Brand: Brushandboot
Address: Upper Floor Lynx House, Ferndown, Northwood, Middlesex, HA6 1PQ
Telephone: +44 1764784524
Email: auditor@brushandboot.com

  1. Introduction

Brushandboot respects the privacy of individuals who visit our website, purchase our products, or contact our customer service team. This Privacy Policy outlines how we collect, use, store, disclose, and manage personal data related to our website and the sale of footwear care accessories (including shoe trees, shoe brushes, shoehorns, and shoe bags).

Brushandboot acts as the data controller for the personal data processed for the purposes described in this policy. We process personal data in accordance with applicable data protection regulations, including the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and the applicable EU General Data Protection Regulation (EU GDPR).

By using our website, placing an order, or contacting us, you acknowledge that you have read this Privacy Policy. Where required by law, we will seek your consent separately.

  1. Personal Data We Collect

Depending on how you interact with our website, we may collect the following categories of personal data:

2.1 Contact Information

When you place an order or contact us, we collect your name, email address, telephone number, billing address, and delivery address.

2.2 Order Information

Details of purchased products, order number, purchase date, order amount, delivery preferences, order status, and correspondence related to your purchase.

2.3 Payment-Related Information

Payment status, transaction number, details of the payment method you provide, and information required to verify and manage the order.

Where applicable, payment card information is processed via Stripe’s payment processing services. We do not knowingly collect or retain full payment card numbers or card verification codes within our own website systems.

2.4 Website Usage Information

Depending on website functionality and your cookie preferences, we may collect information such as your IP address, browser type, device information, pages visited, access times, and interactions with website features.

2.5 Customer Service Communication Information

Information contained in emails, voicemails, and other communications you send us regarding products, purchases, delivery arrangements, or returns.

We strive to collect only information relevant to the purposes described in this policy.

  1. How We Use Personal Data

Brushandboot may process personal data for the following purposes:

Receiving, confirming, and managing customer orders.
Arranging payment processing and maintaining transaction records.
Preparing and fulfilling purchase orders, and communicating relevant order updates.
Responding to product inquiries and customer service requests.
Handling returns, refunds, and complaints.
Maintaining accounting, tax, and other business records as required by law.
Identifying and addressing suspected fraudulent transactions or misuse of our website.
Maintaining, reviewing, and improving the operation of our website.
Complying with applicable legal obligations, and establishing, exercising, or defending legal claims.
Sending promotional information where permitted by law (and, where required, with your consent).

We will not use personal data for purposes incompatible with the original collection purpose, unless permitted by applicable law.

  1. Legal Basis for Processing

Where required by the UK GDPR or EU GDPR, Brushandboot processes data based on one or more of the following legal grounds:

Performance of a contract: Processing necessary to accept and manage your orders, arrange payment, fulfill purchases, and respond to transaction-related requests.

Legal obligation: Processing necessary to comply with applicable accounting, tax, record-keeping, and other legal requirements.

Legitimate interests: Processing necessary for our legitimate business interests (including managing customer relationships, maintaining business records, addressing misuse, reviewing website performance, and establishing or defending legal claims), provided that these interests are not overridden by your rights and interests. Consent: Processing based on your consent when required, including the use of certain optional cookies and the sending of electronic marketing communications.

Where processing is based on your consent, you may withdraw that consent at any time. Withdrawing consent does not affect the lawfulness of personal data processing activities carried out prior to the withdrawal.

  1. Payment Processing via Stripe

Brushandboot uses Stripe as its payment processing service provider to handle payments for purchases made through this website.

When you proceed to checkout, relevant information may be provided to Stripe, including your name, email address, billing information, transaction amount, order reference number, payment method details, and other details necessary to process the transaction.

Stripe processes payment-related information to facilitate transactions; depending on the specific processing activity, Stripe may act as a data processor on behalf of Brushandboot or as an independent data controller for purposes determined by Stripe itself (including compliance with specific legal, regulatory, and transaction risk-related obligations).

