Please also see additional GDRP compliance appended
SECTION 1 - WHAT DO WE DO WITH YOUR INFORMATION?
When you purchase something from our store, as part of the buying and selling process, we collect the personal information you give us such as your name, address and email address.
When you browse our store, we also automatically receive your computer’s internet protocol (IP) address in order to provide us with information that helps us learn about your browser and operating system.
Email marketing (if applicable): With your permission, we may send you emails about our store, new products and other updates.
SECTION 2 - CONSENT
How do you get my consent?
When you provide us with personal information to complete a transaction, verify your credit card, place an order, arrange for a delivery or return a purchase, we imply that you consent to our collecting it and using it for that specific reason only.
If we ask for your personal information for a secondary reason, like marketing, we will either ask you directly for your expressed consent, or provide you with an opportunity to say no.
How do I withdraw my consent?
If after you opt-in, you change your mind, you may withdraw your consent for us to contact you, for the continued collection, use or disclosure of your information, at anytime, by contacting us at email@example.com or mailing us at:
Bauer Outlet Store
Wheels (Skate Sales) LTD, Austen House, 4 Melford Road, Hazel Grove. SK7 6DD
SECTION 3 - DISCLOSURE
We may disclose your personal information if we are required by law to do so or if you violate our Terms of Service.
SECTION 4 - SHOPIFY
Our store is hosted on Shopify Inc. They provide us with the online e-commerce platform that allows us to sell our products and services to you.
Your data is stored through Shopify’s data storage, databases and the general Shopify application. They store your data on a secure server behind a firewall.
If you choose a direct payment gateway to complete your purchase, then Shopify stores your credit card data. It is encrypted through the Payment Card Industry Data Security Standard (PCI-DSS). Your purchase transaction data is stored only as long as is necessary to complete your purchase transaction. After that is complete, your purchase transaction information is deleted.
All direct payment gateways adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover.
PCI-DSS requirements help ensure the secure handling of credit card information by our store and its service providers.
For more insight, you may also want to read Shopify’s Terms of Service (https://www.shopify.com/legal/terms) or Privacy Statement (https://www.shopify.com/legal/privacy).
SECTION 5 - THIRD-PARTY SERVICES
In general, the third-party providers used by us will only collect, use and disclose your information to the extent necessary to allow them to perform the services they provide to us.
However, certain third-party service providers, such as payment gateways and other payment transaction processors, have their own privacy policies in respect to the information we are required to provide to them for your purchase-related transactions.
For these providers, we recommend that you read their privacy policies so you can understand the manner in which your personal information will be handled by these providers.
In particular, remember that certain providers may be located in or have facilities that are located a different jurisdiction than either you or us. So if you elect to proceed with a transaction that involves the services of a third-party service provider, then your information may become subject to the laws of the jurisdiction(s) in which that service provider or its facilities are located.
As an example, if you are located in Canada and your transaction is processed by a payment gateway located in the United States, then your personal information used in completing that transaction may be subject to disclosure under United States legislation, including the Patriot Act.
When you click on links on our store, they may direct you away from our site. We are not responsible for the privacy practices of other sites and encourage you to read their privacy statements.
SECTION 6 - SECURITY
To protect your personal information, we take reasonable precautions and follow industry best practices to make sure it is not inappropriately lost, misused, accessed, disclosed, altered or destroyed.
If you provide us with your credit card information, the information is encrypted using secure socket layer technology (SSL) and stored with a AES-256 encryption. Although no method of transmission over the Internet or electronic storage is 100% secure, we follow all PCI-DSS requirements and implement additional generally accepted industry standards.
SECTION 7 - COOKIES
Here is a list of cookies that we use. We’ve listed them here so you that you can choose if you want to opt-out of cookies or not.
_session_id, unique token, sessional, Allows Shopify to store information about your session (referrer, landing page, etc).
_shopify_visit, no data held, Persistent for 30 minutes from the last visit, Used by our website provider’s internal stats tracker to record the number of visits
_shopify_uniq, no data held, expires midnight (relative to the visitor) of the next day, Counts the number of visits to a store by a single customer.
cart, unique token, persistent for 2 weeks, Stores information about the contents of your cart.
