This version is effective from 2 October 2023
When we mention “we”, “us” or “our”, we are referring to Vista Musical Instruments Limited and or one or more of its group companies, including those companies set out below. In relation to information provided through this website or via sales made at one of our Dawsons stores, the data controller is Vista Musical Insturments Limited..
Location: United Kingdom
Vista Musical Instruments UK Limited (company no: 11963924) is a company established under the laws of England and Wales with its registered office at Griffin House, 135 High Street, Crawley, West Sussex, RH10 1DQ, United Kingdom.
Swee Lee Holdings Pte Ltd (company no: 199100662M) is a company established under the laws of Singapore with its registered office at 56 Neil Road Singapore 088830.
Vista Musical Instruments Pte Ltd (company no: 202140151N) is a company established under the laws of Singapore with its registered office at 56 Neil Road Singapore 088830.
Vista Musical Instruments LLC (company no: 6262268) is a company established under the laws of America with its registered office at 225 Parsons St, Kalamazoo, MI 49007, USA.
1. HOW WE COLLECT AND RECEIVE PERSONAL DATA ABOUT YOU AND WHAT INFORMATION WE COLLECT ABOUT YOU
Information you give to us:
- In order to process your requests and orders, it is necessary to collect personal data from you. This includes, but is not limited to: your name, delivery address, billing address, email address, telephone number, partial credit/debit card information, bank account details, Account username, password (“Services Data”).
- We will also collect your first and last name, email address, telephone number and delivery address (“Contact Data”) in order to send you communications as described below.
- We also process data when providing our services such as invoices, orders, details about payments made between you and us, details of products purchased from us (“Transaction Data”). We are unable to provide you with products and services if you do not provide certain information to us.
- You will also be asked to provide additional (non-mandatory) pieces of information such as your interests, preferences, age, gender, feedback, and survey responses so that we can better understand our customers (“Profile Data”). You can also choose to provide such information by posting on a forum, filling out a web form or when you communicate with us.
- If you apply for a job with us we may also collect your date of birth and personal data included in your CV.
- We will also collect your marketing preferences and service communications preferences data (“Marketing and Communications Data”).
Information we collect automatically when you use the Website or Services:
- We collect information about your interaction with our sites and Services from the devices you use, such as your unique device ID, device type, browser type and operating system, your IP address and approximate location at the time of browsing and advertising ID (“Technical Data”).
- We also collect information about your visits and activity on our sites (and sites operated by our Group Companies) including the content and any advertisements that you view and interact with, the address of the site from which you arrived and other technical data about your equipment, browsing actions and patterns (such as the pages you view, the links you click, the items you add to your shopping basket, the length of your internet session) (“Behavioural Data”). This information is collected using cookies, web beacons, pixel tags and other similar technologies (which we generically refer to as “Cookies”). To learn more about these technologies and your choices, go to our Cookie Notice.
Information collected from other sources:
- We may combine your information with information we collect from third parties or public sources, including analytics providers, data brokers, third party directories, advertising networks and third parties that provide us with technical services so that we can improve our sites and our Services.
Information collected from social media:
- Certain sites offer services that require you to set up an account prior to receiving such services. To create a secure Account with us, you can use your email address and a password or, if the site offers a Facebook or Google single-sign-on service, you will be able to register for and log-in to your Account using your Facebook account. If you choose to use the Facebook or Google single-sign-on service, you are granting permission to Facebook or Google to share certain profile information with us. This will include your name, profile picture and list of friends and any other information notified to you by Facebook prior to you completing the single-sign-on authorisation process. You control what social media information you allow us to have access to using the privacy settings on the applicable social media platform and any permissions you give as part of the singlesign-on authorisation process.
Our websites are not intended for children under the age of 13. If you are under 13, please do not provide any information to us and instead ask your parent or guardian to do this on your behalf. You must be at least 18 years of age to purchase products or services from us. If you are under the age of 18, you must ensure that your parent or guardian purchases the products or Services on your behalf.
