Introduction
Welcome to Postcode
Cleaners' privacy policy.
Postcode Cleaners
respect your privacy and is committed to protecting your personal data. This
privacy policy will inform you as to how we look after your personal data when
you visit our website (regardless of where you visit it from) and tell you
about your privacy rights and how the law protects you.
1.
Important
information and who we are
Purpose of this privacy policy
This privacy
policy aims to give you information on how Postcode Cleaners collects and
processes your personal data through your use of this website, including any
data you may provide through this website when you create an account.
This website is
not intended for children and we do not knowingly collect data relating to
children.
It is important
that you read this privacy policy together with any other privacy policy or
fair processing policy we may provide on specific occasions when we are
collecting or processing personal data about you so that you are fully aware of
how and why we are using your data. This privacy policy supplements other
notices and privacy policies and is not intended to override them.
Controller
Postcode Cleaners Limited
(trading as “Postcode Cleaners”) is the controller and responsible for your
personal data (collectively referred to as “Postcode Cleaners”, "we",
"us" or "our" in this privacy policy).
We have appointed
a data privacy manager who is responsible for overseeing questions in relation
to this privacy policy. If you have any questions about this privacy policy,
including any requests to exercise your
legal rights, please contact the data privacy manager using the details set
out below.
Contact details
If you have any
questions about this privacy policy or our privacy practices, please contact
our data privacy manager in the following ways:
Full name of legal
entity: Postcode
Cleaners Limited
Email address: info@postcodecleaners.co.uk
Postal address: Briarwood Barrack
Road, West Parley, Ferndown, England, BH22 8UB
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 (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.
Changes to the
privacy policy and your duty to inform us of changes
We keep our
privacy policy under regular review. This version was last updated on 31 August
2020.
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.
Third-party links
This website may
include links to third-party websites, plug-ins and applications. Clicking on
those links or enabling those connections may allow third parties to collect or
share data about you. We do not control these third-party websites and are not
responsible for their privacy statements. When you leave our website, we
encourage you to read the privacy policy of every website you visit.
2.
The
data we collect about you
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,
use, store and transfer different kinds of personal data about you which we
have grouped together as follows:
· Identity
Data
includes first name, maiden name, last name, username or similar identifier,
marital status, title, date of birth and gender.
· Contact
Data
includes billing address, delivery address, email address and telephone numbers.
· Financial
Data
includes bank account and payment card details.
· Transaction
Data
includes details about payments to and from you and other details of products
and services you have purchased from us.
· Technical
Data
includes internet protocol (IP) address, your login data, browser type and
version, time zone setting and location, browser plug-in types and versions,
operating system and platform, and other technology on the devices you use to
access this website.
· Profile
Data
includes your username and password, purchases
or orders made by you, your interests, preferences and feedback.
· Usage
Data
includes information about how you use our website, products and services.
· Marketing
and Communications Data includes your preferences in receiving
marketing from us and our third parties and your communication preferences.
We also collect, use and share Aggregated
Data
such as statistical or demographic data for any purpose. Aggregated Data could
be derived from your personal data but is not considered personal data in law
as this data will not directly or
indirectly reveal your identity. For example, we may aggregate your Usage Data
to calculate the percentage of users accessing a specific website feature.
However, if we combine or connect Aggregated Data with your personal data so
that it can directly or indirectly identify you, we treat the combined data as
personal data which will be used in accordance with this privacy policy.
We do not collect any Special
Categories of Personal Data about you (this includes details about
your race or ethnicity, religious or philosophical beliefs, sex life, sexual
orientation, political opinions, trade union membership, information about your
health, and genetic and biometric data). Nor do we collect any information
about criminal convictions and offences.
If you fail to
provide personal data
Where we need to collect personal data by
law, or under the terms of a contract we have with you, and you fail to provide
that data when requested, we may not be able to perform the contract we have or
are trying to enter into with you (for example, to provide you with goods or
services). In this case, we may have to cancel your account with us but we will
notify you if this is the case at the time.
3.
How
is your personal data collected?
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:
· create an account
on our website;
· subscribe to our
service or publications;
· request marketing
to be sent to you; or
· give us feedback
or contact us.