_secure_session_id, unique token, sessional
storefront_digest, unique token, indefinite If the shop has a password, this is used to determine if the current visitor has access.
SECTION 8 - AGE OF CONSENT
By using this site, you represent that you are at least the age of majority in your state or province of residence, or that you are the age of majority in your state or province of residence and you have given us your consent to allow any of your minor dependents to use this site.
If our store is acquired or merged with another company, your information may be transferred to the new owners so that we may continue to sell products to you.
QUESTIONS AND CONTACT INFORMATION
If you would like to: access, correct, amend or delete any personal information we have about you, register a complaint, or simply want more information contact our Privacy Compliance Officer at firstname.lastname@example.org or by mail at
Bauer Outlet Store
[Re: Privacy Compliance Officer]
Wheels (Skate Sales) LTD, Austen House, 4 Melford Road, Hazel Grove. SK7 6DD
Wheels (Skate Sales) LTD Data Protection Policy
NOTE: THIS IS A DRAFT POLICY – THE DATA PROTECTION BILL AND ICO GUIDANCE HAS NOT YET BEEN FINALISED
1. Policy Statement
Every day our business will receive, use and store personal information about our customers, colleagues, sub-contractors. It is important that this information is handled lawfully and appropriately in line with the requirements of the [Data Protection Act 2018] (the Act) and the General Data Protection Regulation (collectively referred to as the ‘Data Protection Requirements’).
We take our data protection duties seriously because we respect the trust that is being placed in us to use personal information appropriately and responsibly.
2. About This Policy
This policy, and any other documents referred to in it, sets out the basis on which we will process any personal data we collect or process.
Wheels (Skate Sales) LTD, is responsible for ensuring compliance with the Data Protection Requirements and with this policy. Any questions about the operation of this policy or any concerns that the policy has not been followed should be referred in the first instance to Derek Armstrong or reported in line with the organisation’s Whistleblowing Policy or Grievance Policy.
3. What is Personal Data?
Personal data means data (whether stored electronically or paper based) relating to a living individual who can be identified directly or indirectly from that data (or from that data and other information in our possession).
Processing is any activity that involves use of personal data. It includes obtaining, recording or holding the data, organising, amending, retrieving, using, disclosing, erasing or destroying it. Processing also includes transferring personal data to third parties.
Sensitive personal data includes personal data about a person’s racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic, biometric, physical or mental health condition, sexual orientation or sexual life. It can also include data about criminal offences or convictions. Sensitive personal data can only be processed under strict conditions, including with the consent of the individual.
4. Fair and Lawful Processing
The Data Protection Requirements are not intended to prevent the processing of personal data, but to ensure that it is done fairly and without adversely affecting the rights of the individual.
In accordance with the Data Protection Requirements, we will only process personal data where it is required for a lawful purpose. The lawful purposes include (amongst others): whether the individual has given their consent, the processing is necessary for performing a contract with the individual, for compliance with a legal obligation, or for the legitimate interest of the business. When sensitive personal data is being processed, additional conditions must be met.
5. Processing for Limited Purposes
In the course of our business, we may collect and process the personal data set out in the schedule This may include data we receive directly from a data subject (for example, by completing forms or by corresponding with us by mail, phone, email or otherwise) and data we receive from other sources (including, for example, location data, business partners, sub-contractors in technical, payment and delivery services, credit reference agencies and others).
We will only process personal data for the specific purposes set out in the schedule or for any other purposes specifically permitted by the Data Protection Requirements. We will notify those purposes to the data subject when we first collect the data or as soon as possible thereafter.
6. Notifying Individuals
If we collect personal data directly from an individual, we will inform them about:
The purpose or purposes for which we intend to process that personal data, as well as the legal basis for the processing.
Where we rely upon the legitimate interests of the business to process personal data, the legitimate interests pursued.
The types of third parties, if any, with which we will share or disclose that personal data.
The fact that the business intends to transfer personal data to a non-EEA country or international organisation and the appropriate and suitable safeguards in place.
How individuals can limit our use and disclosure of their personal data.
Information about the period that their information will be stored or the criteria used to determine that period.
Their right to request from us as the controller access to and rectification or erasure of personal data or restriction of processing.
Their right to object to processing and their right to data portability.
Their right to withdraw their consent at any time (if consent was given) without affecting the lawfulness of the processing before the consent was withdrawn.
