Customer Privacy Policy
Quick Links
- Who we are?
- What information do we collect and how do we use it?
- What information do we collect from third parties?
- What is our legal basis for using your personal information?
- What cookies do we use?
- What happens if I don’t provide my information?
- Will we change the purpose for using your information?
- How long do we keep your information?
- Who do we share your information with?
- Do we transfer information outside the Nigeria?
- How do we keep your information secure?
- What are your rights?
- How you can contact us
Who are we?
We are Gallery Bebe Limited, and our Data Controller is responsible for deciding how your personal information is collected, stored and used
What information do we collect and how do we use it?
The personal information we collect and use will depend on why we need it and whether you are buying or browsing, online. We collect most information directly from you when you order or buy from us. We need different types of information and have explained what categories we collect, why it is needed and where we get it from below. We will never collect more than is necessary in line with the data minimisation principle of GDPR (General Data Protection Regulation).
Sometimes we are given information about you unexpectedly, such as
from the police,
organisations and agencies trying to prevent threats and fraud, and
from the public. We
will process this data only where completely necessary.
Our use
of your details will
depend on you and what you are doing: browsing or buying if you are
new to us or a
registered customer.
Use will be different on-line, but we will try to join up details of
our relationship
with you in our distribution/collection centres and online in our
records, even if you
use different devices online. We explain our lawful reasons for use
of your personal
information in “What is Our Legal Basis for using your Personal
Information” section.
We may share your personal information within our company for
internal reporting
purposes, in order to facilitate business improvement and efficacy,
including research,
systems and our supplier testing and development. We have
specifically identified where
we use your personal information (with your consent) across the
group for marketing
purposes below.
We use cookies on our website which collect
information from you
such as your browsing patterns. Please see our Cookie Policy for
more information.
What information do we collect and how do we use it?
The personal information we collect and use will depend on why we need it and whether you are buying or browsing, online. We collect most information directly from you when you order or buy from us. We need different types of information and have explained what categories we collect, why it is needed and where we get it from below. We will never collect more than is necessary in line with the data minimisation principle of GDPR (General Data Protection Regulation).
Sometimes we are given information about you unexpectedly, such as
from the police,
organisations and agencies trying to prevent threats and fraud, and
from the public. We
will process this data only where completely necessary.
Our use
of your details
will depend on you and what you are doing: browsing or buying if you
are new to us or a
registered customer.
Use will be different on-line, but we will try to join up details of our relationship with you in our distribution/collection centres and online in our records, even if you use different devices online. We explain our lawful reasons for use of your personal information in “What is Our Legal Basis for using your Personal Information” section.
We may share your personal information within our company for
internal reporting
purposes, in order to facilitate business improvement and efficacy,
including research,
systems and our supplier testing and development. We have
specifically identified where
we use your personal information (with your consent) across the
group for marketing
purposes below.
We use cookies on our website which collect
information from you
such as your browsing patterns. Please see our Cookie Policy for
more information.
| What we collect | Why we need it | Which Controller | Where will you collect products from? | |||
|---|---|---|---|---|---|---|
| Full name, address, delivery address (if different), telephone number, mobile number, e-mail address, details of a nominated ‘Authorised Person’. | To administer your order (including dealing with queries, issues, returns, payment) and delivery of your products or make them available for collection in accordance with our Terms and Conditions. | Gallery Bebe Limited. | You, if you purchase products with us, we will nominate a designated collection point close to point close tom you. | |||
| Full name, address, telephone number, mobile number, e-mail address. | To set up and administer your account, to keep details of your orders and to make sure the check-out process is more convenient for you. | Gallery Bebe Limited | You, if you create an account with us online, or if you call us. | |||
| Full name, address, delivery address (if different) telephone number, mobile number, email and recipient email (e-card only). | To administer your order (including dealing with queries, issues and returns) and deliver your voucher to make available for collection in accordance with our Terms and Conditions. | Gallery Bebe Limited | You, if you purchase vouchers or redeem vouchers with us online, or if you call us. | |||
When purchasing products from us
| What we collect | Why we need it | Which Controller | Where we collect it from | |||
|---|---|---|---|---|---|---|
| Personal information via cookies. | We get technical details from the devices you use to access our website and from cookies which tell us what you look at online, where and when. Like most other websites, our technology also lets us know when and how you use our websites, such as when you have added to or abandoned your basket or filled in a form. See below for how we use Cookies. | Gallery Bebe Limited. | You, if you browse our online website. | |||
| IP address, internet provider, operating system and browser used, type of device, such as laptop or smart phone, device cookie settings and other device details, such as MAC address and the geographic region which your device reports to us that you are located in. |
So our website technology can work properly with your
device and make sure
you can see and use our intended website and on the
device you are using.
