INTRODUCTION

September 2023 Update – This privacy policy explains how Manolo Blahnik International Limited and its affiliates (collectively, “MBIL”, “we”, “us” or “our”) use personal data including information you provide to us and information we obtain based on your choices and explains your rights and how you can manage your personal data. This policy only applies to the personal information we collect outside of the United States and from residents of the EU while in the United States, including when you access or use our websites, native mobile applications, or any other applications, services, or features that link to this privacy policy; interact or communicate with us in any way or using any media; purchase or use our products, services, or features; engage with us on social media; interact with our advertisements or marketing materials; or participate in any of our programs or events. For information about our usage of personal information collected in the United States from individuals who are not residents of the EU, please see our Privacy Notice available here.

Additional privacy disclosures may apply for certain products, services, features, activities, programs, and offerings. We may also provide additional “just-in-time” notices that supplement or clarify our privacy practices or provide you with additional choices regarding your personal data.

You can click specific sections which explain how we operate and use personal data.

We use personal data to provide you with products and services, to communicate with you and to comply with our legal obligations. We may use your personal data to develop and grow our business and improve our products and services.

We aim to be transparent on how and for what purpose we hold and use personal data. We strive to keep data safe and secure and hold it only for as long as we need it. We do not knowingly collect or process data relating to children.

Should you have any queries or need further information, please contact dataprotection@manoloblahnik.com

ABOUT US

Manolo Blahnik is the brand name of different legal entities, details of which are set out on this page. Manolo Blahnik International Limited (company number 00971691) with registered office at 31 Old Burlington Street, London, W1S 3AS is a “controller” also referred to as a “data controller” in respect of personal data processed according to this policy. This means that we are responsible for and control what happens to your personal data. We are registered with the Information Commissioner under registration number ZA262518.

The following commonly-owned and commonly-branded affiliates of MBIL follow, and are covered by, this policy: 

  • MANOLO BLAHNIK SWITZERLAND SA
  • BLAHNIK GROUP LIMITED
  • MB FRANCE SAS
  • MB AMERICAS LLC
  • CALZATURIFICIO RE MARCELLO S.R.L

This policy is issued on behalf of MBIL and the related companies above. We may share personal data between these companies, which are subject to this policy.

Our website may link to third party sites, plug-ins or applications. This notice does not apply to this external content and we do not control or monitor external sites. We recommend that you review notices on external websites and applications as their approach and notices will be different.

CHANGES TO THIS NOTICE

We may update this notice at any time and will post the changes online.

WHAT IS “PERSONAL DATA”? WHAT IS “PROCESSING”?

“Personal data” is information that allows you to be identified. This does not include anonymous data where you cannot be recognised, for example financial data or general sales data that we process in an aggregated form.  

“Processing” includes the collection, storage, transfer, editing and updating of personal data. Almost every “use” of personal data is likely to be “processing”. We have categorised the different types of personal data below and explained how and why we “process” this data.

HOW AND WHY WE USE PERSONAL DATA

We use personal data when the law allows us to do so. There are different grounds for using personal data, each known as a “lawful basis”, which include:

  • compliance with the law or our legal obligations;
  • performing a contract with you or a contract we may be about to enter with you;
  • where necessary for our “legitimate interests” or those of a third party; and
  • where you consent to processing.

A “legitimate interest” means a business or commercial reason to use your personal data. We balance this against the impact on you (both positive and negative) and your legal rights. In some instances, more than one lawful basis may apply.

We explain the lawful basis we rely upon and use of your personal data below and retain data only for as long as is necessary to comply with our legal obligations or another legal basis as set out above or to fulfil the purpose for which the data was collected.

For details on requesting copies or deleting your personal data please see the section below.

CONTACT INFORMATION AND IDENTIFICATION

Name, surname, website username, addresses, email address and telephone numbers.

TYPE OF DATA / USE FURTHER DETAILS “LAWFUL BASIS”
New accounts and purchases. To create an account on our website we need details to identify you and manage your account.

We also use this information to administer your account, to process and send you an order, including where you do not create an account but order as a “guest”.

 To perform the contract between us or where you have not yet entered into a purchase it is in our legitimate interest.
Communicating about orders, returns and after sales service. When you place an order, we use your details to confirm and accept the order and to send information on delivery.

