1. WHAT IS PERSONAL INFORMATION?
Before you read any further, we thought it would be useful to explain what we mean by “personal information”. The relevant legal definition can be found here. In brief, it is information which relates to you and from which you can be identified, whether from that information alone or from that information combined with other information. It is a very broad definition, so lots of types of information can amount to personal information.
2. WHEN DO WE COLLECT PERSONAL INFORMATION ABOUT YOU?
We collect personal information in the following ways:2.1 WHEN YOU GIVE IT TO US DIRECTLY For example, personal information that you submit to us when you purchase products from our website, sign up for email discounts, make enquiries via our website or leave reviews. 2.2 WHEN YOU VISIT OUR WEBSITE When you visit or use our website, we automatically collect the following types of personal information:
technical information, including the internet protocol (IP) address used to connect your device to the internet, browser type and version, time zone setting, browser plug-in types and versions and operating systems and platforms; and information about your visit to our website, including the uniform resource locator (URL) clickstream to, through and from the website (including date and time), services you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling and clicks) and methods used to browse away from the page.
MISSING RETURNS OR REFUNDS
If you haven’t received any contact regarding your refund, please follow the below steps: Check your bank account to ensure the payment hasn’t already been received – refund payments can take 5-10 working days in some cases, so it is worth checking with your payment card provider and bank if you have any concerns. If you’ve done this and still have not received your refund please contact us at firstname.lastname@example.org
WHAT PERSONAL INFORMATION DO WE USE?
We may collect, store and otherwise process the following kinds of personal information: Your name and contact details such as postal address, telephone number and email address; your payment card and bank details (such as sort code and account number); your Paypal account details; your user account details, such as username and password; products assigned to you on your wishlist; your language preferences; your geographical location (for example if you use our product delivery tracking service); your communications and marketing preferences; information related to social media accounts or profiles; your transaction history; nformation about your computer/mobile device and your visits to and use of our website, including, for example, your IP address and geographical location; information about our brands, services and products, or our selected partners’ services and products, which we consider may be of interest to you; your opinions, criticisms or other feedback if you leave a review; and/or any other personal information which we may collect as per section 2 of this Policy.
HOW AND WHY WILL WE USE YOUR PERSONAL INFORMATION?
We mainly collect and use personal information because we can’t provide our services otherwise. In general, we use your personal information to achieve the purposes set out in this Policy. In particular, we may use your personal information to: personalise, administer and manage your user account on our website; provide you with information, products or services you request from us; to process your payments and transactions; carry out any other obligations arising from contracts entered into between you and us; ensure that content from our website is presented in the most effective manner for you and for your devices; to administer your transaction or other interaction with us; respond to communications from you in general; provide you with information about other products or services we or offer that are similar to those you have already purchased, used or enquired about (only where you have provided your consent for us to do so – please see section 11 of this Policy); administer our website for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes; keep our website safe and secure, for example by conducting analysis required to detect malicious data and understand how this may affect your IT system; notify you about changes to our services; analyse and improve our work, services and products; maintain internal records where appropriate (for example, in case a legal claim is reasonably foreseeable); provide training and/or quality control; audit and/or administer our accounts; satisfy legal obligations which are binding on us, for example in relation to regulatory, government and/or law enforcement bodies with whom we may work (for example requirements relating to the payment of tax or anti-money laundering); prevent fraud and/or misuse of services; and/or establish, defend and/or enforce legal claims. Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.
