THE PULBOROUGH EXCHANGE - PRIVACY NOTICE
Welcome to our website which is provided by THE PULBOROUGH EXCHANGE LIMITED, a company registered under number 118953795 in England and whose registered address is at 81 Lower Street, Pulborough, West Sussex RH20 2BP
Your use of this website signifies your consent to us collecting and using personal data about you as specified below in accordance with this policy statement. Should we choose to change these terms for any reason, the changes will be posted here so that you are always kept informed about the collection and use of your personal information, and when we disclose it.
WHO WE ARE
We are THE PULBOROUGH EXCHANGE LIMITED. Our contact and other details are set out at the end of this policy. We are the data controller in relation to the personal data processed in accordance with this policy (except where this policy explains otherwise).
THE PULBOROUGH EXCHANGE LIMITED is the controller and responsible for your personal data.
HOW WE COLLECT PERSONAL INFORMATION ABOUT YOU
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- engage us to provide our services;
- request that information about us is sent to you;
- enter a competition, promotion or survey; or
- give us some feedback.
- Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies. [We may also receive Technical Data about you if you visit other websites employing our cookies.]
- Third parties or publicly available sources. We may receive personal data about you:
- Technical Data from the following parties based inside or outside the European Economic Area (EEA):
- analytics providers such as Google;
- advertising networks; and
- search information providers;
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services;
- Identity and Contact Data from data brokers or aggregators;
- Identity and Contact Data from publicly availably sources.
PURPOSES FOR WHICH WE COLLECT PERSONAL DATA
Our primary goal in collecting personal information from you is to provide you with the best experience while using our services. This allows us to provide services and features that most likely meet your needs, and to customise our service to make your experience easier and quicker. Personal information will be used in accordance with the United Kingdom law and regulation on data protection, principally, the Data Protection Act 2018.
We may use your personal data to:
- enable your use of the services available on the website;
- process client orders, including sending goods and supplying services, and the management of payments;
- manage our relationship with you which will include:
- improving your browsing experience by personalising the website;
- sending to you general (non-marketing) commercial communications;
- sending to you email notifications, sales enquiries, proposals and quotations which you have specifically requested;
- dealing with enquiries and complaints made by or about you relating to the website;
- keeping the website secure and to prevent fraud;
- verifying compliance with the terms and conditions governing the use of the website;
- inviting you to events we feel may be of interest to you;
- asking you to leave a review;
- enable you to partake in a competition or complete a survey;
- administer and protect our business and this website;
- deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you;
- use data analytics to improve our website, products/services, marketing, customer relationships and experiences;
- make suggestions and recommendations to you about goods or services that may be of interest to you.
WHERE WE PROCESS YOUR PERSONAL DATA
We normally process personal data only in the UK.
Where personal data is transferred in relation to providing our services we will take all steps reasonably necessary to ensure that it is subject to appropriate safeguards, such as relying on a recognised legal adequacy mechanism which may include by entering into EC approved standard contractual clauses relevant to transfers of personal information – see:
SECURITY OF YOUR PERSONAL DATA
All personal data processed by us is stored securely (the level of security being appropriate to the nature of the data concerned and the other relevant circumstances). Any payment transactions administered by us will be encrypted using appropriate technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website or systems, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website and any transmission is at your own risk. Once we have received your information, we will use appropriate procedures and security features to try to prevent unauthorised access
WHO WE SHARE YOUR PERSONAL DATA WITH
We may where appropriate share your personal data with:
- Any member of our company
- Appropriate third parties including:
- our business partners, customers, suppliers and sub-contractors for the performance of any contract we enter into or other dealings we have in the normal course of business with you or the person that you work for;
- The media, where you are participating in advertising or other marketing or promotion that is intended to be publicly disseminated;
- Our auditors, legal advisors and other professional advisors or service providers;
- Credit or other similar reference agencies for the purpose of assessing your suitability or ability where this is in the context of us entering (or proposing to enter) into a contract with you or the person that you work for.
- In relation to information obtained via our website:
- our advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers, but we will provide them with aggregate information about our users. We may also use such aggregate information to help advertisers reach the kind of audience they want to target. We may make use of the personal data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience and subject to the cookie section of this policy;
- analytics and search engine providers that assist us in the improvement and optimisation of our site and subject to the cookie section of this policy.
- We may provide aggregate statistics about sales, customers, traffic patterns and information to third parties, but these statistics will not include any information that identifies you
- You can adjust your privacy settings at any time by emailing hello@ThePulboroughExchange.co.uk advising your preferences in detail.
- Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.
- Marketing. We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Where the website contains links to other websites. We are not responsible for the privacy policies or practices of third party websites.
DISCLOSURE OF YOUR PERSONAL DATA
We require all third parties to respect the security of your personal data and to treat it in accordance with the Data Protection Requirements. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
- We may have to share your personal data with:
- service providers who provide IT and system administration services;
- professional advisers;
- regulators and other authorities in the United Kingdom who require reporting of processing activities in certain circumstances.