Where you ask to return a product, we need to identify you, your order and may communicate with you if you have queries or ask to return a product.

 To perform the contract between us.

To give effect to your legal rights and to comply with our legal obligations.
Contacting you about new products, news and events.

 We want to keep you informed about our new products and exciting news about our brand. We will only do this where you have asked us to contact you and you can ask us to stop at any time.

You can unsubscribe at any time via the link in the emails that we send to you or by contacting us at dataprotection@manoloblahnik.com

 It is in our legitimate interests to promote our brand, services and products.

We ask for your consent to contact you for marketing.

You provide this consent when you tick the box online, enter your email into the newsletter sign-up field on the website or where you provide your details to a sales assistant in our boutiques and confirm you want to be contacted.
Communicating with you when you contact us. If you ask us a question, raise a concern or if you get in touch with us for any reason, we need to use your contact details to answer and communicate with you.

 To perform the contract between us or where we have not yet entered into a contract, it is in our legitimate interests.
Payment processing.

 We need personal data to process payments.

We do not have access to or store any card data. We use a third-party payment service provider to process payments.

Without your data we cannot process and receive your payment and you will not receive your order.

We also use this information when we process refunds to ensure the payment can be made and is made correctly.

 To perform the contract between us.

To comply with our legal obligations.
To let you know if we change our terms and policies. When we make significant updates to this notice and how we use data, we want you to know about the changes. We may send an email to let you know what has changed and where you can review the changes and what this means for you and your data or may post the updated policy online.

 To perform the contract between us or where we have not yet entered into a contract, it is in our legitimate interests.

To comply with our legal obligations.
To prevent fraud, security breaches, legal violations and misuse of our website.

 We need to check that payments made to us are genuine and not fraudulent.

We need to protect you against fraud and criminal activity and protect our business.

We use third party service providers to assist with fraud screening and monitoring. 		To comply with our legal obligations.

It is in our legitimate interest to protect our website from misuse either to comply with legal obligations or prevent breaches of our website terms.
To send you “abandoned basket” emails.

If you are part way through the order process and the transaction is closed we may send an email to confirm whether you meant to cancel the order and to give you the chance to restore your transaction.

This saves you having to go back to our site and repeat the order process.

You will only receive one email in a 7 day period. 30 days after the email is sent your email address will be anonymised on the system.

Emails submitted via this function will not be used for marketing or other purposes unless you have requested this separately. 		It is in our legitimate interests to check that everything is OK with your order, to ask if you would like to complete the transaction and to help track purchases on the website.
To send “back in stock” emails.

If you ask to be notified when a product is back in stock by giving us your email, we will contact you to confirm your request and then once more if the product comes back into stock.

The email will contain an option to stop tracking the product at any time and email addresses will be automatically deleted after 120 days.

Email addresses submitted via this function will not be used for marketing or any other purposes. 		To perform the contract between us and because you have asked us to do something before entering into the contract.

It is in our legitimate interests to offer this function to customers and to notify customers of stock and availability when requested.
DATE OF BIRTH AND GENDER
TYPE OF DATA / USE FURTHER DETAILS “LAWFUL BASIS”
To prevent fraud, security breaches, legal violations and misuse of our website. We need to check that payments made to us are genuine and not fraudulent.

We need to protect you against fraud and criminal activity and protect our business.

We use third party service providers to assist with fraud screening and monitoring (see below).		 To comply with our legal obligations.

It is in our legitimate interest to protect our website from misuse which may not result from compliance with a legal obligation but is a breach of our website terms.
To recommend products to you and to understand more about you. We may recommend products and services to you that are of interest and better suited to you as an individual.

We also need to understand more about you and demographics, so we can offer a range and variety of products and services that you and other customers want.

 It is in our legitimate interest to understand more about you, who is buying our products and how we can improve our products and services, so they are suited to our customers and clients as a whole and to particular individuals.
Age verification

We need to verify the age of people using our site to ensure the website is not being used by children. To comply with our legal obligations.
PAYMENT DETAILS AND PAYMENT INFORMATION
HOW DO YOU USE THIS DATA? FURTHER DETAILS “LAWFUL BASIS”
Payment processing We need personal data to process payments.

