Who we are
Pala (and where appropriate those people who perform services on our behalf) (“We”) are committed to protecting and respecting your privacy.
Pala (collectively referred to as “we” or “our”) is an online retailer of premium quality eyewear rooted in ethics and aesthetics.
Pala are the controller and are responsible for your personal data, which means that we determine the purposes and ways of the processing of your personal data.
Our full details are:
Company name: Farther and Sun Limited, trading as Pala
Postal address: please email [email protected] and we will provide you this information. I mean after all it’s where the owner lives and whilst they would love to see the queues of satisfied Pala customers outside their home wanting to share their delight at their purchase, they’re worried about the health and safety issues that come with it. We’re just thinking about you.
Contact Name: Data Privacy Officer. Yes, this is indeed the title bestowed to the person that looks after your data. We felt the title sufficiently encapsulated the demands of the role as well as sounding VERY important.
The data we collect about you
Personal data means any information about you from which you can be identified. It does not include data where the identity has been removed (i.e. anonymous data).
We use different methods to collect data from and about you, including through:
- Direct interactions. This refers to personal data you provide directly to us (for example by purchasing one of our products or by corresponding with us via email).
- Automated interactions. As you interact with our website, we may automatically collect data about your equipment, browsing actions and patterns. For example, we collect information which may include your IP address, the browser type and your location.
- Third Parties: We may also receive data about you from third parties, as set out below.
Data Collected by Us
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Contact Data includes data such as your email address, first name and last name, phone number, address (including your state, province, zip/postal code and city).
- Financial Data includes data such as billing address, payment details and phone number.
- Marketing and Communications Data includes data such as Contact Data, photos and images.
- Technical Data includes data such as your internet protocol (IP) address, login data, operating system data, browser type and version, time zone settings, country location and cookies and usage data.
Pala uses the collected data for various purposes:
- To provide and maintain our Service;
- To notify you about changes to our Service;
- To allow you to participate in interactive features of our Service when you choose to do so;
- To provide customer support;
- To gather analysis or valuable information so that we can improve our Service;
- To monitor the usage of our Service;
- To detect, prevent and address technical issues; and
- To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information
Data Collected From Third Parties
If you buy one or more of our products for a friend or family member we will collect and process the Contact Data for that friend or family member for the purposes of providing them with such products.
If you enter a competition for the potential to win a prize we will collect and process your Contact Data.
We may receive data from third party analytics providers to help improve the website user journey and/or to improve our marketing and communications with you and/or your overall customer experience. For example we may use Google Analytics to help us learn about who visits our site and what pages are being looked at.
One of our key business principles is to help communities in Africa. We may collect and process information such as name, age, photos and images relating to people in those communities. Pala has in place a Code of Ethics for working with people during these outreach projects.
Data we do not collect
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.
This website is not intended for children and we do not knowingly collect data relating to children. However part of the Pala narrative is to provide visibility of the people we are helping through our work so buyers of our product can see the change they are creating.
Therefore, on occasion we will collect name, age and image data from both adults and children. We explain at the time, and in local language why we require the personal data we have asked for, and what we will do with it, in a way which they can understand. This will be provided in local language form.
As a matter of good practice, we explain the risks inherent in processing, and how we intend to safeguard against them, in a child friendly way, so that children (and their parents) understand the implication of the sharing of their personal data.
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 our products). For example, we may have to cancel the order you have with us, but we will notify you if this is the case at the time.
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.
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 email us at [email protected] if you need further details about the specific legal ground we are relying on to process your personal data.
|Purpose/Activity||Type of data||Lawful basis for processing|
|Receiving your order for product(s)||Receiving your order for product(s)||Necessary for the performance of a contract|
|Processing payments||Necessary for the performance of a contract|
|Shipping the product(s) to you||Contact Data||Necessary for the performance of a contract|
|Shipping the product(s) to you||Contact Data||Necessary for the performance of a contract.|
|Return of product(s)||Necessary for the performance of a contract.|
|Sending you confirmation email(s) and receipts and dealing with live requests||Contact Data||Necessary for the performance of a contract.|
|Sending you marketing communications (including our email newsletter)||Legitimate interests|
|Improving our products and website||Necessary for the performance of a contract.|
|Maintain and retain records in connection with legal claims and regulatory investigations; and for governance & compliance purposes.||Necessary for the compliance with a legal obligation to which we are subject.|
We have a legitimate interest in processing your personal data for the purposes of sending you marketing communications (including our email newsletter) and for doing press and public relations so that we can keep you up to date on our latest products and any offers or special promotions we may be running with regard to our products. We will only use the personal data that we consider to be necessary for these purposes such as Contact Data. You can unsubscribe from our emails at any time by clicking on the unsubscribe button (which is on the bottom of every email we send you).