The right to lodge a complaint with the Information Commissioners Office.
Other sources where personal data regarding the individual originated from and whether it came from publicly accessible sources.
Whether the provision of the personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether the individual is obliged to provide the personal data and any consequences of failure to provide the data.
The existence of automated decision-making, including profiling and meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the individual.
If we receive personal data about an individual from other sources, we will provide them with this information as soon as possible (in addition to telling them about the categories of personal data concerned) but at the latest within 1 month.
We will also inform data subjects whose personal data we process that we are the data controller with regard to that data and our contact details are Wheels (Skate Sales) LTD, Austen House, 4 Melford Road, Hazel Grove. SK7 6DD.
7. Adequate, Relevant and Non-excessive Processing
We will only collect personal data to the extent that it is required for the specific purpose notified to the data subject.
8. Accurate Data
We will ensure that personal data we hold is accurate and kept up to date. We will check the accuracy of any personal data at the point of collection and at regular intervals afterwards. We will take all reasonable steps to destroy or amend inaccurate or out-of-date data.
9. Timely Processing
We will not keep personal data longer than is necessary for the purpose or purposes for which it was collected. We will take all reasonable steps to destroy, or erase from our systems, all data which is no longer required.
10. Processing in line with Data Subject’s Rights
We will process all personal data in line with data subjects’ rights, in particular their right to:
Confirmation as to whether or not personal data concerning the individual is being processed.
Request access to any data held about them by a data controller (see also Clause 15 Subject Access Requests).
Request rectification, erasure or restriction on processing of their personal data.
Lodge a complaint with a supervisory authority.
Object to processing including for direct marketing.
Not be subject to automated decision making including profiling in certain circumstances.
11. Data Security
We will take appropriate security measures against unlawful or unauthorised processing of personal data, and against the accidental or unlawful destruction, damage, loss, alteration, unauthorised disclosure of or access to personal data transmitted, stored or otherwise processed.
We will put in place procedures and technologies to maintain the security of all personal data from the point of the determination of the means for processing and point of data collection to the point of destruction. Personal data will only be transferred to a data processor if they agree to comply with those procedures and policies, or if they put in place adequate measures themselves.
We will maintain data security by protecting the confidentiality, integrity and availability of the personal data, defined as follows:
Confidentiality means that only people who are authorised to use the data can access it.
Integrity means that personal data should be accurate and suitable for the purpose for which it is processed.
Availability means that authorised users should be able to access the data if they need it for authorised purposes. Personal data should therefore be stored on Wheels (Skate Sales) LTD central computer system instead of individual PCs.
Security procedures include:
We may transfer any personal data we hold to a country outside the European Economic Area (‘EEA’) or to an international organisation, provided that one of the following conditions applies:
The country to which the personal data are transferred ensures an adequate level of protection for the data subjects’ rights and freedoms.
The data subject has given his consent.
The transfer is necessary for one of the reasons set out in the Act, including the performance of a contract between us and the data subject, or to protect the vital interests of the data subject.
The transfer is legally required on important public interest grounds or for the establishment, exercise or defense of legal claims.
The transfer is authorised by the relevant data protection authority where we have adduced adequate safeguards with respect to the protection of the data subjects’ privacy, their fundamental rights and freedoms, and the exercise of their rights.
Subject to the requirements above, personal data we hold may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Those staff may be engaged in, among other things, the fulfilment of contracts with the data subject, the processing of payment details and the provision of support services.
12. Disclosure and Sharing of Personal Data
We may share personal data we hold with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
13. Subject Access Requests
Individuals must make a formal request for information we hold about them. Employees who receive a request should forward it to Wheels (Skate Sales) LTD.
When receiving telephone enquiries, we will only disclose personal data we hold on our systems if the following conditions are met:
We will check the caller’s identity to make sure that information is only given to a person who is entitled to it.
We will suggest that the caller put their request in writing if we are not sure about the caller’s identity and where their identity cannot be checked.
Where a request is made electronically, data will be provided electronically where possible.
Our employees will refer a request to their line manager Derek Armstrong for assistance in difficult situations.
14. Changes to this Policy
We reserve the right to change this policy at any time. Where appropriate, we will notify changes by mail or email.