Privacy Policy
INTRODUCTION
Welcome to Portmeirion Greater China’s privacy notice.
Portmeirion respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data 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.
Please use the Glossary to understand the meaning of some of the terms used in this privacy notice.
Important Information and Who We Are
The Data We Collect About You
How Is Your Personal Data Collected
How We Use Your Personal Data
Disclosures of Your Personal Data
International Transfers
Data Security
Data Retention
Your Legal Rights
Glossary
Important information and who we are
Purpose of this privacy notice
This privacy notice aims to give you information on how Portmeirion Greater China collects and processes your personal data.
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 data 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.
Use of our websites are governed by this notice and our Terms and Conditions and Cookie Policy. By visiting our websites you are accepting to the practices described in this notice.
Controller
This privacy notice is issued on behalf of the Portmeirion Greater China so when we mention "Portmeirion", “Portmeirion” "we", "us" or "our" in this privacy notice, we are referring to the relevant company in the Portmeirion Group responsible for processing your data as follows:
Website
www.portmeirion-china.com
Data controller
SNF Houseware (Shenzhen) Limited
Website
www.portmeirion-hongkong.com
Data controller
SNF Asia Limited
We have appointed a data protection lead who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data protection lead using the details set out below.
Contact details
If you need to contact us about your data please do so by contacting SNF Asia Limited or SNF Houseware (Shenzhen) Limited by emailing the data protection lead at info@schneidteufel.com or by telephoning (852) 2421 7679 or (86) 755 8257 1589 between 9.00am and 5.00pm GMT+8 (Monday to Friday, excluding public holidays in China or Hong Kong).
Data protection law requires Portmeirion Greater China, as controller for your data:
to process your data in a lawful, fair and transparent way;
to only collect your data for explicit and legitimate purposes;
to only collect data that is relevant, and limited to the purpose(s) we have told you about;
to ensure that your data is accurate and up to date;
to ensure that your data is only kept as long as necessary for the purpose(s) we have told you about; and
to ensure that appropriate security measures are used to protect your data.
Changes to the privacy notice and your duty to inform us of changes
We may need to update or change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes. This policy is effective 1 September 2021 It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us. Please inform us at info@schneidteulfel.com of any changes in your data.
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 and organisations connected with us (such as Facebook, Twitter, Instagram and Pinterest) have a social media presence for the purpose of communicating with you, sharing photos and promoting competitions.
If you enable such connections or choose to communicate your personal data to us via third-party websites or social media, please remember that we do not control these third-party websites and are not responsible for their privacy statements. When you leave our website or interact with us on social media, we encourage you to read the privacy notice of every website or forum that you visit or use.
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 data about you which we have grouped together as follows:
Identity Data includes first name, last name, username or similar identifier, marital status, title, date of birth and gender.
Contact Data includes billing address, delivery address, email address and telephone numbers and records of correspondence if you contact us including your email address if you email us, address if you write to us and your telephone number if you call us.
Financial Data includes bank account and payment card details.
Transaction Data includes details about payments to and from you and other details of products you have purchased from us.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
Usage Data includes information about how you use our websites, products and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
We refer to the above categories of data in the data subject category tables which can be found here. 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 data but is not considered personal data 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 data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any Special Categories of Personal Data 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 data
Where we need to collect personal data 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 into 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.
How is your personal data collected?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
apply for our products or services;
create an account on our website;
subscribe to our service or publications;
request marketing to be sent to you;
enter a competition, promotion or survey; or
give us some feedback.
Automated technologies or interactions. As you interact with our websites, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our Cookie Policy for further details. The Portmeirion Greater China Mailing List uses tracking pixels to collect Technical Data for analytics purposes, if you would like to object to the use of tracking technology in relation to the mailing list please contact info@schneidteufel.com.
Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:
Technical Data from the following parties:
analytics, providers (such as Google) based in and outside Greater China;
advertising networks based in and outside the Greater China; and
search information providers based in and outside the Greater China.
Contact, Financial and Transaction Data from providers of technical and payment services such as credit reference agencies based in China, Hong Kong, Macau and Taiwan.
How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
where we need to perform the contract we are about to enter into or have entered into with you.
