Draft Policy | 2021 | Draft
1. SECTION 1 – DATA PROTECTION PRINICPLES
We are committed to protecting the privacy and security of your personal information. This privacy notice describes how we collect and use personal information about you during and after your relationship with us, in accordance with the General Data Protection Regulations (GDPR).
GDPR states that the personal information we hold about you must be:
a) Used lawfully, fairly and in a transparent way.
b) Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
c) Relevant to the purposes we have told you about and limited only to those purposes.
d) Accurate and kept up to date.
e) Kept only as long as necessary for the purposes we have told you about.
f) Kept securely.
2. SECTION 2 – INFORMATION WE HOLD ABOUT YOU AND WHY
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
When you make a purchase from our store, and as part of the transaction or when you sign up to the newsletter, we will collect, store, and use the following categories of personal information about you:
1. Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses.
2. Your computers protocol (IP) address. This will be collected when you browse the store online.
We process the above data for appropriate lawful purposes as follows:
Provision of services. The completion of a contract to purchase outdoor goods such as clothing, footwear, accessories or equipment;
Provision of marketing further information. We undertake marketing activities therefore we have carried out the following steps to ensure that when we do so we are compliant:
1. We have checked that consent is the most appropriate lawful basis for processing.
2. We have made the request for consent prominent and separate from our terms and conditions.
3. We ask people to positively opt in.
4. We tell individuals they can withdraw their consent.
5. We ensure that individuals can refuse to consent without detriment.
1. We keep a record of when and how we got consent from the individual.
2. We keep a record of exactly what they were told at the time.
We will not share your data, other than with the necessary third parties such as credit card companies, postal organizations and if there is a legal requirement. We will also not hold or transfer your data outside the UK.
We will normally hold personal data for no longer than 12 months unless there is a legal obligation to hold it for longer.
3. SECTION 3 - CONSENT
How do you get my consent?
When you provide us with personal information to complete a transaction, verify your credit card, place an order, arrange for a delivery or return a purchase, we imply that you consent to our collecting it and using it for that specific reason only.
If we ask for your personal information for a secondary reason, like marketing, we will ask you directly for your expressed consent and provide you with an opportunity to say no.
How do I withdraw my consent?
If after you opt-in, you change your mind, you may withdraw your consent for us to contact you, for the continued collection, use or disclosure of your information, at any time, by contacting us at email@example.com.
You can also withdraw consent using the “unsubscribe me” button which is included at the bottom of every marketing e-mail which we send you.
4. SECTION 4 - DISCLOSURE
We may disclose your personal information if we are required by law to do so or if you violate our Terms of Service.
5. SECTION 5 – WEBSITE
Our website is provided to you by an ecommerce or content management system and hosted on a purpose-built secure server, behind a firewall. Your personnal information is stored and secured within our business systems on purpose-built servers situated behind a firewall.
For websites hosted on Shopify Inc. They provide us with the online e-commerce platform that allows us to sell our products and services to you. Your data is stored through Shopify’s data storage, databases and the general Shopify application. They store your data on a secure server behind a firewall.
We will keep and process your personal data only for as long as is necessary for the purposes for which it was collected in connection with your relationship with us, unless we have a legal right or obligation to retain the data for a longer period, or the data is necessary for the establishment, exercise or defence of legal claims.
If you choose a direct payment gateway to complete your purchase, then Shopify stores your credit card data. It is encrypted through the Payment Card Industry Data Security Standard (PCI-DSS). Your purchase transaction data is stored only as long as is necessary to complete your purchase transaction. After that is complete, your purchase transaction information is deleted.
All direct payment gateways adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover.
PCI-DSS requirements help ensure the secure handling of credit card information by our store and its service providers.
Where our Payment Service Provider is Opayo (formerly Sage Pay & Protx) (the largest independent payment service provider (PSP) in the UK and Ireland).
Opayo provides a secure payment gateway (Level 1 PCI DSS), processing payments for thousands of online businesses, including ours. It is Opayo’s utmost priority to ensure that transaction data is handled in a safe and secure way.
