Privacy Policy

Farrago understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits this website, www.farrago.uk (“Our Site”) and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.

Please read this Privacy Policy carefully and ensure that you understand it. You will be deemed to have accepted the terms of this Privacy Policy on your first use of Our Site.

1. Definitions and Interpretation

In this Policy the following terms shall have the following meanings:

“Account”	means an account required to access and/or use certain areas and features of Our Site;
“Cookie”	means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out below; and
“Cookie Law”	means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;

2. Information About Us

Our Site is owned and operated by Farrago Footwear Limited, a limited company registered in England under company number 14252037.

Data Protection Officer: Matthew Bedford.

Email address: matthew@farrago.uk.

3. What Does This Policy Cover?

This Privacy Policy applies only to your use of Our Site. Our Site may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.

4. What Is Personal Data?

Personal data is defined by the UK GDPR and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

5. What Are My Rights?

Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:

a) The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the contact details available in this Privacy Policy.

b) The right to access the personal data we hold about you.

c) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details available in this Privacy Policy.

d) The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details available in this Privacy Policy to find out more.

e) The right to restrict (i.e. prevent) the processing of your personal data.

f) The right to object to us using your personal data for a particular purpose or purposes.

g) The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.

h) The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.

i) Rights relating to automated decision-making and profiling.

j) For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details available in this Privacy Policy.

It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details available in this Privacy Policy.

6. What Data Do You Collect and How?

Depending upon your use of Our Site, we may collect and hold some or all of the personal and non-personal data set out in the table below, using the methods also set out in the table. Please also see below for more information about our use of Cookies and similar technologies.

Data Collected	How We Collect the Data
Identity Information including, but not limited to, name, title, date of birth and gender.	Collected when you create an account, place an order, subscribe to our newsletter, or contact us directly.
Contact information including, but not limited to address, email address and telephone number.	Collected when you place an order, sign up for marketing communications, or enter a competition or giveaway.
Payment information including, but not limited to, card details, bank account numbers and addresses.	Processed securely via third-party payment providers (e.g., Shopify Payments, PayPal, Klarna) when you make a purchase. We do not store card details.
Profile information including, but not limited to, preferences, interests, login details, purchase history.	Collected when you create an account, browse the site, save products to a wishlist, or make a purchase. Data may also be inferred from shopping behaviour and interactions with our site.
Technical information including, but not limited to, IP address, browser type and version, operating system.	Collected automatically through cookies and tracking technologies when you visit our site. This helps improve site functionality, security, and user experience.

7. How Do You Use My Personal Data?

Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes how we may use your personal data, and our lawful bases for doing so:

What We Do	What Data We Use	Our Lawful Basis
Registering you on Our Site	Identity information, contact information	Performance of a contract with you
Providing and managing your Account	Identity information, contact information, profile information	Performance of a contract with you
Providing and managing your access to Our Site	Identity information, technical information	Legitimate interests – to ensure site functionality and security
Personalising and tailoring your experience on Our Site	Profile information, technical information	Legitimate interests – to improve user experience and offer relevant products
Administering Our Site	Technical information, profile information	Legitimate interests – to maintain website security and improve performance
Administering Our Business	Identity information, contact information, payment information	Legitimate interests – to operate and manage our business effectively
Supplying Our Products to You	Identity information, contact information, payment information	Performance of a contract with you
Managing payments for Our Products	Payment information, identity information, contact information	Performance of a contract with you; legal obligation (for financial compliance)
Personalising and tailoring Our Products for You	Profile information, purchase history, preferences	Legitimate interests – to improve our offerings and customer experience
Communicating with You	Contact information, profile information	Performance of a contract (order-related updates); Legitimate interests – to respond to enquiries
Supplying you with information by email and/or post that you have opted into (you may opt-out at any time by clicking the “unsubscribe” link in our emails or contacting us directly)	Contact information, marketing preferences	Consent – you can withdraw consent at any time

With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email, telephone, text message and post with information, news, and offers on our products and services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.

Third Parties whose content appears on Our Site may use third-party Cookies, as detailed below. Please note that we do not control the activities of such third parties, nor the data that they collect and use themselves, and we advise you to check the privacy policies of any such third parties.

We use the following automated systems for carrying out certain kinds of decision-making and profiling. If at any point you wish to query any action that we take on the basis of this or wish to request ‘human intervention’ (i.e. have someone review the action themselves, rather than relying only on the automated method), the Data Protection Legislation gives you the right to do so. Please contact us using the details available in this Privacy Policy.

