1. INTRODUCTION
2. YOUR PERSONAL DATA
2.6 Please note that it is important that the personal data We hold about You is accurate and current. Please keep Us informed if Your personal details change during Your relationship with Us.
2.7 Please note that Our Website is not intended for use by children under the age of 18 years of age, and We do not knowingly collect or use personal information relating to children.
3. THE PURPOSES FOR WHICH YOUR INFORMATION IS USED
Data protection law requires that We only use Your personal data for the purposes for which it was acquired, or where We have a proper reason for using it. Those reasons may include the following:
3.2 The reasons set out above represent the general position as to the purposes for which data may be used. The specific position in relation to Your personal data, however, is that We may use it for the following purposes: You may also opt to rather present it in a table (see Schedule A)]
3.2.1 In order to supply goods and/or services to You through or via Our Website. This processing relies on the performance of a contract between Us and the steps needed to deliver those contractual services.
3.2.2 To prevent or detect fraud, either against You or against any other person involved in any matter in which You are involved. This will help to prevent any damage either to You, a third party, or to Us. This processing relies on factors related to Our legitimate interests in processing the data.
3.2.3 To preserve the confidentiality of commercially sensitive information, and for Our legitimate interests or those of a third party in relation to the protection of Our, or another’s, intellectual property and other commercially-valuable information. This processing relies on Your consent where this has been given, or on factors related to Our legitimate interests in processing the data (in that We are seeking to monitor and improve Our Website and/or the services/products We provide).
3.2.4 In connection with credit control and credit reference checks in relation to the services We perform or the products We supply. This processing relies on Your consent where this has been given, on factors related to Our legitimate interests in processing the data (in that We are seeking to provide services as part of Our business, or the performance of a contract between Us, and the steps needed to deliver those contractual services).
3.2.5 To analyse the use made of Our Website. Here We may make use of Your IP address, where You are based, the type and version of the browser You use, details of Your operating system, how You came to Our Website (for example whether You were referred from another Website or from a search engine), how long You remained on Our Website, the number of pages on Our Website that You viewed, how You moved around Our Website, the links that You followed, and whether any of those links were used to leave Our Website. This processing relies on Your consent where this has been given, or on factors related to Our legitimate interests in processing the data (in that We are seeking to monitor and improve Our Website and/or the services/products We provide).
3.2.6 To improve the operation of Our Website and provide those services which You have requested Us to provide. This may include taking such security measures as are appropriate, backing up the data We hold, and contacting You. This processing relies on Your consent where this has been given, or on factors related to Our legitimate interests in processing the data (in that We are seeking to provide services as part of Our business, or the performance of a contract between Us, and the steps needed to deliver those contractual services).
3.2.7 In relation to information which You wish to include in, or post on, Our Website (for example by submitting a review of Our services/products, supplying a blog post or the publishing of other information). This processing relies on Your consent where this has been given, or on factors related to Our legitimate interests in processing the data (in that We are seeking to provide services as part of Our business, or the performance of a contract between Us, and the steps needed to deliver those contractual services).
3.2.8 For dealing with an enquiry submitted by You to Us in connection with Our goods and/or services, or in relation to the supply of newsletters, email notifications, product data or general updates. This processing relies on Your consent where this has been given, or on factors related to Our legitimate interests in processing the data (in that We are seeking to provide services as part of Our business, or the performance of a contract between Us, and the steps needed to deliver those contractual services).
3.2.9 Where it is necessary for Us to do so in order to establish, exercise or defend a legal claim, whether in court proceedings or in an administrative or out-of-court procedure. This processing relies on factors related to Our legitimate interests in processing the data.
3.2.10 In connection with the compliance by Us with a legal obligation that We are subject to, or in order to protect Your, or Our, vital interests, or the vital interests of another natural person.
3.3 The purposes set out above will not apply to what is termed ‘special category personal information’. This includes personal information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs, or trade union membership, genetic and biometric data, and data concerning health, sex life or sexual orientation. We will only ever process information of that nature with Your explicit consent.
4. CONTACTING YOU
4.1 In addition to the general matters dealt with in paragraph 3.2 above, We may also need to send You updates concerning Our services, and about relevant developments in relation to You, Our services, or other related matters which might concern You, or be of interest to You. This may be by post, telephone, email or text, and may include information about the services We offer and information relating to changes in those services.