Opayo uses a range secure methods such as fraud screening, I.P address blocking and 3D secure. Once on the Opayo systems, all sensitive data is secured using the same internationally recognised 256-bit encryption standards.
Opayo is PCI DSS (Payment Card Industry Data Security Standard) compliant to the highest level and maintains regular security audits. They are also regularly audited by the banks and banking authorities to ensure that their systems are impenetrable.
Opayo is an active member of the PCI Security Standards Council (PCI SSC) that defines card industry global regulation.
In addition, you know that your session is in a secure encrypted environment when you see https:// in the web address, and/or when you see the locked padlock symbol alongside the URL.
So when buying through our site, you can be sure that you are completely protected.
Where we accept payment via Amazonpay this is secure and fully PCI compliant. We have no access to your credit or debit card information via Amazon Pay.
Where we accept payment via PayPal this is secure and fully PCI compliant. We have no access to your credit or debit card information via Paypal.
6. SECTION 6 - THIRD-PARTY SERVICES
In general, the third-party providers used by us will only collect, use and disclose your information to the extent necessary to allow them to perform the services they provide to us (eg postal services). However, certain third-party service providers, such as payment gateways and other payment transaction processors, have their own privacy policies in respect to the information we are required to provide to them for your purchase-related transactions.
For these providers, we recommend that you read their privacy policies so you can understand the manner in which your personal information will be handled by these providers.
In particular, remember that certain providers may be located in or have facilities that are located a different jurisdiction than either you or us. So if you elect to proceed with a transaction that involves the services of a third-party service provider, then your information may become subject to the laws of the jurisdiction(s) in which that service provider or its facilities are located.
As an example, if you are located in Canada and your transaction is processed by a payment gateway located in the United States, then your personal information used in completing that transaction may be subject to disclosure under United States legislation, including the Patriot Act.
Once you leave our store’s website or are redirected to a third-party website or application, you are no longer governed by this Privacy Statement or our website’s Terms of Service.
When you click on links on our store, they may direct you away from our site. We are not responsible for the privacy practices of other sites and encourage you to read their privacy statements.
7. SECTION 7 - SECURITY
To protect your personal information, we take reasonable precautions and follow industry best practices to make sure it is not inappropriately lost, misused, accessed, disclosed, altered or destroyed.
If you provide us with your credit card information, the information is encrypted using secure socket layer technology (SSL) and stored with an AES-256 encryption. Although no method of transmission over the Internet or electronic storage is 100% secure, we follow all PCI-DSS requirements and implement additional generally accepted industry standards.
8. SECTION 8 – COOKIES
A cookie is a small file of letters and numbers that, if you give consent, we store on the internet browser your device is using.
We use the following types of cookies:
- Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
- Analytical or performance cookies. These allow us to recognise and count the number of visitors to our website and to see how visitors move around it. This helps us to improve the way our website works, for example, by ensuring that users can easily finding what they are looking.
- Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
- Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
9. SECTION 9 - AGE OF CONSENT
By using this site, you represent that you are at least the age of majority in your state or province of residence, or that you are the age of majority in your state or province of residence and you have given us your consent to allow any of your minor dependents to use this site.
10. SECTION 10 - CHANGES TO THIS PRIVACY STATEMENT
We reserve the right to modify this privacy statement at any time, so please review it frequently. Changes and clarifications will take effect immediately upon their posting on the website. If we make material changes to this statement, we will notify you here that it has been updated, so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we use and/or disclose it.
You have a duty to inform us of changes to your personal data as it is important that the information we hold about you is accurate and current. Please keep us informed if your personal information changes during the period your data is held by us.
If our store is acquired or merged with another company, your information may be transferred to the new owners so that we may continue to sell products to you.
Questions, Contacts and Resources.
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 to contact us.
Bollin Group Data Protection email: firstname.lastname@example.org
If you would like more information from an external source, we recommend contacting the Information Commissioner's Office (ICO), the UK's independent authority set up to uphold information rights in the public interest, either via their contact form or by phone: 0303 123 1113.