Introduction
Welcome to the privacy notice of Wendy Freestone
Wendy Freestone respects your privacy and is committed to protecting your
personal data. This privacy notice will inform you as to how we look after
your personal data which you provide to us when you enter into a contract
with us to purchase goods or services through our online store, make
payment to us, make an enquiry to us, visit our website at
www.wendyfreestone.co.uk (regardless of where you visit it from) or
otherwise. This privacy notice will also tell you about your privacy rights
and how the law protects you. In case of conflict, this privacy notice
shall prevail over any contract with us to purchase goods or services
through our online store.
Whenever you give us personal data, you are consenting to its collection
and use in accordance with this privacy notice, including our use of
cookies. If you give us personal data on behalf of someone else, you are
confirming that you have given them the information in this privacy notice
and that they have agreed for us to use their personal data in the way we
describe in this privacy notice.
Please use the Glossary to understand the meaning of some of the terms used
in this privacy notice.
Purpose of this privacy notice
This privacy notice aims to give you information on how Wendy Freestone
collects and processes your personal data which you provide to us when you
enter into a contract with us to purchase goods or services through our
online store, make payment to us, make an enquiry to us, visit our website
(regardless of where you visit it from) or otherwise.
It is important that you read this privacy notice together with any other
privacy notice or fair processing notice we may provide on specific
occasions when we are collecting or processing personal data about you so
that you are fully aware of how and why we are using your data. This
privacy notice supplements the other notices and is not intended to
override them.
Controller
Wendy Freestone is the controller and is responsible for your personal data
(collectively referred to as the “Company”, “we”, “us” or “our” in this
privacy notice).
We have appointed a data privacy manager who is responsible for overseeing
questions in relation to this privacy notice. If you have any questions
about this privacy notice, including any requests to exercise your legal
rights, please contact the data privacy manager using the details set out
below.
Contact details
Our full details are:
Wendy Freestone – for the attention of the data privacy manager
44 Board Lane, Evenley, Brackley, Northants NN13 5SF
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 notice and your duty to inform us of changes
This version was last updated in May 2018 and historic versions can be
obtained by contacting us.
It is important that the personal data we hold about you is accurate and
current. Please keep us informed if your personal data changes during your
relationship with us.
Third-party links on our website
Our website may include links to third-party websites, plug-ins and
applications. Clicking on those links or enabling those connections may
allow third parties to collect or share data about you. We do not control
these third-party websites and are not responsible for their privacy
statements. When you leave our website, we encourage you to read the
privacy notice of every website you visit.
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).
We may collect, use, store and transfer different kinds of personal data
about you which we have grouped together as follows:
We may also collect, use and share Aggregated Data such as
statistical or demographic data for any purpose. Aggregated Data may be
derived from your personal data but is not considered personal data in law
as this data does not directly or indirectly reveal your
identity. For example, we may aggregate your Usage Data to calculate the
percentage of users accessing a specific feature of our website. However,
if we combine or connect Aggregated Data with your personal data so that it
can directly or indirectly identify you, we will treat the combined data as
personal data which will be used in accordance with this privacy notice.
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 contract you have with us but we will notify
you if this is the case at the time.
We may use different methods to collect data from and about you including
through:
We may also record phone conversations we have with you.
We will only use your personal data when the law allows us to. Most
commonly, we will use your personal data in the following circumstances:
Generally we do not rely on consent as a legal basis for processing your
personal data other than in relation to sending direct marketing
communications to you via email or text message. 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, in a table format, a description of all the 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 in the table below.
Marketing
We strive to provide you with choices regarding certain personal data uses,
particularly around marketing and advertising.
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 goods, services, offers and
other information (such as in respect of events we may run or news updates
we may provide) may be relevant for you (we call this marketing).
You may receive marketing communications from us if you have requested
information from us, purchased goods or services from us, or if you
provided us with your details when you entered a competition or registered
for a promotion. In each case, you will only receive such marketing by
electronic means (such as by email or text) if you have opted-in to receive
that marketing and have not subsequently opted out of receiving that
marketing.
Third-party marketing
We will also get your express opt-in consent before we share your personal
data with any company outside the Company (or our group) for marketing
purposes.
Opting out
You can ask us or third parties to stop sending you marketing messages at
any time by following the opt-out links on any marketing message sent to
you or by contacting us at any time.
Cookies
We may use cookies to monitor how people use our website. This helps us to
understand how our customers and potential customers use our website so we
can improve things like layout, function and design.
A cookie is a piece of information stored on your computer’s hard drive
that records how you have used a website. The next time you visit that
website, it can tailor your options based on the information it has stored
about your last visit.
You can set your browser to refuse all or some browser cookies, or to alert
you when websites set or access cookies. If you disable or refuse cookies,
please note that some parts of our website may become inaccessible or not
function properly.
Further information can be found at
https://ico.org.uk/for-the-public/online/cookies.
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.
We may have to share your personal data with the parties set out below for
the purposes set out in the table in paragraph 4 above.
We require all third parties to respect the security of your personal data
and to treat it in accordance with the law. We would not allow any
third-party service providers to us to use your personal data for their own
purposes and would only permit them to process your personal data for
specified purposes and in accordance with our instructions.
We do not generally transfer your personal data outside the European
Economic Area (“EEA”). However, some External Third Parties may run their
operations outside of the EEA. Although they may not be subject to the same
data protection laws as organisations based in the UK, we will take steps
to make sure they provide an adequate level of protection in accordance
with UK data protection law. By submitting your personal information to us
you agree to this transfer, storing or processing at a location outside of
the EEA.
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.
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 available from us by request. Please be aware that, by law, we have to
keep basic information about our customers (including Contact, Identity,
Financial and Transaction Data) for six years after they cease being
customers for tax purposes.
In some circumstances you can ask us to delete your data. Please see 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.
Under certain circumstances, you have rights under data protection laws in
relation to your personal data. These are explained in the Glossary.
If you wish to exercise any of these rights, 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.
LAWFUL BASIS
Legitimate Interest
means the interest of our business in conducting and managing our business
to enable us to give you the best goods and services 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
Internal Third Parties
Other companies in the Company’s group, acting as joint controllers or
processors.
External Third Parties
include:
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 goods or services to you. We will advise you if this is
the case at the time you withdraw your consent.