PRIVACY AND COOKIES NOTICE
Last updated: 30 August 2019
- ABOUT THIS PRIVACY AND COOKIES NOTICE
1.1 The website www.safehaus-uk.co.uk (the Site) is operated by SafeHaus UK Ltd (“we”, “us”, “our”), a company incorporated in England and Wales under company number 08207774. Our registered office is at Hillcrest, Woodstock Drive, Worsley, Manchester, M28 2NP.
1.2 We are committed to protecting your privacy and complying with our data protection obligations under the Data Protection Act 2018 (the DPA 2018), the General Data Protection Regulation 2016/679 (the GDPR) and any other applicable UK legislation (together, Data Protection Law).
1.3 When you interact with us or use the Site, we act as the data controller of your personal data. This means that we are responsible for processing your personal data and deciding how to use it. This privacy and cookies notice explains the types of personal data we may collect about you when you interact with us, why we collect it, what we use it for and what rights you have over that data. Personal data is any information about an identifiable person. Processing is anything we do with your personal data, including using, storing, sharing and deleting it.
1.4 This notice was last updated on the date shown at the top. We may change this notice at any time by posting an updated version on the Site and will make reasonable efforts to bring any material changes to your attention. You may wish to check it before using the Site as any changes will be effective from the date that they are made.
- CONTACT INFORMATION
2.1 If you have any concerns or would like further information about our use of data or this notice in general, you can contact Hilaria Asumu at Woodstock Drive, Worsley, Manchester, M28 2NP.
- WHAT INFORMATION DO WE COLLECT?
3.1 We collect, store and use the types of personal data set out in the table at the end of this notice.
- HOW WILL WE USE YOUR PERSONAL DATA?
4.1 We will use your personal data for the purposes set out in the table at the end of this notice.
- HOW DO WE SHARE YOUR PERSONAL DATA?
5.1 When we share personal data, we do so in accordance with Data Protection law. We may share certain personal data:
5.1.1 with group, associated or
affiliated companies including Safehaus-UK Nigeria and Safehaus-UK Canada, for
internal administrative purposes;
5.1.2 with employees, contractors, consultants or advisers, to facilitate sales and for general commercial purposes;
5.1.3 with parties who provide products or services to us, such as software development, email services, payment processing, advertising, user notification and feedback functionality, marketing companies who help us manage our communications with you etc;
5.1.4 with government or quasi-governmental organisations, law enforcement and other regulatory authorities or third parties when required or permitted by law, including but not limited to in response to court orders, for the prevention and detection of crime and to protect intellectual property and any other legal rights;
5.1.5 if the Company or part of the business is sold, transferred or integrated with another business, with our advisers, a prospective purchaser, a prospective purchaser’s advisers or the new owner of the Company to facilitate the process; and
5.2 We may also provide third parties with aggregated but anonymised information and analytics
about our customers. Before we do so we will make sure that it does not identify you.
6.2 We use the following categories of cookies and similar technologies on this Site:
6.2.1 Strictly necessary cookies: These cookies are essential to enable you to movearound the Site and use its features. Without these cookies, services you have asked for (such as remembering your login details or the items you placed in your basket) cannot be provided.
6.2.2 Analytics cookies: These cookies collect information about how you use the Site, forinstance which pages you go to most often, what searches you perform and if you get error messages from web pages. Information these cookies collect can be used to improve how the Site works.
6.2.3 Customization cookies: These cookies allow the Site to remember choices youmake (such as your user name) and provide enhanced, more personal features. These cookies cannot track your browsing activity on other Sites.
6.2.5 Social media cookies: These
cookies allow you to share your activity on the Site onsocial media such as Facebook and Twitter. These cookies are not
within our control. Please refer to the privacy policies of the social networks
in question for information regarding how their cookies work.
6.2.6 Targeting or advertising cookies: These cookies record your visit to the Site, thepages you have visited and the links you have followed. We use this information to make our Site and the advertising displayed on it more relevant to your interests. [We may also share this information with third parties for this purpose.
6.3 When you visit the Site for the first time (and periodically after that), we will request your consent to the setting of all cookies other than strictly necessary cookies.
6.4 You can delete existing cookies and disable some or all types of cookies in future if you wish. To disable some or all types of cookies, you will have to change the settings on your browser. If you change your mind, you can enable cookies again at any time. Disabling cookies on your browser may stop the Site from working properly.
6.5 To find out more about cookies please visit www.allaboutcookies.org.
- THIRD PARTY LINKS
7.1 This Site contains links to other websites over which we have no control. We are not responsible for and do not review or endorse the privacy policies or practices of other Sites which you choose to access from this Site. We encourage you to review the privacy policies of those other Sites, so you can understand how they collect, use and share your personal information.
- YOUR RIGHTS
8.1 We respect your rights to privacy and will respond to requests for access or control over information about you in accordance with Data Protection Law. We may require you to verify your identity before we take any action.
8.2 Depending on the reason we have your personal data, you have a right to:
8.2.1 access the personal information we hold about you (commonly known as subject access);
8.2.2 request that we correct or complete personal information we hold about you that is inaccurate or incomplete;
8.2.3 request that we erase your personal information in some circumstances, or object to our processing it as detailed at paragraph 8.5;
8.2.4 restrict how we use your personal information, in certain circumstances;
8.2.5 request that we provide you with copies of your personal information in a machine-readable format or transfer it across different services; and
8.2.6 where we have asked for your consent to process your data, to withdraw this consent.
8.3 These rights are limited in some situations under Data Protection Law – for example, where we can demonstrate that we are under a legal obligation to process your data.
