, mitigate or detect and investigate crime, fraudulent or illegal activities.
Process purchases, payments, customer support and order fulfilment.
Note that we may process your personal information for more than one lawful ground depending on the specific purpose for which we are using your data. If you need details about the specific legal ground we are relying on to process your personal information where more than one ground has been set out in the table below you can request this information by e-mailing your request for this information to email@example.com
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
To register you as a new customer
To process and deliver your order including:
To manage our relationship with you which will include:
|To enable you to partake in a prize draw, competition or complete a survey||
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) and to prevent, detect, mitigate and investigate fraudulent or illegal activities
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||
||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 use data analytics to improve our website, products/services, marketing, customer relationships and experiences||
||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||
we strive to provide you with choices regarding certain personal information uses, particularly around marketing and advertising. You can view and make certain decisions about your personal information use at any time at your account, or by e-mailing or contacting our Customer Services team. All of these options are available by clicking here Contact us.
amend your options within the "Your Details" section of "Sign in" on the Website;
Call us on:
UNITED STATES: 06468106476
Write to us at Strings Universal Inc,19W 34th ST STE 1018 New York 10001, United States.
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 (we call this marketing).
MARKETING COMMUNICATIONS FROM US
In general, you will receive marketing communications from us by email, postal mail, or phone if you have requested information from us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
Strings Universal is committed to transitioning over time the basis of its e-mail marketing communications to customer consent. To achieve this we will be gradually transitioning our lawful basis for processing to consent and will do this in a number of ways and over a period of time depending on how you engage with us, and whether you are new to Strings Universal or an existing customer or user of Strings Universal products or services.
If you have any questions about how we are lawfully processing your information you can request this information by e-mailing your request for this information to firstname.lastname@example.org
We will get your express opt-in consent before we share your personal information with any other company other than Strings Universal INC. for marketing purposes.
THIRD-PARTY COOKIES USED FOR RETARGETING
We have relationships with carefully selected third parties who may also set cookies during your visit to be used for remarketing purposes – in other words to show you different products and services based on what you appear to be interested in. This type of advertising is designed to provide you with a selection of products based on what you’re viewing on stringsuniversal.com, which are presented to you by our business partners when you visit other selected websites. The adverts may highlight products you’ve viewed, alternative styles and colours, as well as products from other categories deemed relevant to your browsing history. The technology behind these adverts is based on cookies.
Disabling these advertisements
we would like to continue to display content that's relevant to you, however, you can choose to opt out of this type of advertising permanently by deleting our cookies. Please note that if you delete your cookies, we will no longer know that you have opted out, and the banners from Amnet or our other providers from time to time will reappear when you visit other selected websites. You can request more details of our third party service providers from email@example.com.
You can use your web browser to: > delete all cookies. > block all cookies. > allow all cookies. > block third-party cookies. > clear all cookies when you close the browser. > open a 'private browsing' / 'incognito' session, which allows you to browse the internet without storing local data. > install add-ons and plug-ins to extend browser functionality.
To find information about controlling cookies see our Cookies Policy.
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact firstname.lastname@example.org. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
You can ask us or third parties to stop sending you marketing by contacting us at any time.
THE RIGHT TO OBJECT TO PROFILING
Where we process personal information relating to your interaction (transactions, site visits, app usage) with email@example.com to enable us to personalise your experience with stringsuniversal.com. This processing activity constitutes profiling under the GDPR and we process your personal information in this way as it is in our legitimate interest to offer you a personalised experience on our sites and to provide you with personalised advertising and marketing.
We do see profiling as a beneficial service allowing you to have easier and quicker access to products, services and offers tailored more specifically to your interests, but we respect that not everyone feels the same way and we will be sad to see you go.
CHANGE OF PURPOSE
We will only use your personal information 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 get 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 information 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 information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
6. Disclosures of your personal data
We may have to share your personal information with the parties set out below for the purposes set out in the table in paragraph 4 above.
Internal Third Parties as set out in the Glossary below.
External Third Parties as set out in the Glossary below.
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal information in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.
Please contact firstname.lastname@example.org if you want further information on the third parties we use.
7. International Transfers
Many of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal information will involve a transfer of data outside the EEA.
Whenever we transfer your personal information out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
We will only transfer your personal information to countries that have been deemed to provide an adequate level of protection for personal information by the European Commission. For further details, see European Commission: Adequacy of the protection of personal information in non-EU countries.
Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal information the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal information to third countries.
Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal information shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
8. Data security
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
9. Data retention
HOW LONG WILL YOU USE MY PERSONAL INFORMATION FOR?
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. In addition, this includes that we may retain personal information from closed accounts to comply with legal requirements, prevent fraud and resolve disputes. After it is no longer necessary for us to retain your personal information, we dispose of it securely according to our data retention and deletion policies
When we determine the maximum retention duration of any personal data we hold we do so with regard to our legitimate interests to retain data, our obligation under GDPR to minimise data we hold, the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see Request erasure in section 10. Your Legal Rights below for further information.
In some circumstances we may anonymise your personal information (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.
10. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data as set out below:
If you wish to exercise any of the rights set out above, please contact us.
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), such as:
This is a security measure to ensure that not to disclose personal information to unauthorized person. We may also contact you to ask you for further information in relation to your request to speed up our service.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may 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.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.