If you have also signed up to receive our marketing, we will personalise your emails based upon your interaction with our website across your devices. This will allow us to remember information about you even when you use different devices to build a holistic picture of your interests and preferences. |
Gallery Bebe Limited | You, if you browse our online website technology interaction with your browser/devices. | |||
| Mobile number. | So we can send you information service updates to you (regarding delivery). | Gallery Bebe Limited | You, if you purchase products with us online, or if you call us. | |||
Information about our website and your personal devices, such as phones
Contact history
| What we collect | Why we need it | Which Controller | Where we collect it from | |||
|---|---|---|---|---|---|---|
| Full name, address, telephone number, mobile number, e-mail, baby’s due date or your child’s birthday and your child’s gender. | We use this to reserve your place at a our Parent to Be Event or to send reminders on collection of your delivery. | Gallery Bebe Limited. | You, if you book an appointment for a Parent to Be Event or to remind you to collect your products from our distribution/collection centres. | |||
| Full name, address, contact number, mobile number, e-mail, details of query or issue you have raised. | If you reach us via the ‘Complaint Resolution’ link on our website, we will also collect your order number. We require it to access your account if you have one and to respond to you to investigate, consider and deal with any issue or complaint you have raised. We retain all previous conversations that we have had with you, this is so that we have an audit trail and for complaint/dispute resolution. | Gallery Bebe Limited | You, if you contact us via our online website. | |||
| Account holder or Authorised Person only, e-mail if you do not have this you will be asked for account holder surname, address, account and/or deposit number. | We need this for ID & Verification purposes to gain access to the account. You will be asked a series of questions to verify that you are the account holder. Where you have nominated an ‘authorised person’ on your account and they are calling for assistance, the ‘authorised person’ will be asked for the account holder’s email address, surname, address or account number or deposit number and a series of verification questions will need to be answered based on the ‘authorised person’s own personal information | Gallery Bebe Limited | You, if you contact us via Customer Services for assistance, in order to access your account. | |||
Purchasing history
| What we collect | Why we need it | Which Controller | Where we collect it from | |||
|---|---|---|---|---|---|---|
| What you have bought in the past and what you have searched for. | We match your purchases to links from affiliates who might have introduced you to Gallery Bebe or promoted a particular product when you visited their site. We share relevant purchase history with them, so they know when they have made a successful introduction. | Gallery Bebe Limited. |
3rd party, we have a number of “introducers” who direct new customers to us or promote our products on their sites |
|||
Payment information
| What we collect | Why we need it | Which Controller | Where we collect it from | |||
|---|---|---|---|---|---|---|
| Name, card issuer and card type, number, issue number, start and expiry dates and cvv code (we don’t retain this). | So we can check the right person is using the right card/account and meet the payment requirements of the card/account issuers; and make sure we are paid for what you buy. So we can process refunds and to keep a record of any financial transactions with you for tax purposes. | Gallery Bebe Limited. | You, your payment / Card issuer or, where you purchase products with us online, or if you call us on customer service line. | |||
| Fraud checks or flags raised about your transactions, the payment card you want to use, payment card refusals, suspected crimes, complaints, claims and accidents. | So we can protect you, other customers and our business against criminal activities and risks, make sure we understand and can meet our legal obligations to you and others and can defend ourselves. | Gallery Bebe Limited. | You, the police, crime and fraud prevention agencies, payment card providers, the public, regulators, yours and our professional advisors and representatives. | |||
Our social media pages
| What we collect | Why we need it | Which Controller | Where we collect it from | |||