The following automated decision-making methods may be used:

Fraud Prevention & Security Checks: Our Site uses automated systems to detect potentially fraudulent transactions based on factors such as transaction history, IP address, and payment details. This is necessary to protect both our business and our customers from fraudulent activity and is based on our legitimate interest in ensuring a secure shopping environment. Transactions flagged as high risk may be automatically declined or held for manual review.
Personalised Marketing & Advertising: We use automated tools to tailor marketing messages and promotions based on your browsing behaviour, purchase history, and interactions with our Site. This allows us to provide relevant recommendations and exclusive offers. This processing is based on your consent, which you can withdraw at any time by updating your cookie or marketing preferences.

The following automated profiling may take place:

Customer Behaviour & Preferences Analysis: We analyse customer interactions, including product views, purchases, and time spent on pages, to understand shopping preferences and improve our offerings. This helps us provide a more personalised shopping experience, including curated product recommendations and customised styling suggestions. This processing is based on our legitimate interest in optimising our store and marketing efforts.

If you wish to query any decision made based on automated processing or request human intervention, please contact us using the details available in this Privacy Policy.

We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details available in this Privacy Policy.

If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.

In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.

8. How Long Will You Keep My Personal Data?

We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):

Type of Data	How Long We Keep It
Identity Information (e.g. name, title, date of birth, gender)	Retained for as long as you have an active account with us. If your account is inactive for 5 years, we will delete your data unless required for legal or regulatory reasons.
Contact Information (e.g. address, email address, telephone number)	Retained for as long as necessary to fulfil orders, provide customer support, or for marketing (if consent is given). If you opt out of marketing, we will retain minimal details to ensure no further communications are sent.
Business Information (e.g. business name, job title, profession)	Retained as long as necessary to maintain business relationships or where legally required for tax and contractual obligations.
Payment Information (e.g. card details, bank account numbers)	We do not store full card details. Payment providers (e.g., Shopify Payments, PayPal, Klarna) handle transactions securely. Partial data for record-keeping is retained for up to 7 years to comply with tax and financial regulations.
Profile Information (e.g. preferences, interests, username, password, purchase history)	Retained for as long as you have an active account. If inactive for 5 years, we will delete or anonymise your data unless required for legal or business purposes.
Technical Information (e.g. IP address, browser type and version, operating system)	Retained for up to 2 years for security, fraud prevention, and analytics purposes, after which it is anonymised or deleted.

9. How and Where Do We Store or Transfer Your Personal Data?

We may store some or all of your personal data in countries outside of the UK and the European Economic Area (the “EEA”). These are known as “third countries.” We will take additional steps to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation. These steps include:

Ensuring that your personal data is protected under binding corporate rules, which are a set of common rules that all our group companies and partners must follow when processing personal data.
Only storing or transferring personal data in or to countries that are deemed to provide an adequate level of protection for personal data, as determined by the UK government and/or the European Commission.
Using specific approved contracts (Standard Contractual Clauses) which ensure the same levels of personal data protection that apply under the Data Protection Legislation.

For further information about adequacy decisions, binding corporate rules, or Standard Contractual Clauses, please refer to the Information Commissioner’s Office (ICO).

The security of your personal data is essential to us, and we take a number of important measures to protect it, including:

Limiting access to your personal data to only those employees, agents, contractors, and third parties with a legitimate need to know, ensuring they are subject to strict confidentiality obligations.
Implementing encryption, secure storage solutions, and access controls to protect against unauthorised access, loss, or disclosure.
Having procedures in place to deal with data breaches, including notifying you and/or the Information Commissioner’s Office where legally required.

If you would like further details about how we protect your data when transferring it internationally, please contact us using the details available in this Privacy Policy.

10. Do You Share My Personal Data?

We will not share any of your personal data with any third parties for any purposes, subject to the following exceptions.

If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Policy.

In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

11. How Can I Control My Personal Data?

In addition to your rights under the Data Protection Legislation, when you submit personal data via Our Site, you may be given options to restrict our use of your personal data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails.

You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.

12. Can I Withhold Information?

You may access certain areas of Our Site without providing any personal data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.

You may restrict our use of Cookies.

13. How Can I Access My Personal Data?

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email address shown below.

There is not normally any charge for a subject access request. If your request is manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We will respond to your subject access request within one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

14. How Do You Use Cookies?

Our Site may place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by us and are used only by us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve our products and services. By using Our Site you may also receive certain third-party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, and/or parties other than us. Third-party Cookies are used on Our Site for analytics, marketing, and improving user experience, including tracking website traffic, delivering personalised advertisements, and enabling social media features. In addition, Our Site uses analytics services provided by Google Analytics and other third-party providers to track and analyse website traffic, user behaviour, and improve overall site performance, which also use Cookies. Website analytics refers to a set of tools used to collect and analyse usage statistics, enabling us to better understand how people use Our Site.

15. How Do I Contact You?

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details:

Email address: info@farrago.uk

16. Changes to this Privacy Policy

We may change this Privacy Policy from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of this Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date. This Privacy Policy was last updated on 11th February 2025.