We collect, use and are responsible for certain personal information about you. When we do so we are subject to the General Data Protection Regulation, which applies across the European Union (including in the United Kingdom) and we are responsible as ‘controller’ of that personal information for the purposes of those laws.
Key termsIt would be helpful to start by explaining some key terms used in this policy:
|We, us, our||Twin Busch UK Ltd and our group companies|
|Personal information||Any information relating to an identified or identifiable individual|
Personal information we collect about youWe may collect and use the following personal information about you:
- your name and contact information, including email address and telephone number and company details
- Information to enable us to check and verify your identity, e.g. your date of birth
- your gender information, if you choose to give this to us
- location data, if you choose to give this to us
- your billing information, transaction and payment card information
- your [contact history,] purchase history and saved items
- information to enable us to undertake credit or other financial checks on you
- Information about how you use our website, IT, communication and other systems
How your personal information is collectedWe collect most of this personal information directly from you—in person, by telephone, text or email and/or via our website . However, we may also collect information:
- from publicly accessible sources, e.g. Companies House;
- directly from a third party, e.g.:
- credit reference agencies;
- customer due diligence providers;
- leasing/financing providers;
- from a third party with your consent, e.g. your bank or building society
- via our IT systems, e.g. automated monitoring of our websites and other technical systems, such as our computer networks and connections, CCTV and access control systems, communications systems andemail systems;
How and why we use your personal informationUnder data protection law, we can only use your personal information if we have a proper reason for doing so, eg:
- to comply with our legal and regulatory obligations;
- for the performance of our contract with you or to take steps at your request before entering into a contract;
- for our legitimate interests or those of a third party; or
- where you have given consent.
The table below explains what we use (process) your personal information for and our reasons for doing so:
|What we use your personal information for||Our reasons|
|To provide productsandservices to you||For the performance of our contract with you or to take steps at your request before entering into a contract|
|To prevent and detect fraud against you or Twin Busch UK Ltd||For our legitimate interests or those of a third party, i.e. to minimise fraud that could be damaging for us and for you|
|Conducting checks to identify our customers and verify their identity|
Screening for financial and other sanctions or embargoes
Other processing necessary to comply with legal and regulatory obligations that apply to our business, e.g. under health and safety regulations
|To comply with our legal obligations|
|Ensuring business policies are adhered to, e.g. policies covering security and internet use||For our legitimate interests or those of a third party, i.e. to make sure we are following our own internal procedures so we can deliver the best service to you|
|Operational reasons, such as improving efficiency, training and quality control||For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price|
|Ensuring the confidentiality of commercially sensitive information||For our legitimate interests or those of a third party, i.e. to protect trade secrets and other commercially valuable information|
To comply with our legal and regulatory obligations
|Statistical analysis to help us manage our business, eg in relation to our financial performance, customer base, product range or other efficiency measures||For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price|
|Preventing unauthorised access and modifications to systems||For our legitimate interests or those of a third party, i.e. to prevent and detect criminal activity that could be damaging for us and for you|
To comply with our legal and regulatory obligations
|Updating and enhancing customer records||For the performance of our contract with you or to take steps at your request before entering into a contract|
To comply with our legal and regulatory obligations
For our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about existing orders and new products
|Statutory returns||To comply with our legal and regulatory obligations|
|Ensuring safe working practices, staff administration and assessments||To comply with our legal and regulatory obligations|
For our legitimate interests or those of a third party, eg to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you
|Marketing our products and services to:|
—existing and former customers;
—third parties who have previously expressed an interest in our services;
—third parties with whom we have had no previous dealings.
|For our legitimate interests i.e. to promote our business to existing and former customers|
|External audits and quality checks, e.g. the audit of our accounts||To comply with our legal and regulatory obligations|
Promotional communicationsWe may use your personal information to send you updates (by email, telephone or post) about our productsand services, including exclusive offers, promotions or new productsand services.
We have a legitimate interest in processing your personal information for promotional purposes (see above ‘How and why we use your personal information’). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.
We will always treat your personal information with the utmost respect and never sellor share it with other organisations outside the Twin Busch group for marketing purposes.
You have the right to opt out of receiving promotional communications at any time by:
- contacting us at [firstname.lastname@example.org ]
- using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts
Who we share your personal information withWe routinely share personal information with:
- companies within the Twin Busch group based within the EEA
- third parties we use to help deliver our productsand services to you, e.g. payment service providers, and delivery companies;
- other third parties we use to help us run our business, e.g. website hosts;
- third parties approved by you, eg third party payment providers;
- our insurers and brokers;
- our bank;
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
We will not share your personal information with any other third party.
Where your personal information is heldInformation may be held at our offices and those of our group companies, third party agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal information with’).
Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below: ‘Transferring your personal information out of the EEA’.
How long your personal information will be keptWe will keep your personal information while you have an account with us or we are providing productsand services to you. Thereafter, we will keep your personal information for as long as is necessary:
- to respond to any questions, complaints or claims made by you or on your behalf;
- to show that we treated you fairly;
- to keep records required by law.
When it is no longer necessary to retain your personal information, we will delete or anonymise it.
Transferring your personal information out of the EEATo deliver services to you, it is sometimes necessary for us to share your personal information outside the European Economic Area (EEA), e.g.:
- with our offices outside the EEA;
- with your and our service providers located outside the EEA;
- if you are based outside the EEA.
- where there is an international dimension to the services we are providing to you.
The following countries to which we may transfer personal information have been assessed by the European Commission as providing an adequate level of protection for personal information;Andorra, Argentina, Canada, Faroe Islands, Guernsey, Israel, Isle of Man, Jersey, New Zealand, Switzerland, Uruguay and the United States of America (limited to the Privacy Shield framework)
Except for the countries listed above, these non-EEA countries do not have the same data protection laws as the United Kingdom and EEA. We will, however, ensure the transfer complies with data protection law and all personal information will be secure.
If you would like further information please contact us(see ‘How to contact us’ below).
Your rightsYou have the following rights, which you can exercise free of charge:
|Access||The right to be provided with a copy of your personal information (the right of access)|
|Rectification||The right to require us to correct any mistakes in your personal information|
|To be forgotten||The right to require us to delete your personal information—in certain situations|
|Restriction of processing||The right to require us to restrict processing of your personal information—in certain circumstances, e.g. if you contest the accuracy of the data|
|Data portability||The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations|
|To object||The right to object:|
—at any time to your personal information being processed for direct marketing (including profiling);
—in certain other situations to our continued processing of your personal information, eg processing carried out for the purpose of our legitimate interests.
|Not to be subject to automated individual decision-making||The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you|
For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please:
- email, call or write to us—see below: ‘How to contact us’; and
- let us have enough information to identify you (e.g. your full name, address and order reference number);
- let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
- let us know what right you want to exercise and the information to which your request relates.
Keeping your personal information secureWe have appropriate security measures to prevent personal information from being accidentally lost, or used or accessed unlawfully. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
How to complainWe hope that we can resolve any query or concern you may raise about our use of your information.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns or telephone: 0303 123 1113.
We may change this privacy notice from time to time—when we do we will inform you via a notice on our website.
Our contact details are shown below:
Address: Twin Busch UK LTD
Unit 9 Linnell Way
Telford Way Industrial Estate
Tel: 01536 522 960
Do you need extra help?If you would like this notice in another format (for example audio, large print, braille) please contact us (see ‘How to contact us’ above).
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