2. WHO WE COLLECT PERSONAL DATA ABOUT
|If you browse our sites or register an account on our sites, we will collect and process your personal data in connection with your interaction with us and our site.
|If you buy our Services, we may collect and process your personal data in connection with the supply of services to you.
|People who contact us with enquiries
|If you contact us with an enquiry through our sites, submit a complaint through our sites or provide any feedback to us in our surveys and feedback forms, we will collect and process your personal data in connection with your interaction with us and our site.
|People who work for our customers and suppliers
|If you work for one of our customers or suppliers and have responsibility for placing orders with us, administering your organisation’s account with us or handling our orders or our account with your organisation, we will process your personal data in connection with your organisation’s relationship with us.
|Visitors to our physical locations
|If you attend one of our physical stores, offices or other locations, we may process personal data that you volunteer in connection with your visit and any enquiries you make. For example, you may volunteer personal data when asking us to assist you in finding accommodation or transportation suitable for your needs, or when signing in as a guest. CCTV footage may also be collected for security purposes.
|If you attend one of our events, we will process personal data about you in connection with your attendance at the event. For example, we may ask you to complete a registration or feedback form, or other document relating to the event.
|If you apply for a job with us, whether through the site or otherwise, we will collect and process your personal data in connection with your application.
3. HOW WE USE INFORMATION ABOUT YOU
We will use your information for the following purposes:
Use of our sites and the provision of our Services
- Service Access and Registration: We will process your Services Data to register you as a new customer when you purchase product or service from us or create an Account on our website in order to access one of our services.
Our legal basis for processing: It is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you or it is in our legitimate interest to use personal data in such a way to ensure that we provide access to the sites and our products and Services in a secure and effective way and so that we can make improvements to our sites.
- Sales and Fulfilment: We will process your Services Data and your Transaction Data to process and deliver your order; to manage payments, fees and charges; to collect and recover money owed to us; to provide you with services you have requested from us when we collected the information from you, and/or to provide you with certain offers and benefits.
Our legal basis for processing: It is necessary for us to use your personal data in such a way to perform our obligations in accordance with any contract that we may have with you for the products and Services, or it is in our legitimate interest or a third party’s legitimate interest to use personal data in such a way to ensure that we provide our products and services in an effective, safe and efficient way.
- Customer Relationship Management: We will process your Services Data to identify you when you log into your Account, to contact you about your Account, subscription or other order; to provide you with customer service (such as responding to questions, concerns and feedback and contacting you via email, telephone, SMS/text, post, direct message or other similar communication method for this purpose); to notify you of material changes to our terms or this Privacy and Cookies Policy. We will also process certain Technical Data and Marketing and Communications Data so that we can administer your Account; to send you service related communications; to ask you to leave a review or take a survey.
Our legal basis for processing: It is in our legitimate interest to use your personal data in the ways described above to ensure that we are able to help you with your enquiry, provide a good standard of service and improve our customer services. Where we process your personal data in relation to a review or survey it is in our legitimate interest to use the personal data provided by you so that we can improve our sites and our products and Services and provide them in an effective way.
- Contests, Awards, Events, Product Trials, Surveys: to enable you to participate in contests, prize draws, product trials, events, awards, surveys, polls and quizzes and to provide you with any prizes, products or awards as applicable. For the purposes of administering such promotions we may process your Service Data, Profile Data, Behavioural Data and/or Technical Data and any other personal data volunteered by you in relation to your promotion entry.
Our legal basis for processing: It is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you (e.g. the contest terms and conditions) or it is in our legitimate interest to use your personal data to enable us to administer our contest fairly and effectively and to ensure that we comply with self-regulatory codes governing the operation of the contests.
- Systems Administration and Security: We may process your personal data in order to administer and protect our systems and our sites for purposes such as integration, troubleshooting, testing, system maintenance, support, reporting and hosting data; to ensure network and system security and prevent detect, mitigate and investigate fraud, security breaches and other prohibited or illegal activities; to verify your identity.
Our legal basis for processing: It is in our legitimate interest to process your personal data in order to provide administration and IT services, to keep our systems and sites secure and for network security and fraud prevention.
Physical security: We have security measures in place at our premises or venues at which we host events, including CCTV and building access controls. There are signs in place showing that CCTV is in operation. The images captured are securely stored and only accessed on a need to know basis (e.g. to look into an incident). CCTV recordings are typically automatically overwritten after a short period of time unless an issue is identified that requires investigation (such as an allegation of criminal behaviour).
We may require visitors to our premises to sign in on arrival and where that is the case we will keep a record of visitors for a short period of time. Our visitor records are securely stored and only accessible on a need-to-know basis (e.g. to look into an incident).
Our legal basis for processing: It is in our legitimate interests to process your personal data so that we can keep our premises and event venues secure and provide a safe environment for our personnel and visitors to our premises or venues.
