PRIVACY POLICY

Just like you, the VOCLA® team shops online for personal and business products, providing our data so that those transactions can be properly fulfilled and signing up to marketing initiatives so we can be kept up-to-date about new products and offers. We don’t want our data to be misused so we promise to not misuse yours either.

VOCLA complies with the GDPR (General Data Protection Regulations) which apply to EU citizens and the CCPA (California Consumer Privacy Act) and CPRA (California Privacy Rights Act) which apply to Californian citizens.

For all our services, the data controller, responsible for your data privacy, is VOCLA Limited (registration 07910951, registered in England). Our contact details are:

Registered Address: Unit 2, Tilson Road, Roundthorn Industrial Estate, Manchester, UK, M23 9GF
Phone: 0161 282 5028
E-mail: contact@vocla.com

If you have any questions about how we protect your privacy and use your data, please contact us in any of the above ways.

We may change our Privacy Policy from time to time, to reflect changes in how we process your data, as well as changes in the relevant regulations and data privacy guidance.

1. Our Lawful Basis for Processing Your Data

Under the new General Data Protection Regulations, we have different lawful bases to process your data:

For operational or transactional purposes (ie to fulfil your orders), we have a contractual lawful basis to process your data. We cannot send you your order and therefore complete our contract of sale with you if we cannot process your name and address details. We also have a legitimate interest when we process personal data to prevent fraud and ensure network and information security.

For the purposes of marketing, we have a consensual lawful basis to process your data. This means that you specifically provide consent, you can opt in and out of specific marketing initiatives, you are in charge, providing and removing your consent whenever you wish.

2. Using Your Data

YOUR PERSONAL DATA

This includes your name, billing address, delivery address, phone number, IP address, account username and e-mail address.

HOW WE USE YOUR PERSONAL DATA	WHY?
To deliver your purchases to you	We have to use your details to fulfil our contract of sale with you – we can’t send you your order if we don’t have your name & delivery address
To send you service messages	We have to use your details to fulfil our contract of sale with you – we can’t let you know that your order has been dispatched or provide tracking numbers if we can’t e-mail or send you an SMS
To detect & prevent fraud	We need to detect and prevent fraud against VOCLA® and yourself, for example we will match the location of your IP address to your billing and delivery address which helps us determine if a card may be stolen
To identify you	We need to check your identify when you login, to keep your data safe and comply with legislation
To send you information about new products & services or special offers	We only do this when you opt in, providing us with consent. You can remove consent at any time. Please see section 4 Marketing below
To send you updates about your account, our service, and our Terms & Conditions	We legally have to do this as part of our contractual commitment with you
To direct you to the right page of our Website	We can more efficiently get you to the products and information that is most relevant to you, for example, products that you previously viewed
To display VOCLA® adverts as you surf the web	This lets you see information about new products & services or special offers. We only do this if you have cookies enabled on your browser and opt into marketing cookies. You can stop this by clearing your browser cookies

YOUR COMMUNICATION DATA

This includes e-mails you have sent us, messages sent through our online contact form and messages on social media (eg Twitter and Instagram). We do not currently record phone calls. We keep e-mails for six months. We are unable to delete social media messages as these are kept by those respective platforms.

HOW WE USE YOUR COMMUNICATION DATA	WHY?
To provide customer service and support	We need to answer your enquiries and we need to communicate with you if there is an issue with an order
To train staff	We need to use enquiries to train our staff so they can provide a great service to you in the future

YOUR PAYMENT DATA

When you input payment details on our website, that section of the website is fully encrypted and operated by our payment processor, Stripe, who holds all the necessary SSL security certificates to keep your payment details secure. If you use Clearpay/Afterpay or Klarna, they will review the data that your provide and by completing their application, you are submitting your personal data to them.

VOCLA® does not collect or see payment data such as your specific card details. However, we are able to see some generic transaction data (eg whether you input a correct 3D secure password or not). This transaction data is only used to review for fraud, for which we have a legitimate lawful basis.

