LAST MODIFIED: 22/05/2018
1. HARTBRIGHTS LIMITED APPROACH TO PRIVACY
1.2 For the purposes of the Data Protection Act 1998 and the General Data Protection Regulation 2016/679, Hartbrights Limited is the data controller of the personal information we hold about you.
2. PERSONAL INFORMATION WE COLLECT ABOUT YOU AND HOW WE USE IT
2.1 We collect personal information about you when you voluntarily submit information directly to us or our site. This can include information you provide to us when you complete a form, purchase products, correspond with us, subscribe to our mailing lists, newsletters or other forms of marketing communications or respond to surveys, enter a promotion or use some other feature of our site.
2.2 We also collect personal information from you indirectly such as information about the pages you look at on our site or the device you use to view our site
2.3 The list sets out below the categories of personal information we collect about you and how we use that information.
Contact details: We collect contact information such as your name, your email address, your telephone number and addresses associated with your account or order. We will use your contact details so that we can communicate with you directly about the products we sell and the services we provide, to deliver products to you and about queries, issues or concerns you or other users have.
Comments and opinions: When you contact us directly, e.g. by email, phone, post or by completing an online form we will record your comments and opinions. We will also record comments and opinions you express when responding to surveys, entering competitions or taking part in other promotions we run. We will use your comments and opinions to address your queries, issues and concerns and improve our products and services. We will also use comments and opinions you express when responding to surveys, entering competitions or taking part in other promotions to determine products and services that may be of interest to you and to send you marketing communications in accordance with your marketing preferences.
Payment and transaction information: We keep records of the products and services you purchase from us and the payment method you use for the transaction. We will use payment and transaction information to process payment for any product or service you purchase from us. We will also use your payment and transaction information to understand item popularity, determine products and services that may be of interest to you and send you marketing in accordance with your marketing preferences.
Website login details: Where you create an account with us we will hold your user name and password details so that we can keep your account secure. Where you are provided with the option to log-in using a social network, for example through Facebook, Twitter or Google+ sign-in, we will not be provided with your password or other account login details for those accounts.
Information provided by social networks you connect to our site: If you connect a social network, such as Facebook, Twitter or Google+, to our site we will collect personal information from the social network in accordance with your privacy settings on that network. The connected social network may provide us with information such as your name, Facebook id, twitter handle, profile picture, network, gender, username, user ID, age or age range, language, country, friends list, follower list and any other information you have agreed it can share. We will use the personal information provided to help create a profile for you and, where we provide the functionality, we will also use the information provided to assist you in sharing your experiences on our site with your friends, followers or contacts on the connected social network. We may also use the connection between the social network and our site to provide you with updates on the social network that are relevant to any account you have with us or promotion you are taking part in. Such updates will only be provided with your consent, we will not post to your social network or to your friends, followers or contacts without your consent
Your preferences: We hold information about the preferences you set for notifications, marketing communications and how our site is displayed. We will use your preference settings for the purpose of providing notifications, sending marketing communications and displaying our site in accordance with your choices.
Information about how you use and connect to the site: We collect information about how you use the site such as the pages and links you access, the time you access the site and how long you use it for, the website from where you came to the site or go to after leaving the site and any selections and choices you make when using the site We also collect information about the computer, tablet, smartphone or other electronic device you use to connect to the site. This information can include details about the type of device, unique device identifying numbers, operating systems, browsers and applications connected to the site through the device, your internet service provider or mobile network, your IP address and your device’s telephone number (if it has one). Typically, the information we collect about how you use or connect to our site is associated with your device and not you as a named individual. However, if you are logged into a registered account you have with us this information may also be associated with you directly. We use information about how you use and connect to our site to present our site to you on your device and to determine products and services that may be of interest to you for marketing purposes.
Information about your location: Other than information you choose to provide to us, we do not collect information about your precise location. Your device’s IP address may help us determine an approximate location. We may use an approximate location to ensure content on our site is relevant to the area, city, state or country you are using your device in. We may also use this information to determine products and services that may be of interest to you.
Information provided by other users: Other visitors to our site may provide information that is associated with you. We will use personal information about you that is contained in private messages sent to us by other users to fulfil and deliver orders and to respond to any query, issue or concern they raise. Where users of our site want to invite you to use our site or to share information with you about our products and services we will use personal information that they provide about you to assist them in doing this; we will only do this though where they indicate that you have provided your consent for them to communicate with you in this way.
Information about fraudulent or criminal activity relating to your account: We will use information about fraudulent or criminal activity relating to your use of our site for the purposes of detecting and preventing fraud or crime.