- Business administration and legal compliance: We may use your personal data: (i) to comply with our legal obligations; (ii) to enforce our legal rights; (iii) to protect the rights of third parties; and (iv) in connection with a business transition such as a merger, reorganisation, acquisition by another company, or sale of any of our assets.
Our legal basis for processing: Where we use your personal data in connection with a business transition, to enforce our legal rights or to protect the rights of third parties, it is in our legitimate interest to do so. For all other purposes described in this section, we have a legal obligation to use your personal data to comply with any legal obligations imposed upon us, such as a court order.
We will not process any special (or sensitive) categories of personal data or personal data relating to criminal convictions or offences except where we are able to do so under applicable legislation or with your explicit consent.
- Recruitment: We use your personal data for recruitment purposes, in particular, to assess your suitability for any of our positions that you apply for, whether such application has been received by us online, by email or by hard copy and whether submitted directly by you or by a third-party recruitment agency on your behalf. We also use your First name, last name, email address and telephone number to communicate with you about the recruitment process, to keep records about our recruitment process and to comply with our legal and regulatory obligations in relation to recruitment.
We will process any personal data about you that you volunteer, including during any interview, when you apply for a position with us. We may also process your personal data obtained from any third parties we work with in relation to our recruitment activities, including without limitation, recruitment agencies, background check providers, credit reference agencies and your referees.
The personal data we process may include your date of birth, gender, details of your education, qualifications and employment history, any other personal data which appears in your curriculum vitae or application, any personal data that you volunteer during an interview or your interactions with us, or any personal data which is contained in any reference about you that we receive. Such information may also include special categories of personal data (such as information about your health, any medical conditions and your health and sickness records) and information relating to criminal convictions and offences if that information is relevant to the role you are applying for.
We may also use your personal data for the purposes of reviewing our equal opportunity profile in accordance with applicable legislation. We do not discriminate on the grounds of gender, race, ethnic origin, age, religion, sexual orientation, disability or any other basis covered by local legislation. All employment-related decisions are made entirely on merit.
Our legal basis for processing:
Where we use your personal data in connection with recruitment, it will be in connection with us taking steps at your request to enter into a contract we may have with you or it is in our legitimate interest to use personal data in such a way to ensure that we can make the best recruitment decisions.
We will not process any special (or sensitive) categories of personal data or personal data relating to criminal convictions or offences except where we are able to do so under applicable legislation or with your explicit consent.
Receipt of products and services from our suppliers: If we have engaged you or the organisation you represent to provide us with products or services we will collect and process your personal data in order to manage our relationship with you or the organisation you represent, to receive products and services from you or the organisation you represent and, where relevant, to provide our products and Services to others. The personal data we collect from you may include your Contact Data and any other personal data you volunteer which is relevant to our relationship with you or the organisation you represent.
Our legal basis for processing:
It is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you or the organisation you represent, or it is in our legitimate interest to use personal data in such a way to ensure that we have an effective working relationship with you or the organisation you represent and are able to receive the products and services that you or your organisation provides, and provide our products and Services to others, in an effective way.
- Business contacts: If we are engaging with you for a potential collaboration or business opportunity we may process your Contact Data including additional data such as your business card in order to contact you in relation to this opportunity.
Our legal basis for processing:
It is in our legitimate interest to use your personal data in such a way to ensure that we have an effective working relationship with you or the organisation you represent for a future business opportunity.
Insight, Data Analytics and retargeting through Cookies:
We and our third-party partners Cookies collect data from the devices that you use to access our sites, our products and Services and any emails that you receive from us. The data that is collected includes Behavioural Data and Technical Data, and certain Profile Data. Please see our Cookie Notice for further information, including details of our third-party partners.
We and our third-party partners use this data to analyse how you use our Site and our Products and Services and the effectiveness of our Site and our Products and Services, including:
- Personalisation: to personalise content, services and communications and target advertising;
- Advertising: to select and deliver advertising and content to you and measure the delivery and effectiveness of such advertising and content (for example, analysing open and click rates);
- to analyse how you use, and the effectiveness of, our sites and our products and Services;
- to count users who have visited our sites or opened an email and collect other types of information, including insights about visitor browsing habits, which helps us to improve our sites, our products and Services and the effectiveness of our emails;
- to measure the effectiveness of our content;
- to learn what parts of our sites are most attractive to our users, which parts of our sites are the most interesting and what kind of features and functionalities our visitors like to see;
- to help us understand the type of marketing content that is most likely to appeal to our visitors and customers; and
- to help us with the selection of future product and service lines, website design and to remember your preferences.