HOW WE USE YOUR PAYMENT DATA	WHY?
To assess whether payment has successfully been taken for an order	We need to verify with the payment processor, that payment has been made, so that a contract of sale exists and we can then dispatch your order
To provide refunds where necessary	We have to find your transaction details on merchant accounts and use these to request a refund to be made
To detect and prevent fraud using fraud management systems	We need to use this to detect and prevent fraud against VOCLA® and yourself
To verify a delivery address where payment is placed through a Paypal account, rather than by card	Where payment is made through a Paypal account, Paypal will provide your verified delivery address on that account, helping us to reduce fraud and ensure your order is dispatched to the correct address
To offer you Buy Now Pay Later options	If you opt for Klarna or Clearpay as a payment option, we will pass your personal data in the form of contact and order details to those payment providers, in order for them to assess whether you qualify for their payment methods and to tailor those payment methods for you. Your personal data is transferred in line with their privacy notices. Klarna privacy notice Clearpay privacy notice

YOUR ACTIVITY ON OUR WEBSITE

This includes:

* Your order history

* Your wish-list, if you create this

* Your subscription data, if you have a VA Club underwear subscription

* Your basket data – saved and abandoned carts

* Details of recently viewed products

* Your broswsing data

If you decide to hold an account with us, you can view your order history within this account. If you create a wish-list, you can view saved items which you can also e-mail to someone else. If you put items into a basket, but are not ready to pay for those items, you can save the basket for later, and you will receive abandoned cart e-mails via our Klaviyo provider, to allow you to checkout easily when ready.

HOW WE USE YOUR ACTIVITY DATA	WHY?
To help you complete an order	It’s much easier, faster and more practical for you to complete an order at a later date if you’ve saved items and baskets or you are e-mailed with a link direct to a saved basket
To provide customer service & support	If you have a question about a previous order, you may wish to see the order details in your order history, and we will need to view your order history to follow-up your enquiry If you have trouble completing a transaction, we will need to view the order details to help you
To complete returns	We have to view your order history to complete a return and fulfil our contract of sale with you – we can’t refund an item on an order if we can’t view that order
To request service reviews	We use Trustpilot to gather reviews of our service and store, if you have an order history. This helps identify issues, provides praise and feedback to employees, and gives potential customers an independent opinion on the service. It is your choice as to whether you provide a service review
To request product reviews	Our e-commerce system requests product reviews, based on your order history, if you provide consent on the checkout page. Product reviews help others to decide which items may be of interest, providing more independent opinions on products
To help you save items of interest for a later date	It’s much easier, faster and more practical for you to be able to save items of interest in a wish-list so that you can come back to purchase them when you are ready. You may want to e-mail your saved items/wish-list to friends and family for a birthday or maybe even Santa!
To detect and prevent fraud	Reviewing your order history is one way that VOCLA® can help detect and prevent fraud
To manage your VA Club subscription	If you have an underwear subscription, we cannot send you the correct size, quantities, and styles, if we don’t have your preferences on record
To send you automated basket abandonment e-mails	The website uses cookies to help keep track of items you put into your shopping cart including when you have abandoned your cart and this information is used to determine when to send cart reminder messages via SMS or e-mail so you can complete your purchases faster when ready
To identify issues with our e-commerce store	We collect browsing data and statistics through Google Analytics. This helps to show how customers ‘collectively’ browse and flow through our website, helping us identify issues so that we can fix them or improve the shopping experience.

YOUR DEVICE AND BROWSER DATA

We cannot use your device (eg mobile, tablet, desktop) and browser data (eg the browser used, the version of that browser) to specifically identify you, but we use Google Analytics and Klaviyo to review the devices and browsers which our website visitors collectively use.

HOW WE USE YOUR DEVICE AND BROWSER DATA	WHY?
To collectively review which browsers and devices our customers use to view our online store	To help develop our online store to provide a better shopping experience – we need the store to work well on the most popular browsers and devices
To collectively review who our visitors are – if you have enabled cookies on your browser, Google Analytics collects and reviews the geo-location, demographics and interests that it believes you have, based upon your browser cookies and surfing habits	To help us to understand our visitors better so we can provide a better online store and shopping experience

YOUR SOCIAL MEDIA DATA

If you leave comments or engage with our social media profiles, we and others can see those comments and engagements. Social media platforms also gather data about you (and us) which allows businesses such as ours to collectiviely understand who their followers are (ie their general demographics).

HOW WE USE YOUR SOCIAL MEDIA DATA	WHY?
To collectively review the demographics of our followers	Social media platforms allow us to view insights about the collective demographics of our social followers, which helps us understand who our potential customers are so we can make more relevant social media posts, and improve the product offering and service of our Website over time, tailored to the needs of our followers
To view and respond to comments on social posts	So we can engage with you, afterall that’s why you engaged with a social post. But we also value your opinions and wish to monitor the opinions of our followers, so we can improve our product offering and service
To read & respond to social media messages	If you contact us via social media messaging, we need to be able to read your enquiry and respond to you
To share or retweet posts	If you have tagged VOCLA in a post, we may retweet or share this to followers as a mark of respect to you. We can remove any retweet or share, at any time, if you ask us to.
To create social media posts	We would ask you first, and if you gave us permission, we would create a social post using your photo, so others can see how you rock! We would always ask you first.

