2. Information we may collect from you
Personal data, or personal information, 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 collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
- Identity Data includes first name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Contact Data includes billing address, delivery address, email address and telephone numbers.
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
- Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our website, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offenses.
If you fail to provide personal data:
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 goods 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.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
a) apply for our products or services;
b) create an account on our website;
c) subscribe to our service or publications;
d) request marketing to be sent to you;
e) enter a competition, promotion or survey; or
f) give us some feedback.
Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our section on Cookies for further details.
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 the following parties:
a) analytics providers such as Google based outside the EU;
b) advertising networks; and
c) search information providers.
Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
Identity and Contact Data from data brokers or aggregators.
Identity and Contact Data from publicly availably sources.
Informing us of changes: 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.
Information about other people: If you give us information on behalf of someone else, you confirm that the other person has appointed you to act on his/her behalf and has agreed that you can give consent on his/her behalf to the processing of his or her personal data and receive on his/her behalf any data protection notices.
Monitoring: 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.
Credit checking: To enable us and other companies in our group to make credit decisions about you and for fraud prevention and money laundering purposes, we may search the files of credit reference and fraud prevention agencies (who will 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. If you provide false or inaccurate information and we suspect fraud, we will record this.
4. Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the basis we are relying on to process your personal data where more than one ground has been set out in the table below.
Type of data
Lawful basis for processing including basis of legitimate interest
To register you as a new customer
Performance of a contract with you
To process and deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
(c) Facilitating or offering financing options
To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey
(d) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to partake in a prize draw, competition or complete a survey
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you
Necessary for our legitimate interests (to develop our products/services and grow our business)
Information we receive from other sources: We may combine this information with information you give to us and information we collect about you. We may us this information and the combined information for the purposes set out above (depending on the types of information we receive).
5. Disclosure of your personal data
We may share your personal information with any member of our group, which means our affiliate companies and subsidiaries.
We may share your information with selected third parties including:
Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you; analytics and search engine providers that assist us in the improvement and optimization of our website or business operation; and credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a transaction or relationship with you.
We may disclose your personal information to third parties:
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.
A cookie is a small text file which is placed onto your computer (or other electronic device) when you access our website.
Cookies are small files saved to your computer's hard drive that track, save and store information about your interactions and usage of the Site. This allows the Site, through its server to provide the users with a tailored experience.
We work with third-party suppliers who may also set cookies on our Site, for example Twitter, Facebook and LinkedIn. These third-party suppliers are responsible for the cookies they set on our Site. If you want further information please go to the website for the relevant third party.
How to turn off cookies
If you do not want to accept cookies, you can change your browser settings so that cookies are not accepted. If you do this, please be aware that you may lose some of the functionality of this website. For further information about cookies and how to disable them please go to: www.aboutcookies.org or www.allaboutcookies.org
Also you can refer to these detailed instructions specific to your browser application used:
Internet Explorer - http://windows.microsoft.com/en-us/internet-explorer/delete-manage-cookies#ie=ie-11
Opera - http://www.opera.com/help/tutorials/security/privacy/
Safari - http://support.apple.com/kb/ph11913
7. International Transfers: RESERVED.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. However, the transmission of information via the internet is not completely secure. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
9. Data Retention
We will only keep your data for as long as is reasonable. We are working on a data retention policy.
By law we keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax reasons, insurance compliance, and other purposes.
In some circumstances you can ask us to delete your data: see Right to be forgotten below for further information.
In some circumstances we may anonymize 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.
10. Third Party Links
Our website(s) may, from time to time, contain links to and from the websites of our 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. Please check these policies before you submit any personal data to these websites.
11. Your rights
You have the right to:
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction 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.
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. 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 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.
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.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data 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 data. 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.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure to consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Under the California Consumer Privacy Act, you have the following four basic rights
The right to know what personal information is collected, used, shared or sold, both as to the categories and specific pieces of personal information;(Cal. Civ. Code § 1798.100, § 1798.110, § 1798.115).
The right to delete personal information held by businesses and by extension, a business's service provider; (Cal. Civ. Code § 1798.105)
The right to opt-out of sale of personal information. Consumers are able to direct a business that sells personal information to stop selling that information. (Cal. Civ. Code § 1798.120, § 1798.135) Children under the age of 16 must provide opt in consent, with a parent or guardian consenting for children under 13. (Cal. Civ. Code § 1798.120)
The right to non-discrimination in terms of price or service when a consumer exercises a privacy right under CCPA. (Cal. Civ. Code § 1798.125)
Right to notice at collection regarding the categories of personal information collected. (Cal. Civ. Code § 1798.140)
Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, social security number, driver's license number, passport number, or other similar identifiers.
Personal information means any information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. "Personal information" does not include publicly available information that is lawfully made available to the general public from federal, state, or local government records.
Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer's interaction with an internet website, application, or advertisement.
Geolocation data. We collect your IP address automatically when you visit our website or initiate your order. We may determine your general location based on your IP address.
Audio, electronic, visual, or similar information. When you contact us via phone, we may record your call. We will notify you at the beginning of the call that the call may be recorded for training purposes. We use this information to monitor our customer service and train employees.
Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. We analyze your preferences through a series of computer processes. Based on this information, we use to gauge and develop marketing activities, applications or tools, and to provide you with targeted information and offers.
Opting out of Disclosing, Sharing, and Selling Personal Information
You have the right to opt out of us disclosing, sharing, or selling personal information for commercial purposes. To exercise the right to opt-out of the sale of your information, you may submit a request by mail at:
Attn: OPT-OUT, Privacy Department
145 West 7200 South, Suite A
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