We do not have access to or store card data. We use third party payment service providers to manage and handle payments.

You provide information directly to the relevant provider, which operates a secure server to process payment details, encrypting your information and authorising payment.

Information provided is not within our control and is subject to the payment provider’s privacy notices and terms.

We do not have access to or store any card data. We use a third-party payment service provider to process payments.

Without your data cannot process and receive your payment and you will not receive your order.

We also use this information where we deal with refunds to ensure the payment can be made and is made correctly.

 To perform the contract between us.
To prevent fraud, security breaches, legal violations and misuse of our website. We need to check payments are genuine and not fraudulent.

We need to protect you against fraud and criminal activity and protect our business.

 To comply with our legal obligations.

It is in our legitimate interests to protect you and our business against fraud and criminal activity.
To comply with our tax and accounting obligations.

 We need to keep a record of invoices we issue and payments made and received for audit and tax purposes.

We keep invoices that we send to you and information on payments received.

This may include your contact details, order details and invoice number / order number.

 To comply with our legal obligations.
TRACKING AND RECORDING PURCHASES
TYPE OF DATA / USE FURTHER DETAILS “LAWFUL BASIS”
Storing and recording your purchases and orders. We do this so you can make a purchase and place your order. We need to have a record of this information to accept your order and send you your purchase.

If you open an account, you can easily see what you have purchased and your order history.

We also use this information to deal with queries and communications you might send about your purchases.

 To perform the contract between us.

It is in our legitimate interest to keep track of purchases and orders of our products from our website.
To offer you additional products, services and benefits. We keep a record of the purchases you make as we may offer new or similar styles or products in future that may be of interest. This helps us to understand your interests.

For some customers and clients we may also offer access to additional benefits, sales, discounts, exclusive offers and events based on their purchase history. 		It is in our legitimate interest to offer you products and services that you want to receive and deals or benefits you might be interested in.
To understand more about our business, products and about you. We use the data to understand what styles are successful and popular including region specific preferences, so we can offer customers and clients what they want and provide the best products and services as a business. It is in our legitimate interest to track and understand our successful products, so we can grow and improve our business.
SALES AND EVENTS
TYPE OF DATA / USE FURTHER DETAILS “LAWFUL BASIS”
We store your contact information if you are invited to an exclusive sale or event. We retain details of people who attend our events, so we know who attended for similar events in the future.

In most cases you will be invited by someone you know at Manolo Blahnik or referred by a friend.

Normally you will be invited by a personal contact or because you have asked to be contacted for such events.

You can change your preference at any time by contacting us at atdataprotection@manoloblahnik.com

It is in our legitimate interest to invite our customers and contacts to events.
COMMUNICATIONS WITH YOU
TYPE OF DATA / USE FURTHER DETAILS “LAWFUL BASIS”
Records of communications with you including emails, chats with customer services and notes we might make in conversations or telephone calls with you. We keep a record of our communications with you so we can offer you the best service, improve our standards and how we operate and to train our team.

We will use this information to handle any queries or concerns and see a complete history of our communications. This may be shared with relevant individuals within our business depending on the nature of your request.

We also keep a record of this information so we can handle any similar queries or concerns from other customers and clients.

 To perform the contract between us.

It is in our legitimate interests to keep proper records of communications in our business – of course we will only keep them for as long as necessary.

It is in our legitimate interests to learn from any feedback received in emails, chats and calls, so that we can improve our business.
SOCIAL MEDIA
TYPE OF DATA / USE FURTHER DETAILS “LAWFUL BASIS”
Your username and information when you contact us via social media accounts and our conversation history. We use this information to communicate with you via social media if you contact us with queries or concerns. We will retain the conversation history so our customer service team can see the entire interaction and to improve our responses and service.

 To perform the contract between us.

It is in our legitimate interests to keep proper records of communications in our business, however we will only keep them for as long as necessary.

It is in our legitimate interest to learn from any feedback received in emails, chats and calls, so that we can improve our business.
Username and likes in relation to our social media campaigns. We may record and store the number of likes and comments on our official account and posts on social media and may download and store all comments on a particular post or campaign.

This allows us to improve and develop our posts and service to see which styles, images and posts are positively received.