4.2 We regard ourselves as having a legitimate interest in processing Your personal data for these purposes, and We take the view that We do not require Your consent in order to do so. From time to time We undertake what are known as ‘legitimate interest assessments’ in order to balance Our interests in contacting You with Your interests in relation to Your data. Where We believe that consent is required, We will contact You specifically for this, and will do so in a clear and transparent manner.
4.3 Where You have agreed to Us doing so, We may also send You information about third party services in which You have expressed an interest, or which are relevant to any services that We have supplied.
4.4 Be assured that We treat Your personal data with the utmost respect and will never share it with others for marketing or promotional purposes. You have, at all times, the right to request that We do not contact You for any purpose other than providing Our services. We may, however, require that You confirm Your marketing preferences from time to time so that We can be sure that Your views remain the same, especially in relation to issues such as legal and regulatory updates.
5. SHARING YOUR DATA WITH OTHERS
6. HOW YOUR PERSONAL DATA IS KEPT
7. TRANSFERRING YOUR DATA OUTSIDE THE UK
8. YOUR RIGHTS IN RELATION TO YOUR DATA
9. ABOUT COOKIES
Strictly necessary cookies: These cookies are essential to enable you to use the website effectively, such as when buying a product and / or service, and therefore cannot be turned off. Without these cookies, the services available to you on our website cannot be provided. These cookies do not gather information about you that could be used for marketing or remembering where you have been on the internet.
– Performance cookies: These cookies enable us to monitor and improve the performance of our website. For example, they allow us to count visits, identify traffic sources and see which parts of the site are most popular.
– Functionality cookies: These cookies allow our website to remember choices you make and provide enhanced features. For instance, we may be able to provide you with news or updates relevant to the services you use. They may also be used to provide services you have requested such as viewing a video or commenting on a blog. The information these cookies collect is usually anonymised.
However, You should be aware that if You block or delete cookies this may have a detrimental impact on Your ability to access Our Website, and the services that We provide. It may mean that not all of the facilities on Our Website will be accessible by You. We regret that We cannot, for technical reasons, supply services unless Your browser is set to accept cookies.
10. KEEPING YOUR DATA SECURE
11. MAKING A COMPLAINT
Despite Our best efforts, inevitably sometimes things do go wrong. If You are unhappy with any aspect of the use and/or protection of Your personal data, You have the right to make a complaint to the Information Commissioner’s Office, who may be contacted in writing at Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF; by telephone on 0303 123 1113; by fax on 01625 524510; or online at www.ico.org.uk.
12. THIS POLICY
The terms and provisions of this privacy policy may be changed, updated and amended from time to time. If We do so during the time when We are providing You with services We will inform You of those changes
Schedule A
CATEGORY OF PERSONAL DATA
| PURPOSE OF PROCESSING
| LAWFUL BASIS FOR PROCESSING
| RETENTION PERIOD
|
Name and contact details | Fraud prevention and detection | Compliance with legal obligation | 3 Years from last log-on to the Website |
Date of birth | For fraud prevention and detection
To ensure legal sale of age-restricted products | Compliance with legal obligation Legitimate interests in ensuring your safety | 3 Years from last log-on to the Website |
Information collected through cookies and similar technologies | To conduct and store Website usage analytics, statistical and trend analysis and market research To generate customer profiles to facilitate marketing initiatives | Consent | 3 Years from last log-on to the Website |
Contact history | To provide customer service and support To train our staff | Performance of contract Legitimate interests in dealing with complaints or claims | 6 Years from last log-on to the Website |
Browser, device and Website usage information | To improve the Website To protect the Website against fraud To set default options for you, such as language and currency | Performance of contract Legitimate interest in maintaining our Website | 6 Years from last log-on to the Website |
CATEGORY OF PERSONAL DATA
| PURPOSE OF PROCESSING
| LAWFUL BASIS FOR PROCESSING
| RETENTION PERIOD
|
Information from linked accounts | To enable you to log into the Website simply without having to create a specific account | Legitimate interest in providing high quality customer service | 3 Years from last log-on to the Website |
Responses to surveys, competitions and promotions | To run the survey, competition or promotion | Performance of contract Legitimate interest in administering and/or improving our products and services generally | 3 Years from last log-on to the Website |
Customer comments and product reviews | To improve our products and services Where relevant, to establish, exercise or defend legal claims | Performance of contract Legitimate interest in dealing with complaints or claims and improving our products and/or services generally | 3 Years from last log-on to the Website |