- IMPORTANT INFORMATION AND WHO WE ARE
- THE DATA WE COLLECT ABOUT YOU
- HOW IS YOUR PERSONAL DATA COLLECTED?
- HOW WE USE YOUR PERSONAL DATA
- DISCLOSURES OF YOUR PERSONAL DATA
- INTERNATIONAL TRANSFERS
- DATA SECURITY
- DATA RETENTION
- YOUR LEGAL RIGHTS
IMPORTANT INFORMATION AND WHO WE ARE
Our website is not intended for children and we do not knowingly collect data relating to children, where we sell products that are mainly for use by Children we expect responsible adults to purchase those products themselves. We ask that you do not submit details of children to us under any circumstances in order to better protect their interests and reduce any risk of harm.
Full name of legal entity: Pure Tec Limited
Postal address: Puretec Offices, Britannia Road, Goole, East Riding Of Yorkshire, England, DN14 6ET
Customer Services telephone number: 01482 212 098
Data Privacy Manager: Andrew Leak
Data Privacy Manager Email address: firstname.lastname@example.org
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO (and the ICO generally prefer that too) so please contact us in the first instance.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, receive, use, store and transfer different kinds of personal data about you which we would generally expect to fall within one of the following categories or types of personal data as follows:
· Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth (excluding year of birth unless specifically required for identification purposes) and gender (class and/or pronoun).
· Contact Data includes billing address, delivery address, email address and telephone numbers and may also include delivery instructions where provided.
· Financial Data includes bank account and payment card details.
· Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us, which may include partial Financial Data where that information is provided to us by a third party payments processor (as may be further described in the relevant third party’s privacy notice).
· Technical Data includes partial and full internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
· Profile Data includes your username and password, your interests, preferences, feedback and survey responses.
· Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or to deliver them to the correct address). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- apply to purchase any of our products, or any warranties relating to those products or where you sign up to receive content;
- create an account on our website;
- subscribe to our publications, such as our newsletters or sign up to be notified when we publish new blog posts;
- request marketing or other product information to be sent to you;
- Contact us in relation to any issues you have with a product or to request a repair or replacement from us or any applicable third party supplier whether or not under a warranty;
- enter a competition, promotion or survey; or
- give us feedback, complain or contact us by any means.
Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
Technical Data from the following parties/services:
the Google Analytics service provided by Google Ireland Limited based in Ireland and their parent Company Google Inc based in the USA (see the Glossary below for more details);
advertising networks such as those offered by LinkedIn Ireland Unlimited Company based in Ireland (explained here at https://www.linkedin.com/help/linkedin/answer/a421454 and here https://www.linkedin.com/legal/privacy-policy) as well as the Ad networks operated by Facebook (Meta) and Instagram as operated by Facebook Ireland Ltd based in Ireland (as further set out at https://en-gb.facebook.com/privacy/explanation); and
· Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as any of the Delivery Partners we use to deliver our products across the UK and Europe.
· Complaints information, which could include personal data that we aren’t able to anticipate at the time of placing your order, which we need to process in order to resolve a complaint or other enquiry that you make in relation to one of the third parties we work with as set out in the Glossary below. In the event we are required to deal with this sort of circumstance, those third parties might share further information with us for the purpose of dealing with that issue, where those third parties are legally able to provide that data to us.
HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
· Where we need to perform the contract we are about to enter into or have entered into with you, for example where our contract with you requires us to provide data with third party manufacturers or suppliers of products for the purpose of administrating contractual warranties.
· Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
· Where we need to comply with a legal obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as a new customer||(a) Identity|
|Performance of a contract with you|
|To activate a product warranty for a product you have purchased||(a) Identity|
|Performance of a contract with you|
|To administrate and manage any rights you have under any applicable third party warranty, and to share relevant information with the provider of that warranty, including as to product safety||(a) Identity|
|(a) Performance of a contract with you|
(b) Necessary to comply with a legal obligation (for example, if we need to report something to a regulator under product safety laws, where we are legally required to do so)
|To process and deliver your order including:|
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(c) manage third party finance arrangements with Pay4Later Limited, trading as Deko.
(e) Marketing and Communications
|(a) Performance of a contract with you|
(b) Necessary for our legitimate interests (to recover debts due to us)
|To manage our relationship with you which will include:|
(b) Asking you to leave a review or take a survey
(d) Marketing and Communications
|(a) Performance of a contract with you|
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
|To enable you to partake in a prize draw, competition or complete a survey||(a) Identity|
(e) Marketing and Communications
|(a) Performance of a contract with you|
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity|
|(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)|
(b) Necessary to comply with a legal obligation
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.||(a) Identity|
(e) Marketing and Communications
|Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences||(a) Technical|
|Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
|To make suggestions and recommendations to you about goods, services or content that may be of interest to you, or to send you a special birthday offer.||(a) Identity|
(f) Marketing and Communications
|Necessary for our legitimate interests (to develop our products/services and grow our business)|
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You are able to view and adjust your marketing preferences by using the privacy centre established by our third party marketing service, just follow the links we provide for that purpose within each of the marketing emails that we send to you. Alternatively you can always contact us with any questions about this process or to ask us to adjust your marketing preferences on your behalf.
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 (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.
We do not plan on sharing any of your personal information with any third party for the purpose of them sending their own marketing to you. We may share details of third party products where we consider that they are relevant to you and we might base this opinion on the data we hold about you or are reasonably justified in predicting about you based on what we know about you or our customers generally. For the avoidance of doubt we will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you. If you can’t do either of these things or that still doesn’t work for some reason then you can always contact us directly at any time.
