We are Siddall & Hilton Products Limited, a company incorporated in England and Wales. Our company number is 03460386 and our registered office is at Birds Royd Lane, Brighouse, West Yorkshire HD6 1LT (“we”/ “our” / “us”). We are committed to ensuring that your privacy is protected. We will continue to comply with the provisions of the General Data Protection Regulation ((EU) 2016/679) (“GDPR”) unless and until the GDPR is no longer directly applicable in the UK, together with any national implementing laws, regulations and secondary legislation as amended or updated from time to time in the UK including the Data Protection Act 2018 (“DPA”), and any successor legislation to the GDPR and the DPA (together “Data Protection Legislation”). We are the controller of personal data you pass to us pursuant to this policy.
We have nominated our Technology Director to have day to day responsibility for ensuring we comply with the Data Protection Legislation and dealing with any requests we receive from individuals exercising their rights under the Data Protection Legislation.
1. What information do we hold and how will we use it?
1.1 We may collect and process the following data about you:
1.1.2 Information we collect about you: We may collect the following information from you when you visit our website:
18.104.22.168 technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug in types and versions, operating system and platform; and
22.214.171.124 information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from the website (including date and time), products you viewed or searched for, page response times, website errors, length of visits to certain pages, page interaction information, methods used to browse away from the page and any phone number used to call our customer services number.
3. Use made of the information
3.1 We may use the information we receive and/or collect about you to:
3.1.1 fulfil our obligations under any contract we have entered into with you and to provide you with information, products and services you have requested (in which case our external fair processing notice, available here [insert link] will also apply to our processing of your personal data);
3.1.2 send you newsletters and marketing information if you have consented to us doing so or if there are other grounds in GDPR which mean we are entitled to send marketing communications to you;
3.1.3 notify you of products and services we offer that are similar to those you have purchased or enquired about;
3.1.4 notify you of other products and services we feel may interest you, or permit third parties to do so if you have consented to us doing so;
3.1.5 notify you of changes to our services and products; and
3.1.6 monitor website usage and provide statistics to third parties for the purposes of improving and developing the website and the services we provide via the website.
3.2 We collect and process much of your personal information on the grounds of legitimate interests, which include some or all of the following:
3.2.1 where the processing enables us to enhance, modify, personalise or otherwise improve the website, our services and communications for the benefit of our customers;
3.2.2 to identify and prevent fraud;
3.2.3 to enhance the security of our network and information systems;
3.2.4 to better understand how people interact with our websites;
3.2.5 administer the website and carry out data analysis, troubleshooting and testing; and
3.2.6 to determine the effectiveness of promotional campaigns and advertising.
3.3 If we require your personal data for fulfilment of a contract with you (for example to provide goods and services you have requested), we may be unable to fulfil the contract without your personal data.
3.4 If we are unable to rely on legitimate interests or any other ground set out in the GDPR to process your personal data, we will obtain consent from you to the processing.
3.5 If we obtain consent from you to do so, we may provide your personal details to third parties so that they can contact you directly in respect of services and/or products in which you may be interested.
3.6 You have the right to withdraw your consent to the processing of your personal data at any time. If you would like to withdraw your consent, or prefer not to receive any of the above-mentioned information (or if you only want to receive certain information) from us please let us know by contacting us via our website or, if applicable, by clicking the “unsubscribe” option in one of our emails to you. Please bear in mind that if you object this may affect our ability to carry out tasks above for your benefit. Withdrawal of your consent won’t affect any processing we have carried out in respect of your personal data prior to you withdrawing consent.
3.7 If you wish to have your information removed from our database or if you do not want us to contact you for marketing purposes, please let us know by clicking the “Unsubscribe” option in any email we send to you and providing the details requested or by contacting us via our website and we will take steps to ensure that this information is deleted as soon as reasonably practicable.
3.8 We will not share, sell or distribute any of the information you provide to us (other than as set out in this policy) without your prior consent, unless required to do so by law.
3.9 If you would like more specific information about the grounds on which we rely on to process different elements of your personal data, please contact us at firstname.lastname@example.org.
4. Third Party Sites
5. How safe is your information?
5.1 Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
5.2 Protecting your security and privacy is important to us and we make every effort to secure your information and maintain your confidentiality in accordance with the terms of the Data Protection Legislation. The website is protected by various levels of security technology, which are designed to protect your information from any unauthorised or unlawful access, processing, accidental loss, destruction and damage.
