Privacy Policy – The Brand Hangar
We take your privacy very seriously. Please read this privacy notice carefully as it contains important information on who we are and how and why we collect, store, use and share your personal data for our own business purposes. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint. We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation (UK GDPR).
Separately from our processing of personal data for our own business purposes, we may collect and process your personal data on behalf of our fashion industry clients – for example, if you place an order with them for an item of clothing and the order is captured and processed by our warehouse management system. In capturing and storing your order placed with our client, we will process any personal data in your order as a “data processor” on behalf of our clients who will be the “data controller”. Where we process personal data on behalf of clients as a “processor”, we do not process it for our own purposes – and we will only use it to provide our services to our data controller clients. This Privacy Notice does not apply to any such processing. Please contact the Brand Hangar client from whom you ordered your items if you’d like to know more about the processing of your personal data for those purposes.
Key terms
It would be helpful to start by explaining some key terms used in this notice:
| We, us, our | The Brand Hangar Ltd, a limited company registered in England and Wales under company number 10496794 |
| Personal data | Any information relating to an identified or identifiable individual |
| Data subject | The individual who the personal data relates to |
Personal data we collect about you
If you are (or work for) our client, or an organisation we would like to provide services to, we may collect and use the following personal data about you:
- your name and contact information, including email address and telephone number and company details
- your billing information
- your professional online presence, eg LinkedIn profile
- Information about how you use our website, IT, communication and other systems
- your responses to surveys, competitions and promotions
- your contact preferences
- your authentication details for your use of our Warehouse Management System.
We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below.
How your personal data is collected
We collect most of this personal data directly from you—in person, by telephone, text or email and/or via our website. However, we may also collect information:
- from publicly accessible sources, eg LinkedIn
- from the organisation you work for, if you work for one of our clients
- via our Warehouse Management System.
How and why we use your personal data
Under data protection law, we can only use your personal data if we have a proper reason, eg:
- where you have given consent;
- to comply with our legal and regulatory obligations;
- for the performance of a contract with you or to take steps at your request before entering into a contract; or
- for our legitimate interests or those of a third party.
A legitimate interest is when there is a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests of us and others, to balance our interests against your own.
The table below explains what we use your personal data for and why.
| What we use your personal data for | Our reasons |
| Providing our fulfilment services to you or the organisation you work for, including creating an account and credentials for you on our warehouse management system | To perform our contract with you or your organisation or to take steps at your request before entering into a contract For our legitimate interest and that of our client, ie to provide a fulfilment service to your organisation. |
| Preventing and detecting fraud against your organisation or us or our clients | For our legitimate interest, ie to minimise fraud that could be damaging for your organisation and/or us |
| Conducting checks to identify our clients and verify their identity Reporting to HMRC regarding our due diligence obligations as a fulfilment provider Other activities necessary to comply with legal and regulatory obligations that apply to our business. | To comply with our legal and regulatory obligations |
| To enforce legal rights or defend or undertake legal proceedings | Depending on the circumstances: —to comply with our legal and regulatory obligations; —in other cases, for our legitimate interests, ie to protect our business, interests and rights |
| Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies | To comply with our legal and regulatory obligations |
| Ensuring business policies are adhered to, eg policies covering use of our warehouse management system | For our legitimate interests, ie to make sure we are complying with the requirements of the provider of our warehouse management system and so we can deliver the best service to your organisation |
| Statistical analysis to help us manage our business, eg in relation to use of our Warehouse Management System | For our legitimate interests, ie to be as efficient as we can so we can deliver the best service to your organisation at the best price |
| Preventing unauthorised access and modifications to systems including our warehouse management system | Depending on the circumstances: —for our legitimate interests, ie to prevent and detect criminal activity that could be damaging for your organisation and/or us; —to comply with our legal and regulatory obligations |
| Updating client records | Depending on the circumstances: —to perform our contract with your organisation or to take steps at your request before entering into a contract; —to comply with our legal and regulatory obligations; —for our legitimate interests, eg making sure that we can keep in touch with our clients about existing orders and new services |
| Communications with you not related to marketing, including about changes to our terms or policies or changes to the products or other important notices (other than those addressed above) | For our legitimate interests which is to be as efficient as we can so we can deliver the best service to your organisation |
| Statutory returns | To comply with our legal and regulatory obligations |
| Marketing our services to: —existing and former clients; —people who have previously expressed an interest in our services; —people with whom we have had no previous dealings. | Depending on the circumstances: For our legitimate interests, ie to promote our business to existing and former clients
|
| Credit reference checks via external credit reference agencies | For our legitimate interests, ie to ensure our clients are likely to be able to pay for our products and services |
| External audits and quality checks | Depending on the circumstances: —for our legitimate interests, ie to maintain our accreditations so we can demonstrate we operate at the highest standards; —to comply with our legal and regulatory obligations |
| To share your personal data with members of our group and third parties that will or may take control or ownership of some or all of our business (and professional advisors acting on our or their behalf) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency In such cases information will be anonymised where possible and only shared where necessary | Depending on the circumstances: —to comply with our legal and regulatory obligations; —in other cases, for our legitimate interests, ie to protect, realise or grow the value in our business and assets |
Marketing
We will use your personal data to send you updates (by email, text message, telephone or post) about our services, including news, offers, promotions or new services.