Where you opt out of receiving these marketing messages, this will not necessarily restrict our continued processing of your personal data which you’ve provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions where we process your information on any other legal basis that might apply other than legitimate interests or your consent. For example, we will continue to process your personal data where required for legal or contractual reasons such as warranty claims, insurance and other similar matters.
Social media platforms and widgets
Our website may include social media features, such as the Facebook Like button. These features may collect information about your IP address and which page you are visiting on our website, and they may set a cookie to make sure the feature functions properly. Social media features and widgets are either hosted by a third party or hosted directly on our website. We also maintain presences on social media platforms, including Facebook, Twitter, and Instagram. Any information, communications, or materials you submit to us via a social media platform is done at your own risk without any expectation of privacy. We cannot control the actions of other users of these platforms or the actions of the platforms themselves. Your interactions with those features and platforms are governed by the privacy policies of the companies that provide them.
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 we think it’s going to be completely unexpected or that you might reasonably object to our change of purpose, as it relates to how and why we process your personal data, then we would contact you to let you know what we plan to change before we actually change any of the purposes we set out in this policy. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, you can always 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.
DISCLOSURES OF YOUR PERSONAL DATA
We may share your personal data with the parties set out below for the purposes set out in the table Purposes for which we will use your personal data above.
· Internal Third Parties as set out in the Glossary.
· External Third Parties as set out in the Glossary.
· Specific third parties listed in the table Purposes for which we will use your personal data above.
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 unless they have made it clear to you that they are collecting your information directly from you as a Controller in their own right (in which case, they will set that out in their own privacy notice).
We do not usually transfer your personal data outside the UK, except as stated in this policy.
We use an email marketing service called “Mailchimp” and this is operated by a company called Mailchimp Inc based in the USA who we transfer information to on the basis of the Standard Contracts Clauses (see bullet points below). To find out more about how Mailchimp protects your privacy you can view their privacy notice for Contacts at https://mailchimp.com/legal/privacy/#3._Privacy_for_Contacts.
Whenever we transfer your personal data out of the UK, 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.
· Where we use certain service providers, we may use specific contracts approved for use in the UK and/or the EEA which give personal data the same protection it has in the UK or EEA. These contracts are referred to as the Standard Contracts Clauses and they provide a standardised level of contractual protection to your information whilst it is processed in that country.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used 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.
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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, regulatory, tax, accounting or other requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for ten (10) years after they cease being customers for consumer product safety legal compliance as well as tax purposes.
We will retain certain information for the duration of any applicable warranty, and that might be for the duration of your lifetime where any lifetime warranty applies, but we will try to limit the amount and type of personal data that we retain for this purpose.
In some circumstances you can ask us to delete your data: see your legal rights below for further information, but that might not apply to all information we process about you and it won’t affect the legality of any processing that took place before you asked us to delete that information.
In some circumstances we will 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.
YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out 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.
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 could refuse to comply with your request in these circumstances, and you would be free to complain to the UK’s data regulator, the Information Commissioners Office (ICO), if you disagree with our decision.
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.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could 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. If you fail to provide us with any information we need to comply with your request when we reasonably ask you to provide it then this time limit may be paused and/or we might refuse to comply with your request but we will tell you the reason for this where that is the case.
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). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract, or contractual necessity 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 obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
Internal Third Parties
Other companies in the Pure-Tec Group acting as joint controllers or processors and who are based in the United Kingdom and provide IT and system administration services and undertake leadership reporting.
External Third Parties
· Third party manufacturers of products, or providers of services, which will be made clear to you when you make a purchase. You will either see the branding that appears on the product itself or we will let you know the name of the original manufacturer or relevant distributor/supplier when you make a purchase. If this third party entity changes for some reason (for example, if they are bought by another business) after you’ve made a purchase and you want to activate, register or enforce any applicable warranty then we will share your information with the entity who we have been informed has taken over this liability and is most able to process your request.
· Service providers acting as processors upon our express instructions who are based in the United Kingdom and who provide advertising networking, security, IT and system administration services.
· Our Delivery Partners, who act as processors under our strict instructions in relation to the personal data we provide to them, and as Controllers in their own right in relation to any personal data that you supply to them directly (for example, additional delivery information), including:
· UPS or United Parcel Service, Inc and their corporate group, whose privacy notice is available at: https://www.ups.com/gb/en/help-center/legal-terms-conditions/privacy-notice.page;
· DX (Group) Plc along with their subsidiaries and affiliates including DX Network Services Limited, and DX Network Services Ireland Limited (collectively "DX") whose privacy notice is available at: https://www.dxdelivery.com/privacy-policy;
· DPD (DPDgroup UK Ltd) whose privacy notice is available at: https://www.dpd.co.uk/privacy_policy.jsp; and
· Palletways Group Limited whose privacy notice is available at: https://www.palletways.com/terme-cond-v2.
· Linkedin Ireland Limited, who operate the Linkedin Ads network. If you want to opt out of this processing, you can do so and more at https://www.linkedin.com/psettings/guest-controls. Linkedin’s privacy notice is available at https://www.linkedin.com/legal/privacy-policy.
· Google Ireland Limited, who provide the Google Analytics service, based in Ireland. Their privacy notice is available at https://policies.google.com/privacy?hl=en-GB. You can find out more about asking Google to delete information they hold about you at https://policies.google.com/privacy?hl=en-GB#infodelete.
· Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
· HM Revenue & Customs, regulators (including relevant consumer bodies) and other relevant legal and supervisory authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
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:
· If you want us to establish the data's accuracy.
· Where our use of the data is unlawful but you do not want us to erase it.
· 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.
· 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.