Fair processing notice

Your personal data includes all the information we hold that identifies you or is about you, including but not limited to your name, email address, postal address, phone number, date of birth, and in some cases opinions that we document about you.

Everything we do with your personal data counts as processing it, including collecting, storing, amending, transferring and deleting it. We are therefore required to comply with the Data Protection Legislation to make sure that your information is properly protected and used appropriately.

This fair processing notice provides information about the personal data we process about you, why we process it and how we process it.

Our responsibilities

Why do we process your personal data?

We process your personal data in order to fulfil the contract we have entered into with you, to receive services or goods from you, and/or to provide the services you have requested from us. We may also process your personal data to respond to any queries or comments you submit to us, including via our website.

We may need personal data from you to be able to enter into a contract with you and provide you with all the information you need. If we do not receive that personal data from you, we may be unable to fulfil our obligations to you.

We process most of your information on the grounds of our legitimate interests (i.e.processing that is necessary to continue our relationship with you and to provide you with or receive from you (as applicable) services or products), fulfilment of our contract with you or to comply with a legal obligation.

If none of the grounds set out above applies, we will obtain separate consent from you to the processing of your personal data. You can withdraw your consent at any time. This won’t affect the lawfulness of any processing we carried out prior to you withdrawing your consent.

Who will receive your personal data?

We only transfer your personal data to the extent we need to. Recipients of your personal data include:

• third party delivery companies; and
• where relevant, third parties that carry out inspections of products you have purchased from us on our behalf.
• We may also transfer your personal data outside of the EEA to The Rocket Science Group LLC, trading as MailChimp, a provider of marketing and email platforms. MailChimp is located in the United States of America and is a registered member of the Privacy Shield scheme which guarantees appropriate safeguards are in place in respect of personal data we transfer to it.

How long will we keep your personal data?

If we send marketing communications to you we will continue to do so for a 10 year period unless you unsubscribe or opt out. We do so on the grounds that many customers require new products within a 10 year period and so we feel it is in our legitimate interests to continue sending you information. In respect of all other personal data we hold about you, we will retain the data for 8 years following our last contact with you as our customer, supplier or contact. We retain your information for this period in case any issues arise or in case you have any queries. Your information will be kept securely at all times. Following the end of the 8 period, your files and personal data we hold about you will be permanently deleted or destroyed. If we are required to obtain your consent to send you marketing communications, any information we use for this purpose will be kept until you withdraw your consent, unless we have other legitimate reasons to retain the data. We will retain your personal data on a suppression list to ensure we don’t send you any more marketing communications if you unsubscribe or opt out.

What are your rights?

You benefit from a number of rights in respect of the personal data we hold about you. We have summarised your rights below, and more information is available from the Information Commissioner’s Office website (https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/). These rights apply for the period in which we process your data.

1. Access to your data

You have the right to ask us to confirm that we process your personal data, as well as access to / copies of your personal data. You can also ask us to provide a range of information, although most of that information corresponds to the information set out in this fair processing notice.

We will provide the information free of charge unless your request is manifestly unfounded or excessive or repetitive, in which case we are entitled to charge a reasonable fee. We may also charge you if you request more than one copy of the same information.

We will provide the information you request as soon as possible and in any event within one month of receiving your request. If we need more information to comply with your request, we’ll let you know.

2. Rectification of your data

If you believe personal data we hold about you is inaccurate or incomplete, you can ask us to rectify that information. We will comply with your request within one month of receiving it, unless we don’t feel it’s appropriate in which case we’ll let you know why. We’ll also let you know if we need more time to comply with your request.

3. Right to be forgotten

In some circumstances, you have the right to ask us to delete personal data we hold about you. This right is available to you:

• where we no longer need your personal data for the purpose for which we collected it;
• where we have collected your personal data on the grounds of consent and you withdraw that consent;
• where you object to the processing and we don’t have any overriding legitimate interests to continuing processing the data;
• where we have unlawfully processed your personal data (i.e. we have failed to comply with GDPR); and
• where the personal data has to be deleted to comply with a legal obligation.

There are certain scenarios in which we are entitled to refuse to comply with a request. If any of those apply, we’ll let you know.

4. Right to restrict processing

In some circumstances you are entitled to ask us to suppress processing of your personal data. This means we will stop actively processing your personal data but we don’t have to delete it. This right is available to you

• if you believe the personal data we hold isn’t accurate – we’ll cease processing it until we can verify its accuracy;
• if you have objected to us processing the data – we’ll cease processing it until we have determined whether our legitimate interests override your objection;
• if the processing is unlawful; or
• if we no longer need the data but you would like us to keep it because you need it to establish, exercise or defend a legal claim.

5. Data portability

You have the right to ask us to provide your personal data in a structured, commonly used and machine-readable format so that you are able to transmit the personal data to another data controller. This right only applies to personal data you provide to us:

• where processing is based on your consent or for performance of a contract (i.e. the right does not apply if we process your personal data on the grounds of legitimate interests); and
• where we carry out the processing by automated means.

We’ll respond to your request as soon as possible and in any event within one month from the date we receive it. If we need more time, we’ll let you know.

6. Right to object

You are entitled to object to us processing your personal data:

• if the processing is based on legitimate interests or performance of a task in the public interest or exercise of official authority;
• for direct marketing purposes (including profiling); and/or
• for the purposes of scientific or historical research and statistics. We don’t use your personal data for these purposes.

In order to object, you must have grounds for doing so based on your particular situation. We will stop processing your data unless we can demonstrate that there are compelling legitimate grounds which override your interests, rights and freedoms or the processing is for the establishment, exercise or defence of legal claims.

Automated decision making

Automated decision making means making a decision solely by automated means without any human involvement. This would include, for example, an online credit reference check that makes a decision based on information you input without any human involvement. It would also include the use of an automated clocking-in system that automatically issues a warning if a person is late a certain number of times (without any input from HR, for example).

We don’t carry out any automated decision making using your personal data, although we may undertake re-marketing if you consent to our use of cookies when you use our website. Further information is set out in our privacy policy.

Your right to complain about our processing

If you think we have processed your personal data unlawfully or that we have not complied with GDPR, you can report your concerns to the supervisory authority in your jurisdiction. The supervisory authority in the UK is the Information Commissioner’s Office (“ICO”). You can call the ICO on 0303 123 1113 or get in touch via other means, as set out on the ICO website - https://ico.org.uk/concerns/.

Any questions?

If you have any questions or would like more information about the ways in which we process your data, please contact our Group Finance Director.