Clever Clogs @19 takes your data privacy seriously.  In order to provide you with our services we collect and use personal data which means that we are a ‘Data Controller’ and we are responsible for complying with Data Protection Laws and the General Data Protection Regulations (GDPR).

In this Privacy Notice, we want to let you know you what information we collect, how we use it and what rights you have in relation to the collection and processing of your personal data.

Our Contact Details

Clever Clogs @19                                                                               

Address: 19 Bank Street, Falkirk, FK1 1NB

Telephone: 01324 633090


If you have any questions in respect of this Privacy Notice or how we manage your personal data, please contact:

Lesley Urquhart at Clever Clogs @19 using the contact details above

What personal data we collect

We collect the following types of data:

  • General contact details such as, Name, Address, email address, Telephone number
  • Details of Goods purchased by you
  • Financial Details – such payment or bank details
  • For recruitment: Employment and Education History
  • In respect of employment: performance and payroll information
  • Information obtained through our use of cookies (please see the Cookies and Similar Technologies)
  • Your marketing preferences


We collect the following data for children

  • Name and last measured shoe size

Where we collect such information for children, we do so only with strict consent of a parent or guardian and do so only to enhance our service to returning customers.  Such information is stored with additional safeguards and access control at all times.

Special Categories of Personal Data that we collect:

We collect the following types of special category data in relation to employees only:

  • Employment History
  • Sickness and Absence Records
  • Health and Medical details where necessary for absence management or accessibility only

How we collect your information

In most cases / We collect your data directly from you.  We collect data and process it when you

  • Register / Subscribe on our Website
  • Make a purchase via our website or in our store
  • Complete an online ‘contact us’ form
  • Speak to us on the telephone to discuss or use our products
  • Email or write to us to enquire about or use our products
  • View our website via your browsers cookies (see our Cookie Policy)

We also receive your data indirectly from the following sources:

  • Social Media Sites
  • Public sources – demographic data, Market Research
  • Credit Agencies

Why we do we collect your information?

Where we collect and process personal data, we identify both the purpose and legal basis for doing so.  There are 6 possible legal bases which are:

Consent – where we have consent from the individual to the processing of his or her personal data for one or more specific purpose

Contract – where the processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract

Legal Obligation – The processing is necessary for compliance with a legal obligation to which we are subject

Vital Interests – Where the processing is necessary in order to protect the vital interests of the data subject or another natural person

Public Interest – Where the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller

Legitimate Interests – Where the processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal date, in particular where the data subject is a child.

Our purpose and legal basis for the information we collect, and process allows us to:

To understand your requirements prior to entering into a contract of sale with you The processing is necessary for the performance of an anticipated Contract
To understand your requirements to ensure that any contract of sale meets your needs The processing is necessary for the performance of a Contract with you
To fulfil your contract of sale and provide you with the agreed services therein The processing is necessary for the performance of our Contract with you
To manage our business operations and comply with any internal policies and procedures It is in our legitimate interests to use your personal information to ensure that we provide and adapt our services
To notify registered users / existing customers about changes to our service It is in our Legitimate Interests to use your personal information to keep you informed about any changes that may affect you
For Marketing of similar services to existing or previous customers or enquirers It is in our legitimate interests to use your personal information for marketing purposes where the services being marketed are similar and  relevant to you.
For electronic Marketing of services to new customers We rely on Consent for direct marketing to individuals
To comply with our legal obligations, law enforcement, court and regulatory bodies requirements To comply with our Legal Obligations
To identify and prevent fraud It is in our Legitimate Interests to act as a responsible business

Where we rely on your consent you have the right to withdraw this consent at any time by contacting us.  Full contact details can be found at the beginning of this notice.

Legitimate Interests – Where the processing of personal data is based on our Legitimate Interests, it is to improve on our service, security and prevent fraud or illegal activity in favour of the wellbeing of our customers, employees and shareholders.

Who we share your information with?