In some of our email messages, we use a “click-through URL” linked to certain websites administered by us or on our behalf. We may track click-through data to assist in determining interest in particular topics and measure the effectiveness of these communications.
Our legal basis for processing
Where your data is collected through the use of non-essential cookies, we rely on consent to collect your personal data and for the onward processing purpose. Please see our Cookie Notice for further details.
- Marketing communications: We will process your Contact Data to provide you (or the organisation you represent) with marketing via email, post, telephone, SMS/text. Our marketing will include press releases and information about us, our site, our products and Services, any events we may hold and the offers and promotions we offer from time to time. Our marketing communications will include personalised and non-personalised marketing.
Personalised marketing has been specifically tailored to you and will include content that we think is most relevant to you, based on what we know about you. Non-personalised marketing is marketing that is not tailored to you.
Where we are sending you personalised marketing, we may also use Profile Data, Transaction Data and Behavioural Data to help us decide what sort of personalised marketing to send you (please see the “Insight, Data Analytics and retargeting through Cookies” section for more details).
Our legal basis for processing
It is in our legitimate interest to use your personal data for marketing purposes, for example to decide what marketing content we think may appeal to you. It is in our legitimate interest to use your personal data to send our marketing to you by post.
We will only send marketing communications to you by email and/or SMS where you have consented to receive such content by email and/or SMS, or where we have another lawful right to send marketing to you using email and/or SMS. For example, in certain circumstances we may rely on our legitimate interest to send marketing by email and/or SMS to consumers who have purchased our products and Services. We may also rely on our legitimate interest to send marketing by email and/or SMS to certain business users of our sites and our products and Services.
- Online personalised advertising: We and our third party partners may use your Behavioural Data and Technical Data and other data that is collected through your interactions with third party websites and services to provide you with, and analyse the effectiveness of, personalised ads when you visit other websites and/or use other services (including the social media and other platforms described in the “Marketing via third party channels” section below).
By “personalised ads”, we mean advertisements for products and services that you have shown an interest in when you have used our Site or which we or our partners otherwise think you might be interested in based on your browsing habits. Note our third- party partners may also use the data that is collected to show personalised ads for products and services offered by third parties.
Our legal basis for processing
Where we use your personal data to display online personal advertising to you, we rely on the consent that you have provided in respect of the collection of such data, or it is otherwise in our legitimate interests to promote our sites and our products and Services to you.
Our third-party partners may rely on a different lawful basis in respect of their use of your personal data. Please read the privacy notice of the relevant third-party provider, as described in our Cookie Notice.
Marketing via third party channels:
We share your email address and other identifiers such as your phone number or device ID (usually in an encrypted or ‘hashed’ form) with third third-party providers of social media platforms and other services, such as Facebook and Google (“Platforms”), so that the third party providers can try to “match” your data with the data of their registered users of their Platforms e.g. via Facebook Custom Audiences and Google Custom Match.
Where there is a successful match, we will display our advertising to you to make suggestions and recommendations to you about goods and services that could be of interest to you when you use the relevant Platform (e.g. on your Facebook newsfeed). This is known as “custom audience” advertising, because we “customise” the audience that we want to reach on the relevant service.
Some of the advertising that you see may be personalised to you. The data that we use to personalise our advertising, such as your Behavioural Data and Technical Data, will not be provided to the third-party providers of the Platforms for this purpose but please see the “Insight, Data Analytics and retargeting through Cookies” section for details of where we may share such data.
This activity is also subject to the privacy choices you have elected to make on such Platforms.
Our legal basis for processing
We will only share your personal data with the third-party providers of the Platforms, so that we can advertise our products and Services to you when you use those Platforms, where you have provided your consent.
You can opt-out of our sharing of your personal information with the third-party providers by exercising your rights as a data subject as set out below.
- Advertising to other people who share similar interests and characteristics to you (or if you are someone that sees such advertising): We will provide your personal data to third-party providers of Platforms as described in the “Marketing via third party channels” and the “Insight, Data Analytics and retargeting through Cookies” sections. If you are a user of those Platforms, we may ask the third-party providers of those Platforms to find other registered users of their services who share similar interests and characteristics to you, which will be based on information that the third party holds about you and its other registered users.
