We take your privacy very seriously. Please read this privacy notice carefully as it contains important information on who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint.
When we use your personal data we are regulated under the General Data Protection Regulation (GDPR) which applies across the European Union (including in the United Kingdom) and we are responsible as a ‘controller’ of that personal data for the purposes of the GDPR. Our use of your personal data is subject to your instructions, the GDPR, other relevant UK and EU legislation and our professional duty of confidentiality.
1. KEY TERMS
It would be helpful to start by explaining some key terms used in this policy:
we, us, our means Golden Bear Products Limited, company registration number 01414582, of Hortonwood 40, Telford, Shropshire TF1 7EY; and
personal data means any information relating to an identified or identifiable individual.
2. PERSONAL DATA WE COLLECT ABOUT YOU
The table below sets out the personal data we will or may collect when you use or order our products or services.
|Personal data we will collect||Personal data we may collect|
|Your name, physical address, telephone number, and email address.||Your billing information, transaction and payment card information.|
|Information about how you use our website, IT, communication and other systems.|
|Your contact history and purchase history.|
This personal data is required to enable us to provide our products and services to you. If you do not provide the personal data we ask for, it may delay or prevent us from providing our products and services to you.
3. HOW YOUR PERSONAL DATA IS COLLECTED
We collect most of this information directly from you whether in person or via post, telephone or email. However, we may also collect information:
- via messages you post to our website and emails and letters you send to us;
- when you place an order; and
- when you sign up to our newsletter.
4. HOW AND WHY WE USE YOUR PERSONAL DATA
Under data protection law, we can only use your personal data if we have a proper reason for doing so, for example:
- to comply with our legal and regulatory obligations;
- for the performance of our contract with you or to take steps at your request before entering into a contract;
- for our legitimate interests or those of a third party; or
- where you have given consent.
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
The table below explains what we use (process) your personal data for and our reasons for doing so:
|What we use your personal data for||Our reasons for doing so|
|To provide products and services to you.||For the performance of our contract with you or to take steps at your request before entering into a contract|
|To prevent and detect fraud against you.||For our legitimate interests or those of a third party, i.e. to minimise fraud that could be damaging for us and for you|
|Operational reasons, such as improving efficiency, training and quality control.||For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best products and services to you.|
|Marketing our services to: (i) existing and former customers; (ii) third parties who have previously expressed an interest in our services; and (iii) third parties with whom we have had no previous dealings.||For our legitimate interests or those of a third party, i.e. to promote our business to existing, former and potential customers|
|Updating and enhancing customers’ records
|For the performance of our contract with you or to take steps at your request before entering into a contract.
To comply with our legal and regulatory obligations.
For our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about existing orders and new products.
|To provide you with access to all parts of our website.||For our legitimate interests or those of a third party, i.e. to ensure that you have the ability to fully use and enjoy our website.|
5. PROMOTIONAL COMMUNICATIONS
We may use your personal data to send you updates (by email, text message, telephone or post) about products and services which may be of interest to you and/or information about our products and services, including exclusive offers, promotions or new products and services.
We have a legitimate interest in processing your personal data for promotional purposes (see above ‘how and why we use your personal data’). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.
We will always treat your personal data with the utmost respect and never share it with other organisations for their marketing purposes.
You have the right to opt out of receiving promotional communications at any time by emailing us at firstname.lastname@example.org or writing to us at Golden Bear Products Limited, Hortonwood 40, Telford, Shropshire TF3 1QT.
We may ask you to confirm or update your marketing preferences if you purchase our products and services in the future, or if there are changes in the law, regulation, or the structure of our business.
6. WHO WE SHARE YOUR PERSONAL DATA WITH
We routinely share personal data with:
- third parties (where you have consented) about products and services which may be of interest to you;
- third parties who act for us for the purposes set out in this policy or for other purposes approved by you. Those parties process information, fulfil and deliver orders, process credit card payments and provide support services on our behalf; and
- external service providers that we use to make our business more efficient, or to help us promote our products and services (with your consent).
We will only allow our service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We will also impose contractual obligations on service providers to ensure they can only use your personal data for the agreed purposes.
We may also need to share some personal data with other parties, such as potential buyers of some or all of our business or during a re-structuring or re-organisation. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
7. WHERE YOUR PERSONAL DATA IS HELD
Information may be held at our offices and those of our group companies, third party agencies, service providers, representatives and agents as described above (see ‘who we share your personal data with’).
Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal data when this occurs, see below: ‘transferring your personal data out of the EEA’.
8. HOW LONG YOUR PERSONAL DATA WILL BE KEPT
We will keep your personal information while you have an account with us or we are providing products and services to you. Thereafter, we will keep your personal information for as long as is necessary:
- to respond to any questions, complaints or claims made by you or on your behalf;
- to show that we treated you fairly;
- to keep records required by law.
We will not retain your data for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal data.
When it is no longer necessary to retain your personal data, we will delete or anonymise it or restrict access to it.
9. TRANSFERRING YOUR PERSONAL DATA OUT OF THE EEA
To deliver products and services to you, it may sometimes be necessary for us to share your personal data outside the European Economic Area (EEA), for example:
- with our product and service providers located outside the EEA; and
- if you are based outside the EEA;
These transfers are subject to special rules under European and UK data protection law. We will comply with data protection law in this respect. If personal data is to be transferred to non-EEA countries:
- the country will be one which has been assessed by the European Commission as providing an adequate level of protection for personal data;
- the organisation will be a participant in the EU/US Privacy Shield (for further details please see https://www.privacyshield.gov/welcome); or
- the contract between us and the organisation will be subject to standard data protection contract clauses which have been approved by the European Commission (for further details please see https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32010D0087).
10. YOUR RIGHTS
You have the following rights, which you can exercise free of charge:
|Right||Explanation of your rights|
|To Be Informed||Provide Data Subjects with information about the processing activities being conducted. Contained in this notice.|
|Access||The right to be provided with a copy of your personal data.|
|Rectification||The right to require us to correct any mistakes in your personal data. It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.|
|To be forgotten||The right to require us to delete your personal data in certain situations.|
|Restriction of processing||The right to require us to restrict processing of your personal data in certain circumstances, e.g. if you contest the accuracy of the data.|
|Data portability||The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party in certain situations.|
|To object||The right to object at any time to your personal data being processed for direct marketing (including profiling); or in certain other situations to our continued processing of your personal data, e.g. processing carried out for the purpose of our legitimate interests.|
|Not to be subject to automated individual decision-making||The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you.|
For further information on each of those rights, including the circumstances in which they apply, please contact us or review the guide available here: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.
If you would like to exercise any of those rights, please:
- email, or write to our Data Protection Team - see below: ‘how to contact us’;
- let us have enough information to identify you (including your full name and address); and
- let us know what right you want to exercise and the information to which your request relates.
11. KEEPING YOUR PERSONAL DATA SECURE
We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
12. HOW TO COMPLAIN
We hope that our Data Protection Team can resolve any query or concern you may raise about our use of your information.
The GDPR also gives you right to lodge a complaint with a supervisory authority, in particular in the EU (or EEA) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone 0303 123 1113.
This privacy notice was published on 18/07/18 July 2018.
14. HOW TO CONTACT US
Our Data Protection Team’s contact details are shown below:
|Address:||Golden Bear Products Limited, Hortonwood 40, Telford Shropshire TF1 7EY|