This Policy applies to our use of any and all data collected by us in relation to your use of Our Site and any Services therein.
1 DEFINITIONS AND INTERPRETATIONS
In this Policy the following terms shall have the following meanings:
"Account" means the customer account, which contains collectively the personal information, payment information and credentials used by Users to access material and / or any Services on Our Site;
“Content” means any text, graphics, images, audio, video, software, data compilations and any other form of information capable of being stored in a computer that appears on or forms part of Our Site;
"Cookie” means a small text file placed on your computer by us when you visit certain parts of Our Site. This allows us to identify recurring visitors and to analyse their browsing habits within Our Site. Where e-commerce facilities are provided, Cookies may be used to store items in your shopping basket. Further details are contained in paragraph 10 and Schedule 1 of this Policy;
“Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;
“Personal Data” has the same meaning as defined in EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”) and in this case, it means the Personal Data that you give to us via Our Site,
“Service” means any online communications infrastructure that we make available through Our Site either now or in the future. This includes, but is not limited to, web-based email, message boards, live chat facilities and email links; and
“User” / “Users” means any third party that accesses Our Site and is not employed by us and acting in the course of their employment.
2 DATA COLLECTED
We may collect various Personal Data from you dependent on the purposes for which you engage with Our Site. These may include, amongst others, your:
2.2 date of birth;
2.5 contact information such as email addresses and telephone numbers;
2.6 demographic information such as post code, preferences and interests;
2.7 financial information such as credit / debit card numbers;
2.8 IP address (automatically collected);
2.9 web browser type and version (automatically collected);
2.10 operating system (automatically collected);
2.11 a list of URLS starting with a referring site, your activity on Our Site, and the site you exit to (automatically collected); and
2.12 Cookie information (see paragraph 10 below).
3 OUR USE OF DATA
3.1 Any or all of the above Personal Data may be required by us from time to time in order to provide you with the best possible service and experience when using Our Site.
We will process your Personal Data where it is necessary to perform a contract we have with you, i.e. to provide the Services; because you have consented to our use of your personal data (e.g. by subscribing to emails); or, because it is in our legitimate interests. Where we are relying on the lawful basis of legitimate interests, our legitimate interests are to provide excellent customer service and to inform you of similar products and services to those which you have previously purchased or expressed an interest in.
Specifically, Personal Data may be used by us for the following reasons:
3.1.1 managing Accounts and completing transactions;
3.1.2 engaging with our customers with marketing emails and social media;
3.1.3 sending service messages and handling any complaints, queries or customer communication;
3.1.4 internal record keeping;
3.1.5 improvement of our products / services;
3.1.6 transmission by email of promotional materials that may be of interest to you;
3.1.7 contact for market research purposes which may be done using email, telephone, fax or mail. Such information may be used to customise or update Our Site; or
3.1.8 website and business analytics, which will be carried out on anonymised data in line with paragraph 8.2 below. Some of this analysis may be grouped by postcodes, which has the limited potential of constituting Personal Data.
4 THIRD PARTY WEBSITES AND SERVICES
5 CHANGES OF BUSINESS OWNERSHIP AND CONTROL
5.1 We may, from time to time, expand or reduce its business and this may involve the sale of certain divisions or the transfer of control of certain divisions to other parties. Personal Data provided by Users will, where it is relevant to any division so transferred, be transferred along with that division and the new owner or newly controlling party will, under the terms of this Policy, be permitted to use the Personal Data for the purposes for which it was supplied by you.
5.2 In the event that any Personal Data submitted by Users will be transferred in such a manner, you will be contacted and informed of the changes. When contacted you will be given the choice to have your Personal data deleted.
6 CONTROLLING YOUR PERSONAL DATA
6.1 Wherever you are required to submit Personal Data, you will be given options to restrict our use of that Personal Data. This may include the following:
6.1.1 use of Personal Data for direct marketing purposes; and
6.1.2 sharing Personal Data with third parties.
6.2 When you submit Personal Data via Our Site, you may be given options to restrict our use of your Personal Data. In particular, we aim to give you strong controls on our use of your Personal Data for direct marketing purposes. This includes the ability to opt-out of receiving emails from us either (i) by not giving your consent at the point of providing your details or (ii) by subsequently unsubscribing using the links provided in our emails.
A customer can unsubscribe from receiving marketing communications at any time, by clicking on the link to unsubscribe which is in all marketing emails.
