4. Maintaining the security of your data is our priority, and we are committed to respecting your privacy rights. We pledge to handle your data fairly and legally at all times. We are also dedicated to being transparent about what data we collect about you and how we use it.
5. This policy, which applies to any personal data we acquire from you, provides you with information about:
o how we use your data;
o what personal data we collect;
o how we ensure your privacy is maintained; and
o your legal rights relating to your personal data.
HOW WE USE YOUR DATA
6. We, and trusted partners covered by this policy, use your personal data:
o to provide goods and services to you;
o to make a tailored website available to you;
o to manage any registered account(s) that you hold with us;
o to verify your identity;
o for crime and fraud prevention, detection and related purposes;
o with your agreement, to contact you electronically about promotional offers and products and services which we think may interest you;
o for market research purposes - to better understand your needs;
o to enable us to manage customer service interactions with you; and
o where we have a legal right or duty to use or disclose your information (for example in relation to an investigation by a public authority or in a legal dispute).
7. We uses your personal data for electronic marketing purposes (with your consent) and may send you postal mail to update you on the latest offers.
8. We aim to update you about products & services which are of interest and relevance to you as an individual.
9. You have the right to opt out of receiving promotional communications at any time, by contacting us via the contact channels set out in this Policy below.
Our service providers and suppliers
10. In order to make certain services available to you, we may need to share your personal data with some of our service partners. These include IT, delivery and marketing service providers.
11. We only allow our service providers to handle your personal data when we have confirmed that they apply appropriate data protection and security controls. We also impose contractual obligations on service providers relating to data protection and security, which mean they can only use your data to provide services to us and to you, and for no other purposes.
Other third parties
12. Aside from our service providers, we will not disclose your personal data to any third party, except as set out below. We will never sell or rent our customer data to other organisations for marketing purposes.
13. We may share your data with:
o our carefully selected partners who provide our branded products and services, if we have your consent to do so;o credit reference agencies where necessary for card payments;
o governmental bodies, regulators, law enforcement agencies, courts/tribunals and insurers where we are required to do so: -
o to comply with our legal obligations;
o to exercise our legal rights (for example in court cases);
o for the prevention, detection, investigation of crime or prosecution of offenders; and
o for the protection of our employees and customers.
14. To deliver products and services to you, it is sometimes necessary for us to share your data outside of the European Economic Area. This will typically occur when service providers are located outside the EEA or if you are based outside the EEA. These transfers are subject to special rules under data protection laws.
15. If this happens, we will ensure that the transfer will be compliant with data protection law and all personal data will be secure. Our standard practice is to use ‘standard data protection clauses’ which have been approved by the European Commission for such transfers. Those clauses can be accessed here.
How long do we keep your data?
16. We will not retain your data for longer than necessary for the purposes set out in this Policy.
17. Different retention periods apply for different types of data, however the longest we will normally hold any personal data is 6 years
WHAT PERSONAL DATA MIGHT WE COLLECT?
18. We may collect the following information about you:
o your name, age/date of birth and gender;
o your contact details: postal address including billing and delivery addresses, telephone numbers (including mobile numbers) and e-mail address;
o purchases and orders made by you;
o your on-line browsing activities on our websites;
o any password(s) we allocate to you;
o when you make a purchase or place an order with us, your payment card details;
o your communication and marketing preferences;
o your interests, preferences, feedback and survey responses;
o your location;
o your correspondence and communications with us; and
o other publicly available personal data, including any which you have shared via a public platform (such as a Twitter feed or public Facebook page)
19. Our website are not intended for children and we do not knowingly collect data relating to children.
20. The above list is not exhaustive and, in specific instances, we may need to collect additional data for the purposes set out in this Policy. Some of the above personal data is collected directly, for example when you set up an on-line account on our websites, or send an email to our customer services team.
21. Other personal data is collected indirectly, for example your browsing or shopping activity. We may also collect personal data from third parties who have your consent to pass your details to us, or from publicly available sources.
HOW WE PROTECT YOUR DATA
22. We are committed to keeping your personal data safe and secure. Our security measures include:
o encryption of data;
o security controls which protect our IT infrastructure from external attack and unauthorised access; and
o internal policies setting out our data security approach and training for employees
WHAT YOU CAN DO TO HELP PROTECT YOUR DATA
23. We will never ask you to confirm any bank account or credit card details via email. If you receive an email claiming to be from us asking you to do so, please ignore it and do not respond.
24. If you are using a computing device in a public location, we recommend that you always log out and close the website browser when you complete an online session.
25. In addition, we recommend that you take the following security measures to enhance your online safety both in relation to us and more generally:
o keep your account passwords private. Remember, anybody who knows your password may access your account.
o when creating a password, use at least 8 characters. A combination of letters and numbers is best. Do not use dictionary words, your name, email address, or other personal data that can be easily obtained. We also recommend that you frequently change your password.
o avoid using the same password for multiple online accounts
26. You have the following rights:
o the right to ask what personal data that we hold about you at any time, subject to a fee specified by law (currently £10);
o the right to ask us to update and correct any out-of-date or incorrect personal data that we hold about you free of charge; and
o (as set out above) the right to opt out of any marketing communications that we may send you.
27. If you wish to exercise any of the above rights, please contact us using the contact details set out below
28. We collect and use customers’ personal data because is it necessary for:
o the pursuit of our legitimate interests (as set out below);
o the purposes of complying with our duties and exercising our rights under a contract for the sale of goods to a customer; or
o complying with our legal obligations.
29. In general, we only rely on consent as a legal basis for processing in relation to sending direct marketing communications to customers via email or text message.
30. Customers have the right to withdraw consent at any time. Where consent is the only legal basis for processing, we will cease to process data after consent is withdrawn.
Our legitimate interests
31. The normal legal basis for processing customer data, is that it is necessary for our legitimate interests, including:
o selling and supplying goods and services to our customers;
o protecting customers, employees and other individuals and maintaining their safety, health and welfare;
o promoting, marketing and advertising our products and services;
o sending promotional communications which are relevant and tailored to individual customers;
o understanding our customers’ behaviour, activities, preferences, and needs;
o improving existing products and services and developing new products and services;
o complying with our legal and regulatory obligations;
o preventing, investigating and detecting crime, fraud or anti-social behaviour and prosecuting offenders, including working with law enforcement agencies;
o handling customer contacts, queries, complaints or disputes;
o managing insurance claims by customers;
o protecting ourselves, and employees and customers, by taking appropriate legal action against third parties who have committed criminal acts or are in breach of legal obligations to ourselves;
o effectively handling any legal claims or regulatory enforcement actions taken against us; and
o fulfilling our duties to our customers, colleagues, shareholders and other stakeholders
32. If you have any questions about how we use your personal data that are not answered here, or if you want to exercise your rights regarding your personal data, please contact us by any of the following means:
o phone us on: 01636-894900;
o e-mail us at: email@example.com or
o write to us at: Gusto Group Ltd, Millennium Green Business Centre, Rio Drive, Collingham, Newark, Nottinghamshire NG23 7NB
41. You have the right to lodge a complaint with the Information Commissioner’s Office. Further information, including contact details, is available at https://ico.org.uk.
33. This policy was last updated in March 2018