1. The Policy
1.1. Who we are
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the supervisory authority for data protection issues in the UK (phone: 0303 123 1113 or at https://ico.org.uk/concerns), however, we would appreciate the chance to deal with your concerns before you approach the ICO, so please feel free to contact us in the first instance. We can be contacted by emailing email@example.com.
1.2. Changes to the Privacy Notice
It is important that the personal data that we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
1.3. Third Party Links
Our websites may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
2. Your Personal Data
2.1. Personal data
This means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may process different kinds of personal data about you, which we have categorised as follows:
- Identity Data: including your name, username (or similar unique identification numbers that we may apply to you), email address, title, date of birth and gender.
- Contact Data: including your address, email address and telephone number(s).
- Technical Data: including information we collect through your use of our websites, how often you visit and use our websites, technical information about the devices you use to access our websites (including your device’s unique identifying codes (e.g. its “MAC” address), relevant IP address, operating system and version, web browser and version, and geographic location).
- Profile Data: including your username and password, your interests, your preferences, your feedback, your survey responses, your social media content (where this is in the public domain including posts and comments, pictures and video footage) and profile information and insight from organisations that already hold information on you (such as credit reference agencies and ‘customer insight companies’ who give us their views on your household, your status, as well as your possible preferences and behaviours).
- Usage Data: including information about how you use our website, products and services.
- Marketing and Communications Data: including your preferences in receiving marketing from us and our third parties, your communication preferences and information on what you view, click on and access in and through our marketing emails, text messages and push notifications.
Through our websites, we do not collect any Special Categories of Personal Data about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, and information about your health and genetic and biometric data. We also do not knowingly process any data relating to children. See section 3.3 for further detail.
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with products or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.
2.2. If you don’t provide personal data
You don’t have to give us any of your personal data butif you don’t you are unlikely to receive our optimal customer service experience. Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you, i.e. any contracts for provision of services.
2.3 Keeping your data up to date
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
3. Sensitive Data
In certain situations we may have to collect Sensitive Data about you. Under data protection law this is known as “special category” data and includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, and information about your health and genetic and biometric data.
We only collect and process Sensitive Data where you provide such information to us in the following situations:
3.1. As part of any feedback and/or complaints which you raise with us, for example:
- Where you believe we have been discriminatory against you (i.e. discrimination based on race or sexual orientation).
When you provide details of what happened, this may include giving us Sensitive Data. We areallowed to process this Sensitive Data (together with any other relevant information), to investigate, address and resolve your issue and to administer any possible legal claims or out-of-court procedures.
3.2. Where you are applying for a job with us.
In this situation, we can process your Sensitive Data because it is necessary for carrying out our obligations and rights related to employment law and your working capacity. We do not routinely collect and process Sensitive Data in any other situations. If we do, we will obtain your explicit consent.
3.3. Children’s Data
We do not collect data about children
4. How we collect Personal Data
We use different methods to collect data from and about you including through:
4.1. Direct interactions
You may give us your Identity, Contact, Financial, Profile and Marketing and Communications Data by filling in forms or by corresponding with us by post, phone, email, social media or otherwise. This includes personal data you provide when you:
- purchase our products or services;
- create an account on our websites;
- subscribe to our mailing lists or newsletters;
- request marketing to be sent to you;
- take part in a competition, promotion or survey; or
- give us some feedback.
4.2. Social Media Interactions
Our website and services may allow you to interact with them by using your social media applications. This interaction may result in us collecting some of your social media content (including posts and comments, pictures and video footage), but only where this content is in the public domain and/or where this content has been sent by you to us in a private message via social media; and also your Technical, Profile and Marketing and Communications Data
4.3. Automated technologies or interactions
4.4. Third Parties or Publicly Available Sources
We may receive personal data about you from various third parties and public sources as set out below:
- Technical Data from analytics providers such as Google, advertising networks search information providers.
- Marketing and Communications Data and Technical Data from online advertising data providers such as Google based outside the EEA.
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
- Profile Data and Marketing and Communications Data from social media providers such as Facebook based inside and outside of the EEA.
- Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EEA,
5. How We Process Your Personal Data
We only process your personal data when allowed to do so by law. Most commonly, we will process your personal data:
- With your consent. Please remember, you have the right to withdraw your consent at any time by contacting us.
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
5.1. The below table sets out how we process your personal data. Please contact us if you would like further information about the specific basis for processing.
||Basis for Processing
|To register you as a new customer and manage your account: including to receive news, offers, promotions, to receive a voucher, to enter a prize draw or survey
||Identity Data, Contact Data, Profile Data, Marketing & Communications
||To perform our contract with you: we can’t process the activity if we don’t know who you are.
We have a legitimate interest to study how customers use our products and services, to develop them and grow our business
|To tailor our marketing to you including SMS, Push Notification and Email.
||Identity Data, Contact Data, Technical Data, Transaction Data, Usage Data, Profile Data, Marketing & Communications Data
||We have a legitimate interest – to make it easier for you to be informed and to tailor our marketing and business strategy to customer needs so we can offer you services related to what we have previously provided you.
And for new customers, with your consent when you sign up for the new information.
|To understand our customers, using various sources to build a profile of you; this may include:
understanding your habits, your location, your personal circumstances, and the things you may like or dislike.
