23. Data Processing and Privacy Policy

Version: May 2018

Please read this privacy policy carefully: by accessing the Website, or ordering any item from us, you confirm that you have read, understood and agree to this privacy policy in its entirety. If you do not agree to this privacy policy in its entirety, you must not use the Website. If you have any questions relating to this privacy policy, please contact us at info@thorndale.co.uk

This policy sets out the basis on which we collect and process your personal data through your use of our website, and/or signing up for newsletters, competitions and other marketing activities either in-store or online.

Any changes we make to this policy in the future will be posted on this page and, if appropriate, notified to you by email so please check this page regularly.

Who we are

The Website is operated by LS Manufacturing UK Ltd a company registered in England and Wales with company number 04767368. VAT number: 100471626

In this privacy policy, "we" "us" and "our" mean LS Manufacturing UK Ltd t/a Thorndale and "you" and "your" means the individual accessing the Website. We respect your right to privacy and will only process personal information you provide to us in accordance with the Data Protection Act 1998, the Privacy and Electronic Communications (EC Directive) Regulations 2003 and other applicable privacy laws. If you have any questions about how we collect, store and use personal information, or if you have any other privacy related questions, please contact us by any of the following means:

Email us at: info@thorndale.co.uk

Write to us at: Thorndale c/o LS Manufacturing UK Ltd, Sidney Street, Wolverhampton. WV2 4HL

YOUR PERSONAL DATA

Information you provide to us

You will provide some or all of the following information to us when you purchase goods from our website, register a customer account with us, contact us, or sign up for newsletters and other marketing activities online:

  • Your Identity and Contact Details -includes your name, email address, home postal address/billing address, delivery address (if different), and your contact telephone number;
  • Your Payment Details - your bank details and payment card details, however your payment transactions will be encrypted by the acquiring bank so we will not retain any payment card details submitted by you;
  • Your Profile Data - if you register a customer account, this includes the profile you create to identify yourself when connecting to our website (including your username and password) and other data about purchases and your personal preferences;
  • Additional Personal Details - At your option, you can also provide additional personal information to us such as your date of birth, gender, product preferences and interests. This additional information would only be collected and stored by us for the purpose of analysing sales to help us understand and improve our business and for the purpose of any direct marketing which you may have expressly given your consent to.

We do not collect any categories of sensitive personal data and this website is not intended for children so we do not knowingly collect data relating to children.

WHAT WE USE YOUR PERSONAL DATA FOR

Data protection law in the UK allows us to collect, use, store and transfer personal information if we have one or more of the following purposes for doing so:

  • To fulfill a contract with you; or
  • Where necessary to comply with a legal or regulatory obligation; or
  • Where necessary for our legitimate interests (or those of a third party) provided your interests and fundamental rights do not override these interests); or
  • For other reasons where you have expressly consented to those purposes.

Below are the ways we will use your personal data to fulfill your contract and/or for our legitimate interests:

  • Processing your order, including taking payment, supplying products and any after sales services such as cancellations and returns;
  • identify verification and credit checking;
  • keeping you updated on the progress of your order, we will usually communicate with you about your order by email, but we or our couriers may also contact you by phone;
  • where you have registered with us, processing and administering your account;
  • processing information required for competition, promotion or survey entries by you;
  • allowing you to participate in interactive features of our service if you choose to do so;
  • analysing sales to help us understand and improve our business;
  • administration, analysis and assessment of our website and its performance, to understand and develop our business and for the improvement and optimisation of our website; and
  • as part of our efforts to keep our website safe and secure.

Direct Marketing

We need your consent for direct marketing communications. If you have expressly given your consent to receive direct marketing from us, whether via our website, or in store, we may use the information you have given us for:

  • delivering direct marketing, advertising and updates from us to you, such as telling you about forthcoming events, products, services and offers and updates and information about us;
  • measuring and understanding the effectiveness of advertising we serve to you and others; and
  • making suggestions and recommendations to you and other users of our website and our Apps about goods or services that may interest you or them.