|---|---|---|---|---|---|---|
| Comments and photos. | Monitor our customers views or opinions and we may want to respond to you or react, particularly if you are unhappy with something. We will always ask for your permission to use a photo. | Gallery Bebe Limited. | You, when you post on our social media pages. | |||
Surveys and feedback
| What we collect | Why we need it | Which Controller | Where we collect it from | |||
|---|---|---|---|---|---|---|
| Full name, e-mail, and the information you provide to rate our services. | For customer service rating and delivery distribution rating to help us understand how we can improve our services. | Gallery Bebe Limited. | You, if you complete surveys with us online. | |||
| Full name, e-mail, comments and any additional personal information that you enter in at the time of review. | To review and improve our products and services and with your permission, it will be published on our website and other social media pages. | Gallery Bebe Limited. | You, if you comment on or review our products or services online. | |||
Marketing
| What we collect | Why we need it | Which Controller | Where we collect it from | |||
|---|---|---|---|---|---|---|
| Full name, e-mail, and any marketing preferences. | To send you information about these preferences. You can opt out of receiving these at any time and an option to unsubscribe will be given in each e-mail should you decide you don’t want to receive these anymore. | Gallery Bebe Limited. | You, if you sign up for news ,offers, events and new product arrivals with us online. | |||
| Verified e-mail clicks, e-mail open status or views of advertisements | Our emails may contain a beacon to advice us whether our whether our emails are opened and verify any clicks through to links or advertisements within the email. We may use this information for purposes including determining which of our emails are more interesting to users, to query whether users who do not open our emails wish to continue receiving them. We cannot identify individual users from this information nor do we capture any personal information. If you do not wish the beacon to be downloaded to your device, you should select to receive emails from us in plain text rather than HTML or follow the steps outlined in our Cookie Policy. | Gallery Bebe Limited. | You, if you sign up for news , offers, and events with us online. | |||
|
Your customer journey before, during and after visiting
our online website
from your device. Details of your online browsing activities, based upon our online website, cookies and other similar technologies, such as the pages, products or areas of our online website that you visit, or which link has brought you to our website from our email communication. Similar details from your contact information, historic order information online through e-receipts, preference information, voluntary information and online observed information. |
Some marketing will be done by profiling, which is where
we tailor the
information and offers we send to you. So we can learn more about you; try to understand the type of customer you are, to predict what you are most interested in, what offers you will like most, tailor our adverts and offers. |
Gallery Bebe Limited. |
You, your interaction with
our online website using your browser/devices, and other
similar
technologies which track
the pages you visit;
without seeing the details
collected, from cookies set by ad providers, social
media platforms and
Google.
We will also collect this data through your e-receipts, online transactions, at the point in which you sign up to receive our marketing and where you state your preferences. (accessible via the unsubscribe link in all our marketing emails, or via your Account or by calling Customer Services). |
|||
Information regarding a person's health, criminal history, sexual orientation, color, ethnicity, health, or disability are examples of other sensitive personal information that falls under the category of "Special Categories" and requires a higher level of protection.
Other personal information that we collect
In order to meet our legal and compliance duties, we may use your personal information to initiate or defend legal action. This could involve gathering your signature and using it to resolve any delivery problems.
Back To TopWhat information do we collect from third parties?
If you sign up to receive promotional emails, we will also gather personal information from you (online).