Items may be exchanged within the 14-day returns period and outside the 14-day period if defective. If you need to exchange please send us an email at email@example.com and send your items to: POTTER & MOORE INNOVATIONS Online Order Returns 1210 Lincoln Road Werrington Peterborough PE4 6ND United Kingdom
LAWFUL BASIS FOR PROCESSING
Applicable data protection law requires us to rely on one or more from a set of “lawful bases” to collect and use your personal information. In short, these are six reasons recognised by regulators as giving us lawful grounds to collect and use your personal information. We consider the grounds listed below to be relevant: Where you have provided your consent for us to use your personal information in a certain way (for example, we will ask for your consent to collect your personal information by using cookies or other tracking technologies, or to send you marketing material by email); In order for us to comply with a legal obligation which is binding on us (for example, where we are obliged to share your personal information with regulatory bodies which govern our work and services); Where necessary for the performance of obligations under a contract to which you are a party or to take steps at your request prior to entering a contract (for example, to provide you with the products you have purchased); or Where there is a legitimate interest in us doing so. Applicable data privacy law allows us to collect and use your personal information if it is reasonably necessary to achieve our, your or others’ legitimate interests (as long as that use is fair, balanced and does not unduly impact your rights). In brief, “legitimate interests” is a broad concept and can potentially include any reasonable, legitimate and valid objective (whether commercial or otherwise). Our legitimate interests could, for example, include provision, promotion or improvement of our products and services. When we process your personal information to achieve such legitimate interests, we consider and balance any potential impact on you (both positive and negative), and your rights under applicable data protection law. We will not use your personal information for activities where our interests are overridden by the impact on you, such as where that use would be excessively intrusive (unless, for instance, we are otherwise required to or permitted to by law).
WILL WE SHARE YOUR PERSONAL INFORMATION?
We may sell advertising space on our website. Those adverts may be delivered to you by our selected commercial partners via cookies deployed on our website. The cookies which are served via our website allow the advertiser to recognise your device, compile information such as your browsing history and send you personalised adverts accordingly. Please see our Cookies Notice for more information on how to opt out of receiving these adverts. We will also share your personal information with selected third parties where required by law, where it is necessary to administer our working relationship with you or where we have another valid and lawful reason for doing so, including if you have given your consent. Those selected third parties include: suppliers and sub-contractors for the performance of any contract we enter into with them, for example IT service providers such as website hosts or cloud storage providers, payment service providers or debt recovery service providers; professional advisers or service providers, such as lawyers, accountants, auditors and insurers; egulatory authorities, such as tax authorities or the Information Commissioner’s Office (the UK data protection regulator, “ICO”) if our use of your personal information requires reporting in certain circumstances; parties assisting us with research to monitor the impact/effectiveness of our work and services, for example analytics providers who help us evaluate your use of our website, provide reports on how the website is used and let us know which content is most popular; parties who help us protect the safety and property of P&M, its personnel, users, visitors or others; and parties relevant to any corporate transaction relevant to P&M. We may also need to disclose your personal information to third parties: in the event that we sell or buy any business or assets, in which case we may disclose your personal information (solely as relevant to the transaction) to the (prospective) seller or buyer of such business or assets; if substantially all of our assets are acquired by a third party, personal information held by us may be one of the transferred assets; If we are under any legal or regulatory duty to do so; and/or To protect the rights, property or safety of P&M, its personnel, users, visitors or others. Where appropriate, we require third parties to enter into contracts with us which place obligations on them to protect your personal information in line with our policies and procedures and our obligations under applicable data privacy law.
HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?
In general, unless still required in connection with the purpose(s) for which it was collected and/or subsequently used, we remove your personal information from our records 6 years after the date it was collected. However, if before that date (i) your personal information is no longer required in connection with such purpose(s), (ii) we are no longer lawfully entitled to process it or (iii) you validly exercise your right of erasure (please see section 10 below), we will remove it from our records at the relevant time.
SECURITY/STORAGE OF AND ACCESS TO YOUR PERSONAL INFORMATION
P&M is committed to keeping your personal information safe and secure and therefore takes reasonable and proportionate technical and organisational precautions to prevent the loss, misuse or alteration of your personal information. We restrict access to those who have a need to know and we train staff in handling your personal information securely and in line with P&M’s obligations under applicable data privacy law. Unfortunately, there is no such thing as 100% security in the online environment. As a result we cannot and do not guarantee the security of any personal information you submit to us through or in connection with our website. If you consider that your interaction with us is no longer secure (e.g. you consider that the security of any account you might have with us has been compromised), please immediately notify us by contacting us at [firstname.lastname@example.org].