3. Sharing Your Data
We do not sell any information or data to any third party.

COMPANIES WHO REQUIRE DATA TO FULFILL THE SERVICE

We share your information with companies who process elements of your data, where this is essential to fulfil our services and contract with you, and to meet our legal obligations. The following companies are vital for us to be able to provide our services to you:
- Companies that provide IT and operational services that allow our Website to function:
  - Our content management system, related e-commerce plugins and theme providers, who are used to operate, build and display our Website
    
    Our IT support company that provides hosting and support services
- Payment merchants who provide the secure encrypted payment gateways on our Website, monitor fraud, and process refunds
- Couriers and their associated service providers abroad (for export orders) to process parcels for dispatch, label them, generate any relevant customs forms, electronically provide customs data, deliver and return orders, communicate about missing or late parcels, and make claims for compensation
- Affiliates and affiliate platforms who help us to reach potential new customers. If you linked through to our website from an affiliate, we will log the order details to recognise any commission due to those affiliates through an affiliate platform. Your personal data will not be logged, just your order data
- Review platforms – we use Trustpilot to request a service review and from time to time, we use Google Merchant services. This helps to provide us with feedback on areas to improve, praise for VOCLA employees, and allows other potential customers to understand the quality of service, prior to purchasing. It can also highlight issues. We provide your e-mail address and order number, so Trustpilot can request the review. You do not have to make a review, it is your choice. You can just ignore the e-mail and you will not be contacted again. If you do make a review, you would be requested to provide your order number, so they can verify that it is a legitimate review. Your order number and details would not appear on the review. You can anonymize your name on any review. You can delete reviews at any time within your Trustpilot account
- Marketing platform providers who provide services such as order confirmations, other operational e-mails, e-mail and/or SMS parcel tracking details, and saved baskets. The same providers are used for our e-mail and SMS marketing services, but these require explicit consent, so data is not automatically transferred for those services
- E-mail providers who provide systems, platforms and software for e-mail communications
- Law enforcement agencies, if and where we are required to do so by law
COMPANIES WHO RECEIVE DATA IF YOU OPT TO ALLOW IT

We only share data with other companies if you opt to use a service that is relevant to them or provide explicit consent:
- If you opt for Buy Now Pay Later options (eg Klarna, Clearpay/Afterpay), your order details and contact details are passed to the relevant provider, so they can assess whether you qualify and to tailor those payment methods for you. Data in transferred in line with their privacy policies.
- Marketplaces (eg eBay) where your order is placed via one of these.
- Data analytics platforms (eg Google Analytics), whose Analytics code is embedded on our website, so we can review how visitors with enabled cookies on their browser use the website, allowing us to improve it. The code also helps us to identify which marketing initiatives generate our sales. The retention period for data sent, that is associated with cookies and advertising identifiers, is retained for 24 months and then automatically deleted. We are unable to identify specific individuals from the cookie data and advertising identifiers, it is collective data, and IP addresses are annoymized.
- Advertising platforms and providers who may show you VOCLA® adverts after you have left the website. This would only occur if you opted into marketing cookies. You would be able to stop these by clearing cookie and browsing data on your browser.
- Marketing platform providers if you have given prior consent (see section 4 Marketing), we transfer to them, the data which is necessary to send you marketing activity to which you have subscribed and consented. For example: e-mail newsletters, SMS deals, requests for product reviews
GOOGLE FONTS

Websites that use Google Fonts allow Google to track usage of their fonts, which can identify your IP address. VOCLA uses a google font but this font has been downloaded onto our server. The fonts on our website are therefore generated directly from our server, to avoid any tracking of customer data by Google.
4. Consentual Marketing
Under the GDPR regulations, we have a consensual lawful basis to process your data for marketing purposes.

If you have consented to us doing so, we will send you direct marketing messages to keep you aware of our new products, abandoned carts, special offers, exclusive deals and developments at VOCLA®. There are subscription forms on our website, where you can consent to these marketing messages.

You can select which methods you consent to, whether that be by e-mail or SMS text or both. It is entirely your choice, you do not have to consent to anything.

You can change your consent to direct marketing preferences at any time, in the following ways:
- By unsubscribing on e-mails or replying to SMS messages
- By contacting us via e-mail, phone, or by post
We will update your details within 7 days.

