4.2 COMMUNICATIONS PREFERENCES
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established a preference centre where you can view and make certain decisions about your personal data use. You can decide how you would like us to communicate with you, how often and what information you would like to hear from us about.
4.3 PROMOTIONAL OFFERS FROM US
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.
You will receive marketing communications from us if you have requested information from us or purchased goods from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
4.4 THIRD-PARTY MARKETING
We do not sell, rent or otherwise disclose your personal information to third parties for their marketing purposes. We will get your express opt-in consent before we share your personal data with any company outside the Tabitha James Kraan group of companies for marketing purposes.
4.5 OPTING OUT
If you do not wish to receive marketing communications from us, you can unsubscribe at any time via the link in an e-mail you received, or by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by contacting us at firstname.lastname@example.org at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product purchase, warranty registration, product experience or other transactions.
4.7 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. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we 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.
5. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the:
- External Third Parties as set out in the Glossary.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
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.
6. WHERE YOUR PERSONAL DATA MAY BE PROCESSED
Sometimes we need to share your personal data with third parties outside the European Economic Area (EEA). The EEA consists of all EU Member States as well as Norway, Iceland and Liechtenstein.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
7. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, u sed or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know.They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
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.
If you have any questions about security of our website, please contact us at email@example.com.
8. DATA RETENTION
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. At the end of that retention period, your data will be either deleted or completely anonymised (as discussed further below).
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.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see section 9, “Request erasure” 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.
9. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
Please see the Glossary (“Your Legal Rights”) and our data subject access request policy for more about these rights:
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us at firstname.lastname@example.org.
9.1 NO FEE USUALLY REQUIRED
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
9.2 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.
9.3 TIME LIMIT 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.
10.1 LAWFUL BASIS
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 we 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).
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.
Consent means that the data subject’s clear and unambiguous consent; this must be requested in an intelligible and easily accessible form, using clear and plain language and where it is required in writing, it is clearly distinguishable from any other matters which may also be referred to. Consent can be withdrawn by the data subject at any time.
10.2 THIRD PARTIES
EXTERNAL THIRD PARTIES
Service providers acting as processors who:
◦ Help us with our IT and our systems administration services (including hosting).
◦ Operational companies, who help us with our order fulfilment such as delivery partners and courier companies. Please note that we supply our products directly to customers in the jurisdictions listed on our website (the list of which is updated from time to time), some of which are outside the EEA. Where your order is required to be delivered to you outside of the EEA, we will share your data with third parties in order to deliver your product to you.
◦ Direct marketing companies, who help us manage our electronic communications to you and companies that carry out data analysis and survey/research work.
◦ Google and Facebook to show you products that might interest you whilst you’re browsing the internet. This is based on either your marketing consent or your acceptance of cookies. See our Cookies Notice for further information.
Please contact us at email@example.com. if you would like an up to date list of all our data processors.
◦ Professional advisers (acting as processors where access to personal data is necessary) including lawyers, bankers, auditors and insurers based in the jurisdictions in which we operate who provide consultancy, banking, legal, insurance and accounting services. We take advice in relation to supplying our products to consumers and other corporate customers in all countries in which we operate.
◦ HM Revenue & Customs, regulators and other authorities (acting as processors or controllers in their own right) based in the United Kingdom who require reporting of processing activities in certain circumstances.
10.3 YOUR LEGAL 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.
Some of our site pages utilize “cookies” and other tracking technologies. A “cookie” is a small text file that may be used, for example, to collect information about site activity. Some cookies and other technologies may serve to recall Personal Information previously indicated by a site user. You may block cookies, or delete existing cookies, by adjusting the appropriate setting on your browser. Please consult the HELP menu of your browser to learn how to do this. If you block or delete “cookies” you may find the usefulness of our site to be impaired.
Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us. You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.
You can opt out should you not want to receive remarketing ads by visiting Google’s Ads Settings page or alternatively by visiting the Network Adverting Initiative opt out page.
What we collect
We may collect the following information:
– Contact information including email address
– Demographic information such as postcode, preferences and interests
– Other information relevant to customer surveys and/or offers
We require this information to understand your needs and provide you with a better service, and in particular for the following reasons:
– Internal record keeping.
– We may use the information to improve our products and services.
– We may periodically send promotional emails about new products, special offers or other information which we think you may find interesting using the email address which you have provided.
– We may use the information to customise the website according to your interests.