The Clinkard Group Limited ("we", "us" or "our") are committed to protecting and respecting your privacy.
This policy explains the way we use your personal data and sets out specifically:
2. How and why we use your personal data.
3. Our legal basis for using your personal data.
4. Obligations on you to provide us with personal data.
5. When your personal data will be shared.
6. Where we use your personal data.
7. How long we store your personal data for.
8. Your rights in relation to our use of your personal data.
9. Changes to this policy.
10. How to make a complaint.
11. How to contact us contact.
Please read this policy carefully to understand our practices regarding your personal data and how we will treat it.
We will use the following personal data about you:
· Information you give us. You will give us information about you by [filling in forms on our site or by corresponding with us by phone, e-mail or otherwise.] This includes information you provide when you [register to use our site, subscribe to our service, search for a product, place an order on our site, participate in discussion boards or other social media functions on our site, enter a competition, promotion or survey and when you report a problem with our site]. The information you give us will include, but is not limited to, [your name, address, e-mail address and phone number, financial and credit card information, personal description and photograph].
· Information we collect about you. With regard to each of your visits to our site we will collect the following information:
· technical information, including the [IP address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform]; and
· information about your visit, including [when and how you accessed 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 and any phone number used to call our customer service number].
· Information we receive from other sources. We will receive information about you if you use any of the other websites we operate, the other services we provide and/or any of our social media pages. We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and will receive information about you from them.
2. How and why we use your personal data
We use personal data held about you in the following ways and for the following purposes:
· Contractual and sales purposes
- we need to use your personal data for administrative purposes, in respect of our relationship with you as a customer or supplier;
- we need to use your personal data to enable us to carry out our obligations arising from any contracts entered into between you and us; and
- we need to use your personal data to notify you about changes to our service.
· Marketing purposes
- we need to use your personal data for direct marketing purposes, so that we can communicate to you information about goods and services, that we or selected third parties offer, that are similar to those you have already purchased or enquired about or which we feel may interest you;
- we need to use your personal data so that we can measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
· Website purposes
- we need to use your personal data to personalise your experience of our site as a user, so that the content from our site is presented in the most effective manner for you and for your computer and so that you can participate in interactive features of our site when you choose to do so;
- we need to use your personal data to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes; and
- we need to use your personal data to facilitate our efforts to keep our site safe and secure.
3. Our legal basis for using your personal data
So that we can process your personal data for the purposes set out above, we rely on the following legal bases:
The legal basis we rely on to use your personal data is that it is necessary for the purpose of our legitimate interests. Our legitimate interest for using your personal data is so that we are able to:
· fulfil our obligations to you as a customer or supplier;
· provide you with information about goods and services that we, or selected third parties, feel may interest you;
· provide you with a personalised and functional experience both online and offline; and
· operate our administration services effectively.
Our legitimate interest is therefore our commercial interest. However, our legitimate interest is also in your interest as our use of your personal data allows us to provide a more effective and efficient service to our customers and suppliers. We use your personal data in a way that has a minimal impact on your rights and only in ways that you would reasonably expect considering the nature of our goods and services.
We also use your personal data where it is necessary for the performance of a contract between us and you as a customer or supplier. This is a separate legal basis which applies when you buy something from us or where we buy something from you.
We may in some circumstances ask for your consent to use your personal data. If we do so, we will make it clear that we are asking for your consent, as this is the legal basis we intend to rely on for using your personal data in that instance.
We will ensure that you know why we are asking for your consent and how we will use your personal data so that you can make an informed decision as to whether to consent to us processing your personal data.
We will only ask for your consent where absolutely necessary. If you do not provide us with your consent when we request it, we will not use your personal data for the purpose to which the requested consent relates, and we will not rely on any other legal basis to do so.
For example, if we ask for your consent so that we can communicate marketing materials to you, and you do not provide us with your consent, or if you later withdraw your consent, we will not rely on our legitimate interest to use your personal data in this way.
When we ask for your consent, we will do so by:
· asking you to tick a tick-box on our website or a form in one of our retail stores;
· verbally over the telephone;
When you provide us with your consent, we will keep a record of this.
However, should you wish to withdraw your consent, you have the right to do this at any time and you should do this by [accessing the preferences section of your online account or by contacting our customer services department on 0345 241 7742.
You must be over the age of 16 to provide us with your consent. If you are 16 or under, your parental guardian must authorise your consent first and complete our online and offline forms do show this where necessary.
4. Obligations on you to provide us with your personal data
There is no statutory obligation on you to provide us with your personal data. However, you may be required to provide your personal data when entering into a contract with us. Without this personal data, we may not be able to carry out our obligations arising from any contracts entered into between you and us
5. When your personal data will be shared
We may share your personal data with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries. These are companies that are legally connected to us, because of the way in which they are owned.
We may share your personal data with selected third parties including:
· business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
· advertisers and advertising networks that require the personal data to select and serve relevant adverts to you and others;
· analytics and search engine providers that assist us in the improvement and optimisation of our site; and
· credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you.
We may disclose your personal data to third parties:
· in the event that we sell or buy any business or assets, in which case we may provide your personal data to the prospective seller or buyer of such business or assets;
· if The Clinkard Group Limited or substantially all of its property are bought by a third party, in which case personal data held by it about its customers will be one of the transferred property; and
· if we are under a duty to provide or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our or and other agreements; or to protect our rights, property, or safety, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
6. Where we use your personal data
The personal data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (EEA). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers.