This is known as “lookalike” audience advertising because we are trying to show our advertising to people who “look like” you.
If you are someone who has seen this advertising on a Social Platform, please note that this activity is based on data that you have provided to the Social Platform (which we do not receive) and is also subject to the privacy choices you have elected to make on such third-party services.
Our legal basis for processing
Please see the “Marketing via third party channels" section for details of the lawful basis that we rely on to share your personal data with the Platforms.
It is in our legitimate interests to further use your personal data to advertise our products and Services to other individuals that use those Platforms and who share similar interests and characteristics with you.
If you are someone who has seen this advertising on a Platform, it is in our legitimate interests that the Platform uses the data that you have provided to it to advertise our products and Services, although please note that we do not receive this data and you should exercise your rights in respect of such data in accordance with the privacy notice of the relevant Platform.
- Aggregation and Anonymisation: We may aggregate and anonymise your Profile Data and Behaviour Data, so that we can improve and market our advertising services and monitor the efficacy of our business partnerships.
Our legal basis for processing
We will rely on our legitimate interests to aggregate and anonymise your personal data for the purposes set out above.
Marketing – further information and how to opt out
Where we have the appropriate permissions or as otherwise authorised by applicable law, we will use your information to market and advertise our products and Services, our group companies’ products and services, and occasionally third party products and services that could be of interest to you including third party offers, advertisements, competitions or commercial communications by telephone (mobile and landline when available), post, electronic messaging (including SMS and MMS), email, online or via applications. You could be contacted directly by our group companies for these purposes.
- Marketing communications
- Online personalised advertising
- Marketing via third party channels
- Advertising to other people who share similar interests and characteristics to you (or if you are someone that sees such advertising)
You can always tell us that you wish to stop receiving direct marketing communications from us. But remember, if you do not want us to get in touch, you will miss out on offers.
If you would prefer not to receive direct marketing communications, simply let us know at any time by writing to the Data Protection Officer at email@example.com with the subject line “Privacy”, or by following the opt-out instructions in the relevant communication. Please note that this will not stop you from receiving service related messages from us. Where you would like to stop receiving online marketing communications from us or our third party partners, you will need to opt out as described in our Cookies Notice.
4. IF YOU FAIL TO PROVIDE YOUR PERSONAL DATA
Where we are required by law to collect your personal data, or we need to collect your personal data in order to perform a contract we have with you, and you fail to provide that personal data when we request it, we may not be able to perform the contract we have or are trying to enter into with you. This may apply where you do not provide the personal data we need in order to provide the products and services you have requested from us or to process an application to register an account. In these circumstances, we may have to cancel your application or the provision of the relevant products and Services to you, in which case we will notify you.
5. WHAT WILL WE DISCLOSE TO THIRD PARTIES?
We share your personal data with our group companies for the purposes outlined in this Privacy and Cookies Policy.
We also pass your personal data to third parties where we are legally permitted to do so. When we share personal data with others, we put contractual arrangements and security mechanisms in place to protect the personal data shared and to comply with our data protection, confidentiality and security standards and obligations. Please note, the list below is non-exhaustive and there may be circumstances where we need to share personal data with other third parties:
|Third-party suppliers who provide applications/ functionality, data processing or IT services
|We share personal data with third parties who support us in providing our Site and help provide, run and manage our internal IT systems. Such third parties may also include, for example, providers of information technology, cloud-based software-as-a-service providers, identity management, website design, hosting and management, data analysis, data back-up, disaster recovery services, security and storage services. The servers powering and facilitating that cloud infrastructure are located in secure data centres around the world, and personal data may be stored in any one of them. We also share your personal data with third-party service providers to assist us with insight analytics. These providers are described in our Cookie Notice.
|Payment providers and banks
|We share personal data with third parties who assist us with the processing of payments and refunds.
|Delivery and courier companies
|We share personal data with third parties who assist us with the processing a request, order or Service;
|Third-party suppliers who assist us in administering our promotions
|We share personal data with specialist suppliers who assist us in administering our promotions and to supply you with a prize in the event you win a competition
|We share your information with our advertising partners as described in our Cookies Notice when you use our sites. This data is used to provide you with, and measure the effectiveness of, online personalised advertising and for other advertising related activities.
