This privacy notice tells you what to expect us to do with your personal information.
· Contact details
· What information we collect, use, and why
· Lawful bases and data protection rights
· Where we get personal information from
· How long we keep information
· Who we share information with
· How to complain
We collect or use the following information to provide services and goods, including delivery:
· Names and contact details
· Addresses
· Date of birth
· Credit reference information
We collect or use the following information for service updates or marketing purposes:
· Names and contact details
· Addresses
· Marketing preferences
· Location data
· Records of consent, where appropriate
We collect or use the following information to comply with legal requirements:
· Name
· Contact information
· Identification documents
We collect or use the following personal information for dealing with queries, complaints or claims:
· Names and contact details
· Address
· Account information
· Correspondence
Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.
Which lawful basis we rely on may affect your data protection rights which are in brief set out below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:
· Your right of access - You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for. You can read more about this right here.
· Your right to rectification - You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. You can read more about this right here.
· Your right to erasure - You have the right to ask us to delete your personal information. You can read more about this right here.
· Your right to restriction of processing - You have the right to ask us to limit how we can use your personal information. You can read more about this right here.
· Your right to object to processing - You have the right to object to the processing of your personal data. You can read more about this right here.
· Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you. You can read more about this right here.
· Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time. You can read more about this right here.
If you make a request, we must respond to you without undue delay and in any event within one month.
To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.
Our lawful bases for collecting or using personal information to provide services and goods are:
· Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
· Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
· Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
o Legitimate interests for collecting or using personal information are for the purposes of providing services to customers. Data control procedures are in place to mitigate risks of collecting data.
Our lawful bases for collecting or using personal information for service updates or marketing purposes are:
· Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
· Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
o Legitimate interests for collecting or using personal information are for the purposes of providing services to customers.
Our lawful bases for collecting or using personal information for legal requirements are:
· Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
Our lawful bases for collecting or using personal information for dealing with queries, complaints or claims are:
· Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
· Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
· Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
o Collecting complaints and query data will help improve customer experience and service.
· Directly from you
· Suppliers and service providers
Data Retention Schedule
Type of Document
Retention Period
Justification
Comments
Customer Service Enquiries / complaints
2 years
Commercial / best practice
Customer Contract Information
6 years from the end of a customer contract
Commercial / best practice
HMRC Requirements
Customer Identification Documents
5 years from the end of a customer contract
Comply with Anti-money laundering
MLRS Requirements
Website Enquiries / requests for contact or information
2 years
Commercial / best practice
Supplier Contracts
6 years from the end of a supplier contract
Commercial / best practice
HMRC Requirements
· Organisations we need to share information with for safeguarding reasons
· Professional or legal advisors
· Financial or fraud investigation authorities
· Relevant regulatory authorities
· Suppliers and service providers
If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice.
If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.
The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
Website: https://www.ico.org.uk/make-a-complaint
1 December 2024