Privacy policy
Privacy Notice
We have updated our Privacy Notice on 26/10/2023 to ensure you have all the latest, up to date information regarding your data and how we use it. Here are the highlights;
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We have partnered with a data protection expert and reworded parts of the notice to make it easier to read and digest
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Additional information has been included to increase transparency. For example, we have produced a condensed list of when we work with third parties to process your data
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We have integrated our cookie policy into the privacy policy
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We have added the details of our EU Representative for those who are located in the EEA
Please let us know if you have any questions regarding the update, or any other privacy matters by
contacting privacy@houseofava.co.uk, or by writing to:Data Privacy Team 41 Bounces Road
Lower Edmonton London
N9 8JD
House of Ava’s Privacy Notice Data we collect and how we collect it
At House of Ava, we collect data directly from individuals, or via specialist data co-op partners with your explicit consent. We collect, process and store data of employees, prospective employees, partners, customers of House of Ava and 3rd party suppliers.
We collect special category data such as gender to give you the best shopping experience possible and to satisfy other laws outside of data protection, such as employment law or when you give it to us directly.
Here is a table of the data we collect:
*when visiting our website
Data we collect for employment purposes can be found within our employee contracts and full data protection policy. This notice relates directly to customers of House of Ava.
Definitions:
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Customers of House of Ava = customers who visit the House of Ava website, receive marketing via email, post or SMS and place orders with us.
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Partner = a company which provides goods or services to House of Ava which are required for us to provide our services to you.
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3rd Parties = other suppliers of goods or services to House of Ava.
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Employee = someone who works for House of Ava.
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Prospective employee = someone who has applied for or has been approached directly by House of Ava for a vacant job role.
Your Privacy Choices and Rights
Your choices
You can choose not to provide us with personal data. If you choose to do this, you can continue to use the House of Ava website and browse its pages, but we will not be able to process transactions or continue a relationship without personal data.
You can block cookies by activating a setting on our cookie banner, allowing you to refuse cookies. You can also delete cookies through your browser settings. If you turn off non essential cookies, you can continue to use the House of Ava website and browse its pages. See the cookie section below for further detail.
You can opt-out of marketing by clicking the unsubscribe option in any marketing communications.
Your rights
You can exercise your rights by sending an email to privacy@houseofava.co.uk .
You have the right to access the information we hold about you. This includes the right to ask us supplementary information about:
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the categories of data we’re processing
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the purposes of data processing
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the types of third parties to whom the data may be disclosed
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how long the data will be stored (or the criteria used to determine that period)
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your other rights regarding our use of your data
We will provide you with the information within one month of your request unless doing so would adversely affect the rights and freedoms of others (e.g. another person’s confidentiality or intellectual property rights). We’ll tell you if we can’t meet your request for that reason.
You have the right to make us correct any inaccurate personal data about you.
You can object to us using your data for profiling or making automated decisions about you.
We will use your data to determine whether we should let you know information relevant to you (for example, tailoring emails or social media advertising to you based on your behaviour).
You have the right to port your data to another service. We will give you a copy of your data in CSV format so that you can provide it to another service.
If you ask us, and it is technically possible, we will directly transfer the data to the other service for you. We will not do so to the extent that this involves disclosing data about any other individual.
You have the right to be ‘forgotten’ by us. You can do this by asking us to erase any personal data we hold about you if it is no longer necessary for us to store the data for purposes of your relationship with House of Ava or any other law.
You have the right to complain about our use of your data; please tell us first so we have a chance to address your concerns. If we fail in this, you can address any complaint to the UK Information
Commissioner’s Office, either by calling their helpline or as directed on their website at www.ico.org.uk.
Or you can make a complaint to your local supervisory authority. Details can be found by following this link:https:// globalprivacyassembly.org/participation-in-the-assembly/members- online/
These rights apply to all the data categories listed in the ‘Data we collect and how we collect it’ section.
Security
We do everything we can to ensure the security of your data.
In today’s data-driven and connected world, the security of your data is more critical than ever. We recognise this and have implemented security to keep your data safe.
All staff are bound by confidentiality and will never disclose or share your data unless authorised to do so.
House of Ava’s data protection role
House of Ava is a controller in relation to your data; we are not a processor or a sub-processor of any other brand or company. As a controller, we use 3rd parties to process data; please see below in the 3rd parties section.
Where is your data stored?
Like most companies, House of Ava utilises 3rd parties to provide services to our customers and to store data. An overview of the services our 3rd parties conduct on our behalf is listed below.
These 3rd parties will be based in the UK, EEA and in some cases outside of both the UK and EEA.
House of Ava conducts thorough reviews of all its 3rd parties, including implementing data protection agreements, where possible, to ensure that every possible safeguard is in place and that the data is secure. Should there be a possibility that data could be exposed to a high level of risk, a Data Protection Impact Assessment will be completed and will be available upon request.
Where data is transferred outside of the UK, and the EEA House of Ava has taken steps to ensure that your data is transferred under a lawful condition or safeguard as described in the GDPR.
3rd parties
House of Ava works with several 3rd parties who offer eCommerce solutions for House of Ava to be able to provide online shopping to our customers, most of which do not process customer data in any way; below is a list of those who have access to or process your data and a brief description of what they do.
If you would like to see a full list of processors who House of Ava shares your data with please contact privacy@houseofava.co.uk
Marketing
House of Ava would love to keep in touch with you. When you sign up to receive marketing and open an account with us, we will send you emails, postal marketing and SMS messages (where you have submitted your phone number). We will also display customised advertising when you log in to your social media profiles.
