15th May 2018
1. Important Notice
2. Personal Data We Collect & Why
Personal data is any information which identifies you personally whether directly (for instance, your name and address) or indirectly (for instance, information about your use of our products and services).
We may collect the following data about you:
- Contact details:Your name, address, email address, and telephone number so that we can contact you in response to any order or enquiry which you might make via Victory Colours website or in relation to the products and services that we may have agreed to provide to you;
- Correspondence:We may collect any additional personal data you provide to us from if you contact us by email, letter or telephone or via our website, by submitting a comment on our website, or by any other means;
- Transaction details:We, or our third-party payment providers will collect information relating to transactions you carry out through our website and for the purposes of fulfilling your orders.
3. Visitors to Our Website
Where we collect personal data via our website, we will be upfront about it and it will be made obvious to you that you are providing personal data and how we will be using it.
- When someone visits our website www.victorycolours.co.uk we make use of the Google Analytics service to collect standard information about visitors to the sites and their behaviour (e.g. what pages they viewed). The data provided by Google Analytics is anonymised and in no way enables us to identify individual visitors, however, Google Analytics will place a cookie on your device to enable the service. For more information about how Google Analytics cookies work on websites visit: https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage
What are Cookies?
- A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
- Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
- Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
4.2 Managing Cookies
Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
4.3 Third Party Cookies
- Visit the Internet Advertising Bureau website atyouronlinechoices.com where you will be able to opt-out of receiving Interest-Based Advertising cookies;
- If you would like to learn more about how cookies work, how to manage them, or delete them, visit theWorld Wide Web Consortium’s Website.
5. How we Use Your Personal Data
We use your personal data for the following purposes:
- To provide you with the products and services you have requested - We use your personal data to accept you as a new or returning customer in order to provide you with the products and services you have requested in accordance within the Terms and Conditions of business.
- Direct marketing (including by third parties)- If you have provided your consent or we otherwise have the right to do so, we may use your contact details to send you direct marketing and keep you informed of promotional offers by email, SMS, post or telephone relating to our products and services.
- You can unsubscribe from our direct marketing at any time by clicking the “Unsubscribe” link in any of our emails or by contacting firstname.lastname@example.org
- To provide and improve customer support- We use your personal data to be able to provide and improve the customer support we provide to you (for example, where you have questions about our products and services).
- To maintain our records and improve data accuracy - We process personal data in the course of maintaining and administering our internal records. This includes processing your personal data to ensure that the information we hold about you is kept up to date and accurate.
- To respond to enquiries, complaints and disputes- We use the personal data we hold about you to help us respond to any enquiries or complaints you have made, or deal with any dispute which may arise in the course of us providing our products and services to you, in the most effective manner.
- To investigate, detect and prevent fraud and comply with our legal obligations -In certain circumstances, we may use your personal data, in order to enable us to comply with our legal obligations, including for fraud detection, investigation and prevention purposes. This may require us to provide your personal data to law enforcement agencies if they request it.
6. Legal Grounds for Processing
Data protection law requires us to only process your personal data if we satisfy one or more legal grounds. These are set out in data protection law and we rely on a number of different grounds for the processing we carry out. These are as follows
In certain circumstances, we process your personal data after obtaining your consent to do so for the purposes of:
- Sending marketing communications about our products and services;
- Conducting market research;
- Potentially obtaining your credit score so that we can establish the best possible payment terms we are able to offer to you.
6.2 Necessary to Perform and Comply to Legal and Contractual Obligations
For us to process your basic contact details, payment details and information to perform the business Terms and Conditions between us we rely on this legal ground to:
- Provide you with our products and services;
- Communicate about the products and services that we provide to you, including to letting you know about major changes to those products and services or to the Terms and Conditions of business between us or to any related information;
- Provide customer service and support;
- Notify you about any changes to our service.
You may choose not to give some or all of the aforementioned information to us, however, this may affect our ability to provide our products and services to you.
In certain circumstances, we may use your personal data, if necessary, to enable us to comply with our legal obligations, including to detect, investigate and prevent fraud.
