- Personal contact details such as name, title, addresses, telephone numbers and personal email addresses.
- Information you provide when you register to use our website, subscribe to our service, search for a product, place an order on our website, participate in discussion boards or other social media functions on or via our website and when you report a problem with our website.
- Demographic information such as your postcode
- Information relevant to customer promotions, competitions and/or surveys on our website or via our social media channels
- Marital status and dependants
- Bank account or debit/credit card details
- Details of transactions you carry out through our website or by other means, the fulfilment of your instructions and any subsequent communications with you about any of these.
- Details of your visits to our website including, but not limited to, Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting and location data, browser plug-in types and versions, operating system and platform, information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page, whether this is required for our own administrative purposes or otherwise.
- We may record telephone conversations for training and security purposes. You will be notified if recording is taking place at the commencement of any call.
- Closed circuit television recordings within our premises for safety and security purposes.
- when you provide information in relation to the purchase of goods, or in relation to services we might provide to you, either in store or online;
- when you submit an enquiry about our goods or services;
- when you sign up to our mailing list; and
- when you provide personal information directly to members of our team.
- We may receive information about you if you use any of the other websites we operate, or the websites of our affiliates, or other services that we provide.
- We are also working closely with third parties (including, for example, business partners, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.
- To provide you with information, products or services that you request from us (contact details).
- To carry out our obligations arising from any contracts entered into between you and us, including any delivery obligations (contact details, payment information and any information relating to personalisation status).
- To ensure that content from our website is presented in the most effective manner for you and for your device (online identifiers, location data and other technical information).
- To provide you with information, products or services that we feel may interest you, (where you have consented to be contacted for such purposes to the extent consent is required by law) (contact details and any information relating to personalisation preferences).
- To allow you to participate in interactive features of our service, when you choose to do so (online identifiers, location data and other technical information).
- To notify you about changes to our service (contact details).
- To maintain a basic amount of information about you and your transaction history, in order to provide you with a service tailored to your preferences, including any appropriate advertising (contact details, payment history and any information relating to personalisation status).
- To retain basic transaction details for the purpose of tax reporting (contact details and transaction history).
- To use non-essential cookies on our website (see “Cookies” section below for further information) (online identifiers, location data and other technical information). You have the right to withdraw consent to such use at any time by contacting us but please note that some or all parts of our website may no longer be accessible to you.
- To send you direct marketing communications via email, text message, post or telephone call (contact details). You have the right to withdraw consent to any such use at any time by contacting us.
- sending promotional emails about new products, special offers, customer events or other information which we think you may find useful or interesting using the email address which you have provided;
- contacting you for market research purposes (by email, text message, post or telephone call).
- is specific consent for one or more specified purposes; and
- is given by a clear affirmative act establishing a freely given, specific, informed and unambiguous indication of your agreement to the relevant processing of personal information.
- the country to which the personal information is transferred ensures an adequate level of protection for that individual’s rights and freedoms;
- an individual has given their explicit and informed consent having had the risks explained to them;
- the transfer is covered by one of the derogations set out in the GDPR, including the performance of a contract between us and that individual, or to protect the vital interests of individuals;
- the transfer is legally required on important public interest grounds or for the establishment, exercise or defence of legal claims; or
- the transfer is authorised by the relevant data protection authority where we have checked adequate safeguards exist with respect to the protection of the individual’s privacy, their fundamental rights and freedoms and the exercise of their rights.
- We may transfer your personal information to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
- Where we use service providers, we may use specific contracts approved by the European Commission which give personal information the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
- Where we use service providers based in the US, we may transfer data to them if they are part of the Privacy Shield, which requires them to provide similar protection to personal information shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
We also use Paypal as a payment option on our website. We do not provide any personal information to Paypal, if a client choses this payment option they can make payment via their own account, in which case personal information is provided directly to Paypal.
11. DATA SECURITY
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your data transmitted to our website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
We have put in place internal procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
When you order from us all payments are processed by WorldPay/Sage Pay, Paypal, Amazon Pay, Apple Pay or Shopify Stripe Payments Europe. All payment providers use secure server software that guarantees to protect your information whenever you place an order with us or access your account details. This software encrypts your information on a secure socket layer (“SSL”) and protects the confidentiality and integrity of your information from unauthorised access and disclosure. Our payment providers ensure transaction data is kept secure at all times and no cardholder information is ever passed unencrypted.
The CVV (Card Verification Value code) is the security code number on the back of your credit/debit card, above your signature (the last 3 digits) or the 4 digit code on the front of your American Express card above the long account number. The CVV code may be referred to as CSC, CV2, CVC or CID but the function is the same for all major card types. We do not store your CVV number, but use it to perform a security check.
12. DATA RETENTION
We will not keep personal information in a form which permits identification of individuals for longer than is necessary for the purpose or purposes for which they were collected. We will take all reasonable steps to destroy, or erase from our systems, all data which is no longer required (or, where we are processing on behalf of another data controller, return their information to them). We will comply with our data retention policy which is available here. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of personal information, the purposes for which we process information and whether we can achieve those purposes through other means, and the applicable legal requirements.
We will only keep personal information for as long as is necessary for the purpose or purposes for which that personal information is processed; and we will let anyone about whom we process data know how long that is or the criteria that go into deciding how long that is.
We may sometimes anonymise your personal information (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.
Our website may, from time to time, contain links to and from the websites of partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies or the security of these websites. Please check the relevant policy before you submit any personal information to these websites.
13. YOUR RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal information, as summarised below.
You have the right to:
- Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal information to comply with local law. Note, however, that we may not always be able to comply with your request for erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal information where we are relying on a legitimate interest (of our own or 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 information 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.
- Request restriction of processing of your personal information. This enables you to ask us to suspend the processing of your personal information 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.
- Request the transfer of your personal information to you or to a third party. We will provide to you, or a third party you have chosen, your personal information 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.
- Withdraw consent at any time where we are relying on consent to process your personal information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us at firstname.lastname@example.org. We aim to respond to all legitimate requests within one month (and if we are only processing the data in question on behalf of another party, the response may actually come from that other party as the relevant data controller). Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive - alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask for further information in relation to your request to speed up our response.
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer or device if you agree. Cookies contain information that is transferred to your computer or device. We use the following cookies:
- Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website.
- Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
- Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you and remember your preferences (for example, your choice of language or region).
- Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and any advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
You can find more information about the individual cookies we use and the purposes for which we use them in the table below:
Parts of our website may display video or animation content using Adobe Flash Player. Adobe uses Flash cookies (also known as Local Shared Objects) to help improve your experience as a user; flash cookies are similar to usual cookies but they are managed differently by your browser. If you wish to disable or delete a Flash cookie, see Adobe Flashplayer Security Settings. Please bear in mind that if you disable Flash cookies you'll be unable to access certain types of content on our website, such as videos or animations.
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you block cookies you may not be able to access all or parts of our website.
Except for essential cookies, all cookies will expire between 90 days and 2 years from date of download.
15. CHANGES TO THIS POLICY
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.
You have the right to make a complaint at any time to the Information Commissioner's Office, 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 Information Commissioner's Office, so please contact us in the first instance.