Back To Top| Why we use your personal information | Lawful basis for use | ||||
|---|---|---|---|---|---|
| Create an account or purchase products. | Contract or for taking preliminary steps for that contract | ||||
|
In order to take card payments, we must adhere to
legislative requirements
against money laundering as well as the policies of card
issuers like Visa
to ensure that we are paid. By checking with credit reference bureaus and fraud prevention organizations, who may keep records of this and of any concerns, you can ensure that you are who you say you are and that your use of the card appears to be legal. To assist with this, we make use of specialized payment providers. Preventing and detecting crime is important to everyone and any concerns may be shared with law enforcement agencies. |
Legitimate Interests & Legal Obligation | Legal Claims | |||
| Purchase or redeem vouchers. | Contract or for taking preliminary steps for that contract | ||||
| Surveys and reviews. | Consent | ||||
| News, offers, and events. | Consent | ||||
| In the event that you buy things from us and we want to advertise comparable goods. | Legitimate Interests “soft opt-in” | ||||
| About a good or service you've bought from us, get in touch with us via our online website or by calling customer care. | Contract | ||||
| To get in touch with us about anything else, visit our website or call customer care. | Legitimate Interests | ||||
| The instances where we utilize your personal data to comply with any legal or regulatory requirements. | Legal Obligation | ||||
| The instances where we utilize it to initiate or defend legal actions (where it relates to a contract that we have in place). | Contract otherwise Legititmate Interest | ||||
| Meeting our legal commitments regarding health and safety. | Vital Interests | Health (Preventative medicine); | |||
| Addressing any insurance or legal claims that may be relevant. | Legitimate Interests & Legal Obligation | Legal Claims | |||
| Managing any alleged fraud or other alleged criminal behavior that may involve or have an impact on you. | Legal Obligation | Legal Claims & Substantial Public Interest | |||
| In order to investigate, stop, and identify criminality, one must heed warnings and provide information to law enforcement and fraud prevention organizations. | Legitimate Interests | Substantial public interest | |||
| Addressing any insurance or legal claims that may be relevant. | Legal Obligation | Legal Claims | |||
| To maintain records of our interactions with you so that we can fulfill our legal duties, including those related to accounting, taxation, and data privacy. | Legal Obligation | ||||
| To maintain records for the purposes of risk management and insurance. | Legitimate Interests | ||||
|
The analysis of vast numbers of individual records in
order to identify the
interests, trends, and shifts in the consumer base.
This needed to run our business efficiently, including
ordering stock and
organising supplies and adjusting resourcing such as for
in store colleagues
/ delivery coverage to meet demand.
|
Legitimate Interests | ||||
| To maintain the integrity, security, and proper operation of our systems, websites, and their use, as well as to continuously enhance their effectiveness. | Legitimate Interests | ||||
| Meeting our obligations to secure personal information. | Legal Obligation | ||||
| To guarantee that use of the online website conforms with our terms and policies and to authenticate users, account holders. | Legitimate Interests & Legal Obligation | ||||
| To handle enforceable information requests from courts and other governmental agencies, as well as our legal duties, such as those relating to product recalls. | Legal Obligation | Legal Claims | |||
| To assist with and provide information
to law enforcement,
official government agencies, regulators, courts, and
other parties, even
though it is not required by law to do so. We consider it necessary in this situation to help with crime prevention or detection, legal compliance, or good governance. This includes where we take professional advice to understand and deal with our legal rights and obligations and dealing with our insurers. |
Legitimate Interests & Public Interest | Substantial Public Interest & Legal Claims | |||
| To handle the restructuring or sale of our business or a portion of it, and to share the necessary information with potential buyers and their professional advisors | Legitimate Interest | ||||
What is our legal basis for using your personal information?
We are committed to safeguarding your privacy and will only use your
personal information in
compliance with any applicable data protection laws, such as the Data
Privacy Act of 2019
and the General Data Protection Regulation of Nigeria.
In
accordance with data
protection law, we must have a "legal or lawful basis for processing,"
as it is commonly
referred to,before we can use your personal information. Below is how
we've laid out ours:
What cookies do we use?