8.4 If you wish to exercise any of these rights, please contact us using the details in paragraph
source not found. above.
8.5 Your right to object
You have a right to object to our processing of your personal data and ask us to stop doing so. If we are processing your personal data or direct marketing purposes (which includes profiling to the extent that it is related to such direct marketing) and you object to this, we will stop processing your personal data immediately.
If our processing of your personal data is in the public interest or pursuant to our legitimate interests and you object to this, we will stop processing your personal data unless we have compelling reasons which override your interests, or our use of your personal data is for the establishment, exercise or defence of legal claims.
8.6 We hope that we can satisfy any queries you may have about the way we process your data. However, if you have unresolved concerns you also have the right to complain to data protection authorities (in the UK, the Information Commissioner’s Office). You can call the ICO on 0303 123 1113 or go to their website: https://ico.org.uk/make-a-complaint/).
- DATA RETENTION
9.1 Your personal data will only be kept for as long as necessary for our purposes. Specific periods are set out in the table at the end of this notice.
- DATA PROTECTION PRINCIPLES
10.1 We process your personal data in accordance with the following principles:
10.1.1 we process your personal data lawfully, fairly and in a transparent way;
10.1.2 we collect your personal data for specified, explicit and legitimate purposes; any further processing we do is compatible with the original purposes for which for which we collected it;
10.1.3 we only process personal data which is adequate, relevant and limited to what is necessary to achieve the purpose for which it is processed;
10.1.4 we take reasonable steps to ensure that all personal data is accurate and kept up to date where necessary;
10.1.5 we do not store personal data in a form which identifies you for any longer than is necessary for the purposes of processing; and
10.1.6 we process personal data securely and in a way that protects against unauthorised or unlawful processing, accidental loss, destruction or damage.
10.2 When we ask for your personal data we will tell you whether you are required by law or contract to provide it, and what will happen if you do not provide the data.
10.3 Any request for consent to the processing of your personal data will be made directly to you and will include information about why we require the personal data and what will be done with it.
- WHAT IS OUR LAWFUL BASIS FOR PROCESSING?
11.1 We will only process personal data when we have a lawful basis for doing that processing. The table at the end of this notice sets out the lawful basis we rely on for each type of data we process.
11.2 We will choose one of the lawful bases in the GDPR to justify how we use your personal data.
11.2.1 Consent: You have given consent to the processing of your personal data for one ormore specific purposes.
11.2.2 Contract: The processing is necessary for the performance of a contract with you orin order to take steps at your request before entering into a contract.
11.2.3 Legal obligation: We need to process your personal data to comply with a legalobligation.
11.2.4 Vital interests: The processing is necessary to protect the vital interests of you oranother person.
11.2.5 Public interest: Processing is necessary for the performance of a task carried out inthe public interest or in the exercise of some official authority.
11.2.6 Legitimate interests: Processing is necessary for the purposes of legitimate interestspursued by us or someone else, except where such interests are overridden by your interests or fundamental rights and freedoms requiring the protection of your personal data.
TABLE OF PERSONAL INFORMATION WE USE
The table below sets out detailed information about our purposes for processing, the basis for processing and the retention period for the personal data.
|Category of personal data||Purpose of processing||Lawful basis for processing||Retention period|
|Name and contact details||To send you order updates; For fraud||Performance of contract||For three years since you last|
|prevention and detection||Compliance with legal obligations||logged on to the Site|
|Date of birth||For fraud prevention and detection, To||Compliance with legal obligations||For three years since you last|
|ensure legal sale of age-restricted||Consent||logged on to the Site|
|Payment information||To take payment and give refunds, For||Performance of contract||For three years since you last|
|fraud prevention and detection||Compliance with legal obligations||logged on to the Site|
|Contact history||To provide customer service and||Performance of contract||For six years since you last logged|
|support, To train our staff||Consent||on to the Site|
|Saved items in online||To sell products and services to you||Performance of contract||Until you complete your order or for|
|Compliance with legal obligations||seven days after the item is saved|
|To provide customer service and||Performance of contract||For six years after purchase|
|Purchase history||support and handle returns||Compliance with legal obligations|
|Browser, device and Site||To improve the Site, To protect the Site||Performance of contract||For three years since you last|
|against fraud, To set default options for||Compliance with legal obligations||logged on to the Site|
|you, such as language and currency||Consent|
|Information from linked||To enable you to log into the Site||Performance of contract||For three years since you last|
|accounts||simply without having to create a||Compliance with legal obligations||logged on to the Site|
|Responses to surveys,||To run the survey, competition or||Performance of contract||For six years|
|competitions and||promotion||Compliance with legal obligations|
|To improve our products and services,||Legitimate interest in dealing with complaints||For six years|
|Customer comments and||Where relevant, to establish, exercise||or claims|
|product reviews||or defend legal claims||Performance of contract|
|Compliance with legal obligations|
|To keep our staff and premises safe||Legitimate interest in dealing with complaints||For one month|
|CCTV images||or claims|
|Information generated in||For internal research and development||Legitimate interest in maintaining our Site||For four years|
|purposes, To improve and test the||and improving our products and/or services|
|the course of the use of our|
|features and functions of our Site||generally|
|products and services|
|Performance of contract|
|To conduct and store site usage||Performance of contract||Three years after you last visited|
|Information collected||analytics, statistical and trend analysis||Compliance with legal obligations||the Site|
|and market research, To generate|
|through cookies and similar|
|customer profiles to facilitate marketing|