This Policy applies to our use of any and all data collected by us in relation to your use of our Website and any Services therein.
1. DEFINITIONS AND INTERPRETATIONS
1.1. In this Policy the following terms shall have the following meanings:
"Account" means the customer account, which contains collectively the personal information, payment information and credentials used by Users to access material and / or any Services on our Website;
“Content” means any text, graphics, images, audio, video, software, data compilations and any other form of information capable of being stored in a computer that appears on or forms part of our Website;
"Cookie” means a small text file placed on your computer by us when you visit certain parts of our Website. This allows us to identify recurring visitors and to analyse their browsing habits within our Website. Where e-commerce facilities are provided, Cookies may be used to store items in your shopping basket. Further details are contained in paragraph 10 and Schedule 1 of this Policy;
“Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;
“Personal Data” has the same meaning as defined in EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”) and in this case, it means the Personal Data that you give to us via our Website,
“Service” means any online communications infrastructure that we make available through our Website either now or in the future. This includes, but is not limited to, web-based email, message boards, live chat facilities and email links; and
“User” / “Users” means any third party that accesses our Website and is not employed by us and acting in the course of their employment.
2. DATA COLLECTED
2.1. We may collect various Personal Data from you dependent on the purposes for which you engage with our Website. These may include, amongst others, your:
2.1.2. date of birth;
2.1.3. contact information such as email addresses and telephone numbers;
2.1.4. demographic information such as post code, preferences and interests;
2.1.5. financial information such as credit / debit card numbers;
2.1.6. IP address (automatically collected);
2.1.7. web browser type and version (automatically collected);
2.1.8. operating system (automatically collected);
2.1.9. a list of URLS starting with a referring site, your activity on our Website, and the site you exit to (automatically collected); and
2.1.10. Cookie information (see paragraph 10 below).
3. OUR USE OF DATA
3.1. Any or all of the above Personal Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Website. We will process your Personal Data where it is necessary to perform a contract we have with you, i.e. to provide the Services; because you have consented to our use of your personal data (e.g. by subscribing to emails); or, because it is in our legitimate interests. Where we are relying on the lawful basis of legitimate interests, our legitimate interests are to provide excellent customer service and to inform you of similar products and services to those which you have previously purchased or expressed an interest in. Specifically, Personal Data may be used by us for the following reasons:
3.1.1. managing Accounts and completing transactions;
3.1.2. engaging with our customers with marketing emails and social media;
3.1.3. sending service messages and handling any complaints, queries or customer communication;
3.1.4. internal record keeping;
3.1.5. improvement of our products / services;
3.1.6. transmission by email of promotional materials that may be of interest to you;
3.1.7. contact for market research purposes which may be done using email, telephone, fax or mail. Such information may be used to customise or update our Website; or
3.1.8. website and business analytics, which will be carried out on anonymised data in line with paragraph 8.2 below. Some of this analysis may be grouped by postcodes, which has the limited potential of constituting Personal Data.
4. THIRD PARTY WEBSITES AND SERVICES
5. CHANGES OF BUSINESS OWNERSHIP AND CONTROL
5.1. We may, from time to time, expand or reduce the business and this may involve the sale of certain divisions or the transfer of control of certain divisions to other parties. Personal Data provided by Users will, where it is relevant to any division so transferred, be transferred along with that division and the new owner or newly controlling party will, under the terms of this Policy, be permitted to use the Personal Data for the purposes for which it was supplied by you.
5.2. In the event that any Personal Data submitted by Users will be transferred in such a manner, you will be contacted and informed of the changes. When contacted you will be given the choice to have your Personal data deleted.
6. CONTROLLING YOUR PERSONAL DATA
6.1. Wherever you are required to submit Personal Data, you will be given options to restrict our use of that Personal Data. This may include the following:
6.1.1. use of Personal Data for direct marketing purposes; and
6.1.2. sharing Personal Data with third parties.