These messages will be House of Ava specific we do not sell your data or share it with other brands for advertising purposes unless with your explicit consent.
Our marketing messages are sent via a specialist eCommerce marketing tool. You can opt-out of marketing at any time by clicking the unsubscribe link in your emails and SMS messages or by contacting us directly.
There will be occasions when House of Ava sends administrative messages such as order updates; these messages are not deemed marketing and cannot be opted out of.
Marketing and administration emails you receive from House of Ava contain a tracking pixel. This pixel lets us know things such as our email campaigns' open rates and click rates.
The pixel also lets us know if an email has not been delivered to update our records and keep them current.
When we analyse the data, we do so from an aggregated perspective, meaning that we report upon an overall number of open rates and click rates.
When a purchase is made, or you add an item to your cart, or create an account you will notice that the marketing preference box is pre-ticked. This is because we rely on a soft opt in to promote further, similar goods to you.
If you wish to opt-out of these messages, please untick this box at the cart stage; of course, you can unsubscribe from marketing at any point.
Should you place an item in the cart and not complete an order, House of Ava will send you an abandoned cart message offering you the chance to complete your order. These messages are sent when you provide an email address to House of Ava at the checkout stage or where you are logged in to your House of Ava account.
Abandoned cart messages are sent using the soft opt-in method described above.
When you provide a postal address to House of Ava we will send you postal marketing. Postal marketing can be opted out of by contacting privacy@houseofava.co.uk.
Payment processing
House of Ava does not collect your payment details or process them in any way. All data processed by payment providers is done by you as a customer with no processing from House of Ava.
How long is your data stored?
Once per year, we cleanse data to ensure that we only process the data of those individuals who have an ongoing and active relationship with House of Ava.
As part of our Record of Processing Activities, we have defined the length of time we store all of our data. Should your data be due for deletion, it will be erased during the yearly data cleanse.
To understand data retention in relation to your data, please contact privacy@houseofava.co.uk.
Cookies
To further improve your shopping experience, we store information about you using cookies which are files sent by us to your computer or another access device that we can access when you visit our site at some point in the future.
The cookies we use enable us to save your cart for later and track the opening of our emails, for example. We use several different
cookies on our site. If you do not know what cookies are or how to control or delete them, we recommend that you visit http:// www.aboutcookies.org for detailed guidance.
There are four main types of cookies we store – here’s how and why we use them.
(1) Site functionality cookies (necessary) – these cookies allow you to navigate the site and use our features, such as “add to cart” and “save for later”.
(2) Customer preference cookies – when you are browsing or shopping on the House of Ava website, these cookies will remember your preferences (like your language or location), so we can make your shopping experience as seamless as possible and more personal to you.
(3) 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.
(4) 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.
You can manage your cookie preferences via the cookie banner.
First Party Cookies
These are cookies that are set by this website directly.
We use Persistent Basket Cookie to remember what you have put into your shopping basket over an extended period. This cookie only stores basic data about your basket strictly for our website.
The cookie has an expiration of 90 days to 24 months.
We use a session cookie to remember your login for you if you are a registered user, and we deem these as being strictly necessary to the working of the website. If these are disabled, then various functionality on the site will be broken.
Third-Party Cookies
Our website also uses a recording service that will record mouse clicks, mouse movements, page scrolling and any text keyed into website forms. Data collected by this service is used to improve our website usability. The information collected is stored and is used for aggregated and statistical reporting.
Governing Law
The terms and conditions shall be governed by and construed by the laws of England, and you irrevocably submit to the exclusive jurisdiction of the courts of England and Wales.
We use several different cookies on our site. If you do not know what cookies are or how to control or delete them, we recommend that you visit http://www.aboutcookies.org for detailed guidance.
Further Information
More information on session cookies and what they are used for can be found here, All About Cookies
To view a list of the cookies present when browsing our site, you can right-click within the browser page, click inspect and then click application.
Breaches
Should a breach of your data occur that is likely to result in harm to the rights and freedoms of you as an individual or group of individuals, House of Ava will notify you within 72 hours along with the ICO, where applicable.
The California Consumer Privacy Act (CCPA)
This policy applies to all residents of California.
For the purposes of the CCPA, House of Ava collects the following information:
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Name
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Residential address
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Browsing history and IP address
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Phone number
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Email address
House of Ava collects this data to fulfil orders you have placed and send marketing messages and other processing described throughout this notice.
House of Ava shares data with data processors and sub-processors who assist House of Ava in providing you with products and marketing, such as delivery companies and our marketing and analytical partners. A complete list of House of Ava 3rd parties is available on demand.
House of Ava collects your data directly from you. House of Ava never buys or sells data; we only process your data when freely given to us.
House of Ava will never discriminate against you, we provide the same products and pricing structure available to customers worldwide.
You have the right to be forgotten, where applicable and where House of Ava does not require your data to satisfy a particular law.
You have the right to access your data or ask us to amend it if it is incorrect. Please email privacy@houseofava.co.uk if you wish to do so.
Additional information
House of Ava has appointed a Data Protection Officer who can be contacted via privacy@houseofava.co.uk or by writing to the below address:
Data Protection Officer 41 Bounces Road Lower Edmonton London
N9 8JD
A Record of Processing Activities (ROPA), in which the lawful basis for processing all of the House of Ava customer data is maintained. Wherever Legitimate Interests is relied upon, an impact assessment has been created, available upon demand to those whose data is included.
If you are located in the EEA and have questions about your personal data or would like to request to access, update or delete it, you may contact our representative at:
privacy@houseofava.co.uk and we will be happy to help.