- The personal data disclosed to third parties may:
- relate to performance of our contract with you;
- be necessary for our legitimate interests or to comply with a legal obligation;
- be third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
- If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of supply terms and other agreements with you or the person that you work for; or to protect the rights, property, or safety of our business, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of child protection, fraud protection, or credit risk reduction.
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
Where you opt-out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service agreement/contract or other transactions.
CHANGE OF PURPOSE
We will only use your personal data 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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data 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 data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by the Data Protection Requirements.
WHAT ARE COOKIES AND HOW DO WE DEAL WITH THEM?
If you do not know what cookies are, or how to control or delete them, then we recommend you visit http://www.aboutcookies.org for detailed guidance.
The following describes the cookies we use on this site and what we use them for.
We use both “session” cookies and “persistent” cookies on the website. Session cookies will be deleted from your computer when you close your browser. Persistent cookies will remain stored on your computer until deleted, or until they reach a specified expiry date.
We will use the session cookies to:
- keep track of you whilst you navigate the website;
- prevent fraud and increase website security;
- enhance your user experience.
We will use the persistent cookies to:
- enable our website to recognise you when you visit;
- keep track of your preferences in relation to your use of our website;
- remember your login details.
We use Google Analytics to analyse the use of this website. Google Analytics generates statistical and other information about website use by means of cookies, which are stored on users’ computers. You can find out more about Google’s position on privacy as regards its analytics service athttp://www.google.co.uk/intl/en/analytics/privacyoverview.html.
On some pages of the site you will see ‘social buttons’. These enable users to share or bookmark the web pages. There are buttons for: Twitter, Instagram, Facebook, and LinkedIn.
In order to implement these buttons and connect them to the relevant social networks and external sites, there are scripts from domains outside of this site. You should be aware that these sites are likely to be collecting information about what you are doing all around the internet, including on this site. So if you click on any of these buttons, these sites will be registering that action and may use that information. In some cases these sites will be registering the fact that you are visiting the specific pages you are on, even if you don’t click on the button if you are logged into their services, like Google and Facebook. You should check the respective policies of each of these sites to see how exactly they use your information and to find out how to opt-out, or delete, such information.
We do not currently feature advertisers or payment services. However, if we should add these in the future, our advertisers and/or payment services providers may also send you cookies.
You can change your browser settings to disable cookies if you have privacy concerns. Disabling cookies for all sites is not recommended as it may interfere with your use of some sites. The best option is to disable or enable cookies on a per-site basis. Consult your browser documentation for instructions on how to block cookies and other tracking mechanisms.
THE LEGAL BASIS FOR OUR PROCESSING OF PERSONAL DATA
The legal basis on which we process your personal data is as follows:
- Where it is necessary to obtain your prior consent to the processing concerned in order for us to be allowed to do it, we will obtain and rely on your consent in relation to the processing concerned (in relation to any processing we are carrying out with your consent, see below for how to withdraw your consent).
- Otherwise, we will process your personal data where the processing is necessary:
- for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into such a contract;
- for compliance with a legal obligation to which we are a subject; or
- for the purposes of the legitimate interests pursued by us or another person, provided that this will only be in circumstances in which those legitimate interests are not overridden by your interests or fundamental rights and freedoms which require protection of personal data (most circumstances in which we process your personal data in relation to a relationship that we have with the person that you work for will fall into this category).
HOW LONG WE KEEP YOUR PERSONAL DATA
We process personal data only for so long as is necessary for the purpose(s) for which it was originally collected, after which it will be deleted or archived except to the extent that it is necessary for us to continue to process it for the purpose of compliance with legal obligations to which we are subject or for another legitimate and lawful purpose.
You have the following rights in relation to personal data relating to you that we process:
- You may request access to the personal data concerned.
- You may request that incorrect personal data that we are processing be rectified.
- In certain circumstances (normally where it is no longer necessary for us to continue to process it), you may be entitled to request that we erase the personal data concerned.
- Where we are processing your personal data for marketing purposes or otherwise based on our legitimate interests, you may in certain circumstances have a right to object to that processing.
- Where we are processing personal data relating to you on the basis of your prior consent to that processing, you may withdraw your consent, after which we shall stop the processing concerned.
- You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
- 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.
- We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Our contact details are:
THE PULBOROUGH EXCHANGE
Contact: The Data Protection Officer
Phone: 01798 873752
CONTACTING THE REGULATOR
The Information Commissioner (ICO) is the supervisory authority in the UK and can provide further information about your rights and our obligations in relation to your personal data, as well as deal with any complaints that you have about our processing of your personal data.
You have the right to make a complaint at any time to the ICO, the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
DATE OF THIS POLICY
This policy was last updated on 27 October 2019