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This privacy statement (hereinafter “Privacy Statement”) governs the processing of your personal data by the Lock Stock & Barrel Grooming Company Limited (hereinafter: “Lock Stock & Barrel”,  “we”, “us”, “our”) as part of your visit to our website www.lockstockandbarrel.com (hereinafter: the “Website”), your communication with us via e-mail, telephone, fax and social media channels (such as Facebook, LinkedIn, Instagram and YouTube).

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IN GENERAL

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The data controller of the processing of your personal data is Lock Stock & Barrel Grooming Company Limited, 187 Park Lane, Birmingham B35 6AN, United Kingdom (a list and the contact details of the Lock Stock & Barrel Grooming Company Limited can be found here).

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A reference in this Privacy Statement to certain laws or regulations also includes any change, replacement or annulment of these laws or regulations, including any related executive decisions.

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Lock Stock & Barrel reserves the right to, from time to time, modify, change or amend this Privacy Statement at its own discretion. Such modification change or amendment will be communicated via the Website. If you do not accept the modifications, changes or amendments, you are to inform us by sending an e-mail to privacy@lockstockandbarrel.com. If we do not receive such an e-mail from you within three (3) business days after the changes to the Privacy Statement have been announced on the Website, you will be deemed to have accepted all such changes.

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TYPES OF PERSONAL DATA WE PROCESS

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Whenever you use our Website and social media channels, we may collect

 

• Technical information associated with the device you use, such as your IP-address, browser type, geographical location and operating system;

• Information concerning your browsing behaviour, such as how long you visit, which links you click on, which pages you visit and how many times you visit a page.

• When you fill out the contact form or Sign Up form on our Website, or contact us via e-mail, telephone, fax or social media channels, we collect:

• The basic identity information you provide us with, such as name, e-mail address, postal address, telephone number, your country, and the company you work for;

• The content of your communication or enquiry and the technical details of the communication itself (with whom you correspond at our end, date, time, etc.).

• Your preferences with regard to the communication medium used;

• Publicly available information of your profile on social media channels;

• Any other personal data you choose to provide to us.

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We receive all personal data mentioned above directly from you. We may receive additional information about your preferences and browsing behaviour from partners such as Google, Campaign Monitor or Wix. If you require more information about the personal data these parties process about you and make available to others, you are kindly requested to consult their respective privacy policies.

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PURPOSES FOR WHICH WE USE YOUR PERSONAL DATA

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Lock Stock & Barrel processes your personal data to provide you in a personalised and efficient way the information, products and services you request via the Website, by e-mail, telephone, fax or social media channels.

Lock Stock & Barrel processes your personal data for marketing purposes, i.e. to provide you with targeted communications, promotions, offerings and other advertisements of Lock Stock & Barrel only.

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Lock Stock & Barrel will only send you communications, promotions, offerings, newsletters and other advertisements via e-mail or other person-to-person electronic communication channels if you consented thereto.

Lock Stock & Barrel processes your personal data to comply with legal obligations or to comply with any reasonable request from competent law enforcement agents or representatives, judicial authorities, governmental agencies or bodies, including competent data protection authorities.

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Your personal data may be transferred upon Lock Stock & Barrel’s own initiative to the police or the judicial authorities as evidence, or if there are justified suspicions of an unlawful act or crime committed by you through your registration with or use of the Website, our social media channels or other communications with us.

Lock Stock & Barrel processes your personal data to perform statistical analyses so that we may improve our Website, advertisement, products and services or to develop new products and services.

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Lock Stock & Barrel processes your personal data for the preservation of the legitimate interests of Lock Stock & Barrel, its partners or a third party if your registration with or use of the Website, social media channels or other communication channels can be considered (a) a violation of any applicable terms of use or the intellectual property rights or any other right of a third party, (b) a threat to the security or integrity of the Website, social media channels or other communication channels, (c) a danger to the Website, social media channels or other communication channels or any of Lock Stock & Barrel’s or its subcontractors’ underlying systems due to viruses, Trojan horses, spyware, malware or any other form of malicious code, or (d) in any way hateful, obscene, discriminating, racist, slanderous, spiteful, hurtful or in some other way inappropriate or illegal.

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LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA

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If your personal data is processed in order to take steps prior to entering into a contract with us, we base the processing of your personal data on the necessity for the performance of that contract, or in the process of entering into that contract.

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The processing of your personal is based on your consent.

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The processing of your personal data is necessary for a legal obligation that Lock Stock & Barrel must comply with.

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The processing of your personal data is necessary for purposes of our legitimate interests, such as:

• Continuous improvements of the Lock Stock & Barrel Website, social media channels, products and services to ensure that you have the best experience possible;

• Keeping our Website, social media channels, products and services safe from misuse and illegal activity;

• Marketing and promotion of our products, services, brands and overall successful commercialisation of our products and services.

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TO WHOM WE SEND YOUR DATA

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Lock Stock & Barrel relies on third-party processors to provide you our Website and process your personal data on our behalf. These third-party processors are only allowed to process your personal data on behalf of Lock Stock & Barrel and upon explicit written instruction of Lock Stock & Barrel.

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Lock Stock & Barrel warrants that all third-party processors are selected with due care and are obliged to observe the safety and integrity of your personal data.

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We ensure that all Lock Stock & Barrel entities will take due care that all processing of your personal data is in line with what is set out in this Privacy Statement.