7 DISCLOSURE OF YOUR PERSONAL DATA
7.7 Unless we are obliged or permitted by law to do so, and subject to paragraph 4 above, your Personal Data will not be disclosed to or shared with third parties for any purposes.
8.1 We will only keep your Personal Data for as long as we need to in order to use it as described above in paragraph 3 in line with the following periods:
Customer Account data - This data is deleted after a period of three years of inactivity on the Account. Inactivity means an order, or, communication activity, such as clicking on or opening an email, or making a query.
Subscriber data - Three years
8.2 In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
9 YOUR RIGHT TO WITHHOLD INFORMATION
9.1 You may access certain areas of Our Site without providing any Personal Data at all. However, to use all Services available on Our Site you may be required to submit Account information or other Personal Data.
10 ACCESSING YOUR OWN DATA
10.1 You may access your Account at any time to view or amend the Personal Data. You may need to modify or update your Personal Data if your circumstances change. Additional Personal Data as to your marketing preferences may also be stored and you may change this at any time.
10.2 You have the right to ask for a copy of your Personal Data. Under the GDPR, no fee is payable and we will provide any and all information applicable in response to your request.
11. YOUR RIGHTS
You have the right to:
a) Request access to your personal data (commonly known as a "data subject access request") as in paragraph 10.
b) Request correction of any inaccurate personal data that we hold about you.
c) 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.
d) 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.
e) 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: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
f) Request the transfer of your personal data to you or to a third party 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.
g) 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. (See paragraph 6.2. above for details of how to withdraw your consent to receiving marketing emails from us.)
h) Complain 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.
12.1 All Personal Data is stored securely in accordance with the principles of the GDPR.
12.2 Personal Data security is of great importance to us and to protect your Personal Data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure Personal Data collected online.
12.3 Some or all of your Personal Data may be stored outside of the European Economic Area (“the EEA”). (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). If we do store data outside the EEA, we will implement appropriate safeguards to ensure that your data is treated as safely and securely as it would be within the UK. Please contact us, using the details outlined below, if you want further information on the appropriate safeguard used by us when transferring your personal data out of the EEA.
13.2 Before Our Site sets Cookies on your computer, you will be presented with a prompt requesting your consent to set those Cookies. You will be deemed to have given your consent if you continue to use Our Site without expressly withdrawing your consent. None of the Cookies set by Our Site jeopardise your privacy in any way and no Personal Data is collected. By giving your consent to the setting of our Cookies you are enabling us to provide the best possible experience and service to you through Our Site. If you wish to deny your consent to the placing of Cookies, certain features of Our Site may not function fully or as intended.
13.3 You can choose to enable or disable Cookies in your web browser. By default, your browser will accept Cookies, however this can be altered. For further details please consult the help menu in your browser. Disabling Cookies may prevent you from using the full range of Services available on Our Site.
13.4 You may delete Cookies at any time however you may lose any information that enables you to access Our Site more quickly.
13.5 It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your browser if you are unsure as to how to adjust your privacy settings.
14 CHANGES TO THIS POLICY
We reserve the right to change this Policy as we may deem necessary from time to time or as may be required by law. Any changes will be posted on Our Site.
15 CONTACTING US
If you have any questions about Our Site or this Policy, please contact us by email at firstname.lastname@example.org; by telephone on 020 8207 7000; or by post to All Outdoor Ltd, Units 6 to 8, Hamilton Business Park, Stirling Way, Borehamwood, Herts, WD6 2FR. Please ensure that your query is clear, particularly if it is a request for information about the data we hold about you (as under paragraph 8 above).
Schedule 1: First-Party Cookies
'CMS_toolbar-collapsed': cookie used for django cms to produce a toolbar (admin users only)
'_ga': Google Analytics unique identifier
'_gat'L Google Analytics tracking cookie
'csrftoken': Cross site request forgery token for validation
'sessionid': Used to identify a user in a web session, for example used for maintaining the shopping basket when the user is not logged in
'cb-enabled': Tracks whether the user has agreed the usage of cookies
All Outdoor Ltd
GDPR COMPLIANCE STATEMENT
The EU General Data Protection Regulation (“GDPR”) is now in force across the European Union and brings with it the most significant changes to data protection law in two decades. Based on privacy by design and taking a risk-based approach, the GDPR has been designed to meet the requirements of the digital age.
The 21st Century brings with it broader use of technology, new definitions of what constitutes personal data, and a vast increase in cross-border processing. The new Regulation aims to standardise data protection laws and processing across the EU; affording individuals stronger, more consistent rights to access and control their personal information.
