Privacy policy



This Privacy Policy describes how your personal information is collected, used, and shared when you visit or make a purchase from whistlefish.com (the “Site”).

WHO WE ARE

Milkwood Publishing Ltd, trading as Whistlefish, is the data controller responsible for your personal information.

Company number: 04134140
VAT number: GB684755877

If you have any questions about how we collect, use or protect your personal information, you can contact us at info@whistlefish.com or through our Contact page.

PERSONAL INFORMATION

When you visit the Site, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Site, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site. We refer to this automatically-collected information as “Device Information.”

We collect Device Information using the following technologies:

  • “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.
  • “Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
  • “Web beacons,” “tags,” and “pixels” are electronic files used to record information about how you browse the Site.

Additionally when you make a purchase or attempt to make a purchase through the Site, we collect certain information from you, including your name, billing address, shipping address, payment information (including credit card numbers), email address, and phone number. We refer to this information as “Order Information.”

When we talk about “Personal Information” in this Privacy Policy, we are talking both about Device Information and Order Information.

THIRD PARTY COOKIE TRACKING

We partner with Rakuten Advertising, who may collect personal information when you interact with our site. The collection and use of this information are subject to the privacy policy located here:

Privacy Policy: https://rakutenadvertising.com/legal-notices/services-privacy-policy/

Your Rights/Opt Out: https://rakutenadvertising.com/legal-notices/services-privacy-rights-request-form/

You can read our full Cookie Policy Here

HOW DO WE USE YOUR PERSONAL INFORMATION?

We use the Order Information that we collect generally to fulfil any orders placed through the Site (including processing your payment information, arranging for shipping, and providing you with invoices and/or order confirmations).

Additionally, we use this Order Information to:

Communicate with you;
Screen our orders for potential risk or fraud; and
When in line with the preferences you have shared with us, provide you with information or advertising relating to our products or services.

We use the Device Information that we collect to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimize our Site (for example, by generating analytics about how our customers browse and interact with the Site, and to assess the success of our marketing and advertising campaigns).

SHARING YOUR PERSONAL INFORMATION

We share your Personal Information with third parties to help us use your Personal Information, as described above. For example, we use Shopify to power our online store--you can read more about how Shopify uses your Personal Information here: https://www.shopify.com/legal/privacy. We also use Google Analytics to help us understand how our customers use the Site--you can read more about how Google uses your Personal Information here: https://www.google.com/intl/en/policies/privacy. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout


Finally, we may also share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.

LAWFUL BASES FOR PROCESSING

We only use your personal information where we have a lawful basis to do so under applicable data protection law. Depending on how you interact with Whistlefish, we may rely on the following lawful bases:

  • Contract – where the use of your personal information is necessary to process and fulfil your order, take payment, arrange delivery, manage returns or refunds, provide customer service, or otherwise perform our contract with you.

  • Legal obligation – where we need to use or retain information to comply with legal or regulatory requirements, including accounting, taxation or responding to lawful requests from public authorities.

  • Legitimate interests – where the use of your information is necessary for our legitimate business interests and those interests are not overridden by your rights and interests. This may include protecting our website and business from fraud and misuse, improving our services, analysing business performance and maintaining appropriate records.

  • Consent – where you have actively agreed to a particular use of your personal information, such as receiving certain marketing communications or allowing optional cookies and similar technologies where consent is required. You can withdraw your consent at any time.

Where we send marketing communications using the permitted “soft opt-in” for existing customers, we may rely on our legitimate interests as the lawful basis for processing your personal information, provided the applicable legal requirements are met and you are given a clear opportunity to opt out.

MARKETING COMMUNICATIONS

We may use your personal information to send you news, offers, product updates and other marketing communications from Whistlefish where we are permitted to do so.

You may choose to sign up for marketing communications online, in one of our shops, at a show or event, or when entering a competition. Where consent is required, we will ask you to make a clear positive choice to opt in. Making a purchase, requesting a digital receipt, attending an event or entering a competition does not automatically subscribe you to marketing communications.

In certain circumstances, we may send marketing communications to existing customers using the permitted soft opt-in. Where this applies, we will only use contact details collected directly from you in connection with a sale or discussion about a sale, the marketing will relate to our similar products or services, and you will have been given a clear opportunity to opt out when your details were collected and in every subsequent marketing message.

We may keep information about when, where and how you signed up to receive marketing, including the source of your sign-up and the consent wording presented to you.

You can unsubscribe from marketing emails at any time using the unsubscribe link included in our emails or by contacting us. If you unsubscribe, we may keep limited information on a suppression list so that we can respect your request and avoid sending you further marketing communications.

Where we rely on your consent for marketing, you can withdraw that consent at any time.

INTERNATIONAL TRANSFERS

Some of the service providers we use may process or store your personal information outside the United Kingdom.

Where we transfer personal information outside the UK, we take appropriate steps to ensure that it remains protected in accordance with applicable data protection law.

Depending on the destination and the organisation receiving the information, we may rely on:

  • UK adequacy regulations, where the UK Government has recognised that a country provides an adequate level of protection for personal information; or
  • appropriate safeguards, such as the UK International Data Transfer Agreement (IDTA), the UK Addendum to approved standard contractual clauses, or another legally permitted safeguard.
  • Where required, we also assess the risks associated with international transfers and take additional measures where necessary to protect your personal information.

If you would like more information about the safeguards used for international transfers of your personal information, please get in touch with us at info@whistlefish.com.

BEHAVIOURAL ADVERTISING

As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.

You can opt out of targeted advertising by following the below links for the relevant platform:

Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal.

DO NOT TRACK

Please note that we do not alter our Site’s data collection and use practices when we see a Do Not Track signal from your browser.

YOUR RIGHTS

Under UK data protection law, you may have the following rights in relation to your personal information:

  • Right of access – you can ask us for a copy of the personal information we hold about you.
  • Right to rectification – you can ask us to correct personal information that is inaccurate or complete information that is incomplete.
  • Right to erasure – you can ask us to delete your personal information in certain circumstances.
  • Right to restriction – you can ask us to restrict how we use your personal information in certain circumstances.
  • Right to object – you can object to certain uses of your personal information, including processing based on legitimate interests and direct marketing.
  • Right to data portability – in certain circumstances, you can ask us to provide personal information you have given us in a structured, commonly used and machine-readable format, or to transfer it to another organisation.
  • Right to withdraw consent – where we rely on your consent, you can withdraw it at any time. This will not affect processing carried out before your consent was withdrawn.
  • Rights relating to automated decision-making – where applicable, you may have rights in relation to decisions made solely by automated means that have a legal or similarly significant effect on you.
  • These rights do not apply in every circumstance and may be subject to exemptions under applicable law.

If you would like to exercise any of your rights, please get in touch with us at info@whistlefish.com or through our Contact page. We may need to verify your identity before acting on your request.

DATA RETENTION

We keep your personal information only for as long as reasonably necessary for the purposes for which it was collected, including to fulfil our contractual obligations, provide customer service, comply with legal, accounting and tax requirements, prevent fraud and resolve disputes.

The length of time we retain information may vary depending on the type of information and why we hold it. We regularly review our retention periods and securely delete or anonymise personal information when it is no longer required.

Where you ask us to delete your personal information, we will do so where the right to erasure applies. We may need to retain certain information where we have a legal obligation or another lawful reason to keep it.

CHANGES

We may update this privacy policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons.

CONTACT

For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us.