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Lock Stock & Barrel does not send your personal data in an identifiable manner to any third party without your explicit permission to do so other than the ones mentioned. Lock Stock & Barrel may send anonymised data to other organisations that may use those data for improving products and services as well as to tailor the marketing, displaying and selling of those goods and services.

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LOCATION AND TRANSFER

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Lock Stock & Barrel processes your personal data within the European Economic Area (EEA). However, in order to process your personal data for the purposes outlined above, we may also transfer your personal data to other third parties who process on our behalf outside the EEA. Each entity outside the EEA that processes your personal data will be bound to observe adequate safeguards with regard to the processing of your personal data. Such safeguards will be the consequence of:

• The recipient country having legislation in place which may be considered equivalent to the protection offered within the EEA; or

• A contractual arrangement between Lock Stock & Barrel and that entity. All Lock Stock & Barrel entities are parties to a contractual agreement based on the European Commission’s Standard Contractual Clauses (controller-to-controller) (Commission Decision C(2004)5721).

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Lock Stock & Barrel may transfer anonymised and/or aggregated data to organisations outside the EEA. Should such transfer take place, Lock Stock & Barrel will ensure that there are safeguards in place to ensure the safety and integrity of your data and all rights with respect to your personal data you might enjoy under applicable mandatory law.

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QUALITY ASSURANCES

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Lock Stock & Barrel does its utmost to process only those personal data that is necessary to achieve the above purposes.

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Your personal data is only processed for as long as needed to achieve the purposes mentioned above or up until such time where you withdraw your consent for processing them.

 

Your withdrawal of consent may imply that you can no longer use the whole or part of our Website. Lock Stock & Barrel will de-identify your personal data when they are no longer necessary for the purposes outlined above, unless there is:

• An overriding interest of Lock Stock & Barrel, or any other third party, in keeping our personal data identifiable;

• A legal or regulatory obligation or a judicial or administrative order that prevents Lock Stock & Barrel from de-identifying them.

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You understand that an essential aspect of our marketing efforts pertains to making our marketing materials more relevant to you. This means that, when you consent thereto, Lock Stock & Barrel builds a profile of you based on relevant characteristics outlined in Article 2 above and then uses this profile to provide you with communications, promotions, offerings, newsletters and other advertisements about products and services that may interest you.

Lock Stock & Barrel will take appropriate technical and organizational measures to keep your personal data safe from unauthorised access or theft as well as accidental loss tampering or destruction. Access by personnel of Lock Stock & Barrel or its third-party processors will only be on a need-to-know basis and be subject to strict confidentiality obligations. You understand, however, that safety and security are best efforts obligations which can never be guaranteed.

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If you are registered to receive communications, promotions, offerings, newsletter and other advertisements via e-mail or other person-to-person electronic communication channels, you can change your preferences for receiving such communications, promotions, offerings, newsletter and other advertisements by following the opt-out link provided in each such communications.

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YOUR RIGHTS

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You have the right to request access to all personal data processed by Lock Stock & Barrel pertaining to you. Lock Stock & Barrel reserves the right to charge an administrative fee for multiple subsequent requests for access that are clearly submitted for causing nuisance or harm to Lock Stock & Barrel. Each request will specify for which processing activity you wish to exercise your right to access and will specify to which data categories you wish to gain access to.

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You have the right to ask that any personal data pertaining to you that is inaccurate, is corrected free of charge. If you submit a request for correction, your request needs to be accompanied of proof of the flawed nature of the data for which correction is asked.

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You have the right to withdraw your earlier given consent for processing of your personal data.

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You have the right to request that personal data pertaining to you is deleted if the data is no longer required in the light of the purposes outlined in Article 3 above or if you withdraw your consent for processing them. However, you need to keep in mind that a request for deletion will be evaluated by Lock Stock & Barrel against:

• Overriding interests of Lock Stock & Barrel or any other third party;

• Legal or regulatory obligations or administrative or judicial orders which may contradict such deletion.

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Instead of deletion you can also ask that Lock Stock & Barrel limits the processing of your personal data if (a) you contest the accuracy of the data, (b) the processing is illegitimate, or (c) the data is no longer needed for the purposes listed under Article 3 above.

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You have the right to oppose the processing of personal data if you are able to prove that there are serious and justified reasons connected with these particular circumstances that warrant such opposition. However, if the intended processing qualifies as direct marketing, you have the right to oppose such processing free of charge and without justification.

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You have the right to receive from us in a structured, commonly-used and machine-readable format all personal data you have provided to us.

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If you wish to submit a request to exercise one or more of the rights listed above, please send us your request in writing to The Data Protection Officer, Lock Stock & Barrel Grooming Company Limited, PO Box 16869, Birmingham B35 9DT, United Kingdom, or by e-mail to privacy@lockstockandbarrel.com.

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A request to exercise a right will not be construed as consent with the processing of your personal data beyond what is required for handling your request. Such request should clearly state which right you wish to exercise and the reasons for it if such is required. It should also be dated, signed, and accompanied by a digitally scanned copy of your valid identity card proving your identity. If you use the contact form, we may ask you for your signed confirmation and proof of identity.

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Lock Stock & Barrel will promptly inform you of having received this request. If the request proves valid, Lock Stock & Barrel shall honour it as soon as reasonably possible and at the latest thirty (30) days after having received the request.

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For questions or complaints regarding the processing of your personal data by Lock Stock & Barrel, please feel free to contact Lock Stock & Barrel’s general privacy e-mail address: privacy@lockstockandbarrel.com. You equally have the right to file a complaint with the competent data protection authority.

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