Privacy Notice

Softi Ltd. respects your privacy and is committed to protecting your personal information. This privacy notice will inform you as to how we look after your personal information when you:

visit our website (regardless of where you visit it from);

and tell you about your privacy rights and how the law protects you.

For the purpose of the Data Protection Act 1998 (the Act), the data controller is Softi Limited.

This privacy notice is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.

  1. Important information and who we are:

PURPOSE OF THIS PRIVACY NOTICE  

This privacy notice aims to give you information on how Softi Ltd. collects and processes your personal information through your use of this website, or our mobile app, 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.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal information about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

CONTROLLER  

Softi Limited is the controller and responsible for your personal information (collectively referred to as” Softi Ltd.”, “we”, “us” or “our” in this privacy notice).

This privacy notice is issued on behalf of Softi Ltd. so if you have any questions about this privacy notice, please contact the Support 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 notice and send this to us at the details included on the form.  Our Support team will be happy to help with any questions that you may have.

CONTACT DETAILS 

Our full details are:

Legal entity: Softi Ltd. 

Contact: Support Team

Email address: [email protected]

Postal address:

Softi Ltd

21 Ellis Street,

Knightsbridge, London,

SW1X 9AL

United Kingdom

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). 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 17/02/2023

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 My Account at www.softi.io 

THIRD-PARTY LINKS  

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.

  1. 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).

We may collect, use, store and transfer different kinds of personal information about you which we have grouped together follows:

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.

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 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.

  1. How is your personal data collected:

We capture, process, and retain personal information from you and any devices you may use when you navigate to a www.softi.io or mobile view, by transacting, by registering an account and otherwise interacting with us. We may also collect personal information from you if you physically enter one of our stores or attend an event.

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 www.softi.io

Some more examples of the different methods by which we collect information from and about you include through:

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.softi.io.

Technical Data from the following parties:     

(a)  analytics providers such as Google Analytics and Google DoubleClick based outside the EU/ UK;

(b)  advertising networks based inside the EU and Google Display Network based outside the EU/UK;

(c)  Social Network providers such as Facebook, Instagram based outside the EU/UK;

Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as PayPal based outside the EU/UK;

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.

  1. 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:

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 or text message. You have the right to withdraw consent to marketing at any time by accessing your account “My Account”, or by e-mailing or contacting our Customer Services team: [email protected]

When you apply for rewards for life we check and verify your e-mail address. In performing such checks, your information may be disclosed to credit reference agencies such as Experian who keep a record of that information, but these are not credit checks and your credit rating will not be affected. We may contact you by e-mail, phone, text, or SMS in relation to managing your account or the performance of our contract with you including:

  1. 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 Softi Ltd. better understand you and to enable us to personalise your experience with Softi Ltd., including offers, promotions and services to meet your needs. We use your information to:

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 protected]

 

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
     
To register you as a new customer (a) Identity

(b) Contact

(c) Special Categories of Personal information*

(a) Performance of a contract with you

(b) *Consent (Healthbox users only)

To process and deliver your order including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

(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 debts due to us)

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)

To enable you to partake in a prize draw, competition or complete a survey (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 (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) and to prevent, detect, mitigate and investigate fraudulent or illegal activities (a) Identity

(b) Contact

(c) Technical

(d) Financial

(e) Usage

(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 or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you (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 use data analytics to improve our website, products/services, marketing, customer relationships and experiences (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) *Special Categories of Personal information

(a) Necessary for our legitimate interests (to develop our products/services and grow our business);

(b) In limited circumstances we rely on consent (see marketing communications from us below)

(c) *Consent (for the purpose of Healthbox recommendations

 

 

 

 

 

MARKETING

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: [email protected]

In summary:

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, SMS, phone or social media 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.

Softi Ltd. 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 Softi Ltd. or an existing customer or user of Softi Ltd. 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 [email protected]

THIRD-PARTY MARKETING  

We will get your express opt-in consent before we share your personal information with any company outside Softi Ltd. 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 www.softi.io, 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 protected]

You can use your web browser to:

OPTING OUT  

You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes at My Account to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or you can make changes by contacting us at any time: [email protected]

THE RIGHT TO OBJECT TO PROFILING

Where we process personal information relating to your interaction (transactions, site visits, app usage) with www.softi.io to enable us to personalise your experience with www.softi.io. 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.

You have the right to object to how your personal information is processed including your right to object to profiling as outlined in this privacy policy.  More information on this right to object and how to exercise your rights can be found in section 10. Your Legal Rights below.

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.  

COOKIES

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.

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: [email protected]

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.

  1. 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.

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 [email protected] if you want further information on the third parties we use.

 

  1. 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:

Please contact [email protected] if you want further information on the specific mechanism used by us when transferring your personal information out of the EEA.

  1. 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.

  1. 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.

  1. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal information. Please see below to find out more about these rights and access the request forms should you want to make any of these requests:

If you wish to exercise any of the rights set out above, please send the completed forms to us to the e-mail or postal address included on the form.