 It is in our legitimate interest to monitor and learn from our social media activities, so that we can improve their success.
Username and information when you tag or link to us on social media or your posts.

 If you refer to, link or tag us on social media, we may repost that image along with your username on our official social media accounts. This allows us to interact with you on social media and through posts about our brand.

 It is in our legitimate interests to respond to you when you interact with us on social media, so that we can respond to you and deal with any queries or feedback.
CCTV
TYPE OF DATA / USE FURTHER DETAILS “LAWFUL BASIS”
We have CCTV in our boutiques, this data is only reviewed in the event of a complaint or issue. We use this to prevent and detect criminal activity and to ensure your safety and employee safety.

This information is not reviewed regularly, access is restricted to specific individuals and footage is deleted on a rolling basis unless it needs to be retained where a specific issue has arisen.

 To comply with legal obligations.

It is in our legitimate interests to keep our employees, our customers, our products and our boutiques safe and secure.
TECHNICAL DATA - DEVICES, LOCATION AND USE OF THE WEBSITE

Information you or your device provide when you use our website including your IP address, browser type, device type and in some cases your location.

TYPE OF DATA / USE FURTHER DETAILS “LAWFUL BASIS”
To offer the correct currency, language and delivery information. Our website should automatically select an appropriate currency based on your location. This allows us to show you the correct currency and calculate the correct delivery costs.

This can be changed using the menu on the website.

 It is in our legitimate interest to offer regional personalisation on our website, to make your experience smoother, personalised and appropriate.
To improve and update our website and improve the service we offer. This allows us to review and improve our website including running tests, maintenance and support and reviewing hosting data to understand more about how the website functions and where we need to make changes and improvements.

 It is in our legitimate interest to learn from how users interact with our website, to make your experience smoother.
To prevent fraud, security breaches, legal violations and misuse of our website.

 We need to protect you against fraud and criminal activity and protect our business.

We also audit the use and downloads of data from our website.

We use third party service providers to assist with fraud screening and monitoring (see below). 		To comply with our legal obligations.

It is in our legitimate interests to use the data obtained from our website to improve its security.
Monitoring your use of the website and specific pages.

 We use a third party service that helps us to understand our user’s needs and experience. The service uses cookies and other technologies to collect data on use of the site including an IP address, screen size, device type, browser information and country. This is stored by our service provider under a pseudonymous profile.

We use this data to understand where the website is not working properly or is not effectively laid out and use the data to make changes to the website. 		It is in our legitimate interests to use data obtained from use of the website to make changes to improve the user experience.
OTHER TYPES OF DATA

We do not collect any “special categories” of data or data on criminal convictions or offences about you. Special categories of data include details on race, ethnicity, religious or other beliefs, sexual orientation, political opinions, trade union membership or health and genetic data.

IF YOU DO NOT PROVIDE YOUR PERSONAL DATA

If we need your personal data to comply with the law or to perform our contract and you do not provide your data, we may not be able to perform the contract. If this is the case, we will tell you.

To sell products, we need payment information and contact information to process your payment and order and to send you your purchase. As another example, if you do not wish to provide certain personal data, the functionality of the website and the quality of your experience may be impacted and you may not receive the best service.

If you do not provide your contact details, we may not be able to communicate with you about our new products, invite you to events or provide you with exclusive offers.

CHANGING THE USE OF PERSONAL DATA

We will use personal data for the purpose for which we collected it. If we consider that we need to use personal data for something else, which is compatible with the original purpose, we may use it for that new purpose. If you would like an explanation on how any new purpose is compatible with an original purpose, please contact us at dataprotection@manoloblahnik.com

Where we need to use personal data for an unrelated purpose we will inform you and explain the lawful basis that allows us to do so. We may process your personal data without your knowledge or consent in compliance with this notice, where we are required or permitted to do so by law.

SOURCES OF DATA

We collect your personal data in a number of ways, which are summarised below.

METHOD DESCRIPTION
Directly If you create an account with us, place an order, sign up to our newsletter, contact us or attend an event or sale, you will provide us with your data directly.

You may provide personal details in our boutiques or online or electronically via the website, email or by phone or if you provide feedback or request after-sale support.

