Welcome to our website www.nowallflowerproject.com (the “Site”)
This website is owned and operated by Henrietta O'Connor doing business as No Wallflower Project.
Since personal data (“Personal Data”) of users and customers (collectively "Users") of this Site may be processed in the European Union, any processing of Personal Data will be conducted in compliance with applicable European laws.
Your Personal Data will be processed to provide the services you subscribed to or reserved for registered users, to facilitate your navigation of and shopping from the website and to keep you informed of No Wallflower Project news and offers.
No Wallflower Project is a controller of Personal Data collected and processed for purpose of rendering the e-commerce services and the sale of products (herein the "Commercial Purposes") through the Site.
No Wallflower Project is the sole data controller of the Personal Data processed for marketing purposes, notably to send to Users, also through newsletter, information and updates on its products, offers, exclusive sales, promotional campaigns and on events and similar initiatives organized by No Wallflower Project (herein the "Marketing Purposes").
1. Our Policy
Everyone has the right to protection of his/her Personal Data. We respect Users' right to be informed regarding the collection of and other operations involving their Personal Data. In using data that may directly or indirectly identify you personally, we will apply a principle of strict necessity. For this reason, we have designed the Site in such a way that the use of your Personal Data will be kept to a minimum and will not exceed the purposes for which your Personal Data was collected and/or processed; we do not process your Personal Data when we can provide you with services through the use of anonymous or traffic data (such as marketing research made for improving our services, browsing data processed to provide you with customized contents or offers adapted to your preferred language, your location, etc) or by other means which allow us to identify you, apart from when it is strictly necessary or upon request by competent public authorities or the police (for example, in case of traffic data or your IP address).
2. Who collects and processes Your Personal Data, how and for which purposes?
No Wallflower Project is the controller of your Personal Data as we determine the Commercial Purposes and means of processing Personal Data. For the Commercial Purposes only, No Wallflower London has appointed certain entities that will also process Personal Data relating to the Site’s Users (herein the "Processors").
The above mentioned service providers and Processors have been chosen because of their experience in processing Personal Data and they provide sufficient guarantees regarding compliance with data protection laws (including the technical security measures governing the processing to be carried out). In processing the Personal Data for Commercial Purposes, the Processors shall act only under the instructions from No Wallflower Project. We regularly check that our Processors comply with our instructions and that they continue to provide sufficient guarantees regarding their full compliance with the provisions on Personal Data processing.
Some of the Processors of your Personal Data appointed by Shrimps London Ltd for Commercial Purposes directly are:
CSM, for purposes related to shipping, delivering and returning products purchased on www.nowallflowerproject.com;
DHL, for purposes related to shipping, delivering and returning products purchased on www.nowallflowerproject.com;
Shopify Inc, for purposes related to the housing of No Wallflower Project servers;
GMAIL Ltd UK, for purposes connected to providing Customer Service services to the Site’s Users;
Mail Chimp for purposes related to sending out Marketing Newsletters and Surveys;
Sage Pay, Pay Pal & Shopify for purposes related to payment transactions;
Facebook & Instagram for purposes related to sending out Marketing Campaigns;
For the Commercial Purposes, we collect your Personal Data (such as personal details, e-mail address, address, Credit Card numbers, bank code, IP address and telephone number, etc.) on your order form only for the purpose of selling the products ordered by you. Your Personal Data is mostly processed by electronic means and, in some circumstances, by paper-based means, such as when the processing of your Personal Data is required for preventing fraud on the Site. Your Personal Data shall be stored in a way which allows us to identify you for the period necessary for the purposes which the data was collected for and subsequently processed and, in any case, in accordance with applicable laws. Please report any modification of your Personal Data to our Customer Service and select ‘Privacy’ as the argument in the appropriate form or through your personal account on the Site in order to ensure that your Personal Data is always accurate and up-to-date, relevant and complete. Your Personal Data shall not be disclosed to third parties other than us for purposes which are not permitted by law or without your consent.
Aside from the Processors appointed for Personal Data processing, your Personal Data will be made available also to third parties, autonomous controllers, for purposes related to supplying services requested by Users (for example, for purchase transactions) or for purposes of third parties. For more information on the matter, see section 4 (To Whom Your Personal Data Will Be Disclosed). Please contact our Customer Service if you would like to receive a full list of our data Processors involved in processing your Personal Data.
For the Marketing Purposes, we may process your Personal Data as well as browsing data ("Traffic data") resulting from the use of the Site and of our services by any User, in order to provide Users with customized contents and offers on our services or to deliver any newsletter they subscribed to, subject to their discretionary right to withdraw their subscription to such newsletter or to oppose or object to the receiving of any advertising or marketing content which we think is of interest to a specific User. For Marketing Purposes, Personal Data and Traffic data is mostly processed by electronic means and shall be stored for us in any case, in accordance with applicable laws and available to our Processors.
Moreover, your Personal Data may be disclosed to the police or to judicial authorities, according to applicable laws and upon a formal request by such entities, for example in the event we need to prevent fraud on the Site (anti-fraud services).
Data processors will also have access to your Personal Data as stated in section 2 for the specific purposes stated therein. In all the above circumstances, your consent for data processing is not required as Personal Data Processing would be necessary for the performance of Commercial Purposes.