We have a legitimate interest in using your personal data for marketing purposes (see above ‘How and why we use your personal data’). This means we do not usually need your consent to send you marketing information. If consent is needed, we will ask for this separately and clearly.
You have the right to opt out of receiving marketing communications at any time by:
- contacting us at hello@thebrandhangar.com;
- using the ‘unsubscribe’ link in emails.
We may ask you to confirm or update your marketing preferences if you ask us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.
Who we share your personal data with
We routinely share personal data with:
- companies within our corporate group
- third parties we use to help deliver our services to you, eg carriers, the provider of our Warehouse Management System, and the provider of our workflow management system.
- other third parties we use to help us run our business, eg marketing agencies or website hosts;
- third party payment service providers, to process your payments to us;
- credit reference agencies;
- our insurers and brokers;
- our bank;
- HMRC and other government bodies in relation to our regulatory obligations as a fulfilment services provider.
We or the third parties mentioned above occasionally also share personal data with:
- external auditors, eg in relation to the audit of accounts, in which case the recipient of the information will be bound by confidentiality obligations;
- professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations;
- law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations;
- other parties that have or may acquire control or ownership of our business (and our or their professional advisers) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised but this may not always be possible. The recipient of any of your personal data will be bound by confidentiality obligations.
If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).
Where your personal data is held
Personal data may be held at our offices and those of our group companies, third party agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal data with’).
Some of these third parties may be based outside the UK. For more information, including on how we safeguard your personal data when this happens, see below: ‘Transferring your personal data out of the UK.
How long your personal data will be kept
We will not keep your personal data for longer than we need it for the purpose for which it is used.
Different retention periods apply for different types of personal data. Further details on this are available on request.
Transferring your personal data out of the UK
Countries outside the UK have differing data protection laws, some of which may provide lower levels of protection of privacy.
We may have to transfer your personal data to countries outside the UK. In those cases we will comply with applicable UK laws designed to ensure the privacy of your personal data.
We will transfer your personal data to:
- our service providers (e.g. Monday.com, our workflow management system, which is based in the USA)
Under data protection laws, we can only transfer your personal data to a country outside the UK where:
- the UK government has decided the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy regulation’) further to Article 45 of the UK GDPR. A list of countries the UK currently has adequacy regulations in relation to is available here. We rely on adequacy regulations for transfers to countries in the European Economic Area (EEA)
- there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you; or
- a specific exception applies under relevant data protection law.
Where we transfer your personal data outside the UK, we do so on the basis of an adequacy regulation or (where this is not available) legally-approved standard data protection clauses recognised or issued further to Article 46(2) of the UK GDPR. In the event we cannot or choose not to continue to rely on either of those mechanisms at any time, we will not transfer your personal data outside the UK unless we can do so on the basis of an alternative mechanism or exception provided by UK data protection law and reflected in an update to this notice.
If you would like further information about data transferred outside the UK, please contact us (see ‘How to contact us’ below).
Your rights
You have the following rights, which you can exercise free of charge:
| Access | The right to be provided with a copy of your personal data |
| Rectification | The right to require us to correct any mistakes in your personal data |
| Erasure (also known as the right to be forgotten) | The right to require us to delete your personal data—in certain situations |
| Restriction of processing | The right to require us to restrict processing of your personal data in certain circumstances, eg if you contest the accuracy of the data |
| Data portability | The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations |
| To object | The right to object: —at any time to your personal data being processed for direct marketing (including profiling); —in certain other situations to our continued processing of your personal data, eg processing carried out for the purpose of our legitimate interests unless there are compelling legitimate grounds for the processing to continue or the processing is required for the establishment, exercise or defence of legal claims |
| Not to be subject to automated individual decision making | The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you |
| The right to withdraw consents | If you have provided us with a consent to use your personal data you have a right to withdraw that consent easily at any time You may withdraw consents by contacting us at hello@thebrandhangar.com Withdrawing a consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn |
For more information on each of those rights, including the circumstances in which they apply, please contact us (see ‘How to contact us’ below) or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights.
If you would like to exercise any of those rights, please:
- email, call or write to us—see below: ‘How to contact us’; and
- provide enough information to identify yourself and any additional identity information we may reasonably request from you;
- let us know what right you want to exercise and the information to which your request relates.
Keeping your personal data secure
We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your personal data will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
If you want detailed information from Get Safe Online on how to protect your personal data and other information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
How to complain
Please contact us if you have any queries or concerns about our use of your personal data (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.
You also have the right to lodge a complaint with the Information Commissioner.
The Information Commissioner may be contacted using the details at https://ico.org.uk/make-a-complaint or by telephone: 0303 123 1113.
Changes to this privacy notice
We may change this privacy notice from time to time—when we do we will inform you via our website or email.
How to contact us
You can contact us by email at hello@thebrandhangar.com if you have any questions about this privacy notice or the information we hold about you, to exercise a right under data protection law or to make a complaint.