All personal information: We will use all the personal information we collect to monitor and improve our site and our procedures and processes. We will also use the personal information we collect to help us develop new products and services. Our use of your personal information in this way will not result in information that was not previously publicly available being made public on the site.
At various places on our site you may be requested to enter certain personal information. Personal information that must be provided in order to use the requested services will be indicated at the time of collection. Other personal information that you are not required to provide in order to receive our services may be voluntarily given and you are free to decide not to give such personal information.
We may anonymise and aggregate any of the information we collect (so that it does not directly identify you). We may use anonymised information for purposes that include testing our IT systems, research, data analysis, improving the site and developing new products and features.
3. INFORMATION WE SHARE WITH THIRD PARTIES
3.1 We may share your personal information with the following parties:
b. Service providers and advisors: third parties who provide a service to us. For example, we use a third party delivery service to deliver any products you buy to you, we use third parties to send out marketing information to you on our behalf and to otherwise support our marketing efforts, third party service providers which provide us with IT infrastructure and those that help support our IT infrastructure, process payments from you on our behalf, develop analytical information for us about our products and services and provide professional services such as legal and accountancy services. These third parties will only be allowed to use your personal information in accordance with our instructions and will be required to keep your information secure.
c. Purchasers of our business: personal information may be disclosed or transferred to buyers or perspective buyers of our business or any of our assets as part of any such sale.
d. Law enforcement, regulators and other parties for legal reasons: third parties who we are under a legal obligation to disclose your personal information to or to whom we need to disclose your personal information to protect our rights, property or safety or to protect the rights, property or safety of others. We may also disclose personal information to third parties to help detect and investigate illegal activities and breaches of any agreement we have with you.
3.2 We do not disclose information about identifiable individuals to anyone else except as set out above. We may provide third parties with aggregate statistical information and analytics about users of the site but we will make sure no one can be identified from this information before we disclose it.
3.3 Third parties we currently share information with include:
i) Worldpay – our payment provider
ii) Mailchimp – our email marketing provider
4. MARKETING AND ADVERTISING
4.1 Email Marketing: we may, from time to time, contact you by email with information about our products and services. You can let us know at any time that you do not wish to receive marketing anymore by sending an email to us at email@example.com. You may also unsubscribe from our marketing emails by clicking on the unsubscribe link in the emails we send to you or by updating your marketing preferences in the relevant section of your Hartbrights Limited online account (if applicable).
5. STORING AND TRANSFERRING YOUR PERSONAL INFORMATION
5.2 Security: we implement appropriate technical and organisational measures to protect your personal information against accidental or unlawful destruction, loss, change, or damage.
5.4 Length of Time we will Hold Your Personal Information: We will hold relevant personal information indefinitely unless otherwise stated or requested by you for the purposes of carrying out our business’ legal requirements, processing your purchases to conclusion and marketing (via email, online advertising, telephone or mail).
6. OUR POLICY TOWARDS CHILDREN
Our site is not directed to persons under 13 and we do not knowingly collect personal information from children under 13. If you become aware that your child has provided us with personal information, without your consent, then please contact us using the details below so that we can take steps to remove such information and terminate any account your child has created with us.
7. ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION
You have the following rights in relation to your personal information: (i) the right to be informed about how your personal information is being used; (ii) the right to access the personal information we hold about you; and (iii) the right to request the correction of inaccurate personal data we hold about you and to request the blocking or deletion of your personal information where the processing does not comply with local data protection laws. To exercise any of the above rights, or if you have any questions relating to your rights, please contact us by using the details set out in the “Contacting us” section below. Please provide as much information as you can about the personal information you are looking for and we will be happy to try and help you find it.
8. LINKS TO THIRD PARTY SITES
Our site may, from time to time, contain links to and from third party websites of our partner networks, advertisers, partner merchants, news publications, retailers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. Please check the individual policies before you submit any information to those websites.
9. INCORPORATION OF SERVICES AND CONTENTS FROM THIRD PARTIES INTO OUR WEBSITES
Content of third parties, such as videos from YouTube, maps of Google Maps, RSS feeds or graphics from other websites, are or will be integrated into our site. This may require that the providers of the content (“third-party provider”) will process the IP address or other personal information about you. Without this information the third-party provider may not be able to provide content for you to view or use. Where an IP address or other personal information is necessary for showing the third-party provider’s content, we try to use content only from those providers that use the IP address or other personal information only for the delivery of such content. However, we have no influence on whether or not the third-party provider will save the IP address or other personal information for their own use, e.g. for statistical purposes.
10. CHANGES TO THIS POLICY
11. NOTICE TO YOU
12. CONTACTING US
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