We may match and check personal data provided online against data from our boutiques to ensure data is accurate and up to date and that do not have duplicate records.
Automated technology When you use the website, we collect technical information (see “TECHNICAL DATA” above) about your device, browsing and in some cases your location and IP address. This is collected using cookies and similar technologies. We may also receive technical data if you visit other websites that use our cookies.

For more details please see our cookies notice HERE

Third Parties / Public Sources

We may receive personal data from third parties and public sources including data from analytics providers such as Google, search information providers, providers of technical, payment and delivery services, public sources such as Companies House and the Electoral Register, or providers of contact information and databases, some of whom may be based outside of the EEA.

We use third parties to process and provide data including business partners, payment service providers, logistics companies and analytics and search information providers.
Group members or concessions

If you make a purchase in a store operated by another Manolo Blahnik company or through a concession or licensee and provide your personal information, we may be provided with a record of your transaction and your personal details.

Where we receive personal data from a third party, we require that they only provide information in accordance with the law.
CCTV

We use CCTV in our boutiques which may record your visit. This is not reviewed or monitored on a regular basis, is only accessed by permitted individuals and will only be accessed where necessary in the event of an issue, complaint or suspected criminal activity.
AUTOMATED DECISION MAKING AND PROFILING

We may use personal data to carry out automated decision making or profiling. This would include identifying products or providing advertising that is tailored to you. We sometimes use systems to make automated decisions based on personal data we have already or are allowed to collect from other sources. This allows us to make quick, fair, efficient and correct decisions using that data. These decisions can relate to products, services or features that we may offer.

We may also use personal data to detect fraud or money laundering using automated systems via our third party service providers. Our payment service provider, fraud screening services or other third-party agencies may notify us of potential fraud and we can cease payments or activity on a specific account.

In relation to automated decisions, we do not use any systems which may have a legal or similarly significant effect on you. If we should do so in future, these will be separately highlighted. If you have any queries on these rights and these decisions, please contact us at dataprotection@manoloblahnik.com

ADVERTISING, MARKETING AND EMAILS

We want to keep you informed and up to date on our new products, exciting events and offers, however we appreciate you may not want to receive these communications. We give you the choice on how we use personal data for marketing communications.

You will receive marketing emails if you have signed up to our newsletter and have given your consent, either online or via our boutiques.
You can ask us to stop sending communications to you at any time, either by clicking “unsubscribe” in the email we send to you or by emailing us at dataprotection@manoloblahnik.com.

Where you do not give consent or if you withdraw consent to receive marketing communications we still retain your personal data for transactional purposes and we rely on a different “lawful basis”.

For marketing emails, we use a third-party email marketing provider based in the United States called MailChimp. MailChimp act on our instructions and do not share your data with anyone or use it for any other purpose.

MailChimp may use data we provide to them for its legitimate business purposes including management of our account. MailChimp also uses cookies, unique identifiers, web beacons and similar tracking technologies. This allows us and MailChimp to see information about the emails we send, including how many people read, open and/or forward our emails. MailChimp may also transfer your data anywhere in the world. Please read the MailChimp Privacy Notice HERE and other information available HERE.

We may use your personal data to create an impression of what products you may be interested in or products and services that may be relevant to you. This can be used to offer you products, services and offers that are suited to you personally.

We may also advertise online and target advertisements on other websites and platforms. This is carried out with different technical networks, ad exchanges and technology, including cookies, pixels, web beacons and specific services offered by third parties. The advertising you see is based on information we hold about you and your use of our site and purchases or previous interaction with our website.

If you would like to read about how you can control which adverts you see online, see opt-out programs established by the Digital Advertising Alliance (United States) or European Interactive Digital Advertising Alliance. We do not control cookies which are set by advertising networks.

There are also many other places where you may see advertisements for us, and not all of these are based on using your personal data. We may also bid for non-personalised advertising space on websites and social media. So even if you opt out of advertising using one of those programmes, you may still see our advertisements online and in social media.

COOKIES AND OTHER TECHNOLOGY

We use cookies, other technology and applications to collect data about your use of our website including information about your device, connection information, page views, traffic, links referring to the website, Internet Protocol (“IP”) address and standard web log information.

