1. Important Notice
access to your personal data and what your rights are. Please review it carefully.
“controller” of the personal data you provide to us.
You have the right to object to us processing your personal data for our legitimate business interests or for direct marketing purposes (including any related profiling). For more information about your rights and how you can exercise them, please see the section Your rights.
2. Personal Data we may collect and why
Personal data is any information which identifies you personally whether directly (for example, your name) or indirectly (for example, information about your use of our products and services).
- We may collect the following data about you:
Contact details: your name, email address, and telephone number so that we can contact you in response to an enquiry
you make via our Site or in relation to the products and services that we have from time to time agreed to provide to you;
- Correspondence: we collect any additional personal data you may provide to us from time to time if you contact us by
email, letter or telephone, through our Site, by submitting a comment on our Site, or by any other means;
- Survey responses: information from surveys that we use for research purposes, if you choose to respond to them;
- Transaction details: we or our third party providers will collect information relating to transactions you carry out through our Site and for the purposes of fulfilling your orders;
- Details of visits to the Sites: details of your visits to our Site, including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.
What are Cookies?
We collect information about your use of our Site through cookies. Cookies are information that files stored on your
computer, tablet or smartphone that help websites remember who you are and information about your visit. Cookies can
a. What cookies are used on this Site?
The cookies we and our business partners use on our Site are broadly grouped into the following categories:
Essential – Some of the cookies on our Site are essential for us to be able to provide you with a service you have
requested. An example of this could be a cookie used to enable you to log into your account on our Site or which allows
communication between your browser and our Site. Our cookie preference cookie described in the section “How can I
reject or opt out of receiving cookies?” is also an essential cookie. You may not be able to use our Site without these
Analytics – We use analytics cookies to helps us understand how users engage with our Site. An example is counting the
number of different people coming to our Site or using a particular feature, rather than the total number of times the site or
feature is used. Without this cookie, if you visited our Site once each week for three weeks we would count you as three
separate users. We would find it difficult to analyse how well our Site was performing and improve it without these cookies.
use our Site. Examples of this would be remembering you so that you are served with the same content or to remember
you when you come back to our Site.
Social Sharing – We use third party cookies to allow you to share content directly on the social networking/sharing sites
like Facebook, Twitter or Google+. Examples would be if you wanted to “like” or “tweet” about us or our products or
services. Please see our “Third Party Cookies” section below for more details.
Interest-Based Advertising – You will have noticed that when you visit websites you will be shown adverts for products
and services you may wish to buy. The money made by website owners for showing third party adverts on their websites
often pays for the cost of running the website and therefore usually allows you to use the website without having to pay a
registration or usage fee. To try and ensure that the adverts you see are relevant to you third party cookies may be used to
collect information about the types of things that interest you, for example websites you visit and the geography that you are
based in. Having these cookies does not increase the number of adverts you will be shown, but simply makes the adverts
you see more relevant. Please see our “Third Party Cookies” section below for more details.
b. How can I reject or opt out of receiving cookies?
You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of
cookies. However, if you select this setting, you may be unable to access certain parts of our Site. Unless you have
menu of the toolbar on most browsers will tell you how to prevent your browser from accepting new cookies, how to have
the browser notify you when you receive a new cookie, or how to disable cookies altogether. For more information about
cookies and how to stop cookies being installed or how to delete existing cookies from your hard drive visit the following
c. Third party cookies
Some of the cookies described in the “What Cookies are used on our Site” section above are stored on your machine by
third parties when you use our Site. Third parties may also read cookies on your browser to collect information or to serve
content or advertisements to you. We have no control over these cookies or how the third parties use them. They are used
to allow that third party to provide a service to us, for example analytics. For more information on these cookies and how to
disable them, please see:
Internet Advertising Bureau website at http://www.youronlinechoices.com/ where you will be able to opt-out of receiving
Interest-Based Advertising cookies from some of the third parties listed below; and/or
If you want to know more about how cookies work and how to manage or delete them, visit the World Wide Web
4. 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 to provide you with the products and services you have requested in accordance with the Trading Terms or Terms of Trading.
To send you service communications, including in relation to changes to our Trading Terms or Terms of Trading
We use the contact details you have provided to us so that we can communicate with you about the products and services
that we provide, including to let you know about major changes to those products and services or to the Trading Terms or
Terms of Trading between us or to any related information.
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
You can unsubscribe from our direct marketing at any time by clicking the “Unsubscribe” link in any of our emails or by
Our trusted business partners would also like to use your name, email address, postal address and telephone number to
inform you of similar products, services and promotional offers. We will only share your personal data with our partners
where you have provided us with your consent to do so. You can unsubscribe at any time by clicking the “Unsubscribe” link
in any of their emails or by contacting us.
To track your usage of our website, communications, products and services
functionality on our Site, monitor its usage, and provide you with a more personalised experienced.
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
Like any business, 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 use your personal data only to the extent required 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.
5. 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
In certain circumstances, we process your personal data after obtaining your consent to do so for the purposes of:
- sending you marketing communications about our products and services;
- sharing your name, email address, postal address and telephone number with our trusted business partners so that they
may market to you about their own similar products and services;
- conducting marketing research;
- obtaining your credit score so that we can establish the best possible payment terms we are able to offer to you.
