CONTENTS
____________________________________________________________
CLAUSE
Welcome
to the Pinsane's privacy policy.
1. IMPORTANT INFORMATION AND WHO
WE ARE
2. THE DATA WE COLLECT ABOUT YOU
3. HOW IS YOUR PERSONAL DATA
COLLECTED?
4. HOW WE USE YOUR PERSONAL DATA
5. DISCLOSURES OF YOUR PERSONAL
DATA
1. Important information and who we are
Purpose of this privacy policy
This
website is not intended for children and we do not knowingly collect data
relating to children.
Full
name of legal entity: Laura-Beth Harris t/a
Pinsane
Email
address: pins@pinsane.co.uk
Postal
address: Ray Cottage, Orchard Close, New Denham, UB9
4BB
You
have the right to make a complaint at any time to the Information
Commissioner's Office (ICO), the UK supervisory authority for data protection
issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns
before you approach the ICO so please contact us in the first instance.
Changes
to the privacy policy and your duty to inform us of changes
We keep
our privacy policy under regular review.
2. The data we collect about you
· Identity
Data includes first name, maiden name, last
name, username or similar identifier, marital status, title, date of birth and
gender.
· Contact
Data includes billing address, delivery
address, email address and telephone numbers.
· Financial
Data includes bank account and payment card
details.
· Transaction
Data includes details about payments to and
from you and other details of products and services you have purchased from us.
· Technical
Data includes 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 includes your username and password,
purchases or orders made by you, your interests, preferences, feedback and
survey responses.
· Usage
Data includes information about how you use
our website, products and services.
· Marketing
and Communications Data includes your preferences in receiving
marketing from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as
statistical or demographic data for any purpose. Aggregated Data could be
derived from your personal data but is not considered personal data in law as
this data will not directly or
indirectly reveal your identity. For example, we may aggregate your Usage Data
to calculate the percentage of users accessing a specific website feature. However,
if we combine or connect Aggregated Data with your personal data so that it can
directly or indirectly identify you, we treat the combined data as personal
data which will be used in accordance with this privacy policy.
We do not collect any Special Categories of Personal Data about
you (this includes details about your race or ethnicity, religious or
philosophical beliefs, sex life, sexual orientation, political opinions, trade
union membership, information about your health, and genetic and biometric
data). Nor do we collect any information about criminal convictions and
offences.
If you
fail to provide personal data
Where we need to collect personal data by law, or under
the terms of a contract we have with you, and you fail to provide that data
when requested, we may not be able to perform the contract we have or are
trying to enter into with you (for example, to provide you with goods or
services). In this case, we may have to cancel a product or service you have
with us but we will notify you if this is the case at the time.
3. How is your personal data collected?
We use
different methods to collect data from and about you including through:
· Direct interactions. You may give us your Identity, Contact and Financial Data by
filling in forms or by corresponding with us by post, phone, email or
otherwise. This includes personal data you provide when you:
· apply for our products or services;
· create an account on our website;
· subscribe to our service or publications;
· request marketing to be sent to you;
· enter a competition, promotion or survey; or
· give us feedback or contact us.
· Automated technologies or interactions. As you interact with our website, we will automatically collect
Technical Data about your equipment, browsing actions and patterns. We collect
this personal data by using cookies, server logs and other similar technologies.
· Third parties or publicly available sources. We will receive personal data about you from various third parties
as set out below:
Technical
Data from the following parties:
(a) analytics providers such as Google based
outside the EU;
(b) advertising networks; and
(c) search information providers.
· Contact, Financial and Transaction Data from providers of technical,
payment and delivery services such as PayPal (Europe) S.à r.l. et Cie, S.C.A
based inside the EU.
4. How we use your personal data
· 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 a legal obligation.
Purposes
for which we will use your personal data
Purpose/Activity |
Type of data |
Lawful basis for processing including basis of
legitimate interest |
To register
you as a new customer |
(a) Identity (b) Contact |
Performance
of a contract with you |
To process
and deliver your order including: (a) Manage
payments, fees and charges (b) Collect
and recover money owed to us |
(a) Identity (b) Contact (c) Financial (d)
Transaction (e)
Marketing and Communications |
(a)
Performance of a contract with you (b)
Necessary for our legitimate interests (to recover debts due to us) |
To manage
our relationship with you which will include: (a)
Notifying you about changes to our terms or privacy policy (b) Asking
you to leave a review or take a survey |
(a) Identity (b) Contact (c) Profile (d)
Marketing and Communications |
(a)
Performance of a contract with you (b)
Necessary to comply with a legal obligation (c)
Necessary for our legitimate interests (to keep our records updated and to
study how customers use our products/services) |
To enable
you to partake in a prize draw, competition or complete a survey |
(a) Identity (b) Contact (c) Profile (d) Usage (e)
Marketing and Communications |
(a)
Performance of a contract with you (b)
Necessary for our legitimate interests (to study how customers use our
products/services, to develop them and grow our business) |
To
administer and protect our business and this website (including
troubleshooting, data analysis, testing, system maintenance, support,
reporting and hosting of data) |
(a) Identity (b) Contact (c) Technical |
(a)
Necessary for our legitimate interests (for running our business, provision
of administration and IT services, network security, to prevent fraud and in
the context of a business reorganisation or group restructuring exercise) (b)
Necessary to comply with a legal obligation |
To deliver
relevant website content and advertisements to you and measure or understand
the effectiveness of the advertising we serve to you |
(a) Identity (b) Contact (c) Profile (d) Usage (e)
Marketing and Communications (f) Technical |
Necessary
for our legitimate interests (to study how customers use our
products/services, to develop them, to grow our business and to inform our
marketing strategy) |
To use data
analytics to improve our website, products/services, marketing, customer
relationships and experiences |
(a) Technical (b) Usage |
Necessary
for our legitimate interests (to define types of customers for our products
and services, to keep our website updated and relevant, to develop our
business and to inform our marketing strategy) |
To make
suggestions and recommendations to you about goods or services that may be of
interest to you |
(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications |
Necessary
for our legitimate interests (to develop our products/services and grow our
business) |
We will get your express opt-in consent before we share
your personal data with any third party for marketing purposes.
5. Disclosures of your personal data
· Internal Third Parties as set out in the Glossary.
· External Third Parties as set out in the Glossary.
· Specific third parties listed in the table Purposes for which we will
use your personal data above.
· Third parties to whom we may choose to sell, transfer or merge parts of
our business or our assets. Alternatively, we may seek to acquire other
businesses or merge with them. If a change happens to our business, then the
new owners may use your personal data in the same way as set out in this
privacy policy.
We do
not transfer your personal data outside the European Economic Area (EEA).
How
long will you use my personal data for?
If you
wish to exercise any of the rights please contact us.
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). You can obtain further information about how
we assess our legitimate interests against any potential impact on you in
respect of specific activities by contacting us.
Performance of 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 obligation means processing your personal data
where it is necessary for compliance with a legal obligation that we are
subject to.
· Service providers who provide IT and system administration services.
· Professional advisers acting as processors or joint controllers
including lawyers, bankers, auditors and insurers who provide consultancy,
banking, legal, insurance and accounting services.
· HM Revenue & Customs, regulators and other authorities acting as
processors or joint controllers based in the United Kingdom who require
reporting of processing activities in certain circumstances.
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:
· If you want us to establish the data's accuracy.
· Where our use of the data is unlawful but you do not want us to erase it.
· 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.
· You have objected to our use of your data but we need to verify whether
we have overriding legitimate grounds to use it.
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.