For more information on our use of cookies and other technology, please see our cookies policy HERE

Our marketing emails (via MailChimp) also use cookies and other technology such as pixels and web beacons to analyse trends and gather information about the information we send. For more information, please see the MailChimp Privacy Notice HERE and other information available HERE.

SHARING DATA

We share data with companies as part of managing and running our business, providing products and services to you and for online advertising and marketing (where you have given your consent).

We share data with the following categories of recipients:

GROUP AND RELATED COMPANIES

- This allows us to consolidate data across our business.

DELIVERY AND LOGISTICS

We share your data with companies that store, pack and deliver products to physically send products or contact you to provide you with your order. We use a variety of different service providers for this who may subcontract delivery in different countries. For some territories we use a cross border e-commerce solution and may share your data with them for the purpose of fulfilling your order and dealing with returns.

PROFESSIONAL SERVICES

We share your data with hosting companies that administer and host our website, IT service providers who manage our internal systems and technology, finance software and audit providers, database and Enterprise Resource Planning software services that help us manage our business and products, event planners and coordinators and our other professional advisors and agents such as law firms, accountants and insurers.

When you provide data to us directly either in store or online this is provided into a third party system. When you contact us about your order we may use a third party service to help manage these emails and requests. Some data is shared with a third party that provides this platform and software. We have contracts in place with these third parties and they do not sell data collected on our behalf and must collect and use data in accordance with our instructions and in compliance with the law.

FRAUD SCREENING

We are using the services of trusted providers to help us prevent online fraud. Our service providers may use and process your personal data in accordance with data protection law. This includes checking your details before you make a purchase to ensure the transaction is not fraudulent.

PAYMENT SERVICES

We use third party payment providers to process payments and do not store card information for purchases on our website. The platforms process payments and deal with fraud management and screening.

USE OF THE WEBSITE, USER EXPERIENCE AND SEARCH

We use third party services that help us understand customers’ use and experience on the website. This includes the time spent on specific pages, which links are clicked and what users do and do not like. We also use a third party search function on our website to optimise user search experience which can offer similar or complementary products based on previous searches. The services use cookies and other technology to collect data on user actions and devices. The service does not sell data collected on our behalf.

CUSTOMER DATA INTELLIGENCE

We share customer data with a third party that provides customer intelligence which allows us to review, consolidating and segmenting customer data so that we can deliver the most relevant communications to customers in store and online. This can include segmentation by demographic, location and purchase behaviour. This helps us to ensure our marketing (where customers have consented) is relevant and of interest. This system allows us to manage and use customer data effectively and efficiently. We have contracts in place with this third party and it does not sell data collected on our behalf and must collect and use data in accordance with our instructions and in compliance with the law.

GOVERNMENT AND REGULATORY BODIES

We may need to share data with law enforcement, tax authorities, fraud agencies and other governmental and public bodies where required by law, to prevent crime or fraud, to comply with our legal obligations and to support in the investigation and prevention of alleged criminal activity.

COMPANIES YOU ASK US TO SHARE DATA WITH

Insofar as we are able, we will share your data with any third party that you may request.

EMAIL MARKETING

We use MailChimp to send out our emails for marketing. MailChimp may not use our email data for their own purposes and only act on our instructions. For the MailChimp Privacy Policy please click HERE and for other information please click HERE.

We may provide anonymised data to third parties relating to sales, business performance and analytics and to manage and improve our website. We will take steps to remove any personal data from this information prior to this analysis.

If we were to sell, transfer, or merge any part of our business or assets or acquire another business we may need to share data with a third party for that transaction.

If a change happens to our business, any new owner or company may continue to use your personal data as set out in this privacy notice.

TRANSFERS OF DATA

We share personal data within our group of companies and related companies which may involve transferring your data outside of the European Economic Area (EEA).

Some of our service providers are based outside the European Economic Area (EEA) so when we share data with them and they provide us with the services we have requested this will involve processing data outside of the EEA.

We and our processors may transfer your data anywhere in the world.

Whenever we transfer personal data outside of the EEA, we take steps to ensure similar protection as in the EEA by ensuring at least one of the following safeguards is implemented:

  • we transfer personal data to countries that have been deemed to provide adequate protection for personal data by the European Commission; and/or
  • we use specific contracts approved by the European Commission giving personal data the same protection as in Europe.

