Privacy Notice for Customers

Edition Date: 26^th April 2018 fst

It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.

We will comply with data protection law. This says that the personal information we hold about our customers must be:

1. Used lawfully, fairly and in a transparent way.

2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.

3. Relevant to the purposes we have told you about and limited only to those purposes.

4. Accurate and kept up to date.

5. Kept only as long as necessary for the purposes we have told you about.

6. Kept securely.

3. The kind of information we hold about customers

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, store, and use the following categories of personal information about our customers:

• Account contact details such as name, title, addresses, telephone numbers and email addresses.

• Payment details.

• Order history.

• Information about our customers’ use of our information and communications systems.

• Cookie information to distinguish a customer from other customers/users of our website.

We typically collect personal information about customers when you purchase products and/or services from us including via our website, email or telephone. We may sometimes collect additional information from third parties including credit reference agencies or other background/identity check agencies. We may also collect additional personal information throughout the period of us supplying products and/or services to our customers including when a customer registers to use our website, subscribes to our services, searches for a product, places an order on our site and/or signs up for our promotions.

We will use our customers’ personal information as follows:

• To administer or otherwise carry out our obligations arising from any contracts entered into with our customers or to take steps to enter into any contracts between our customers and us.
• To provide our customers with the information, products and services that you request from us and to provide customer service.
• To provide our customers with information about other products and services we offer that are similar to those that may have already been purchased or enquired about.
• To fulfil any requests our customers have made or orders placed, or to contact our customers with information relevant to their interaction with us.

Our lawful basis for these activities above is necessity to perform our contract of sale with our customers.

• To notify our customers about changes to our services.
• For our business purposes, including data analysis, developing new products, enhancing, improving or modifying our services, identifying usage trends and determining the effectiveness of our promotional campaigns.
• To allow our customers to participate in interactive features of our services, when you choose to do so.
• To provide our customers with a good experience when you browse our website and also allow us to improve our site and services and to ensure that content from our services is presented in the most effective manner.
• To ascertain our customers’ ability to pay us for the products and/or services we may provide to them.
• To capture CCTV footage at one of our sites to maintain the security of the premises and for preventing and investigating crime.
• For audit purposes of the Group.
• For fraud monitoring and prevention.

Our lawful basis for these activities above is the pursuit of our legitimate interests of operating and expanding our business activities lawfully.

Some of the above grounds for processing will overlap and there may be several grounds which justify our use of our customers’ personal information.

If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you (such as providing the products and/or services to you).

We will only use our customers’ personal information 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 we need to use a customer’s personal information 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 information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.

We do not envisage that any decisions will be taken about our customers’ using automated means, however we will notify you in writing if this position changes.

We may share customers’ personal information with third parties where required by law, where it is necessary to administer the working relationship with our customers or where we have another legitimate interest in doing so.

Which third-party service providers process customers’ personal information?

"Third parties" includes third-party service providers (including contractors, designated agents and our auditors) and other entities within our Group, including our finance and supplier teams. The following activities are carried out by third party service providers: processing and storage of customer emails (Mimecast); IT support, which can involve third party support staff (from Sage) logging in to our internal systems with full administration rights.

How secure is customers’ information with third-party service providers and other entities in our Group?

All our third-party service providers and other entities in the Group are required to take appropriate security measures to protect customers’ personal information in line with our policies. We do not allow our third-party service providers to use customers’ personal data for their own purposes. We only permit them to process customers’ personal data for specified purposes and in accordance with our instructions.

When might we share customers’ personal information with other entities in the Group?

We will share customers’ personal information with other entities in our Group as part of our regular reporting activities on company performance, in the context of a business reorganisation or Group restructuring exercise, for system maintenance support and hosting of data.

What about other third parties?

We may share customers’ personal information with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share customers’ personal information with a regulator or to otherwise comply with the law – potential recipients include HM Revenue & Customs. Data security

We have put in place measures to protect the security of customers’ information. Details of these measures may be obtained from our DPM.

Third parties will only process customers’ personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.

We have put in place appropriate security measures to prevent customers’ personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to customers’ personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process customers’ personal information on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

How long will we use customers’ information for?

We will only retain customers’ personal information 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. Details of retention periods for different aspects of personal information we process are available in our Data Retention Policy which is available from our DPM.

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 customers’ personal data, the purposes for which we process customers’ personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances we may anonymise customers’ personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer a customer of ours, we will retain and securely destroy your personal information in accordance with our Data Retention Policy.

12. Rights of access, correction, erasure, and restriction

It is important that the personal information we hold about our customers is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.

Your rights in connection with personal information

Under certain circumstances, by law you have the right to:

• Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).
• Object to processing of your personal information 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. You also have the right to object where we are processing your personal information for direct marketing purposes.
• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your personal information to another party.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact our DPM in writing.

No fee usually required

Customers’ will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if a customer’s request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

What we may need from customers

We may need to request specific information from our customers to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

Right to withdraw consent

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact our DPM. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law. 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.

If you have any questions about this privacy notice or how we handle your personal information, please contact our DPM.

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.

This privacy notice does not override any applicable national data privacy laws and regulations in countries where the Rema Tip Top AG group operates.

14. Resources & Further Information

• Data Protection Act 1998
• Twitter Privacy Policy
• Facebook Privacy Policy
• Google Privacy Policy
• Linkedin Privacy Policy
• Mailchimp Privacy Policy