where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
where we need to comply with a legal or regulatory obligation.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email. You have the right to withdraw consent to marketing at any time by contacting us at info@schneidteufel.com.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
PURPOSE/ACTIVITY
To register you as a new customer
TYPE OF DATA
Identity
Contact
LAWFUL BASIS FOR PROCESSING INCLUDING BASIS OF LEGITIMATE INTEREST
Performance of a contract with you
PURPOSE/ACTIVITY
To process and deliver your order including:
Manage payments, fees and charges
Collect and recover money owed to us
TYPE OF DATA
Identity
Contact
Financial
Transaction
Marketing and Communications
LAWFUL BASIS FOR PROCESSING INCLUDING BASIS OF LEGITIMATE INTEREST
Performance of a contract with you
Necessary for our legitimate interests (to recover debts due to us)
PURPOSE/ACTIVITY
To manage our relationship with you which will include:
Notifying you about changes to our terms or privacy policy
Asking you to leave a review or take a survey
TYPE OF DATA
Identity
Contact
Profile
Marketing and Communications
LAWFUL BASIS FOR PROCESSING INCLUDING BASIS OF LEGITIMATE INTEREST
Performance of a contract with you
Necessary to comply with a legal obligation
Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
PURPOSE/ACTIVITY
To enable you to partake in a prize draw, competition or complete a survey
TYPE OF DATA
Identity
Contact
Profile
Usage
Marketing and Communications
LAWFUL BASIS FOR PROCESSING INCLUDING BASIS OF LEGITIMATE INTEREST
Performance of a contract with you
Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
Consent
PURPOSE/ACTIVITY
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
TYPE OF DATA
Identity
Contact
Technical
LAWFUL BASIS FOR PROCESSING INCLUDING BASIS OF LEGITIMATE INTEREST
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)
Necessary to comply with a legal obligation
PURPOSE/ACTIVITY
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
TYPE OF DATA
Identity
Contact
Profile
Usage
Marketing and Communications
Technical
LAWFUL BASIS FOR PROCESSING INCLUDING BASIS OF LEGITIMATE INTEREST
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)
Consent
PURPOSE/ACTIVITY
To use data analytics to improve our website, services, marketing, client relationships and experiences
TYPE OF DATA
Technical
Usage
LAWFUL BASIS FOR PROCESSING INCLUDING BASIS OF LEGITIMATE INTEREST
Necessary for our legitimate interests (to define types of customers for our products/ services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
Consent
PURPOSE/ACTIVITY
To make suggestions and recommendations to you about products and services that may be of interest to you whilst browsing our websites
TYPE OF DATA
Identity
Contact
Technical
Usage
Profile
LAWFUL BASIS FOR PROCESSING INCLUDING BASIS OF LEGITIMATE INTEREST
Necessary for our legitimate interests (to develop our products/services and grow our business)
PURPOSE/ACTIVITY
To send marketing e-mails to you containing news, offers and recommendations about products and services that may be of interest to you.
TYPE OF DATA
Identity
Contact
LAWFUL BASIS FOR PROCESSING INCLUDING BASIS OF LEGITIMATE INTEREST
Consent
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
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).
You will receive marketing communications from us 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 opted in to receiving that marketing.
Third-party marketing
We will get your express opt-in consent before we share your personal data with any company outside of SNF Asia Limited and SNF Houseware (Shenzhen) Limited for marketing purposes.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time by contacting us at info@schneidteufel.com. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase or experience or other transactions.
Cookies
Like many websites, our websites use cookies. This helps us to provide you with a good experience when you browse our websites and also allows us to improve our websites. 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 data 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 at info@schneidteufel.com.
If we need to use your personal data 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 data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in the section “Purposes for which we will use your personal data” above.
Internal Third Parties as set out in the Glossary.
External Third Parties as set out in the Glossary.
Specific Categories of Third Parties such as payment service providers, courier companies, mailing managers, survey providers and analytics providers.
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Where we have given you, or where you have chosen, a password which enables you to access certain parts of our websites you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our websites; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Data retention
How long will you use my personal data for?
We will only retain your personal data 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.
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 the applicable legal requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for seven years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see Request erasure below for further information.
In some circumstances we may anonymise your personal data (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.
Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data as listed below:
Request access to your personal data.
Request correction of your personal data.
Request erasure of your personal data.
Object to processing of your personal data.
Request restriction of processing your personal data.
Request transfer of your personal data.
Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us at info@schneidteulfel.com.
No fee usually required
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 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 data (or to exercise any of your other rights). This is a security measure to ensure that personal data 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.
Glossary
LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Consent means you have made a clear affirmative unambiguous action confirming that you are happy for your data to be processed for specific purposes.
THIRD PARTIES
Internal Third Parties
Companies in the Portmeirion Greater China (including SNF Asia Limited and SNF Houseware (Shenzhen) Limited) acting as joint controllers or processors and who are based in China, Hong Kong, Macau and Taiwan, and provide services including IT and system administration services.
External Third Parties
Service providers acting as processors operating in the China, Hong Kong, Macau and Taiwan, and elsewhere who provide IT and system administration services.
Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the China, Hong Kong, Macau and Taiwan, who provide consultancy, banking, legal, insurance and accounting services.
Inland Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in China, Hong Kong, Macau and China who require reporting of processing activities in certain circumstances.
YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data 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.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data 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 data 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 data 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.
Object to processing of your personal data 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 data 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.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data 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.
Request the transfer of your personal data to you or to 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.
Withdraw consent at any time where we are relying on consent to process your personal data. 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.