Who we are?
This version was last updated on 30.07.18. You can view older versions by contacting us at firstname.lastname@example.org.
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.
When do we collect personal data from you?
We may collect and process the following data about you when you:
- make an online purchase
- purchase a product by phone
- voluntarily sign up to newsletters
- engage with us on social media
- contact us by any means with queries, complaints, etc
- enter prize draws or competitions
- complete any surveys we send you
- register with us
- comment on or review our products and services
- give a third party permission to share with us information they hold about you
We may also collect data from publicly-available sources when you have given consent to share information or where the information is made public as a matter of law.
Personal data we collect from you
We collect the following personal data when you provide it to us:
Personal details, such as:
- name and title
- date of birth
Contact data, such as:
- delivery address
- billing address
- email address
- telephone and mobile number(s)
Payment details, such as:
- bank account
- card details
- Paypal details
Transaction data, such as:
- details about payments to and from you
- details of products and services you have purchased from us
Technical data, such as:
- 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, such as:
- orders made by you
- feedback and survey responses
Usage data, such as:
- information about how you use our website, affiliate websites and products and services
Marketing data, such as:
- your preferences in receiving marketing and communications
Plus, any other information necessary to meet our contractual obligations or provision of a better service to meet your requirements.
We do not collect “special category” personal data. This is a special type of sensitive data to which more stringent processing conditions apply and comprises data concerning your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, sex life or sexual orientation, genetic data and/or biometric data.
We do not collect information about criminal convictions or offences.
How and why 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.
- 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 legal or regulatory obligations.
- 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).
- Performance of the contract 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 or regulatory obligations means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message.
Examples of how we use information held about you include:
- To process any orders that you make on our website. If we don't collect your personal data during checkout, we won't be able to process and deliver your order and comply with legal obligations.
- To respond to your queries, refund requests and complaints. Handling the information you send us enables us to respond. We may also keep a record of these to inform any future communication with us and to demonstrate how we communicated with you throughout. We do this on the basis of our contractual obligations to you, our legal obligations and our legitimate interests in providing you with the best service and understanding how we can improve our service based on your experience.
- To process payments and to prevent fraudulent transactions. We do this on the basis of our legitimate business interests. This also helps to protect our customers from fraud.
- If we discover any criminal activity or alleged criminal activity through our use of fraud monitoring and suspicious transaction monitoring, we will process this data for the purposes of preventing or detecting unlawful acts. We aim to protect the individuals we interact with from criminal activities.
- To listen to recorded telephone conversations for internal staff training.
- To send you relevant communications by email or post in relation to updates, products and services. We'll do this on the basis of our legitimate business interest. You are free to opt out of hearing from us by email or post at any time.
- To develop, test and improve the systems, services and products we provide to you. We'll do this on the basis of our legitimate business interests.
- To comply with our contractual or legal obligations to share data with law enforcement.
- To send you survey and feedback requests to help improve our services. These messages will not include any promotional content and do not require prior consent when sent by email or text message. We have a legitimate interest to do so as this helps make our products or services more relevant to you.
- To build a picture of who you are and your interests, and to inform our business decisions, we'll combine data captured by scooms, third parties and data from publicly-available lists as we have described in the section 'Personal Data we collect from you' We'll do this on the basis of our legitimate business interests.
Who do we share your data with?
We may have to share your personal data with the kind of parties set out below:
- IT companies who support our website and other business systems.
- Operational companies such as delivery couriers and warehouse providers.
- Google, Facebook, Pinterest to show you products that might interest you while you're browsing the internet. We'll also use your data to identify other internet users who share similar interests. This is based on your acceptance of cookies on our website. We may also share your personal details, such as your email address with third parties, such as Pinterest, Facebook and Google, for the purposes of targeted online advertising. To opt out from this form of email-based advertising please email email@example.com.
- Data insight companies to ensure your details are up to date and accurate.
- We may also share certain limited information with companies who assist us with other services, for example, in analysing our customer data in order to better understand, profile and monitor customer patterns so we can consistently improve our products and services and understand what may be of interest to you and other customers.
- For fraud management, we may share information about fraudulent or potentially fraudulent activity in our premises or systems. This may include sharing data about individuals with law enforcement bodies.
- We may also be required to disclose your personal data to the police or other enforcement, regulatory or Government body, in your country of origin or elsewhere, upon a valid request to do so. These requests are assessed on a case-by-case basis and take the privacy of our customers into consideration.
- 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.
In order to protect your privacy, we will:
- Only provide the information necessary to perform their specific services.
- Only use your data for the exact purpose we specify in our contract with them.
- Work closely with them to ensure your privacy is respected and protected at all times.
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 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.
How we protect your data
We have put in place 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. Access to your personal data is password-protected and sensitive data (such as payment card information) is secured and tokenised to ensure it is protected.
We secure access to all transactional areas of our websites and apps using 'https' technology.
How long will you keep my data for?
We will only retain your personal data for as long as it is necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements.
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 requirements. For example, if your order included a product guarantee, the associated personal data will be kept until the end of the guarantee period.
At the end of that retention period, your data will either be deleted completely or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning.
Do we transfer data outside the EU?
Although we are based in the UK, we may transfer your personal information to a location (for example, to a secure server) outside the European Economic Area.
We will only transfer your data outside of the EEA in compliance with data protection laws and provided appropriate or suitable safeguards are in place to protect your data.
We would like to send you information about products and services of ours which may be of interest or a direct benefit to you:
- If you have consented to receive marketing, you may opt out at a later date.
- You have a right at any time to stop us from contacting you for marketing purposes.
- If you no longer wish to be contacted for marketing purposes, you have a right to unsubscribe.
- We may contact you by email, telephone, SMS or by post. You have the right to object or opt out to any of the above forms of communication for marketing purposes.
- There will be occasions where we will contact you to inform you of special offers or promotions which may benefit you. We may utilise the provisions of legitimate interest under the GDPR regulations. Where we use legitimate interest provisions, we will ensure that all checks and balances are thoroughly performed including the appropriate assessments.
- We may store your contact details and carry out marketing profiling activities for direct marketing purposes.
- If you have given your consent or if we are otherwise permitted to do so, we may contact you about our products or services that may be of interest to you. If you prefer not to receive any direct marketing communications from us, you can opt out at any time by sending an email to firstname.lastname@example.org.
What are your rights over your personal data?
Under certain circumstances, you have rights under data protection laws in relation to your personal data. 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: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) 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.
In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.
You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We must always comply with your request.
If you wish to exercise any of the rights set out above, please email email@example.com.
If we choose not to action your request, we will explain to you the reasons for our refusal.
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 may refuse to comply with your request in these circumstances.
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 may 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.
Questions and contact information
If you would like to: access, correct, amend or delete any personal information we have about you, register a complaint or simply want more information, please contact our Privacy Compliance Officer at firstname.lastname@example.org or by mail at:
scooms, 19 Heathman's Road, London SW6 4TJ.