6.3 Necessary to Perform our Legitimate Business Interests or Those of a Third party
In some instances, it will be necessary to collect and use your personal data for our legitimate business interests which are to:
- Provide you with the best possible service as possible, including providing personalised contact and ensuring we inform you of the best offers pertinent to you;
- To Respond to any enquiries or complaints that may arise in the provision of our products and services;
- Help understand our customer base so we can improve products and services to best fit our clientele;
- Ensure our website content is presented in the most effective way for your device and for you;
- To ensure internal administration and management of our business, documentation, and legal compliance in the most effective manner.
- Train our staff in order to provide the best possible customer experience;
- Comply with our contractual obligations to third parties;
- Improve and develop our website to enhance your customer experience;
7. How Long We Keep Your Personal Data For
Unless stated elsewhere in this document or in our Terms of Service we only store the data necessary to provide the services we provide to you. We will keep this data for as long as it is lawful for us to do so (this may be for as long as you are a customer or because of a legal obligation to retain the information, whichever is the longest).
When determining the relevant retention periods, we take into account factors including:
- Legal obligation(s) under applicable law to retain data for a certain period of time;
- Statute of limitations under applicable law;
- Potential or actual disputes; and
- Guidelines issued by relevant data protection authorities.
Otherwise, we will securely erase your personal data from our systems when it is no longer needed.
8. Third party Processors
We use a number of third-party cloud-based services for the purposes of effectively running our business and providing our services to you. We also use a number of third-party organisations, e.g. accountants, HR support, etc.
In all cases where we are using a third-party service or company, we will only provide the minimal amount of information for the purposes of delivering the service to us and to meet our requirements.
We always carry out due diligence against all our third-party suppliers for the purposes of ensuring their compliance with data protection, maintaining adequate security of your data and ensuring they apply adequate data protection principles to the processing of the data we supply.
9. Your Rights
Under current data protection legislation in the UK, you have rights as an individual which you can exercise in relation to the data we store and process about you. You can find more information about your rights on the Information Commissioner’s website: https://ico.org.uk/for-the-public/
What Does This ?ean?
1. Right to be Informed
2. Right to Make a Complaint to the Data Protection Authorities
If you want to make a complaint about the way we are processing your data, you can contact us, using the contact details below. You also have the right to complain to the Information Commissioner’s Office: https://ico.org.uk/concerns/
3. Right to Withdraw Consent and Object to Processing
Where we are processing your data and needed to ask your permission to do so, you are able to withdraw your consent at any time. If you wish to stop receiving our marketing emails you can do so, by clicking on the “unsubscribe” link at the bottom or the email. Otherwise, you can contact us, using the contact details below.
If you wish to raise concerns about the way we are processing your data or would like to raise an objection, then please email Victoria Yardley our Data protection manager via email@example.com your concerns.
4. Right to Keeping Your Data up to Date
It is important that any of your data that we process is kept up to date. We will from time to time ask you to verify your contact details but if you wish to update any information we hold about you, please contact us using the contact details below.
5. The Right to Erasure
Under some circumstances you may request us to delete your data from our systems. Where this is possible (e.g. we don’t have any legal purpose for continuing to process your data) we will erase it from our systems.
If you wish to exercise your right to be forgotten, please contact us via the contact details below.
6. The Right of Data Portability
Your right to portability allows you to request a machine-readable format of the data you supplied to us and associated service logs (where we store them). Please contact us, using the contact details below, if you wish to receive a CSV export of your data.
7. Right of Access to your Data
You have the right to ask us about what data we hold about you, how we process it and provide you with a copy of the information, free of charge and within one month of your request.
To make a request for any personal information we hold and process about you, we would prefer it if you could put it in writing or in an email to the addresses below. We will need to verify your identity before providing the information and where necessary may contact you further to ensure we understand what data you are requesting.
8. Right of Rectification
You are entitled to have your personal data corrected if it is inaccurate or incomplete.
10. Disclosure of Information
We do not share any personal data with any third parties unless it is lawful for us to do so, if required by law to do so or if you provide us with permission to do so.
11. More Information
For more information about your data rights and privacy or data protection in general visit the Information Commissioner’s Office website: https://ico.org.uk
12. How to Contact Us
If you have any questions about how we collect and use your information not covered in this privacy notice, or if you wish to speak to someone about our approach to data protection and privacy, please contact:
Victoria Yardley, Data Protection Officer at firstname.lastname@example.org or call 01258 841310
Victory Colours may change or update elements of this privacy notice from time to time or as required by law. You should check this page to ensure that you are happy with any changes.