Please Contact us at dataprotection@manoloblahnik.com if you would like further information on transfers of personal data outside of the EEA.

PROTECTING DATA AND SECURITY

We require third parties to respect security of personal data we share with them and to treat it in accordance with the law. We do not allow third-party service providers to use personal data for their own purposes and we only permit processing of personal data for specified purposes, in accordance with our instructions and the in compliance with the law. Third parties we share data with are also subject to a duty of confidentiality.

We have security, technical and organisational measures to prevent personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Some examples safeguards we have implemented include firewalls and data encryption, physical access controls and information access controls. We limit access to personal data to employees, agents, contractors and third parties who need to know or need to access that data. We have put in place procedures to deal with data breaches and will notify you and any applicable regulator of a breach where we are required to do so.

Where you have a password for the website, you must keep this confidential and not share this with anyone.

RETAINING DATA

We retain personal data for as long as necessary to fulfil the purposes for which we collected it, including satisfying any legal, accounting or reporting requirements for our business.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means and applicable legal requirements.

For tax and accounting purposes we have to keep some information about our customers for at least six years after a purchase.

In some circumstances you can ask us to delete your data (see “YOUR RIGHTS” below for further information).

In some circumstances we may also anonymise your personal data (so you can no longer be identified) for research or statistical purposes whereupon we may use this information indefinitely.

YOUR RIGHTS

Where we offer goods to customers in the European Union, such customers have the right to make a complaint to a supervisory authority or regulator in the EU (outside of the UK).


MB France is the designated representative of MBIL in the EU. MB France can be contacted at dataprotection@manoloblahnik.com or via post at 11-12 Galerie de Montpensier, Palais Royal, Paris 75001.


You have the following rights:

REQUEST ACCESS TO YOUR PERSONAL DATA
You can request a copy of personal data we hold about you and you can check that we are processing lawfully.

REQUEST CORRECTION OF YOUR PERSONAL DATA
You can request that incomplete or inaccurate data we hold about you is corrected. We may need to verify the accuracy of the new data you provide and your identity.

REQUEST ERASURE OF YOUR PERSONAL DATA
You can ask us to delete or remove your personal data where

  1. there is no good reason for us continuing to process it;
  2. where you successfully exercise your right to object to processing (see below); or
  3. we have processed information unlawfully or where required under local law.

We may not always be able to comply with your request for specific legal reasons which will be notified to you, if applicable.

OBJECT TO PROCESSING OF YOUR PERSONAL DATA
You may object to processing your personal data where we rely on legitimate interests and believe the processing impacts your fundamental rights and freedoms. We may demonstrate that we have overriding legitimate grounds to process your information which override your rights and freedoms.

REQUEST RESTRICTION OF PROCESSING
You may request restriction of processing of your personal data. This enables you to ask us to suspend processing:

  1. if you want us to establish the data's accuracy;
  2. where use of the data is unlawful, but you do not want us to erase it;
  3. 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
  4. you have objected to our use of the data, but we need to verify whether we have overriding legitimate grounds to use it.

REQUEST TRANSFER OF YOUR PERSONAL DATA
You may request we transfer your personal data to you or a third party. We will provide to you, or a third party you have chosen, your personal data 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.

WITHDRAWING CONSENT
Where we rely upon consent, you may withdraw your consent at any time. If you withdraw consent, we may not be able to provide certain products or services to you.

If you wish to exercise your rights, please contact us at dataprotection@manoloblahnik.com.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is unfounded, repetitive or excessive. Alternatively, we may refuse to comply in such cases.

We may need to request specific information to confirm your identity and ensure your right to access the personal data or to exercise a specific right. This is a security measure to ensure personal data is not disclosed to the incorrect person.

We may also contact you to ask you for further information in relation to your request to improve our response and response time.

We will try to respond to legitimate requests within one month, however on occasion it may take us longer where your request is particularly complex or you have made multiple requests.

You have the right to complain to the Information Commissioner's Office (ICO), the UK’s supervisory authority for data protection (www.ico.org.uk). If you have a concern or complaint, we would appreciate the opportunity to try to resolve this with you directly, so please consider contacting us in the first instance at dataprotection@manoloblahnik.com