At any time you can opt out of direct marketing or change your preferences. For further information on how to do this, please see below for ‘Opting out of Marketing and preference updates’

WHO WE SHARE YOUR PERSONAL DATA WITH

We may share your information with our selected third parties for the purposes referred to above. For example:

  • Payment Acquiring Services to process your payment;
  • Delivery and Courier Companies to supply your order;
  • Credit Reference & Fraud Prevention Agencies for credit checking and identity verification;
  • Analytics and search engine providers that assist us in the improvement and optimisation of our website and Apps;
  • Build and hosting service providers that help us to maintain the software that runs our website. They provide us with reporting statistics, and serve cookies on our behalf to enable any website personalisation and sign-in functionality. See below for more information on cookies.
  • Where you opted in to direct marketing, third party advertisers, affiliate marketing agencies and advertising networks engaged by us to select and serve relevant communications to you on our behalf.

We require all third parties engaged by us to respect the security of your personal data and to treat it in accordance with the law. Such third parties are only allowed to process your personal data in accordance with our instructions, and not for their own purposes.

From time to time, we may ask you if you would like to be contacted by other selected third parties, such as part of a joint promotion or a collaboration. If we do this, we will also provide you with a link to that third party’s privacy policy to help you decide whether or not you wish to be contacted by them. If you do consent to this (by an express opt in), that third party would be the data controller in respect of any activity by them that you have consented to.

OPTING OUT OF MARKETING AND PREFERENCE UPDATES

If you no longer wish to receive direct marketing and updates from Thorndale you can unsubscribe at any time by clicking on the link in the footer of the email. Alternatively you can contact customers services on 01902 711823 or email info@thorndale.co.uk. If you are a registered online customer you can also opt out and amend your preference settings within your login profile under "My Account".

SECURITY OF YOUR PERSONAL DATA

Our website has appropriate security measures in place to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. All information you provide to us is stored on secure servers. We have also put in place procedures to deal with any suspected personal data breach.

Where you have chosen a password which enables you to access certain parts of our website, you are responsible for keeping this password confidential. We ask you to choose an effective, secure password and not to share your password with anyone.

We recommend only connecting to secure wireless networks that you trust to reduce the risk of unauthorised people intercepting your online activity. Beware of the risks of using public wifi.

If you receive an email purporting to be from Thorndale asking for personal data, please do not respond to the email but please let us know that this has happened so we can check whether the email is genuine.

Please note, whilst we take appropriate technical and organizational measures to safeguard the personal information that you provide to us, no transmission over the Internet can ever be guaranteed to be secure. Consequently, please note that we cannot guarantee the security of any personal information that you transfer over the Internet to us.

HOW LONG WE KEEP YOUR PERSONAL DATA

We will keep your data for as long as you are a customer and thereafter we may keep it for longer in order to respond to any questions or complaints and to maintain necessary records to satisfy legal, accounting or reporting requirements. We may also keep your data for research or statistical purposes.

YOUR RIGHTS

You have the right to object to our use of your personal information, or to ask us to delete, remove or stop using it if there is no need for us to keep it. Please let us know if you think we should not be using it, but please be aware that there may be legal or other official reasons why we need to keep or use your information.

Your rights under data protection laws in relation to your personal data are briefly summarised below, and you can exercise these rights by emailing us at info@thorndale.co.uk or by writing to us at Thorndale c/o LS Manufacturing UK Ltd, Sidney Street, Wolverhampton. WV2 4HL

  • 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. Please note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which we will tell you about, if applicable, after receiving 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.
  • Request restriction of processing of your personal data. You can 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; © 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. Please 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 if we are relying on your consent to process your personal data (such as direct marketing and cookies). This won’t affect any processing already carried out before you withdraw your consent or processing under other grounds. If you withdraw your consent, we may not be able to provide certain products or services to 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.

You will not have to pay a fee to access your personal data and we try to respond to all requests within one month.

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). However, we would appreciate the chance to deal with any concerns you may have before you approach the ICO so please contact us in the first instance.

If you have any questions or require any more information please contact us at info@thorndale.co.uk

Cookies

A cookie is a small file which asks permission to be placed on your computer's hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us. You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.

International transfers

We will not transfer any personal information relating to you to any country outside of the European Economic Area, without your consent.

Third party sites

Please note that this privacy policy applies only to the personal information that we collect and we cannot be responsible for personal information that third parties may collect, store and use through their websites. You should always read the privacy policy of each website you visit carefully.

International transfers

We will not transfer any personal information relating to you to any country outside of the European Economic Area, without your consent.

Third party sites

Please note that this privacy policy applies only to the personal information that we collect and we cannot be responsible for personal information that third parties may collect, store and use through their websites. You should always read the privacy policy of each website you visit carefully.