Stripe’s processing of personal data is governed by its applicable privacy terms. You can find more information in the Stripe Privacy Center.

Brushandboot receives relevant transaction information needed to manage purchases, reconcile payments, process refunds, and maintain necessary records. We will not ask for your Stripe account password, nor will we request that you send full payment card details via email.

  1. Disclosure of Personal Data

Where necessary and lawful, we may disclose relevant personal data to the following categories of recipients:

Payment processing service providers: Including Stripe, to facilitate transactions and manage payment-related activities.

Shipping and fulfillment service providers: To prepare, ship, and deliver purchased products and provide relevant delivery status updates.

Website and service providers: Vendors providing website hosting, order management, customer communication, data storage, and support for related business functions.

Professional advisors: Accountants, legal counsel, and other professional service providers (where reasonably required for business management or legal matters).

Public authorities and legal recipients: Courts, regulatory bodies, tax authorities, law enforcement agencies, or other recipients where disclosure is required by law or necessary to establish, exercise, or defend legal claims.

Where applicable, we require appropriate confidentiality and data processing measures to be in place. Personal data is disclosed only to the extent reasonably necessary to achieve the relevant purposes or as otherwise permitted by law.

We do not sell personal data to third parties in exchange for payment.

7. International Data Transfers

Some of our service providers (including Stripe and service providers associated with the website) may process personal data outside the UK or the European Economic Area (EEA). Where international data transfers are subject to applicable data protection regulations, we will implement appropriate transfer mechanisms as necessary. Depending on the circumstances, this may include “adequacy decisions,” applicable international data transfer agreements, Standard Contractual Clauses (SCCs), or other lawful transfer mechanisms.

For more information regarding the relevant transfer arrangements, please contact us at auditor@brushandboot.com.

  1. Data Retention Periods

Brushandboot retains personal data only for as long as reasonably necessary to fulfill the purposes for which it was collected, taking into account applicable legal requirements, accounting obligations, customer service needs, and the need to establish or defend legal claims.

Our standard retention periods are as follows:

8.1 Order and Transaction Records

Order confirmations, invoices, transaction reference information, and related accounting records are generally retained for six years following the end of the relevant financial year, in order to comply with applicable UK tax, accounting, and business record-keeping obligations.

If different statutory periods apply, the retention period will be determined by the relevant legal requirements.

8.2 Customer Service Communications

General inquiries and customer service communications are generally retained for up to 24 months after the matter has been resolved; however, they may be retained for longer if reasonably necessary to handle complaints, manage ongoing matters, or fulfill legal obligations.

8.3 Refunds, Returns, and Complaints

Records relating to returns, refunds, complaints, and disputed orders are generally retained for up to six years after the relevant matter has concluded, where necessary for accounting, record-keeping, or legal claim purposes.

8.4 Marketing Preferences

Marketing contact information will be retained for the period necessary to fulfill the relevant communication purposes and as permitted by law. If you withdraw your consent or unsubscribe, we will stop sending promotional communications and retain only the limited information necessary to maintain records and respect your preferences (as applicable).

8.5 Website Logs and Cookie Information

Website logs and information related to cookies will be retained based on their purpose, configuration, and the applicable validity period of the cookies. When such information is no longer required, we will delete or anonymize it within a reasonable timeframe, in compliance with applicable legal requirements.

8.6 Payment Information Held by Stripe

Stripe’s retention of payment-related personal data is governed by its own applicable policies, legal obligations, and contractual arrangements. Brushandboot does not determine the specific data retention periods applied by Stripe.

Upon the expiration of applicable retention periods, personal data will be deleted, anonymized, or otherwise processed in accordance with applicable law, unless continued retention is required by law.

These retention periods are reviewed periodically and are not intended to authorize the indefinite retention of personal data.

  1. Cookies and Similar Technologies

Our website may use cookies and similar technologies to support essential website functions, remember preferences, and understand website usage.