The ways you interact with us, such as subscribing to news, offers, promotions and updates, completing surveys, browsing website pages, interacting – e.g. by likes and comments – with our social media accounts and reviewing our products and services in public forums
|Identity Data, Contact Data, Technical Data, Transaction Data, Usage Data, Profile Data, Marketing and Communications Data
||This is a legitimate business interest, being to develop our business, products, services, relevant campaigns and tracking the effectiveness of our tools and campaigns.
|To process and deliver a product or service that you have ordered from us, including any contractual arrangement that we agree to enter into with you
||Identity Data, Contact Data, Financial Data, Transaction Data
||To perform our contract with you.
|To send you service messages, such as when we need to tell you about an update our privacy notice
||Identity Data, Contact Data
||We’ve a legal obligation to provide you with updated privacy notice information.
|To provide customer service and support
||Transactional Data, Identity Data, Contact Data, Profile Data, Sensitive Data (where this is provided by you)
||To perform our contract with you. You expect (and we want to deliver) the best possible customer service.
5.2. Marketing Messages and Promotional Offers
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
You will receive marketing communications from us if you have said that we can send them to you when you provided us with your details.
You can tell us that you want to stop receiving marketing communications from us at any time. You can do this by clicking on the unsubscribe link in any email we send you or by contacting us directly by email to firstname.lastname@example.org, or by post.
We’ll process any such request as quickly as we can, but it might take a few days for all of our systems to be updated.
5.3. Change of Purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. We regularly review and, where necessary, update our privacy information – if we need to use your personal data for a new purposewe will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
6. Sharing Your Personal Data
We do not and will not, sell any of your personal data to any third party – including your name and contact details. We’re committed to protecting your privacy – we want to earn and maintain your trust, and we believe this is absolutely essential in order do that.
We cannot however, run our business or provide many of the services and benefits you expect to receive without involving other people and businesses. We only share your information in accordance with the laws applicable to us and for the purposes set out in the table in above.
6.1. We share your personal data with:
- All of our Group including new companies, brands or outlets we might acquire in the future (acting as controllers or processors) who are all based in the EEA and who provide IT, HR, system administration services and for whom you may have agreed can provide you with marketing communications.
- Service providers (mainly acting as processors, but sometimes as controllers) who help us provide our websites and related services to you; for example, information technology companies who design and host our websites and data insight specialists.
- Affiliated third parties (acting as processors and controllers) that provide services to us such as market research, marketing agencies, advertising partners, marketing insight services and data analytics services.
- Any new business partners (acting as controllers or processors) we may have over time; for example if we enter into a joint venture, reorganisation, business merger or sale of part of our business, the other party may receive some or all of your information.
- Our professional advisors (acting as controllers or processors); for example, our lawyers, insurers and insurance brokers, when they need it to provide advice to us or help us obtain insurance.
- The Police, the Health and Safety Executive, local authorities, Her Majesty’s Revenue and Customs (HMRC), the Courts and any other central or local government bodies (acting as controllers or processors) where we are required to do so to comply with our legal obligations, or where they request it and we may lawfully disclose it, for example for the prevention and detection of crime or to report serious health and safety incidents.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
7. Sending Your Data to Countries Outside of Europe
Sometimes we might need to transfer your personal data to third-party processors outside the European Economic Area (EEA) – for example, this might be required to provide support services. We will only do this if there are appropriate safeguards in place to make sure your personal data receives the same protection as when it is being processed inside the EEA.
8. Keeping Your Personal Data Secure
We take the security of your personal data very seriously and have in place appropriate security measures at all times, including where we share your information with our suppliers and partners, to protect your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
Please take care of your own information. For security tips and tricks when using the internet, Wi-Fi and smartphones or tablets, please visit www.getsafeonline.org.
9. How Long We Keep Your Personal Data For
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances, you can ask us to delete your data: see the section detailing your legal rights below for further information. 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.
We can only keep your personal data for as long as necessary for the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
We regularly review our retention periods to ensure that we are not keeping your data for longer than necessary. Details of retention periods for different aspects of your personal data are available by contacting us.
10. Your Legal Rights
You have lots of legal rights relating to your personal data. In certain circumstances, you may have the right to request access, transfer, rectification and/or erasure of the personal data that we process about you. You may also have the right to object to and/or restrict our processing of your personal data. Details of the rights are set out below.
- Human intervention: you may request human intervention where a decision has been made about you based solely on automated processing, and/or you may challenge that decision.
- Access: you may request access to your personal data, which enables you to receive a copy of the personal data that we hold about you and to check to see if we are processing it lawfully.
- Transfer: you may request that we transfer your personal data to you or a third party. We will provide to you, or a third party you have chosen, your personal data in a structured format. Please 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.
- Rectification: you may request rectification of the personal data 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.
- Delete: you may request deletion of the personal data that we hold about you. This enables you to ask us to delete or remove personal data 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 data 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 data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object: you may object to how we are processing 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.
- Restriction: you may request that we restrict how we process 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.
The ICO regulates most UK data and information laws. To learn more about your rights, visit the ICO website at https://ico.org.uk/.
10.1. What We May Need From You
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
10.2. Time to Respond
We try to respond to all legitimate requests within one month. 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.