We have a legitimate interest in processing your personal data for the purposes of using social media so that we can keep you up to date on our latest products and any offers or special promotions we may be running with regard to our products. In order for us to provide an optimum level of service and give a better context for our products and for promoting products, we may show people who have tagged us in wearing our eyewear, as well as repost lifestyles images in which we will tag in the owner of the image. We will only use the personal data that we consider to be necessary for these purposes such as Contact Data, name and social handle of image owner and Marketing and Communications Data (image and when necessary location of where the image was taken). If you do not want us to process your data for these purposes, then please email us at [email protected]
We have a legitimate interest in processing your personal data for the purposes of running a competition for you to have to the potential to win a prize and we will then use your contact data to send you marketing and communications in line with the paragraph above. You can unsubscribe from our emails at any time by clicking on the unsubscribe button (which is on the bottom of every email we send you).
We have a legitimate interest in designing and maintaining the website in order to provide you with the best product and customer service experience. We will only use the personal data that we consider to be necessary for these purposes such as Contact Data. If you do not want us to process your data for these purposes, then please email us at [email protected]
We have a legitimate interest in using data analysis to improve the website user journey and/or to improve our marketing and communications and/or your product and customer service experience. Customer feedback is important to us as it will inform us as to how we can make such improvements. We will only use the personal data that we consider to be necessary for these purposes such as Contact Data. If you do not want us to process your data for these purposes, then please email us at [email protected]
We have a legitimate interest in collecting and processing data in to help communities in Africa. We will only use the personal data that we consider to be necessary for these purposes such as Contact Data, photos and images. If you do not want us to process your data for these purposes, then please email us at email@example.com
How third parties process your personal data
In order to provide you with the product(s) you have purchased from us, we may need to give your personal data to third parties who will process your data on our behalf, as set out in the table below.
For example, to process your payment, we need to give your Financial Data to WordPress and PayPal.
We require all third parties to respect the security of your personal data and to process 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.
Certain third-party service providers, such as payment gateways and other payment transaction processors, have their own privacy policies in respect to the information we are required to provide to them for your purchase-related transactions.
For these providers, we recommend that you read their privacy policies, so you can understand the manner in which your personal information will be handled by these providers.
If you would like a full list of third parties who process your data, please email us at [email protected]
|Purpose/activity||Type of data||Third party data is given to||Lawful basis for processing|
|Fulfilling your order||Contact Data||WooCommerce Automattic Inc. 60 29th Street #343 San Francisco, CA 94110 United States of America||Necessary for the performance of a contract|
|Processing Payment||Financial Data||PayPal 2211 N. 1st St. San Jose, CA 95131 USA||Necessary for the performance of a contract|
|Processing Payment||Financial Data||Stripe, 510 Townsend St, San Francisco 94103||Necessary for the performance of a contract|
|Processing Payment||Financial Data||Fast, 349 9th St, San Francisco||Necessary for the performance of a contract|
|Processing Payment||Financial||Necessary for the performance of a contract|
|Shipping and return of products||Contact Data||CRM Trading, Unit 3 Woking 8 Forsyth Road Woking GU21 5SB. | Royal Mail Royal Mail Group Limited 100 Victoria Embankment London EC4Y 0HQ. | UK Mail UK Mail Ltd, Express House, 120 Buckingham Avenue, Slough, SL1 4LZ. | UPS UPS Corporate Headquarters 55 Glenlake Parkway, NE Atlanta, GA 30328 United States. | DHL, 1210 S Pine Island Rd, Suite 400, Plantation, FL 33324 |||Necessary for the performance of a contract|
|Sending you confirmation email(s) and receipts||Contact Data||WooCommerce Automattic Inc. 60 29th Street #343 San Francisco, CA 94110 United States of America||Necessary for the performance of a contract|
|Online retailers||We use third party independent retailers to sell our products. For a full list please contact us at [email protected]||Necessary for the performance of a contract|
|Sending emails in the course of business||Contact Data||Microsoft Microsoft Headquarters One Microsoft Way Redmond, WA 98052 USA||Necessary for the performance of a contract|
|Sending you marketing communications (including emails and newsletters)||contact Data||Klaviyo, 6 Boston, MA 02111 United States||Necessary for the performance of a contract|
|Behavioural Remarketing||Usage Data||Pinterest, 651 Brannan St, San Francisco, CA 94107, USA | Facebook, 1 Hacker Way Menlo Park, CA 94025. | Twitter Inc., 1355 Market Street Suite 900. San Francisco, CA 94103. | Instagram, C/O Facebook 1 Hacker Way Menlo Park, CA 94025. | Recart, 19808 Wilmington, Delaware 2711 Centerville Road.||Legitimate interests|
|Social media communications||Pala Social Media Team. Contact [email protected] for further information||Legitimate interests|
|Social media communications||Trello, Fog Creek Software 75 Broad Street, Suite 1904 New York, NY 10004||Legitimate interests|
|Social media communications||Dropbox Y Combinator 965 Mission St, San Francisco, CA 94103, USA||Legitimate interests|
|Press and PR||PR Consultant. For details please email [email protected]||Legitimate interests|