For non-essential cookies requiring consent, such cookies will not be activated until you provide the necessary consent via the cookie banner or preference settings. You may change your preferences or withdraw your consent through the relevant cookie settings.

Essential cookies may be used to provide services you have requested or to enable website functions permitted under applicable law.

Third-party services (including applicable Stripe services) may use cookies or similar technologies in conjunction with their own services. Their data processing activities are subject to the terms of the relevant service providers and applicable consent requirements.

You may also manage cookies through your browser settings. Disabling certain cookies may affect the functionality of parts of the website.

  1. Data Protection and Confidentiality

Brushandboot implements appropriate organizational and technical measures designed to protect personal data against unauthorized access, unlawful processing, accidental loss, alteration, or disclosure.

Access to personal data is restricted to personnel and service providers who require the information for legitimate business purposes. We also take reasonable steps to ensure that the processing of personal data complies with this policy and applicable data protection requirements.

No method of data transmission or electronic storage is entirely risk-free. In the event of a personal data breach, we will assess the situation and take responsive measures in accordance with applicable legal requirements (including notification obligations where necessary).

  1. Your Data Protection Rights

Subject to applicable law and relevant exemptions, you may have the following rights:

Right of access: To request a copy of the personal data we hold about you. Right to rectification: To request the correction of inaccurate or incomplete personal data. Right to erasure: To request the deletion of personal data, subject to statutory conditions.
Right to restrict processing: To request the restriction of specific processing activities, where applicable.
Right to data portability: To request personal data in a portable format, subject to statutory requirements.
Right to object: To object to processing based on legitimate interests and to object to direct marketing at any time.
Right to withdraw consent: To withdraw consent where processing is based on consent.
Right to lodge a complaint: To lodge a complaint with the relevant data protection supervisory authority.

The exercise of the above rights is subject to the conditions and limitations prescribed by applicable law. For example, even if a deletion request has been submitted, we may need to retain certain transaction records to fulfill statutory obligations.

To exercise your rights, please contact us at auditor@brushandboot.com. Before responding to a request, we may ask you to provide necessary information to verify your identity.

We aim to respond within the timeframes stipulated by applicable law.

  1. Direct Marketing

Brushandboot may send promotional emails where permitted by applicable laws regarding electronic marketing and data protection.

If prior consent is required by law, we will obtain your consent before sending such communications. Where marketing is permitted on other legal grounds, we will comply with relevant conditions and provide an effective way to opt out.

You can unsubscribe via the link in promotional emails or by contacting auditor@brushandboot.com.

Opting out of promotional communications does not affect the sending of necessary, non-promotional communications related to existing orders, transactions, or customer service matters.

  1. Personal Data of Children

Our website and products are intended for general customers and are not specifically targeted at children. We do not knowingly collect personal data from children in violation of applicable laws.

If you believe a child has provided us with personal data in circumstances where such data should not have been collected, please contact us so we can investigate and take appropriate action.

  1. Third-Party Websites

Our website may contain links to external websites or services operated by third parties. These websites have their own privacy policies and terms.

Brushandboot is responsible only for its own processing activities and has no control over the independent privacy practices of external websites. We recommend reviewing the relevant privacy information before providing personal data to other services.

  1. Changes to This Privacy Policy

We may update this privacy policy to reflect changes in our business practices, website functionality, or applicable legal requirements.

The revised version will be posted on this page, with the update date noted where appropriate. Changes take effect from the date specified in the revised policy, subject to any additional notice or consent procedures required by law.

We encourage you to review this page periodically to stay informed about how personal data is processed.

16. Contact Information and Complaints

If you have any questions about this privacy policy, or requests regarding personal data and other privacy-related matters, please contact:

Phone: +44 1764784524
Email: auditor@brushandboot.com

If you are located in the UK, you may also contact the UK Information Commissioner’s Office (ICO). If you are located in the European Economic Area (EEA), you may contact the competent data protection supervisory authority in your country. We will review and respond to privacy-related inquiries in accordance with applicable legal requirements.

 

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