|Third-party post/email marketing and CRM specialists
|We share personal data with specialist suppliers who assist us in managing our marketing database and sending out our post and email marketing communications and account-related communications.
|Recruitment agencies and related organisations
|We share personal data with external recruiters, third-party providers that undertake background checks on our behalf and other entities within our group of companies.
|Auditors, lawyers, accountants and other professional advisers
|We share personal data with professional services firms who advise and assist us in relation to the lawful and effective management of our organisation and in relation to any disputes we may become involved in.
|Law enforcement or other government and regulatory agencies and bodies
|We share personal data with law enforcement or other government and regulatory agencies or other third parties as required by, and in accordance with, applicable law or regulation.
|Potential buyers and/or in relation to merger
|We could merge with or be acquired by another business. If this happens we share the information that relates to you. You will be sent notice of such an event.
|Other third parties
|Occasionally, we may receive requests from third parties with authority to obtain disclosure of personal data, such as to check that we are complying with applicable law and regulation, to investigate an alleged crime, or to establish, exercise or defend legal rights. We will only fulfil requests for personal data where we are permitted to do so in accordance with applicable law or regulation.
6. HOW WE PROTECT YOUR INFORMATION
We are committed to keeping the personal data you provide to us secure and we have implemented information security policies, rules and technical measures to protect the personal data under our control from unauthorised access, improper use or disclosure, unauthorised modification and unlawful destruction or accidental loss. In addition, all our employees and data processors (i.e. those who process your personal data on our behalf) are obliged to respect the confidentiality of the personal data of all users of our sites and those who purchase our products and Services.
7. HOW LONG DO WE KEEP YOUR INFORMATION?
We are required by law to keep certain information about our customers (such as financial and transaction related data) for seven years after they cease being customers for tax purposes. We may then destroy such files without further notice or liability.
If any personal data is only useful for a short period (e.g. for a specific activity, promotion or marketing campaign), we will not retain it for longer than the period for which it is used by us.
If you have opted out of receiving marketing communications from us, we will need to retain certain personal data on a suppression list indefinitely so that we know not to send you further marketing communications in the future. However, we will not use this personal data to send you further marketing unless you subsequently opt back in to receive such marketing.
Our data retention periods depend on the context of the services that we provide to you and our legal obligations. To determine the appropriate period for which we keep your data, we consider the amount, nature and sensitivity of your data, the potential risk or harm from unauthorised use or disclosure of your personal data, the purposes for which we process that data (and whether we can achieve those purposes through other means), and applicable legal requirements.
8. INTERNATIONAL TRANSFERS
We are based in the UK and seek to keep your data within the UK. In some instances we will transfer your data to our Group Companies located outside the UK. Many of our third party service providers and partners are based outside the UK, or use servers located outside of the UK for the purposes of storing and processing data, so their processing of your personal data will involve a transfer of data outside the UK.
Whenever we transfer your personal data out of the UK, we will comply with our legal and regulatory obligations in relation to your personal data, including having a lawful basis for transferring personal data and putting appropriate safeguards in place to ensure an adequate level of protection for the personal data. We will take reasonable steps to ensure the security of your personal data in accordance with applicable data protection laws. When transferring your personal data outside the UK, we will, where required by applicable law, implement at least one of the safeguards set out below. Please contact us if you would like further information on the specific mechanisms used by us when transferring your personal data outside the UK:
Adequacy decision: The data is transferred to a country that has been deemed to provide an adequate level of protection for personal data. For further details, see https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en.
Model clauses: We have used specific contracts approved for use in the UK in our arrangement with the third party, which give personal data the same protection it has in the UK. For further details, see https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.
9. YOUR RIGHTS
You have certain rights in relation to the personal data we hold about you, which we detail below. Certain rights only apply in specific circumstances as set out in more detail below. We also set out how to exercise those rights. When you exercise your rights, 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 may have the right to:
Request access to your personal data. 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 need to verify the accuracy of the new data you provide to us. If we have shared your personal data with others, we’ll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we will also tell you who we’ve shared your personal data with so that you can contact them.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data in some circumstances, such as where we no longer need it or where you withdraw your consent (where applicable). You also have the right to ask us to delete personal data where you have successfully exercised your right to object to processing (see below). Note, however, that we are not always 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. If you ask us, where it is possible and lawful for us to do so, we will also tell you who we have shared your personal data with so that you can contact them directly.