NO FEE USUALLY REQUIRED  

You will not have to pay a fee to access your personal information (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 may 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 information (or to exercise any of your other rights). This is a security measure to ensure that personal information 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 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.

You have the right to:

Request access to your personal information (commonly known as a “data subject access request”. This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it. If you want to receive a copy of any information we process about you please contact our team at [email protected]

Request correction of the personal information 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. You can update your information at any time at your ‘My Account’ or by contacting our team at [email protected]

Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information 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 information 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 which will be notified to you, if applicable, at the time of your request. You can request erasure of your information at any time by contacting [email protected]

Object to processing of your personal information 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 information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. You can update your marketing preferences at any time at your ‘My Account’ and/or object to other processing contacting [email protected]

Request restriction of processing of your personal information. This enables you to ask us to suspend the processing of your personal information in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. You can request restriction of processing contacting [email protected]

Request the transfer of your personal information to you or to a third party. We will provide to you, or a third party you have chosen, your personal information 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. You can request the transfer of your personal information by contacting [email protected]

Withdraw consent at any time where we are relying on consent to process your personal information. 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 can withdraw your consent at any time by contacting [email protected]

  1. Glossary

Cookie Policy

So that you can make full use of the interactive features on our website, your computer, mobile phone or other device (all referred to here as device) will need to accept cookies.

Here you can see what cookies may be sent to your device by www.softi.io and what we use each cookie for. You can set your browser to reject cookies (see the ‘Help’ menu of your browser to find out how to do this), but please bear in mind that if you do this, certain personalised features of this website cannot be provided to you.

What is a Cookie?

A cookie is a small piece of data (text file) that a website, when visited by a user asks your browser to store on your device in order to remember information about you. This information is then sent back to us on each subsequent visit (“first party cookies”), or to another website that recognises that cookie (“third party cookies”). Cookies are useful because they allow a website to recognise a user’s device.

Cookies are also essential to the functioning of certain parts of the site and we use them to collect information about how the site is used, such as how many people visit and return and what products are being viewed. We also use ‘Pixels’, or ‘Transparent GIF files’, to help manage our online advertising. This in turn helps us learn which advertisements are most effective at bringing users to our website.

There are two types of cookies that can be used:

Persistent cookies – these cookies remain on a user’s device for the period of time specified in the cookie. They are activated each time that the user visits the website that created that particular cookie.

Session cookies – these cookies allow website operators to link the actions of a user during a browser session. A browser session starts when a user opens the browser window and finishes when they close the browser window. Session cookies are created temporarily. Once you close the browser, all session cookies are deleted.

Cookies do lots of different jobs, like letting you navigate between pages efficiently, remembering your preferences, and generally improving your user experience. They can also help to ensure that adverts you see online are more relevant to you and your interests.

You can find more information about cookies at aboutcookies.org and ICO.org

Cookies used on the Website

A list of all the cookies used on the website by category is set out here:

 

Strictly Necessary Cookies

These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, accessing secure areas of the website, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work for example such as shopping baskets or e-billing. These cookies do not store any personally identifiable information.

Performance Cookies

These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies we will not know when you have visited our site, and will not be able to monitor its performance.

Functional Cookies

These cookies enable the website to provide enhanced functionality and personalisation by remembering your choices to improve your experience. This can include remembering your user name, language, region you are in, text size, fonts and other parts of web pages that you can customise. They may be set by us or by third party providers whose services we have added to our pages. If you do not allow these cookies then some or all of these services may not function properly.

Targeting Cookies

These cookies may be set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. They do not store directly personal information, but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising.

Social Media Cookies

These cookies are set by a range of social media services that we have added to the site to enable you to share our content with your friends and networks. They are capable of tracking your browser across other sites and building up a profile of your interests. This may impact the content and messages you see on other websites you visit. If you do not allow these cookies you may not be able to use or see these sharing tools.

Behavioural advertising and online privacy

Behavioural advertising enables retailers to display adverts to you on the web based on the products and retailers that you have previously visited. A guide to behavioural advertising and online privacy has been produced by the internet advertising industry which can be found at www.youronlinechoices.eu. The guide contains an explanation of the self-regulatory scheme to allow you greater control of the advertising you see.

You agree that we may also use technologies, such as our own cookies, to provide you with relevant online display advertising tailored to your interests.

Managing cookies

Because we respect your right to privacy, you can choose not to allow some types of cookies. 

However, cookies are essential to allow you to take advantage of some of the website’s features, so we recommend that you leave them turned on. For example, if you block or otherwise reject cookies you will not be able to add items to your Shopping Basket or sign into your account.

You can find more information about this topic at ICO.org or PDPC.gov

As is true of most web sites, we and our third-party tracking-utility partner gather certain information automatically and store it in log files.  This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data.

You agree that we may use this information to analyse trends, to administer the website, to track users’ movements around the website and to gather demographic information about our user base as a whole.

Contacting Us

If you have any queries, please contact us at [email protected] or writing to us at Softi Ltd. Our company registered address is Softi Ltd, 21 Ellis Street, Knightsbridge, London, SW1X 9AL, United Kingdom.

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