When you browse our website, we may use “cookies” to keep track of your visit and give you a better browsing experience. Please click here to view the full details of our cookie policy.
Our website, like the majority of websites, records a variety of
information about visitors,
including internet protocol (IP) addresses, browser types, information
about internet
service providers (ISPs), referring / exit pages, and date / time
stamps. We may use your
information to track your browsing activities on our website, administer
the site, analyse
trends, and compile broad demographic data. We might also use this data
to drive our
marketing and future business plans; as a result, it might be disclosed
to outside parties,
like our advertisers. We won't use your personal information to identify
you; any
information we do give will be in statistical form.
The use of your
consent serves as
the legal foundation for any personal information we gather through
cookies.
What happens if I don’t provide my information?
We won't be able to execute your order, enter into a contract with you, or respond to any inquiries if you choose not to give us your personal information.
Back To TopWill we change the purpose for using your information?
Except in cases where a different reason is compatible with the original purposes, we will only use your personal information for those purposes as stated above. If we decide to use your personal information for an unconnected reason, we will let you know and provide you with information about the legal justification for doing so.
Back To TopHow long do we keep your information?
Depending on the type of information and the purpose for which it was
obtained from you, we
may keep your personal information for a shorter or longer period of
time. However, there
are some circumstances in which personal information may be kept for an
extended period of
time. For instance, personal information that we must keep for legal
reasons will typically
be kept for at least six years in accordance with customary business
practice and legal
obligations. In order to comply with legal requirements relating to
product recalls and
personal injury claims, the personal information will be transferred
after this time to a
safe, encrypted, and anonymized archive where it will be kept for an
additional 23 years.
If you have given us permission to contact you for marketing
purposes, we will keep
your personal information for up to 300 days before requesting your
updated permission.
Who do we share your information with?
Periodically, we might divulge your private information to dependable
other parties.
Nonetheless, we won't divulge your personal data to a third party for
marketing purposes. No
personal information about you is ever sold to a third party so they can
market to you.
The third parties with whom we might disclose your personal information
are listed below. We
shall use organizational and technical safeguards to safeguard your data
and limit how it
may be used in ways that don't violate data protection laws:
- Card Payment Processor:
CyberSource Limited and CyberSource Corporation (collectively, "CyberSource") shall process your personal information and credit card information in order to handle payment transactions and prevent fraud. CyberSource will process your personal information on our behalf, and it will also receive and keep the information from your credit or debit card. With CyberSource and other fraud-prevention organizations, we might conduct fraud and security checks. If we or they suspect or spot fraud, we or they may note it and/or share it with other organizations for the aim of preventing fraud. In the future, this information may be used for fraud prevention by us, CyberSource, and these other organizations. - IT Suppliers:r:
Our IT systems are provided to us and are supported by other parties. To the degree necessary to provide their services, they may have access to your personal information. - Distribution/Collection:
We use third parties as our distribution/collection points. - Website Analysis and Profiling Companies:
In order to better our website and your experience with it, we employ third parties to conduct usage analyses, such as examinations of customer traffic patterns or browsing habits. They also assist us in customizing the news and deals we bring your way. - Survey and Marketing Companies:
We use third parties to send out and administer our surveys and send out some of our marketing like Dotmailer, Survey Monkey, Text Anywhere and Feefo. - Legal and Regulatory Requirements:
We will share your personal information with entities, companies or individuals (including Police, Government Bodies & Regulators) where this is necessary to comply with any law, rule, regulation, legal procedure. - Professional Advisors:
Additionally, we may disclose your personal information to our professional advisers (such as attorneys, insurers, and/or insurance brokers) in order to receive advice, for example, in relation to any complaint or claim you may make. - Third party content and links on our websites
We occasionally include connections to other websites and apps on our websites and apps that we believe you'll enjoy. Although we don't provide them your information, if you click on those links, our website will be left behind. If you want to do so, their privacy policy will apply to any personal data you choose to disclose with them independently.