Such staff may be engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services.
7. How long we will store your personal data
We will continue to store your personal data in circumstances where the criteria set out below is satisfied. We will review this annually to help ensure that your personal data is not stored for longer than necessary.
Your personal data will be held with us for as long as you are actively purchasing with us as your contact details will be used in order to ensure we can fulfil your order and communicate order updates to you.
Should you wish to no longer purchase with us we will anonymise and/or delete your data after 18 months of inactivity on your account.
8. Your rights
You have a number of legal rights in relation to your personal data. If you wish to exercise any of your rights in relation to the way we use your personal data, or require any further information, please contact us using the contact information set out below.
We will aim to respond to your request to exercise any of your rights as set out below and contact you directly within one month from the date of your request. If we are unable to deal with your request within this time, we will contact you directly with the reasons for the delay, and details of an extension to our one month response time.
We will only refuse a request made by you to exercise one of your rights if:
· we are required to do so by law;
· we cannot verify your identity;
· you already have the information that you have requested from us; or
· we consider your request to be excessive.
Where we consider your request to be excessive, we reserve the right to charge a reasonable fee based on administrative costs.
Right of access. You have the right to ask us whether we use personal data relating to you. If we do hold any of your personal data, you have a right to a copy of this free of charge. If you require any further copies of the same personal data, we reserve the right to charge a reasonable fee based on administrative costs.
If you require the personal data we hold about you, please make your request in writing addressed to the contact details set out below and include in your request whether you have a preference of receiving a physical or digital copy. Please specify the information that you require in as much detail as you can, so that we can deal with your request as efficiently as possible.
Right to object. You have the right to object to the way we use your personal data, in certain circumstances, for the reason that you object to the legal basis we rely on to use your data. If you object to our use of your personal data, please contact us using the contact information set out below so that we can consider your request. As part of your request, please include details of the types of information you object to us using, and why you object to the way in which we use it.
Right to object to profiling. You have a right to object to us making a decision on the basis of your personal data by using computer programmes that make decisions automatically, where such a decision would significantly affect you. We do not use your personal data in this way.
Right to object to direct marketing. You have a further right to object to our use of your personal data for direct marketing purposes. If you object to our use of your personal data for direct marketing, please contact us using the contact information set out below so that we can process your request. As part of your request, please include details of the types of information you object to use using, and why.
Right of correction. You have the right to ensure that the personal data we hold about you is accurate and up to date. If you believe your personal data may no longer be accurate or up to data, please contact us using the contact information set out below so that we can consider your request. Until we can verify that your personal data is correct, we will stop using it from the time of your request. As part of your request, please include details of the types of information you would like us correct, and why.
Right to be forgotten. You have the right to have the personal data we hold about you deleted in certain circumstances. Should you wish to have your personal data erased, please contact us using the contact information set out below so that we can consider your request. As part of your request, please include details on the types of information you would like us to delete, and why.
Right to restrict. You have the right to restrict the way in which we use your personal data in certain circumstances. This means that we would only be able to use your personal data for carrying out certain actions. If you wish to only have your personal data used in a certain way, please contact us using the contact information set out below so that we can consider your request. As part of your request, please include details of the types of information you would like use only in certain ways and why.
Right to portability. You have the right to have us transfer your personal data, where it is technically feasible, directly to another organisation who you wish to deal with your personal data. This is so that you do not have to input your personal data on numerous occasions. You also have the right to receive your personal data in a commonly used, electronic format so that you can transfer your personal data to another organisation indirectly.
If you wish to make a portability request, please contact us using the contact information set out below so that we can consider your request. As part of your request, please include details of the types of information you would like us to transfer, who you would like your personal data transferring to, why you would like your personal data transferring and whether you would like us to transfer your personal data to the elected organisation directly, or to you, so that you can do this indirectly.
Please note that your exercise of this right would not require us to delete your personal data, and that we will respond to your requests for free unless we consider your request to be excessive.
9. Changes to this policy
10. How to make a complaint
Should you have any complaint about the way we use your personal data, please contact us using the contact information set out below.
Upon receiving your complaint, our data protection officer orinformation security manager will deal with this in accordance with our internal procedures relating to privacy. If you wish to make a complaint, please set this out separately to any request you may also be making in respect of rights relating to your personal data.
Should you feel that we have not dealt with your complaint to the standards which you expect, you have right to make a complaint to the Information Commissioner’s Office (ICO), the government’s supervisory authority for matters relating to data protection. The ICO can be contacted on their helpline: 0303 123 1113. For further information on the ICO, please visit https://ico.org.uk.
11. How to contact us
As we process a large volume of personal data on a regular basis, we have appointed Julie Monaghan as our Data Protection Officer and Graeme Boulton as our Information Security Manager. Both individuals are your point of contact for any questions, comments or requests regarding this policy.
For the purposes of data protection law, we are a data controller in respect of your personal data. Should you have any queries about your personal data or any questions about this policy, please contact us by using the following details:
Julie Monaghan – Data Protection Officer – email@example.com
Graeme Boulton – Information Security Manager – firstname.lastname@example.org
The Clinkard Group
Cannon Park Way
Telephone: 01642 606162