BOSS DIRECT LTD – PRIVACY POLICY
1. Purpose of this Policy
This privacy notice is to let you have information on how Boss Direct Ltd collects & processes your personal data through your use of our website.
It is important that you read this privacy notice so you can understand how we are using any personal data you provide.
Questions & Complaints
Please see below contact details if you have any questions relating to this policy.
Contact: Caroline Russell
Position: Sales Director
Email address: caroline@bossdirect.co.uk
Tel: 01204 458888
Postal address: Philips Road.Whitebirk Industrial Estate
Blackurn. BB1 5NA
If you wish to make a complaint, we would like the opportunity to rectify any issues, however you have the right to complain direct to the Information Commissioner’s Office (ICO) which is the UK supervisory authority for data protection. (www.ico.org.uk)
If any of your personal data changes during your business with us please keep us informed. It is important to us that the data we hold is accurate.
Third Part Links
Our website may include links to third party companies, we have not control over these websites and their privacy policies. Clicking on these may enable connections for the third party to collect or share your data.
2. The data we collect
Personal data, or personal information, means any information about an individual from which that person can be identified.
Different kinds of personal data may be stored under any of the following categories
- Identity data – first and last name, username, marital status, Date of birth and gender
- Contact data – email address, invoice address, delivery address and contact telephone numbers
- Financial data – payment card & account details
- Transaction data – details of products and services purchased, details of payments made or received
- Technical data – internet protocol (IP) address, your log-in details, operating system and other technology on the devises you use to access our website.
- Profile data – details of order history, and your username and password
- Marketing – this shows what format you would like to receive marketing information
We would also collect analytic data which would show gap analysis on products purchased/not purchased. How many customers use/don’t use our website for ordering, this is not considered to be personal as it is product/system based.
No data relating to health, sexual orientation, political, race, region, etc would never be collected
Failure to provide personal data
Under our terms and conditions, we require by law for you to provide certain details, ie: Company Registration or VAT Numbers to enter into contract for us to provide goods and services.
3. How your personal data is collected.
Your personal data is collected in many ways, as below:
- Contacting us to open an account
- Filling out an account application form
- Creating an account on our website
- Requested marketing material sent via email/post
- Making payments via credit/debit card
- Making bank payments (BACS)
4. How we use your personal data
We will only use your personal data where the law allows us to.
Mainly in the following situations:
- Where we need to set up the contract being entered in to
- 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 or regulatory obligation.
See the Glossary to find out more about the types of lawful basis that we will rely on to process your personal data.
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.
You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
We have set out below a description of ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out below.
To register you as a new customer
To process and deliver your order including payments
To enable you to partake in any competition or surveys
To keep you updated about any changes in our business
To deliver relevant information and monitor the effectiveness of this
To use data analytics to improve our website and customer relations
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing)
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you registered for our email promotions and / or newsletter and, in each case, you have not opted out of receiving that marketing.
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly in relation to marketing and advertising.
Opting out
You can opt out at any time from receiving marketing information by contact us.
Cookies
You can set your browser to refuse all or some cookies, or to alert you when websites set of access cookies. If you disable or refuse cookies, please be aware that some parts of our website may not function properly.
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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
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.
5. Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in paragraph 4
External Third Parties as set out in the Glossary.
Third Parties such as distribution partners and couriers
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.
6. International transfers
We do not transfer your personal data outside the European Economic Area (EEA).
7. Data security
We have put in place appropriate 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.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as 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.
Details of retention periods for different aspects of your personal data are set out in the table in paragraph 4 above.
In some circumstances you can ask us to delete your data: see request erasure. below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing of your personal data.
- Request the transfer of your personal data.
- Right to withdraw consent at any time.
If you wish to exercise any of the rights set out above, please contact us.
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.
10. Glossary
LAWFUL BASIS
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 or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
THIRD PARTIES
External Third Parties
- Service providers who provide IT and system administration services.
- Logistics partners, couriers and direct deliveries via manufacturers
- Professional advisers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.
YOUR LEGAL RIGHTS
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.
Caroline Russell
Sales Director, Boss Direct Limited
January 2022