We shall only give third parties access to your personal information that is required for them to carry out the task or use for which they were hired. In order for a logistics provider, for instance, to transport or pick up your merchandise, we will only provide them with the personal information they require.
Do we transfer information outside the Nigeria?
In some circumstances, the disclosure of your personal information to a
third party as
indicated above may require a transfer of your personal information
outside of Nigeria. This
could be to:
This could be to a country that is thought to have
data protection laws
that are equivalent to those in Nigeria, or it could be to a country
that isn't thought to
have the same standards of protection for personal data as those in
Nigeria. In either case,
we'll take any necessary legal precautions to ensure that there are
enough safeguards in
place to protect your personal information, including, as necessary,
putting contractual
terms approved by the Data Protection Act in place.
How do we keep your information secure?
We have put in place organizational and technical safeguards to guard
against the
unauthorised use, access, use, alteration, or disclosure of your
personal information.
Additionally, we only allow employees, agents, contractors, and other
third parties (listed
above) that have a business need to know access to your personal
information. They are
obligated to maintain their privacy.
When we are legally compelled
to, we shall notify
you and any relevant regulator of a suspected incident. We have set
procedures in place to
deal with any suspected data security event.
Due to security
precautions, on occasion
we may need identification documentation before disclosing personal
information to you.
You should be aware that the method you choose to contact us, such as email or postal letter, may not be completely secure and that your personal data may be subject to interception while in transit. Your personal information is also in danger if an uninvited party accesses your account on our customer portal or any other location where it is kept, including your email account. In order to protect your personal information, you should take all necessary precautions, such as selecting a safe password for both your account and your email account and keeping your passwords to yourself. Every account needs its own password, which you should use.
Back To TopWhat are your rights?
You have a number of rights over your personal information, which are:
- Right of Access: the right to request a copy of the personal data we have on you and to know what information we have about you;
- Right to Rectification: the right to request that we amend any mistakes in your personal data;
- Right to Object: the right to object to our legitimate interests, profiling activities and marketing communications;
- Right to Data Portability the right to request a copy of the personal data you have provided to us in a structured, widely-used, and machine-readable format, as well as the right to transfer that data to another business where: (i) we are using your personal data with your consent or because it is required to fulfill a contract with you; and (ii) we are using it in an automated manner;
- Right of Erasure: the right to request the removal of your personal data where: You withdraw your consent to our use of your personal information, and we have no other legal basis to keep your personal information. You have requested that we review and explain our legitimate interests to you, but we don't actually have a legitimate interest that is sufficient to justify what we are doing. Our use of your personal information is unlawful. We must delete your personal information to comply with our legal obligations.
- Right to Restrict: the right to request that we limit how we use your personal information in the following situations: (i) you believe your personal information is incorrect and want us to verify it; We no longer require your personal information, but you require us to maintain it in order to exercise any legal rights; (ii) What we are doing with your personal information is unlawful, but you would prefer we stop using it rather than delete it; and (iii) and (iv) in order for us to determine if we genuinely have a legitimate reason for doing what we are doing, you have asked us to examine and explain our legitimate interests to you;
- Right to withdraw Consent: You have the right to revoke your permission at any time when our use of your personal information is dependent on it by contacting us at (Email) or (Phone No.) or Gallery Bebe Ltd. (Address). You are entitled to file a complaint. at any time.
Does this policy cover other websites?
This privacy statement does not apply to external links on our website that lead to other websites like Facebook and Instagram. For more information on how those other websites could use your personal information, you should consult their privacy policies.
Back To TopHow you can contact us
If you need to get in touch with us about this notice or any matters
relating to the
personal information we hold on you, you can write to us, Gallery Bebe
Limited, (Address)
Nigeria. Alternatively, you can email (Email) or
call us on (phone no.).
This policy
was constituted on March 2023. Periodically, we'll update it, and if we
make any changes
that might have an impact on you, we'll notify you beforehand.