Ending marketing messages will not affect communications necessary to fulfil a contract of sale with you, so you will still receive communications in relation to orders you place because under GDPR, we have a contractual lawful basis to process your non-marketing data. Your consent is only necessary for marketing communications where under GDPR, we have a consensual lawful basis to process your data.

The marketing platform we use for E-mail and SMS marketing is based in the USA, therefore data is transferred outside the EU. The marketing platform has incorportated the European Commission’s Standard Contractual Clauses into their Data Protection Addendum and terms of service.

4.1.1 E-Mail Marketing

VOCLA uses an external marketing platform to send you e-mail marketing messages, where you have specifically given consent to these. You can select which type of e-mail newsletters you receive (eg menswear and/or fetishwear). E-mails are collected on subscription forms embedded on our website and the data is held on the marketing platform. E-mail addresses are not shared with anyone other than that platform (for the purposes of providing the e-mail marketing services to which you consent) and they are not sold to anyone. You can unsubscribe from e-mail marketing at any time by clicking ‘unsubscribe’ at the bottom of any e-mail.

4.1.2 SMS Marketing

VOCLA uses an external marketing platform (who in turn uses Autodialer) to send you SMS marketing messages, where you have specifically given consent to these. Phone numbers are collected on subscription forms embedded on our website, with clear notifications that by subscribing or ticking an SMS marketing box, you will receive SMS marketing messages. The phone number data is stored on the marketing platform. Phone numbers are not shared with anyone other than the marketing platform (for the purposes of providing the SMS services to which you consent) and they are not sold to anyone. You can unsubscribe from SMS marketing messages at any time by replying ‘STOP’ to the message or clicking the unsibscribe link in a message. Message and data rates may apply. Message frequency varies.

4.1.3 E-Mail Abandoned Cart E-mails

The website uses cookies to help keep track of items you put into your shopping cart including when you have abandoned your cart and this information is used to determine when to send cart reminder messages via e-mail. This would be completed under the basis of legitimate interest, as a communication relevant to the explicit intent to a complete a transaction. Other forms of abandoned cart e-mails, such as browse abandonment and winback, require consent, and are not currently used by VOCLA.

4.1.4 Product Reviews

VOCLA uses a WooCommerce plugin to collect product reviews that may be helpful to other customers. On our checkout, you are requested to explicitly give consent for us to request a review at a later date. This provides us with permission to contact you to make the request. If you do not give consent, we will not contact you to make the request. If you proceed to make a product review, we make you aware that the review may be displayed on our website, showing your name or the name that you have given (you can of course anonymize your name) and that the review may be fed to our Google Merchant account and displayed on our Google Shopping products (although no personal details are fed to or displayed on Google). You may request us to remove your product review(s) at any time by e-mailing contact@vocla.com. If you have added pictures to a review and would like us to remove those but not the text of the review, we can also do this.
5. Keeping Your Data

We will hold your data for as long as you hold your account with us, or as long as is required to be able to provide our services and support to you.

You have the right to request that we delete your data (see section 6 Your Rights). However, we may keep hold of your data as required, even after you close an account or it is nolonger necessary to provide services to you, in order to meet legal or regulatory requirements. For example, under VAT legislation, we need to keep your order information for 6 years.

Communication e-mails and messages are kept for 6 months and then deleted. We are unable to delete social media messages, and you would need to request the social media platform to do this.

Data sent to Google Analytics that is associated with cookies and advertising identifiers is retained for 24 months and then automatically deleted.

We will continue to provide marketing services using your data for as long as you provide consent to this. You can remove your consent at any time as detailed in section 4 Marketing.

6. Your Rights

Your rights in relation to your personal information are as follows:

YOUR RIGHTS	HOW THE RIGHT IS APPLIED
The right to be informed – you have the right to know what data is being processed and how	This Privacy Policy details how your data is used
The right to access the information we hold about you	Please contact us via e-mail or by post to access the information we hold
The right to rectification – you may request us to correct inaccurate data or complete incomplete data	Please use your account or contact us via e-mail or by post to correct any inaccurate information
The right to be forgotten – you may request us to delete your data without undue delay	Please contact us via e-mail or by post to have your data deleted. Once deleted, we can no longer process or collect it
The right to stop direct marketing messages	You can change your marketing preferences, at any time within your account, by unsubscribing to e-mails, replying STOP to SMS messages or by contacting us
The right to portability – you may request us to transfer your data to another organisation	Please contact us via e-mail or by post to transfer elements of your data
The right to complain to your data protection regulator	Within the UK, you can complain to the Information Commissioner’s Office but we would ask that you contact us first so we can try to resolve any issues

This Privacy Policy was last updated June 2023

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