1.1 This Policy (together with the eCommerce Portal Terms and Conditions) apply to your use of the Portal.
1.2 This Policy sets out the basis on which any personal information we collect from you, or that you provide to us, will be processed by us. It is important that you read this Policy so that you are aware of how and why we are using your personal information. The information available on the Platform is intended to give you general information (rather than professional or tailored advice) and may not suit your specific needs. Please contact us with any specific questions.
2.1 In this Policy:
|“Portal”||means the Website as applicable;|
|“we”, “us” or “our”||means Gledhill Response Ltd (Company Number 06714703) a limited company whose registered office is at Sycamore Estate, Squires Gate, Blackpool FY4 3RL.|
|“Website”||Means: https://gledhill-response.net being a website allowing users to access and use the eCommerce portal|
|“you” or “your”||means the person whose personal information (as defined below) we collect, use and process. This includes anyone who contacts us in connection with the delivery or receipt of any services we provide or otherwise interacts with us including third parties that provide services to us.|
3.1 We will comply with data protection law. This says that personal information we hold about you must be:
3.1.1 used lawfully, fairly and in a transparent way;
3.1.2 collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes;
3.1.3 relevant to the purposes we have told you about and limited only to those purposes;
3.1.4 accurate and kept up to date;
3.1.5 kept only as long as necessary for the purposes we have told you about; and
3.1.6 kept securely.
4. What information do we collect?
4.1 We may collect and process information about you. This information is referred to in this Policy as personal information. This personal information may be collected as part of any documents or online forms you complete; via your use of the Platform or from communications between us.
4.2 In particular, we may collect and process the following personal information about you:
4.2.1 information about you that you give us by filling in forms on the portal or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use our portal, subscribe to our service, search for a product, place an order on our portal, participate in discussion boards or other social media functions on our portal, enter a competition, promotion or survey and when you report a problem with our portal. The information you give us may include your name, address, e-mail address and phone number, financial and credit card information, personal description and photograph, and gas safe registration details; and
4.2.2 details of your visits to our portal, for example traffic data, location data (including the country and telephone area code where your computer or access device is located) and the resources that you access (including the pages/areas of our portal that you view); and
4.2.3 information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), products you viewed or searched for’ page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number; and
4.2.4 information we receive from other sources. This is information we receive about you if you use any of the other websites we operate or the other services we provide. In this case we will have informed you when we collected that data if we intend to share those data internally and combine it with data collected on this site. We will also have told you for what purpose we will share and combine your data. We are working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies). We will notify you when we receive information about you from them and the purposes for which we intend to use that information; and
4.2.5 information concerning your marketing preferences.
5. How do we use your personal information?
5.1 We use your personal information in connection with our portal. In particular, we may use your personal information to:
5.1.1 carry out our obligations arising from any contracts entered into between you and us including in connection with the portal;
5.1.2 to provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about;
5.1.3 create and provide you with a portal account;
5.1.4 manage and administer the relationships between you and us;
5.1.5 comply with our legal obligations
5.1.6 notify you about changes to our services and to otherwise communicate with you; for example, we will use your contact details in order to respond to any queries that you submit to us;
5.1.7 train our staff to continuously improve our services; and
5.1.8 to analyse the efficacy of our services and marketing activity and to carry out market research relating to our products and services.
5.2 If you fail to provide certain information when requested, we may not be able to provide the portal services to you or we may be prevented from complying with our legal obligations.
5.3 We will only use your 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 your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
5.4 The section below entitled “What choices do I have?” explains how you can change whether to receive this information. Please note that, even if you choose not to receive this information, we may still use your personal information to provide you with important services communications.
6. With whom do we share your personal information?
6.1 We will share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so.
6.2 We may disclose your personal information to third parties in connection with our portal. For example, we may pass your personal information to:
6.2.1 third party service providers who assist us with running the portal (for example website developers and managed IT infrastructure providers);
6.2.2 third party organisations that provide services to us (including assisting us with carrying out marketing activities);
6.2.3 external agencies and organisations (including the police and other law enforcement agencies) for the purpose of preventing and detecting fraud (including fraudulent transactions) and criminal activity;
6.2.4 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;
6.2.5 third parties if we are under a duty to disclose or share your personal information in order to comply with any legal obligation (including in connection with a court order), or in order to enforce or apply the terms of any agreements we have with or otherwise concerning you (including agreements between you and us); or to protect our rights, property or safety or those of our customers, employees or other third parties;
6.2.6 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 (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in SW1). 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;
6.2.7 analytics and search engine providers that assist us in the improvement and optimisation of our site;
6.2.8 credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you.
6.3 All our third party service providers are required to take appropriate security measures to protect your personal information in line with our policies and in line with current laws on data protection. We do not allow our third party service providers to use your personal information for their own purposes. We only permit them to process your personal information for specified purposes and in accordance with our instructions.
6.4 We may share your personal information with other third parties, for example in the context of the possible sale or reconstruction of the business. We may also need to share your personal information with a regulator or otherwise to comply with the law.
6.5 We may share non-personal aggregate statistics (group) data about visitors to our Platform, sales and traffic patterns with certain third parties to enable us to improve the way we communicate on our Platform with you.
7. Protecting your personal information
7.1 Our security procedures mean that we may occasionally request proof of identity before we are able to disclose personal information to you.
7.2 We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
7.3 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.
7.4 The transmission of information via the internet is not completely secure; this risk is not specific to our Platform and is common across the internet. Unfortunately, we can’t guarantee the security of the transmission of the data to us which is outside our control; any data you send is at your own risk.
7.5 We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for,
8. What choices do I have?
8.1 It is important that the personal information we hold about you is accurate and current. If you think the personal information we hold about you is inaccurate or incorrect, or you would like your information removed you can request that we correct this information (including your marketing preferences) by writing to us using the details below.
8.2 If you do not want us to use your personal information to provide you with information about services, promotions and offers, or to share your personal information with third parties for marketing purposes, please tick the relevant box(es) situated on the form on which we collect your data.
8.3 You can also choose to change your preferences in respect of your data at any time and for any reason by emailing us at email@example.com
8.4 You can 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 may also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing.
8.5 By law, you have the right to 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.
8.6 You can also request that we restrict the processing of your personal information. This enables you to ask us to suspend the processing or personal information about you, for example if you want us to establish its accuracy or the reason for processing.
8.7 If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal information please contact us. Details of how to contact us are set out below in “How to contact us” at clause 12 below.
9. Access to your personal information
9.1 You can request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a coy of the personal information we hold about you and to check that we are lawfully processing it.
9.2 You will not have to pay a fee to access your personal information. However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
9.3 We may need to request specific information from you to help us confirm your identity and ensure your right to access the information. This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
10. Third party websites
10.1 Our Platform may, from time to time, contain links to third party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal information to these websites.
11. Policy changes
12. How to contact us
12.1.1 by telephoning on 0800 1018 365; or
12.1.2 by writing to us at: Gledhill Response Ltd, Sycamore Estate, Squires Gate, Blackpool FY4 3RL.
12.1.3 by emailing us at firstname.lastname@example.org