We are Focus International Limited T/A Focus Brands, a company incorporated in England and Wales with registered number 1461548 and whose registered office is at Ashley Road, St Albans, Hertfordshire, AL1 5UB (“the Company”).
We provide design, sourcing, distribution and promotion services to customers, specialising in apparel, footwear and accessories.
We use your information as further explained in this Privacy Notice. We’ll be the “controllers” of the information you provide to us.
Our website links to other websites, which will have their own privacy notices and terms.
We at Focus Brands take your personal data seriously. This policy:
We will collect certain personal information about you in the course of your relationship with us.
This information includes:
We may also collect sensitive personal data about you. We only collect sensitive personal data from you, and further process this data, where you have given your explicit consent.
We may collect personal data about you from the following sources:
The main purpose for which we use your information is to provide you with the products that you purchase from us and to send you offers and promotions that you might be interested in.
In particular, we use your information:
We will not use your information for any other purposes unless we are required to do so by law.
How long we keep your information will depend on the purpose for which we use it.
In some circumstances, some of your data will be deleted in much shorter timescales, for example:
If reasonably necessary or required to meet legal or regulatory requirements, resolve disputes, prevent fraud and abuse, or enforce our terms and conditions, we will also keep hold of some of your information, even if it is no longer needed to provide our services to you.
We share your personal information with carefully selected third parties to help us to provide you with products, services and to market to you, such as:
We share your personal information with our other JD Group companies for internal reasons, primarily for business and operational purposes:
As we continue to develop our business, we may sell or purchase assets. If another entity acquires us or merges with us, your personal information will be disclosed to such entity. If any bankruptcy or reorganisation proceeding is brought by or against us, all such information will be considered an asset of ours and as such it is possible, they will be sold or transferred to third parties.
Where required we share your personal information with third parties to comply with a legal obligation; when we believe in good faith that an applicable law requires it; at the request of governmental authorities conducting an investigation; to detect and protect against fraud, or any technical or security vulnerabilities; to respond to an emergency; or otherwise to protect the rights, property, safety, or security of third parties, visitors to the our website, our business or the public.
These third parties comply with similar and equally stringent undertakings of privacy and confidentiality.
No other third parties have access to your information unless we specifically say so in this Privacy Notice, or the law requires this.
We process your information:
You’ve the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on legitimate interests. More information on this right and on how to exercise it is set out below.
We use an automated decision-making system to carry out some profiling of you for the purposes of improving and developing our products and services and to help us to tailor our marketing to you. The impact of any automated decision is to ensure you experience the best service possible. We use information that we learn about you such as your gender, preferences, hobbies, interests and purchase history to make sure the marketing you receive from us and the way our websites are displayed to you are appropriate and tailored to you.
You have the right not to be subject to a decision based solely on automated processing, including profiling, which has legal consequences for you or similarly significant effects. While we’re confident that the technology works, we understand that not everyone is comfortable with decisions being left entirely up to machines. If you have any questions about our identity checking system, please contact us on using the details at the end of this Privacy Notice.
We would like to contact you from time to time about our new similar products and promotional offers by email, SMS, social media and post.
We always give you the choice of whether or not you wish to receive marketing communications from us.
All information you provide to us is stored on our secure servers in the UK and European Economic Area (EEA).
The information which we collect about you may be transferred outside the European Economic Area. In the event of such transfer, we will ensure the adequate standard of security is in place for example by incorporating the European Commission approved clauses into our agreements with such third parties to ensure the security of your personal data. A copy of the European Commission approved model clauses is available here.
Where possible, we try to only process your information within the UK and European Economic Area (EEA). If we or our service providers transfer personal data outside of the UK or EEA, we always require that appropriate safeguards are in place to protect the information when it is processed.
Transmission of information via the internet is not and cannot be 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.
We also take steps to ensure all our subsidiaries, agents, affiliates and suppliers employ adequate levels of security.
Further information and advice about your rights can be obtained from the data protection regulator in your country.
In some instances, we may be unable to carry out your request, in which case we will contact you to explain why.
|Rights||What does this mean?|
|1. The right to be informed||You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we’re providing you with the information in this Privacy Notice.|
|2. The right of access||You have the right to obtain access to your information (if we’re processing it), and certain other information (similar to that provided in this Privacy Notice).
This is so you’re aware and can check that we’re using your information in accordance with data protection law.
|3. The right to rectification||You are entitled to have your information corrected if it’s inaccurate or incomplete.|
|4. The right to erasure||This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your information where there’s no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions.|
|5. The right to restrict processing||You have rights to ‘block’ or suppress further use of your information. When processing is restricted, we can still store your information, but may not use it further. We keep lists of people who have asked for further use of their information to be ‘blocked’ to make sure the restriction is respected in future.|
|6. The right to data portability||You have rights to obtain and reuse your personal data for your own purposes across different services. For example, if you decide to switch to a new provider, this enables you to move, copy or transfer your information easily between our IT systems and theirs safely and securely, without affecting its usability.|
|7. The right to object to processing||You have the right to object to certain types of processing, including processing based on our legitimate interests and processing for direct marketing (i.e. if you no longer want to be contacted with potential opportunities).|
|8. The right to lodge a complaint||You have the right to lodge a complaint about the way we handle or process your personal data with your national data protection regulator.|
|9. The right to withdraw consent||If you have given your consent to anything we do with your personal data, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your personal data with your consent up to that point is unlawful). This includes your right to withdraw consent to us using your personal data for marketing purposes.|
To exercise any of the rights above, or to ask a question, contact us using the details set out at the end of this Privacy Notice.
We’ll respond as soon as we can. Generally, this will be within one month from when we receive your request but, if the request is going to take longer to deal with, we’ll come back to you and let you know.
We usually act on requests and provide information free of charge, but may charge a reasonable fee to cover our administrative costs of providing the information for:
Alternatively, the law may allow us to refuse to act on the request.
If you have questions on the processing of your personal data, would like to exercise any of your rights, or are unhappy with how we’ve handled your information, please contact us here.
If you’re not satisfied with our response to any complaint or believe our processing of your information does not comply with data protection law, you can make a complaint to the data protection regulator in your country.
6 Alexandra Road West
+ 44 (0) 1484 466800
+ 44 (0) 1727 883555
26 Eastcastle Street
London W1W 8DQ
6 Alexandra Road West
Huddersfield HD3 4EX
Frankfurter Ring 193a
1013 AP Amsterdam