REDMMAN respects your privacy and is committed to protecting your personal data. This Policy will inform you as to how we look after your personal data when you visit our www.comfortso.com website (Website) and tell you about your privacy rights and how the law protects you.
- Purpose of the Policy and who we are
2.1. Purpose of this Policy
This Policy aims to provide you information on how REDMMAN collects and processes your personal data through your use of this Website, including any data you may provide through this Website when you sign up to receive our emails and/or purchase a product or service.
This Website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this Policy together with any other privacy notice we may provide you 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 Policy supplements the other notices and is not intended to override them.
REDMMAN Ltd is the controller and responsible for your personal data (collectively referred to as “REDMMAN”, “we”, “us” or “our” in this Policy).
If you have any questions about this Policy, including any requests to exercise your legal rights, please contact us using the details set out below.
Full name of legal entity: REDMMAN Ltd
Postal address: 207-211 The Vale, (Access Store), Acton, W3 7QS, United Kingdom
Email address: email@example.comTelephone number: +44 208 1335008
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 contact us in the first instance.
2.3. Changes to the Policy and your duty to inform us of changes
This Policy was last updated on 30th June 2018.
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.
2.4. 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 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.
- The data we collect about you
3.1. Personal data
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, email address, username;
- Contact Data includes shipping address, billing address, email address, telephone number and company’s name (not mandatory);
- Transaction Data includes type of payment (using PayPal or credit card), purchase history (what items bought, price);
- Technical Data includes IP address, type of device, browser type and version, internet provider, time zone setting and location;
- Profile Data includes username, orders made in the past, feedback.
We also collect and use 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 data to calculate the percentage of users originating from the specific geographical region in the world. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we will treat the combined data as personal data which will be used in accordance with this Policy.
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.
3.2. 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.
3.3. 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, Profile and Contact by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- purchase our products or services;
- create an account on our Website;
- request marketing to be sent to you;
- give us some feedback.
- Automated technologies or interactions. As you interact with our Website, we may automatically collect Technical and Transaction Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies (including, cookies at amazon.com, bigcommerce.com, dotomi.com, doubleclick.com, facebook.com, google.com, googleadservices.com, gstatic.com, comfortso.com, hotjar.com, mailchimpapp.com, mediaplex.com, webinterpret.com, zopim.com).
If you have started to buy one of our products i.e. added item to shopping cart when, but have not completed the purchase via checkout, you may have provided partial information, such as your email. In that case, we might send you an email to remind you about the product left in the shopping cart. If you are not comfortable in receiving further emails of this kind, we will give you a simple opportunity to opt-out. Your privacy means a lot to us and we will stop sending you these communications right away.
If you have completed a purchase, we will send you an email to as you to review the product you bought. We value every customer and we want to be sure that whether you are happy with your purchase or have a complaint, you can share your opinion with other customers.
- Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
- Technical Data from the following parties:
analytics providers such as hotjar.com, mailchimp.com and Google based inside or outside the EU;
advertising networks such as Google AdWords based inside or outside the EU; and
- Billing and Shipping Address Data from providers of payment and delivery services such as PayPal and Amazon based inside and outside the EU.
3.4. 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 you have provided consent for us to collect and process your personal data;
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where we need to comply with a legal or regulatory obligation.
You have the right to withdraw your consent to processing of your data at any time by contacting us.
3.5. Purposes for which we will use your personal data
We have set out below 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 below.
3.5.1. Contract performance
The main purpose we will use your data for will be to perform the contract we are about to enter into or have entered into with you.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
We may use your Identity and Contact Data to send you our newsletters containing information on new items and their reviews, technical advises, and discount codes.
You will receive marketing communications from us if you have consented by subscribing to our newsletters, or purchased goods or services from us by providing us with your details and consent for marketing. In each case, you have to opt-in to receive that marketing.
3.5.3. Third-party marketing
We will get your express opt-in consent before we share your personal data with any company outside REDMMAN for marketing purposes.
You can ask us to stop sending you marketing messages at any time by logging into the Website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting us at any time.
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 other transactions.
We use three different types of cookies.
Functional cookies ensure that you can use the basic functionality of the Website and are therefore always enabled. They remember your selection and the choices you make to improve your experience on our Website. They also help make the shopping cart and checkout process possible as well as assist in security issues and conforming to regulations.
Analytical cookies allow us to further develop and improve the Website’s functionality by tracking usage on this Website. In some cases they improve the speed with which we can process your request and allow us to remember site preferences you have selected. De-selecting these cookies may result in an inability to set Website preferences and slow Website performance.
Social media and advertising cookies offer the possibility to connect you to social networks and share content from our Website on social media. Information that we obtain from advertising cookies is used to maintain your personal advertising profile. Deselecting these cookies may result in advertising that is not relevant to you or you may potentially not be effective in connecting to or engaging with social media.
You may refuse or accept cookies from the Site at any time by activating the setting on your browser. Information about the procedure to follow in order to enable or disable cookies can be found on your Internet browser provider's website via your help screen.
3.5.6. 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.
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.
3.6. Disclosures of your personal data
In the exceptional circumstances, we may have to share your personal data with 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 Policy.
In such a case, we will require all third parties to respect the security of your personal data and to treat it in accordance with the law. We will not allow our third-party service providers to use your personal data for their own purposes.
3.7. International transfers
We will only share your personal data within the REDMMAN company. This will not involve transferring your data outside the European Economic Area (EEA).
In case REDMMAN expands outside EEA and your data needs to be transferred to third countries, we will ensure your personal data is protected by requiring all our group companies to follow the same rules when processing your personal data. These rules are called “binding corporate rules”. For further details, see European Commission: Binding corporate rules.
Whenever we transfer your personal data out of the EEA, we will ensure a similar degree of protection is afforded to it by ensuring 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. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
- 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. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
- 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. For further details, see European Commission: EU-US Privacy Shield.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA. Please note, that we would transfer your data to third countries only if REDMMAN expands outside the EEA.
3.8. 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.
3.9. Data retention
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.
In some circumstances you can ask us to delete your data: see Request for Erasure Form.
3.10. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
Request for erasure of your personal data.
Request for access to your personal data.
Request for correction of your personal data.
Request for transfer of your personal data.
If you wish to exercise any of the rights set out above, please contact us.
No fee is 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.
3.11. 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.
3.12. 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 these circumstances the time limit may be extended up to two additional months. In this case, we will notify you and keep you updated.
4.1. Lawful basis
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.
Complying 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.
4.2. Third parties
4.2.1. Internal Third Parties
Fortia, UAB, having its registered office at Kareivių st. 6, LT-09117 Vilnius, Lithuania, acting as the processor of data in accordance with the data processing agreement concluded with REDMMAN and strictly under the requirements of this Policy and the GDPR.
4.2.2. External Third Parties
Professional advisers including lawyers, bankers, auditors and insurers based in the EEA who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.
4.3. 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, 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.
Questions and our contact information
If you would like to: access, correct, amend or delete any personal information we have about you, you are invited to contact us at firstname.lastname@example.org