All the information we collect via our Website or through correspondence with you is used to operate and improve the service we offer you and to personalise our service. We are committed to using your personal information only for:
1. Planning and managing NoWallflowerProject.com's business activities, including analysis of customers' shopping habits, product and style preferences.
2. Technical administration of our website
4. Providing you with information about the services we offer
5. Letting you know about offers and news from NoWallflowerProject.com
6. Managing and fulfilling your order including verifying details of your payment method or credit card account and where necessary carrying out credit checks and to protect against fraud and theft.
We may therefore also share information about the way in which you conduct your account with lenders and credit reference agencies; During your registration process you are given the opportunity to select some of the ways in which we may use your details. See ‘your permission’ and ‘helping us to grow’ below to keep us in touch with anything you specifically don’t want to be informed about.
There are only three circumstances where we may share some of your data with others:
2. To outside research companies whom we may ask to contact you directly for your opinions on our service.
3. If we are requested by the police or a regulatory or government authority investigating illegal activities to provide information concerning your activities whilst using the network we shall do so.
3. What Happens if You Do Not Disclose Your Personal Data to us?
Granting your Personal Data to us (in particular, your personal details, your e-mail address, your address, your Credit/Debit Card numbers and bank code and your telephone number) is necessary for processing your order for the purchase of products on the Site, supplying other services provided on the web site upon your request, or when your Personal Data is needed to fulfil obligations required by law or regulations. The refusal to provide us with some of your Personal Data necessary for performing the above purposes may consequently prevent us from processing your order for the purchase of products sold on the Site or fulfilling obligations required by law and other regulations. Therefore, failing to provide Personal Data may constitute, in some cases, a legitimate and justified reason for not processing your order for the purchase of products sold on the Site or not providing the Site’s services.
Disclosure of further Personal Data to us other than that required for fulfilling legal or contractual obligations and to be properly browsing our services with necessary traffic data is, on the contrary, optional and does not have any effect on the use of the Site and of its services or on the purchase of products on the Site. We will inform you at every step whether disclosing your Personal Data to us is compulsory or optional by marking with an appropriate symbol (*) the information that is compulsory or data needed for the purchase of products on the Site.
4. To Whom Your Personal Data Will Be Disclosed?
Personal Data will be disclosed to third party companies that provide, on behalf of No Wallflower Project, specific services as data Processors or to other recipients of Personal Data collected by us that process your Personal Data only for the Commercial Purposes (for example, HSBC UK.) and, in any case, according to applicable laws and regulations.
Notwithstanding the foregoing, Personal Data will not be disclosed to any other third parties or disseminated or transferred without informing our Users of such disclosure/dissemination/transfer, and, in any case, in accordance with the applicable laws.
5. Security Measures
Site functionality cookies – these cookies allow you to navigate the site and use our features, such as “Add to Basket”.
Site analytics cookies - these cookies allow us to measure and analyse how our customers use the site, to improve both its functionality and your shopping experience.
Customer preference cookies – when you are browsing or shopping on No Wallflower Project, these cookies will remember your preferences (like your location), so we can make your shopping experience as seamless as possible, and more personal to you.
Targeting or advertising cookies – these cookies are used to deliver ads relevant to you. They also limit the number of times that you see an ad and help us measure the effectiveness of our marketing campaigns.
Further information about cookies can be found at https://ico.org.uk/for-organisations/guide-to-pecr/cookies-and-similar-technologies/ and www.AboutCookies.org.
7. Compulsory processing
We wish to inform you that we may process your Personal Data also without your consent in certain circumstances provided by laws.
8. Your Right to Access Personal Data and Further Rights
You are entitled to obtain at any time from us:
a. the updating, adjustment or, when you have an interest in such, the integration of your personal data;
b. the deletion, the transformation into an anonymous form or blocking of your personal data (unlawfully processed), including data which does not need to be stored for the purposes for which it was collected and subsequently processed;
c. the confirmation that the operations under letters a) and b) have been reported (together with the contents of the same) to whom the data was disclosed or disseminated, except when it becomes impossible or if the means used are clearly disproportionate to the right's protection.
You are entitled to object, in whole or in part:
a. for legitimate reasons, to the processing of your personal data, even if it is related to the purposes for which it was collected;
b. to the processing of your personal data for advertising or direct marketing purposes or in order to carry out marketing research or commercial communications.
9. Opt-in/Opt out
Each time your consent is required, No Wallflower Project will inform you in advance and will give you the option to either provide or refuse your consent for the use of your Personal Data, including your e-mail address, for the above purposes, by ticking the appropriate boxes.
We wish to inform you that we may process your Personal Data also without your consent in certain circumstances, such as when such processing is necessary for performing a legal obligation to which we are subject or when such processing is necessary for performing obligations undertaken in contracts with the users.
To the extent of applicable laws and subject to your rights, Your personal data may be processed by us for sending you advertising or offers for Marketing Purposes about products and services unless you object to it at any time, either when Your personal data has been collected or at any time, notably when receiving any offer from Us.
In any case, we wish to inform you that we guarantee that our users may exercise, at any time and without having to state their reasoning, their right not to receive future communications connected to particular services upon request.
10. Links to Other Web Sites
If you wish to receive further information on how we process your Personal Data, please contact our Customer Service at email@example.com.
12. Governing Law
To the extent that we are established in the UK, your use of this website and any dispute arising out of such use of the website is subject to the laws of England, Northern Ireland, Scotland and Wales.