|Website design and maintenance and hosting||Web Master for details please email [email protected]||Legitimate interests|
|Website design and maintenance and hosting||LEAP, Old Bakery Studios, Blewetts Wharf, Malpas Rd, Truro, Cornwall, TR1 1QH | WordPress Automattic Inc. 60 29th Street #343 San Francisco, CA 94110 United States of America.||Legitimate interests|
|Analysing used and/or website behaviour||SEO Expert for details please email [email protected]||Legitimate interests|
|Analysing used and/or website behaviour||Hotjar Limited. Level 2, St Julian’s Business Centre, 3, Elia Zammit Street, St Julian’s STJ 1000, Malta. | Google Analytics, 1600 Amphitheatre Parkway Mountain View, CA 94043. | Bing, Microsoft Headquarters One Microsoft Way Redmond, WA 98052 USA.||Legitimate interests|
|Accounting and financial records||Delphi Accounting, Unit M6, Business Park, Manor Rd, Frome BA11 4FN. | Xero, XERO ONE 19-23 Taranaki St Te Aro, Wellington 6011.||Necessary for the compliance with a legal obligation to which we are subject.|
|In relation to our charitable works||Care4basket, CARE 4 Basket, subsidiary of CAREC4DC Ghana NGO Dansoman Junction, Kaneshie-Winneba Road, Accra, Ghana. | Vision Aid Overseas< Unit 12-13 The Bell Centre, Newton Road, Crawley RH10 9FZ||Legitimate interests|
Links to other websites
The 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.
Third party marketing
We will get your express consent before we share your personal data with any other company for marketing purposes.
To protect your personal information, we take reasonable precautions to make sure it is not inappropriately lost, misused, accessed, disclosed, altered or destroyed.
If you provide us with your credit card information, the information is encrypted using secure socket layer technology (SSL) and stored with a AES-256 encryption. Although no method of transmission over the internet or electronic storage is 100% secure, we follow all PCI-DSS requirements and implement additional generally accepted industry standards.
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.
Whenever we transfer your personal data out of the EEA, we will endeavour to ensure a similar degree of protection is afforded to it by aiming to have at least one of the following safeguards is implemented:
• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
• That appropriate safeguards are in place (including contractual clauses between the controller and processor). Please email us at [email protected] if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
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.
If you would like more information about how we retain your personal data please email us at [email protected]
By law we have to keep basic information about our customers (including Contact Data and Financial Data) for six years after you cease being a customer (including for tax purposes).
In some circumstances you can ask us to delete your data: see below for further information.
Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data, as follows, however, we may need to verify your identity to do so:
To request access to your personal data (commonly known as a “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.
To request confirmation as to whether or not your personal data is being processed.
To request the correction of your personal data that you consider to be inaccurate. This enables you to have any incomplete or inaccurate data we hold about you corrected. However, we may need to verify your identity and the accuracy of the new data you provide to us.
To request erasure of your personal data. This enables you to ask us to delete or remove personal data, including 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. These reasons will be notified to you at the time of your request.
To object to processing of your personal data. This enables you to object to the processing of your personal data if you feel it impacts on your fundamental rights and freedoms. In some cases, we may have compelling legitimate grounds to process your information which can override your right to object.
To request restriction of processing your personal data. This gives you the option to ask us to suspend the processing of your personal data e.g. if you want us to establish the data’s accuracy or you do not want us to erase it.
To request transfer of your personal data. If you request us to do so, we will provide to you, or a third party of your choice, your personal data in a commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use.
To withdraw consent to the processing of your data. If you request us to do so, we will no longer process your data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we will not be able to provide the services for you.
To not have a decision made about you based solely on automated processing.
If you wish to exercise any of the rights set out above, in the first instance, please email us at [email protected]
We will respond to you within 30 days of receipt of your request. Occasionally it may take us longer than 30 days 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 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 email us at [email protected] in the first instance.
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.
Changes and clarifications will take effect immediately upon their posting on the website. If we make material changes to this policy, we will notify you by email that it has been updated.
Your responsibility to inform us of changes
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 by sending an email to [email protected]
Change of opinion
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 email us at [email protected]
For example, if our company is acquired or merged with another company, your information may be transferred to the new owners so that we may continue to sell products to you.
Please note we may disclose your personal information if we are required by law to do so.
There you are, you’re done – hopefully not too painful… somewhere between a trip to the dentist and getting caught in a downpour? We recommend you get up, have a stretch and reward yourself with another biccy – you mostly definitely deserve this one.