Necessary for the performance of a contract and to comply with our legal obligations
It is necessary for us to process your basic contact details, payment details and information about the business you
represent for the performance of the Trading Terms or Terms of Trading between us. In particular, we rely on this legal
- provide you with the products and services;
- communicate with you about the products and services that we provide to you, including to let you know about major
changes to those products and services or to the Trading Terms or Terms of Trading between us or to any related
- provide and improve customer support; and
- notify you about changes to our service
If you choose not to give some or all of the aforementioned information to us, this may affect our ability to provide our
products and services to you.
In certain circumstances, we also use your personal data only to the extent required in order to enable us to comply with
our legal obligations, including to detect, investigate and prevent fraud.
Necessary for the purposes of our legitimate business interests or those of a third party
It is sometimes necessary to collect and use your personal data for the purposes of our legitimate interests as a business,
which are to:
- provide you with products and services that are as useful and beneficial as possible, including by personalising our contact
with you and making sure we tell you about all the offers that are relevant to you;
- better understand our customer base so that we can improve our products and services and marketing activities (which
could also benefit you);
- comply with our contractual obligations to third parties;
- develop and improve our Site to enhance the customer experience;
- train our staff so that we can provide you with a better customer service;
- 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; and
- to ensure that content from our Site is presented in the most effective manner for you and for your computer;
- ensure effective operational management and internal administration of our business, document retention, compliance with regulatory guidance and exercise or defence of legal claims.
Where we think there is a risk that one of your interests or fundamental rights and freedoms may be affected we will not
process your personal data unless there is another legal ground for us to do so (either that we have obtained your consent
to the processing or it is necessary for us to perform our contract with you or to comply with our legal obligations).
6. Who we share your personal data with
We may provide your personal data to our suppliers and service providers, including other companies in our group, who
provide certain business services for us and act as “processors” of your personal data on our behalf. In addition, we may
disclose your personal data if we are under a duty to disclose or share your personal data in order to comply with any legal
obligation, or in order to protect the rights, property, or safety, of our business, our customers or others. This includes, in
specific cases, exchanging information with other organisations for the purposes of fraud protection.
In some cases, the personal data we collect from you may, for the purposes set out above, be transferred outside the
European Economic Area (EEA) and such destinations may not have laws which protect your personal data to the same
extent as in the EEA. We are required by data protection law to ensure that where we or our “processors” transfer your
personal data outside of the EEA, it is treated securely and is protected against unauthorised access, loss or destruction,
7. How long we keep your personal data for
We retain your personal data for no longer than is necessary for the purposes(s) for which it was provided. What this
means in practice will vary between different types of data. 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 securely erase your personal data from our systems when it is no longer needed.
8. Your rights
You have the following rights regarding your personal data:
Rights What does this mean?
1. Rights to be informed You have the right to be provided with clear, transparent and easily
understandable information about how we use your personal data and your rights.
2. Right of access You have the right to obtain access to your personal data (if we are processing it)
is so you are aware and can check that we are using your personal data in
accordance with data protection law.
3. Right to rectification You are entitled to have your personal data corrected if it is inaccurate or
4. Right to erasure This is also known as ‘the right to be forgotten’ and, in simple terms, enable you to
request the deletion or removal of your personal data where there is no
compelling reason for us to keep using it. This is not a general right to erasure;
there are exceptions.
5. Right to restrict processing You have the right to ‘block’ or supress further use of your personal data in certain
circumstances. When processing is restricted, we can still store your personal
data, but may not use it further.
6. Right of data portability You have the right to obtain and reuse your personal data in a structured,
commonly used and machine-readable format in certain circumstances. In
addition, where certain conditions apply, you have the right to have such
information transferred directly to a third party.
7. Right to object to processing You have the right to object to us processing your personal data for our legitimate
business interests or for direct marketing purposes (including in each case any
8. Right to withdraw consent to
processing If you have given your consent to us to process your personal data for a particular
purpose (for example, direct marketing), you have the right to withdraw your
consent at any time (although if you do so, it does not mean that any processing
of your personal data up to that point is unlawful).
9. Right to make a complaint to
the data protection authorities You have the right to make a complaint to the Information Commissioner’s Office
(ICO) if you are unhappy with how we have handled your personal data or believe
our processing of your personal data does not comply with data protection law.
9. How to contact us
If you would like to exercise your data protection rights or if you are unhappy with how we have handled your personal data,
please feel free to contact us by using the details set out on our Site.
If you’re not satisfied with our response to any enquiries or complaint or believe our processing of your personal data does
not comply with data protection law, you can make a complaint to the Information Commissioner’s Office (ICO) by:
- writing to: Information Commissioner’s Officer, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF;
- calling: 0303 123 1113; or
- submitting a message through the ICO’s website at: ico.org.uk
10. Links to other websites
those other websites. We encourage you to read the privacy statements on the other websites you visit, as they will govern
the use of any personal data you provide when visiting those websites. We do not accept any responsibility or liability for
the privacy practices of such third party websites and your use of such websites is at your own risk.