· Automated
technologies or interactions. As you interact with our website, we will
automatically collect Technical Data about your equipment, browsing actions and
patterns. We collect this personal data by using cookies, and other similar
technologies.
·
Third parties or publicly available sources. We will receive
personal data about you from various third parties and public sources as set
out below:
Technical Data from the following
parties:
(a)
analytics
providers such as Google based outside the EU;
(b)
advertising
networks; and
(c)
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 available sources.
4.
How
we use your personal data
We will only use
your personal data when the law allows us to. Most commonly, we will use your
personal data in the following circumstances:
· Where we need to
perform the contract we are about to enter into or have entered into with you.
· Where it is
necessary for our legitimate interests (or those of a third party) and your
interests and fundamental rights do not override those interests.
· Where we need to comply
with a legal obligation.
Generally, we do
not rely on consent as a legal basis for processing your personal data although
we will get your consent before sending third party direct marketing
communications to you via email or text message. You have the right to withdraw
consent to marketing at any time by contacting us.
Purposes for which
we will use your personal data
We have set out
below, in a table format, a description of all the ways we plan to use your
personal data, and which of the legal bases we rely on to do so. We have also
identified what our legitimate interests are where appropriate.
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. Please contact us if you
need details about the specific legal ground we are relying on to process your
personal data where more than one ground has been set out in the table below.
Purpose/Activity
|
Type of data
|
Lawful basis for
processing including basis of legitimate interest
|
To
register you as a new customer
|
(a)
Identity
(b)
Contact
|
Performance
of a contract with you
|
To
process your account details including:
(a)
Manage payments, fees and charges
(b)
Collect and recover money owed to us
|
(a)
Identity
(b)
Contact
(c)
Financial
(d)
Transaction
(e)
Marketing and Communications
|
(a)
Performance of a contract with you
(b)
Necessary for our legitimate interests (to recover debts due to us)
|
To
manage our relationship with you which will include:
(a)
Notifying you about changes to our terms or privacy policy
(b)
Asking you to leave a review
|
(a)
Identity
(b)
Contact
(c)
Profile
(d)
Marketing and Communications
|
(a)
Performance of a contract with you
(b)
Necessary to comply with a legal obligation
(c)
Necessary for our legitimate interests (to keep our records updated and to
study how customers use our products/services)
|
To
administer and protect our business and this website (including
troubleshooting, data analysis, testing, system maintenance, support,
reporting and hosting of data)
|
(a)
Identity
(b)
Contact
(c)
Technical
|
(a)
Necessary for our legitimate interests (for running our business, provision
of administration and IT services, network security, to prevent fraud and in
the context of a business reorganisation or group restructuring exercise)
(b)
Necessary to comply with a legal obligation
|
To
deliver relevant website content and advertisements to you and measure or
understand the effectiveness of the advertising we serve to you
|
(a)
Identity
(b)
Contact
(c)
Profile
(d)
Usage
(e)
Marketing and Communications
(f)
Technical
|
Necessary
for our legitimate interests (to study how customers use our
products/services, to develop them, to grow our business and to inform our
marketing strategy)
|
To
use data analytics to improve our website, products/services, marketing,
customer relationships and experiences
|
(a)
Technical
(b)
Usage
|
Necessary
for our legitimate interests (to define types of customers for our products
and services, to keep our website updated and relevant, to develop our
business and to inform our marketing strategy)
|
Marketing
We strive to
provide you with choices regarding certain personal data uses, particularly
around marketing and advertising. We have established a privacy centre where
you can view and make certain decisions about your personal data use.
Promotional offers
from us
We may use your
Identity, Contact, Technical, Usage and Profile Data to form a view on what we
think you may want or need, or what may be of interest to you. This is how we
decide which products, services and offers may be relevant for you (we call
this marketing).
You will receive
marketing communications from us if you have requested information from us or created
an account with us and you have not opted out of receiving that marketing.
Third-party
marketing
We will get your express opt-in consent
before we share your personal data with any third party for marketing purposes.
Opting out
You can ask us or
third parties to stop sending you marketing messages at any time 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 product/service purchase, warranty
registration, product/service experience or other transactions].