From time to time we may share your personal information with other companies in the Clever Clogs @19 Group or with the following third parties for the purposes set out above:

  • Our Accountant or Payment Service Providers
  • Regulators and Governing bodies, Lawyers and other Professional Services
  • Software and Cloud storage providers
  • Fraud detection Agencies
  • Police and Law Enforcement agencies where reasonably necessary for the prevention or detection of crime
  • Selected Third Parties in connection with any future sale, transfer or disposal of our business

International data transfers

We do not transfer your data outside of the UK

Automated decision-making or Profiling

We do not process personal data for automated decision making or profiling

How Long do we keep personal data for?

We will retain personal data in accordance with legal and regulatory requirements and for no longer than is necessary to fulfil the purposes set out in this privacy policy.  We maintain and review a detailed retention policy which documents how long we will hold different types of data.  The time period will depend on the purpose for which we collected the information and is never on an indefinite basis.  Subsequently, we will delete or destroy your personal data in accordance with our data retention and deletion policy or take steps to properly render the data anonymous, unless we are legally obliged to keep your personal data longer (e.g. for tax, accounting or auditing purposes).

The following details the criteria used to establish the retention period set out within our policy.

Where it is still necessary for the provision of our Services
This includes the duration of any contract for products we have sold to you and for a period of 24 months after the end of any subscription or contract of sale with a view to maintaining and improving the performance of our products, keeping our systems secure, and maintaining appropriate business and financial records. Most of our retention periods are determined on the basis of this general rule.

Where required by Statutory, contractual or other similar obligations
Corresponding storage obligations may arise, for example, from laws or regulation. It may also be necessary to store personal data with regard to pending or future legal disputes. Personal data contained in contracts, notifications and business letters may be subject to statutory storage obligations depending on national law.

Your Rights as a data subject

As a data subject, you have rights in relation to your personal data.  These are:

Access – You have the right to request details of personal information held or processed and to copies of this data.  We do not usually charge for this service.

Rectification – You have the right to request that any information be corrected that you believe is inaccurate or to complete any information that you believe is incomplete.

Erasure – You have the right to request that we erase your personal information with some exceptions.

Restrict Processing – You have the right to request that we restrict the processing of your personal data under certain circumstances

Object to Processing – You have the right to object to our processing of your data, under certain conditions.

Data Portability – In some circumstances, you have the right to request that we transfer the data that we have collected to another organisation or directly to you.

You also always have the Right to Withdraw Consent where you have previously provided this.

To exercise any of these rights, please contact:

Lesley Urquhart at Clever Clogs @19 – Contact details can be found at the beginning of this notice.

You also have the right to complain to the Supervisory Authority.  Where you wish to report a complaint or feel that we have not addressed your concern in a satisfactory manner, you may contact the Information Commissioner’s Office at:

Information Commissioners Office

Wycliffe House

Water Lane




Helpline: 0303 123 1113

Online Enquiries:

Contractual Obligations and Consequences

In some circumstances, the provision of personal data is partly required by law (for example, tax regulations, legal obligations) or can also result from contractual provisions.  This means that it may sometimes be necessary to conclude or fulfil a contract, that the personal data be provided.  In those circumstances where the data is not provided or where certain rights are exercised, (Erasure, Object) there is a possible consequence that the contract could not be fulfilled or concluded and may be cancelled.

Cookies & Similar Technologies

Our website doesn’t currently use cookies. Cookies are small text files that are automatically created by your browser and stored on your device when you visit or use the Website.

External Links

Please remember, when clicking on external links via our website, or where you find us via social media platforms, we have no control over the privacy settings on these websites, so please remember to review the privacy information on those sites and set your preferences in line with their own policies and cookie controls separately.

Data security

We aim to protect your personal data through technical and organisational security measures to minimise risks associated with data loss, misuse, unauthorised access and unauthorised disclosure and alteration.

We store customer records on devices which have controlled and restricted access.  We operate records management and Information security policies which detail physical security, security monitoring, access control and password security measures.

Changes to our Privacy Notice

Clever Clogs @19 keep our Privacy Notice under regular review.  This Privacy Notice was last updated on 28th September 2020.

Contacting Us

If you have any questions in respect of this Privacy Notice or how we manage your personal data, please contact us using the details at the beginning of this notice.

If you would like to see the Cookie Policy, you can find it here.