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 (more information on your marketing choices can be found in the Marketing section above). In certain cases, we will 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 in certain circumstances such as where you contest the accuracy of that personal data or you object to us processing it for a particular purpose. This may not mean that we will stop storing your personal data but, where we do keep it, we will tell you if we remove any restriction that we have placed on your personal data to stop us processing it further. If we’ve shared your personal data with others, we’ll let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal data with so that you can contact them directly.
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.
Not to be subject to a decision when it is based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for the entering into, or the performance of, a contract between you and us.
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. You can exercise your right of withdrawal by contacting us using our contact details in the “How to Contact Us” section or by using any other opt-out mechanism we may provide, such as an unsubscribe link in an email.
Make a complaint. If you have a concern about any aspect of our privacy practices, including the way we have handled your personal data, please contact us using the contact details provided in the “How to Contact Us” section. You can also report any issues or concerns to the Information Commissioner’s Office, the supervisory authority for data protection issues in the UK.
If you wish to exercise any of the rights set out above, please contact us using the details provided in the How to contact us section below.
We keep this Privacy and Cookies Policy under review and will update it from time to time to reflect changes in our privacy practices. We may notify you by email of any significant changes to this Privacy Notice, but we encourage you to review this Privacy Notice periodically to keep up to date on how we use your personal data. If we update this Privacy Notice, we will update the effective date at the top of the page.
11. HOW TO CONTACT US
If you have any queries relating to this Privacy and Cookies Policy please contact us by writing to firstname.lastname@example.org with the subject line “Privacy”.
We use, and allow certain other companies to use, cookies, web beacons and other similar technologies on, including on the website you are using, our other websites, applications and communications (our “Services”).
1. What are ‘cookies’ or similar technologies?
A cookie is a small text file or piece of code which often include an anonymous unique identifier, We, and in certain circumstances third parties, will request to store this text file on your device in order to remember information about you when you visit our sites or open some of our emails. Cookies are useful because, amongst other things, they allow us to recognise you each time you re-visit one of our sites. The entity that places cookies on your device can then read the information on the cookie that it set.
We also use similar technologies to cookies known as “web beacons”, “pixels” or “tags”. These technologies do a similar job to cookies, allowing website operators to count page views and understand how visitors interact with and respond to certain content on a webpage or email.
For the purposes of the remaining sections of this Cookie Notice, we refer to all cookies and similar technologies using the above features as “cookies”.
2. How long do cookies last?
We use “first party cookies” and “third party cookies” in connection with our Service. First party cookies are cookies placed by us to collect information about you. Third party cookies are cookies placed by third party website operators. Information about you collected by those third party cookies will be shared with the relevant third party. Please refer to the relevant third party website operator’s privacy notice for more details about the information they collect and how they use it.
You should be aware that applications you use to access our site, such as your website browser, may also place cookies on your device when visiting our Site, or other websites. An example of this would be where you sign in to Google Chrome using a Google Account (see What about Google Chrome or other browser cookies? section for more information). We do not have control over these third party cookies, so you will need to manage these cookies in the settings of the relevant applications.
For more details on cookies and similar technologies, please visit All About Cookies.
4. Which cookies do we use on our sites?
Different cookies are used to perform different functions which we explain below. A visit to any of our sites could generate the following types of cookie:
Site performance cookies
The information collected from these types of cookies can be used in conjunction with other information we or our third party partners hold in order to record specific browsing information (for example, regarding the way visitors arrive at our sites, pages viewed, options selected, information entered and the path taken through our sites). The data collected will generally be aggregated to provide trends and usage patterns for business analysis, site/platform improvement and performance metrics and to inform our advertising and marketing strategies. Our cookies, or the resulting analysis, can also be shared with our business partners. We also receive similar information about visitors to the sites of our group companies and other partners.
Cookies can also be linked with other information we hold or infer about you for these purposes. For example, if you are a registered user or provide us with your name, email address, social media log-in details or other contact information (e.g. by entering a competition or signing up to our newsletter) or interact with our email communications (e.g. by clicking on links within the emails), this information can be linked with your browsing activity across all your devices to tailor content, services, advertising and offers for you.
We also obtain information from third party service providers such as demographics and interest categories created from a combination of sources that permit us to provide you with more relevant and useful content, communications and advertising. This information does not identify you personally.