6.2. When you submit Personal Data via our Website, 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 Personal Data for direct marketing purposes. This includes the ability to opt-out of receiving emails from us either (i) by not giving your consent at the point of providing your details or (ii) by subsequently unsubscribing using the links provided in our emails.
6.3. A customer can unsubscribe from receiving marketing communications at any time, by clicking on the link to unsubscribe which is in all marketing emails.
7. DISCLOSURE OF YOUR PERSONAL DATA
7.1. Unless we are obliged or permitted by law to do so, and subject to paragraph 4 above, your Personal Data will not be disclosed to or shared with third parties for any purposes.
8.1. We will only keep your Personal Data for as long as we need to in order to use it as described above in paragraph 3 in line with the following periods:
8.1.1. Customer Account data - This data is deleted after a period of three years of inactivity on the Account. Inactivity means an order, or, communication activity, such as clicking on or opening an email, or making a query.
8.1.2. Subscriber data - Three years
8.2. In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
9. YOUR RIGHT TO WITHHOLD INFORMATION
9.1. You may access certain areas of our Website without providing any Personal Data at all. However, to use all Services available on our website you may be required to submit Account information or other Personal Data.
10. ACCESSING YOUR OWN DATA
10.1. You may access your Account at any time to view or amend the Personal Data. You may need to modify or update your Personal Data if your circumstances change. Additional Personal Data as to your marketing preferences may also be stored and you may change this at any time.
10.2. You have the right to ask for a copy of your Personal Data. Under the GDPR, no fee is payable and we will provide any and all information applicable in response to your request.
11. YOUR RIGHTS
11.1. You have the right to:
11.1.1. Request access to your personal data (commonly known as a "data subject access request") as in paragraph 10.
11.1.2. Request correction of any inaccurate personal data that we hold about you.
11.1.3. Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it.
11.1.4. Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
11.1.5. Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
11.1.6. Request the transfer of your personal data to you or to a third party in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
11.1.7. Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. (See paragraph 6.2. above for details of how to withdraw your consent to receiving marketing emails from us.)
11.1.8. You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
12.1. All Personal Data is stored securely in accordance with the principles of the GDPR.
12.2. Personal Data security is of great importance to us and to protect your Personal Data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure Personal Data collected online.
12.3. Some or all of your Personal Data may be stored outside of the European Economic Area (“the EEA”). (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). If we do store data outside the EEA, we will implement appropriate safeguards to ensure that your data is treated as safely and securely as it would be within the UK. Please contact us, using the details outlined below, if you want further information on the appropriate safeguard used by us when transferring your personal data out of the EEA.
13.2. Before our Website sets Cookies on your computer, you will be presented with a prompt requesting your consent to set those Cookies. You will be deemed to have given your consent if you continue to use Our Site without expressly withdrawing your consent. None of the Cookies set by our Website jeopardise your privacy in any way and no Personal Data is collected. By giving your consent to the setting of our Cookies you are enabling us to provide the best possible experience and service to you through our Website. If you wish to deny your consent to the placing of Cookies, certain features of our Website may not function fully or as intended.
13.3. You can choose to enable or disable Cookies in your web browser. By default, your browser will accept Cookies, however this can be altered. For further details please consult the help menu in your browser. Disabling Cookies may prevent you from using the full range of Services available on our Website.
13.4. You may delete Cookies at any time however you may lose any information that enables you to access our Website more quickly.
13.5. It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your browser if you are unsure as to how to adjust your privacy settings.
14. CHANGES TO THIS POLICY
14.1. We reserve the right to change this Policy as we may deem necessary from time to time or as may be required by law. Any changes will be posted on our Website.
15. CONTACTING US
15.1. If you have any questions about our Website or this Policy, please contact us by email at firstname.lastname@example.org. Please ensure that your query is clear, particularly if it is a request for information about the data we hold about you (as under paragraph 8 above).