For the purposes of the Data Protection Act 2018 (‘DPA’) and the EU General Data Protection Regulation (‘GDPR’), (‘we’ or ‘us’) is the ‘data controller’, which means that we are responsible for, and control the processing of, your personal data).
Personal data we may collect about you
We will obtain personal data about you (such as your name, address, whenever you complete an online form by which you consent to us holding that personal data for the purpose specified on that form.
For example, we will obtain your personal data when you e. g. register to use this website, send us feedback, post material, contact us for any reason, sign up to a service, enter a competition, purchase goods or services.
How we use your personal data
We will use your personal data for the purposes described in the data protection notice that was given to you at the time your data was obtained. These purposes include:
to help us identify you and any accounts you hold with us
research, statistical analysis and behavioural analysis
customer profiling and analysing your purchasing preferences
marketing—see ‘Marketing and opting out’ below
fraud prevention and detection
billing and order fulfilment
credit scoring and credit checking—see ‘Credit checking’ below
customising this website and its content to your particular preferences to notify you of any changes to this website or to our services which may affect you
improving our services
Lawful Basis for the Processing of Your Personal Data
We will use the personal data that we hold for the purposes of:
performing any contractual or other obligations that we may have to you,
complying with our legal obligations, and
protecting our legitimate interests or those of others but only if it is necessary to do so and those interest are not overridden by your own interests or rights. You have the right to challenge those interests and to request that we stop processing your personal data on this basis. For further information see below.
We can process your personal data for those purposes without your knowledge or consent, but we will not use your personal data held on that basis for any other purpose without telling you that we will do so and our legal basis for processing it.
We may also process your personal data for any purpose to which you have expressly consented. You can withdraw that consent at any time. For further information see ‘Your rights’ below.
Where Your Personal Data Will be Processed
We will not hold or send your personal data outside the European Economic Area.
We will contact you by email, phone, SMS about our reason for contact eg products, services, promotions, other only if you have asked us to do so. If you have changed your mind and would prefer us not to contact you, then you can opt out at any time. For further information see ‘Your rights’ below.
Disclosure of your personal data
We may disclose your personal data to:
other companies within our group
our agents and service providers (e.g. providers of web hosting or maintenance services)
credit reference agents—see 'Credit checking' below
law enforcement agencies in connection with any investigation to help prevent unlawful activity
our business partners in accordance with the ‘Marketing’ section above
Keeping your data secure
We will use technical and organisational measures to safeguard your personal data, for example:
access to your account is controlled by password and username which are unique to you
we store your personal data on secure servers
Whilst we will use all reasonable efforts to safeguard your personal data, you acknowledge that the use of the internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal data which are transferred from you or to you via the internet.
We may monitor and record communications with you (such as telephone conversations and emails) for the purpose of quality assurance, training, fraud prevention and compliance
To enable us to make credit decisions about you and for fraud prevention and money laundering purposes, we may search the files of credit reference agencies who may record the search. We may disclose information about how you conduct your account to such agencies and your information may be linked to records relating to other people living at the same address with whom you are financially linked. Other credit grantors may use this information to make credit decisions about you and the people with whom you are financially associated, as well as for fraud prevention, debtor tracing and money laundering purposes.
Retention of Your Personal Data
We will not retain your personal data for longer than is reasonably necessary for the purpose for which it was obtained, and unless we have agreed otherwise with you we will at the end of the retention period securely destroy or delete it from our records.
Your Rights in Respect of Personal Data
You have the right to information about what personal data we process, how and on what basis as set out in this policy.
You have the right to access your own personal data by way of a subject access request. We will respond as soon as reasonably practicable and in any event within one month unless the request is complex or numerous in which case the period in which we must respond can be extended by up to a further two months. There is no fee for making a subject access request, but if your request is manifestly unfounded or excessive we may charge a reasonable administrative fee or refuse to respond to your request.
You can correct any inaccuracies in your personal data. To do so you should contact our Data Protection Officer.
You have the right to request that we erase your personal data if we are not legally entitled to process it without your consent or if it is no longer necessary to process it for the purpose for which it was collected. To do so you should contact our Data Protection Officer.
While you are requesting that your personal data is corrected or erased or are contesting the lawfulness of our processing, you can apply for its use to be restricted while that application is made. To do so you should contact our Data Protection Officer.
You have the right to object to data processing where we are relying on a legitimate interest to do so and you think that your rights and interests outweigh our own and you wish us to stop such data processing.
You have the right to object if we process your personal data for the purposes of direct marketing.
You have the right to transfer your personal data to another data controller. We will not charge for this and will in most cases aim to do this within one month.
With some exceptions, you have the right not to be subjected to automated decision-making.
You have the right to be notified of a data security breach concerning your personal data.
In most situations we will not rely on your consent as a lawful ground to process your data. If we do however request your consent to the processing of your personal data for a specific purpose, you have the right not to consent or to withdraw your consent later. To withdraw your consent, you should contact our Data Protection Officer.
You have the right to complain to the Information Commissioner. You can do this be contacting the Information Commissioner’s Office directly. Full contact details including a helpline number can be found on the Information Commissioner’s Office website (www.ico.org.uk). That website has further information on your rights and our obligations.
to recognise you whenever you visit this website
to obtain information about your preferences, online movements and use of the internet
to carry out research and statistical analysis to help improve our content, [products and services] and to help us better understand our [visitor/customer] requirements and interests
to target our marketing and advertising campaigns [and those of our partners] more effectively [by providing interest-based advertisements that are personalised to your interests].
to make your online experience more efficient and enjoyable.
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