Third party advertising cookies
We partner with advertisers, ad network providers and ad serving companies to place cookies on our sites to allow them to show you advertisements both on and off our sites that are more relevant and useful to you, limit the number of times you see a particular ad and to customise ads. We do not share any information with these third parties that will directly identify you in the real world, such as your name, email address, address or phone number. However, these third parties can assume that users who interact with or click on a personalised advertisement or content are part of the group that the advertisement or content is directed towards. The third parties that generate these cookies have their own privacy policies and we have no access to read or write these cookies.
Social media cookies
We use and permit selected third parties to use web beacons (usually in combination with cookies) to compile aggregate information about your site usage and your interaction with email and other communications to measure performance and to provide content and advertisements that are more relevant to you. A web beacon (also called a web bug, clear GIF or pixel tag) can be embedded in online content, videos and emails, and allows a server to read certain types of information from your device, to know when you have viewed the beacon and the IP address of your device. The type of information collected includes, but is not limited to, information relating to advertising responses, page views, promotion views and purchases made. We will include web beacons in certain promotional email messages and newsletters to determine whether the messages have been opened or acted upon and whether our mailing tools are working correctly. The web beacons can be used to recognise cookies generated by third parties and inform us and third parties of which advertisement or link brought you to our site, allowing us to monitor the efficacy of our business relationships with third parties.
The Privacy button on the bottom left hand corner of our website will take you to your Data preferences which sets out more information about the individual cookies we may use on our websites and the purposes for which they are used.
What about Google Chrome or other browser cookies?
Separately to our use of Google Analytics cookies, when you access the site via Google applications such as Google Chrome, Google may collect user information for the purpose of Google serving personalised advertising across your devices. Google is able to place these advertising cookies on the devices used by visitors to the site because we use Google services to run the site. However these cookies are dropped for Google’s own purposes and as such we do not have any control over how or when they are dropped. You will need to opt out of receiving these cookies via your Google settings. For further information about these cookies please see: https://policies.google.com/technologies/types?hl=en-US. Please note that other browsers may use similar tools.
Your options for managing your cookie preferences are set out below:
Through the Data preferences on our site
When you access our websites we will ask you to provide consent for our use of non-essential cookies. We may repeat this request on subsequent visits to our websites, for example if you delete cookies from your browser or we need to request new consents from you.
When we seek your consent, you will either be able to provide consent for all non-essential cookies that we would like to use, or you can tailor your cookie preferences (provide consent for some but not all non-essential cookies) using your Data preferences. You can also change your preferences and/or withdraw consent at any time by clicking the Privacy button on the bottom left hand corner of our website which will take you to your Data preferences.
Just as a reminder, where cookies are essential to the operation of our sites, we can use these without your consent and they cannot be managed using Data preferences.
Using your browser settings or other tools
If you do not want your browser to accept cookies, you can alternatively change your browser settings. You can also delete existing cookies from your browser. However, blocking all cookies will affect your web experience and can result in parts of our sites not functioning properly. Certain cookies are designed to help save you time by, for example, remembering your contact details when you place an order.
The procedure for modifying your privacy preferences is different for each internet browser. Visit your internet browser preferences to configure your cookies. For more information on cookie management and blocking or deleting cookies for a wide variety of browsers, visit All About Cookies.
Alternatively, you can turn off third party cookies relating to interest based advertising by visiting www.youronlinechoices.eu. However, this will not opt you out of receiving adverts altogether – it simply means that the adverts will not be targeted to you. Please note that there are many more networks listed on this site than we use on our sites.
You can opt out of Google Analytics without affecting how you visit our site – for more information on opting out of being tracked by Google Analytics across all websites you use, visit this Google page. For Google Analytics Advertising Features, you can opt-out through Google Ads Settings or by visiting the Network Advertising Initiative opt out page. You can find more information about how Google uses information from our sites [here][https://policies.google.com/technologies/partner-sites].
You can find more information about how to opt-out of the cookies provided by some of our key partners here:
Cookies in emails and newsletters
If you do not wish to accept cookies from any one of our emails, simply close the email before downloading any images or clicking on any links. You can also set your browser to restrict cookies or to reject them entirely. These settings will apply to all cookies whether included on websites or in emails.
In some instances, depending on your email or browser settings, cookies in an email may be automatically accepted (for example, when you've added an email address to your address book or safe senders list). Please refer to your email browser or device instructions for more information on this.
7. Does this Cookie Notice change?
8. Have any feedback for us?