Cookies
You can set your
browser to refuse all or some browser cookies, or to alert you when websites
set or access cookies. If you disable or refuse cookies, please note that some
parts of this website may become inaccessible or not function properly. For
more information about the cookies we use, please see our Cookie Policy.
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 law.
5.
Disclosures
of your personal data
We may share your
personal data with the parties set out below for the purposes set out in the
table above.
· External Third
Parties as set out in the Glossary.
· 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 policy.
We
require all third parties to respect the security of your personal data and to
treat it in accordance with the law. 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.
6.
Data
security
We have put in
place appropriate security measures to prevent your personal data from being
accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
In addition, we limit access to your personal data to those employees, agents,
contractors and other third parties who have a business need to know. They will
only process your personal data on our instructions and they are subject to a
duty of confidentiality.
We have put in
place procedures to deal with any suspected personal data breach and will
notify you and any applicable regulator of a breach where we are legally
required to do so.
7.
Data
retention
How long will you
use my personal data for?
We will only retain
your personal data for as long as reasonably necessary to fulfil the purposes
we collected it for, including for the purposes of satisfying any legal,
regulatory, tax, accounting or reporting requirements. We may retain your
personal data for a longer period in the event of a complaint or if we
reasonably believe there is a prospect of litigation in respect to our
relationship with you.
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 your personal data, the purposes for which we
process your personal data and whether we can achieve those purposes through other
means, and the applicable legal, regulatory, tax, accounting or other
requirements.
8.
Your
legal rights
Under certain
circumstances, you have rights under data protection laws in relation to your
personal data.
If you wish to
exercise any of the rights please contact us on info@postcodecleaners.co.uk.
No fee usually
required
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 could refuse to comply
with your request in these circumstances.
What we may need
from you
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.
Time limit to
respond
We try to respond
to all legitimate requests within one month. Occasionally it could 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.
9.
Glossary
LAWFUL BASIS
Legitimate
Interest means the
interest of our business in conducting and managing our business to enable us
to give you the best service/product and the best and most secure experience.
We make sure we consider and balance any potential impact on you (both positive
and negative) and your rights before we process your personal data for our
legitimate interests. We do not use your personal data for activities where our
interests are overridden by the impact on you (unless we have your consent or
are otherwise required or permitted to by law). You can obtain further
information about how we assess our legitimate interests against any potential
impact on you in respect of specific activities by contacting us.
Performance
of Contract means processing
your data where it is necessary for the performance of a contract to which you
are a party or to take steps at your request before entering into such a
contract.
Comply
with a legal obligation means processing
your personal data where it is necessary for compliance with a legal obligation
that we are subject to.
THIRD PARTIES
External Third
Parties
· Service providers acting
as processors based within the United Kingdom who provide IT and system administration
services.
· Professional
advisers acting as processors or joint controllers including lawyers, bankers,
auditors and insurers based within the United Kingdom who provide consultancy,
banking, legal, insurance and accounting services.
· HM Revenue & Customs,
regulators and other authorities acting as processors or joint controllers
based in the United Kingdom who require reporting of processing activities in
certain circumstances.
YOUR LEGAL RIGHTS
You have the right
to:
Request
access to
your personal data (commonly known as a "data subject access
request"). 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 may need
to verify the accuracy of the new data you provide to us.
Request
erasure of
your personal data. This enables you to ask us to delete or remove personal
data 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 data where you have
successfully exercised your right to object to processing (see below), where we
may have processed your information unlawfully or where we are required to
erase your personal data to comply with local law. Note, however, that we may
not always be 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.
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. In some cases, we
may 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 the following scenarios:
· If you want us to
establish the data's accuracy.
· Where our use of
the data is unlawful but you do not want us to erase it.
· Where you need us
to hold the data even if we no longer require it as you need it to establish,
exercise or defend legal claims.
· You have objected
to our use of your data but we need to verify whether we have overriding
legitimate grounds to use it.
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.
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.
If you withdraw your consent, we may not be able to provide certain products or
services to you. We will advise you if this is the case at the time you
withdraw your consent.