INTERNATIONAL TRANSFERS OF YOUR PERSONAL INFORMATION
As we are a UK-based organisation, when we use your personal information internally we will not transfer it outside of the UK or the European Economic Area (“EEA”). However, because (as set out in section 6 above) we share your personal information with third parties, it is possible information that we collect from you will be transferred to and stored in a location outside the UK or EEA. Some countries outside of the UK or EEA have a lower standard of protection for personal information, including lower security requirements and fewer rights for individuals. Where we cause your personal information to be transferred, stored and/or otherwise used outside the UK or EEA in a country that does not offer an equivalent standard of protection to the UK or EEA, we will take all reasonable steps necessary to ensure that the recipient implements appropriate safeguards (such as by entering into a contract which puts the recipient under similar obligations as if they were based in the UK or an EEA country, or requesting that they have signed up to a domestic certification scheme which guarantees the same level of protection as in the UK or EEA) designed to protect your personal information and to ensure that your personal information is treated securely and in accordance with this Policy. If you have any questions about the transfer of your personal information, please contact us using the details below.
YOUR RIGHTS AND HOW TO EXERCISE THEM
Applicable data protection law gives you certain rights to control how we use your personal information. These are as follows: Right to withdraw consent: where we rely on your consent to use your personal information, you have the right to withdraw that consent at any time. This includes the right to ask us to stop using your personal information for marketing purposes (including to stop receiving promotions and offers from us or our partners at any time). Right of access: you can ask us for confirmation of what personal information we hold about you and to request a copy of that information. Provided we are satisfied that you are entitled to see the personal information requested and we have successfully confirmed your identity, we will provide you with your personal information subject to any exemptions that apply under data protection law to oblige, or allow, us to withhold it. Right of erasure: at your request we will delete (and ask parties with whom we have shared your personal information to delete) your personal information from our records as far as we are required to do so. Right of correction: if you believe that our records of your personal information are inaccurate, you have the right to ask for those records to be updated. You can also ask us to check the personal information we hold about you if you are unsure whether it is accurate or up to date. Right to restrict processing: you have the right to ask for processing of your personal information to be restricted if there is disagreement about its accuracy or legitimate usage (until that disagreement is resolved). Right to object: in the following situations, you have the right to object to our processing of your personal information: where we use your personal information relying on the lawful basis of legitimate interests (please see section 5 above); where we use your personal information for marketing purposes; or where we use your personal information for statistical purposes. We are then required to stop using your personal information in the manner to which you object unless we can demonstrate a reason of compelling importance to continue (unless you object to our use of your personal information for marketing purposes, in which case we must stop regardless of any compelling grounds to continue). Right to portability: in certain limited situations where we process your personal information by automated means, you may ask us to provide that personal information, or another service provider, in a commonly used, machine-readable format. Automated decision-making: you have the right not to be subject to a decision based solely on automated processing of your personal information which produces legal or similarly significant effects on you, unless such a decision is: necessary to enter into/perform a contract between you and us/another organization; is authorised by EU or UK law to which we are subject (as long as that law offers you sufficient protection); or is based on your explicit consent. Right to complain:you are further entitled to make a complaint about us or the way we have used your personal information to the data privacy supervisory authority in your home country. In the UK, the supervisory authority is the ICO – https://ico.org.uk. We may ask you for additional information to confirm your identity and for security purposes before actioning any attempt to exercise these rights. Please note that some of these rights only apply in limited circumstances. For further information on how to exercise these rights, or the extent to which they may apply to you, please contact us using the details below.
COMMUNICATIONS FOR MARKETING
We may use your contact details to provide you with information about our work, events, services and/or products which we consider may be of interest to you (for example, about similar products which you previously purchased). Where we do this via email, SMS or telephone, we will not do so without your prior consent (unless we are allowed to do so via applicable law). Where you have provided us with your consent previously but do not wish to receive marketing material from us anymore, please let us know by emailing email@example.com. You can also opt out of receiving marketing emails from P&M at any time by clicking the “unsubscribe” link at the bottom of our emails.
LINKS AND THIRD PARTIES
We may provide links our website directly to other sites. This Policy does not cover external websites and the privacy practices of their operators and we are not responsible for the content of those sites or the privacy practices of their operators. We encourage you to read the privacy notices of any external websites you visit via links you may click on our website.
CHANGES TO THIS POLICY
HOW TO CONTACT US
Questions, comments and requests regarding this Policy are welcomed and should be sent via the following channels: Post: 1210 Lincoln Road, Werrington, Peterborough, Cambridgeshire PE4 6ND Email:firstname.lastname@example.org Telephone: 01733 281 000