5.3 We will do our best to protect your personal data but the transmission of information via the Internet is not completely secure. Any such transmission is therefore at your own risk.
6. Disclosure of your information
6.1 We may share your information with selected third parties including:
6.1.1 business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you; and/or
6.1.2 third parties who may wish to contact you in respect of services and/or products they offer or sell which may be of interest to you, provided we receive your consent to such disclosure.
6.2 Please note that we may need to disclose your personal information where we:
6.2.1 are under a legal duty to comply with any legal obligation or in order to enforce or apply our terms and conditions; or
6.2.2 need to disclose it to protect our rights, property or safety of our customers or others, including the exchange of information with other companies, organisations and/or governmental bodies for the purposes of fraud prevention and credit risk reduction.
6.4 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.
7. Where we store your personal data
8. What are your rights?
You benefit from a number of rights in respect of the personal data we hold about you. We have summarised your rights below, and more information is available from the Information Commissioner’s Office website (https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/). These rights apply for the period in which we process your data as set out above.
1. Access to your data
You have the right to ask us to confirm that we process your personal data, as well as access to and copies of your personal data. You can also ask us to provide a range of information, although most of that information corresponds to the information set out in this fair processing notice.
We will provide the information free of charge unless your request is manifestly unfounded or excessive or repetitive, in which case we are entitled to charge a reasonable fee. We may also charge you if you request more than one copy of the same information.
We will provide the information you request as soon as possible and in any event within one month of receiving your request. If we need more information to comply with your request, we’ll let you know.
2. Rectification of your data
If you believe personal data we hold about you is inaccurate or incomplete, you can ask us to rectify that information. We will comply with your request within one month of receiving it, unless we don’t feel it’s appropriate in which case we’ll let you know why. We’ll also let you know if we need more time to comply with your request.
3. Right to be forgotten
In some circumstances, you have the right to ask us to delete personal data we hold about you. This right is available to you:
• where we no longer need your personal data for the purpose for which we collected it;
• where we have collected your personal data on the grounds of consent and you withdraw that consent;
• where you object to the processing and we don’t have any overriding legitimate interests to continuing processing the data;
• where we have unlawfully processed your personal data (i.e. we have failed to comply with GDPR); and
• where the personal data has to be deleted to comply with a legal obligation.
There are certain scenarios in which we are entitled to refuse to comply with a request. If any of those apply, we’ll let you know.
4. Right to restrict processing
In some circumstances you are entitled to ask us to suppress processing of your personal data. This means we will stop actively processing your personal data but we don’t have to delete it. This right is available to you:
• if you believe the personal data we hold isn’t accurate – we’ll cease processing it until we can verify its accuracy;
• if you have objected to us processing the data – we’ll cease processing it until we have determined whether our legitimate interests override your objection;
• if the processing is unlawful; or
• if we no longer need the data but you would like us to keep it because you need it to establish, exercise or defend a legal claim.
5. Data portability
You have the right to ask us to provide your personal data in a structured, commonly used and machine-readable format so that you are able to transmit the personal data to another data controller. This right only applies to personal data you provide to us:
• where processing is based on your consent or for performance of a contract (i.e. the right does not apply if we process your personal data on the grounds of legitimate interests); and
• where we carry out the processing by automated means.
We’ll respond to your request as soon as possible and in any event within one month from the date we receive it. If we need more time, we’ll let you know.
6. Right to object
You are entitled to object to us processing your personal data:
• if the processing is based on legitimate interests or performance of a task in the public interest or exercise of official authority;
• for direct marketing purposes (including profiling); and/or
• for the purposes of scientific or historical research and statistics.
In order to object, you must have grounds for doing so based on your particular situation. We will stop processing your data unless we can demonstrate that there are compelling legitimate grounds which override your interests, rights and freedoms or the processing is for the establishment, exercise or defence of legal claims.
Your right to complain about our processing
If you think we have processed your personal data unlawfully or that we have not complied with GDPR, you can report your concerns to the supervisory authority in your jurisdiction. The supervisory authority in the UK is the Information Commissioner’s Office (“ICO”). You can call the ICO on 0303 123 1113 or get in touch via other means, as set out on the ICO website – https://ico.org.uk/concerns/.
If you have any questions or would like more information about the ways in which we process your data, please contact us at email@example.com.