All Outdoor Ltd are committed to ensuring the security and protection of the personal information that we process, and to provide a compliant and consistent approach to data protection. We have always had a robust and effective data protection program in place which complies with existing law and abides by the data protection principles. However, we recognise our obligations in updating and expanding this program to meet the demands of the.
All Outdoor Ltd are dedicated to safeguarding the personal information under our remit and in developing a data protection regime that is effective, fit for purpose and demonstrates an understanding of, and appreciation for the new Regulation. Our preparation and objectives for GDPR compliance have been summarised in this statement and include the development and implementation of new data protection roles, policies, procedures, controls and measures to ensure maximum and ongoing compliance.
How We are Prepared for GDPR law
All Outdoor Ltd already have a consistent level of data protection and security across our organisation, and were fully compliant with the GDPR by 25th May 2018.
Our preparation: -
- Information Audit - carrying out a company-wide information audit to identify and assess what personal information we hold, where it comes from, how and why it is processed and if and to whom it is disclosed.
- Policies & Procedures– revising or implementing new data protection policies and procedures to meet the requirements and standards of the GDPR and any relevant data protection laws, including: -Legal Basis for Processing- we are reviewing all processing activities to identify the legal basis for processing and ensuring that each basis is appropriate for the activity it relates to. Where applicable, we also maintain records of our processing activities, ensuring that our obligations under Article 30 of the GDPR and Schedule 1 of the Data Protection Bill are met.
- Data Protection – our main policy and procedure document for data protection has been overhauled to meet the standards and requirements of the GDPR. Accountability and governance measures are in place to ensure that we understand and adequately disseminate and evidence our obligations and responsibilities; with a dedicated focus on privacy by design and the rights of individuals.
- Data Retention & Erasure – we have updated our retention policy and schedule to ensure that we meet the ‘data minimisation’ and ‘storage limitation’ principles and that personal information is stored, archived and destroyed compliantly and ethically. We have dedicated erasure procedures in place to meet the new ‘Right to Erasure’ obligation and are aware of when this and other data subject’s rights apply; along with any exemptions, response timeframes and notification responsibilities.
- Data Breaches – our breach procedures ensure that we have safeguards and measures in place to identify, assess, investigate and report any personal data breach at the earliest possible time. Our procedures are robust and have been disseminated to all employees, making them aware of the reporting lines and steps to follow.
- International Data Transfers & Third-Party Disclosures – where All Outdoor Ltd stores or transfers personal information outside the EU, we have robust procedures and safeguarding measures in place to secure, encrypt and maintain the integrity of the data. Our procedures include a continual review of the countries with sufficient adequacy decisions, as well as provisions for binding corporate rules; standard data protection clauses or approved codes of conduct for those countries without. We carry out strict due diligence checks with all recipients of personal data to assess and verify that they have appropriate safeguards in place to protect the information, ensure enforceable data subject rights and have effective legal remedies for data subjects where applicable.
- Subject Access Request (SAR) – we have revised our SAR procedures to accommodate the revised 30-day timeframe for providing the requested information and for making this provision free of charge. Our new procedures detail how to verify the data subject, what steps to take for processing an access request, what exemptions apply and a suite of response templates to ensure that communications with data subjects are compliant, consistent and adequate.
- Privacy Notice/Policy – we our Privacy Notice(s) to comply with the GDPR, ensuring that all individuals whose personal information we process have been informed of why we need it, how it is used, what their rights are, who the information is disclosed to and what safeguarding measures are in place to protect their information.
- Obtaining Consent - we our consent mechanisms for obtaining personal data, ensuring that individuals understand what they are providing, why and how we use it and giving clear, defined ways to consent to us processing their information. We have developed stringent processes for recording consent, making sure that we can evidence an affirmative opt-in, along with time and date records; and an easy to see and access way to withdraw consent at any time.
- Direct Marketing - we the wording and processes for direct marketing, including clear opt-in mechanisms for marketing subscriptions; a clear notice and method for opting out and providing unsubscribe features on all subsequent marketing materials.
- Data Protection Impact Assessments (DPIA) – where we process personal information that is considered high risk, involves large scale processing or includes special category/criminal conviction data; we have developed stringent procedures and assessment templates for carrying out impact assessments that comply fully with the GDPR’s Article 35 requirements. We have implemented documentation processes that record each assessment, allow us to rate the risk posed by the processing activity and implement mitigating measures to reduce the risk posed to the data subject(s).
- Processor Agreements – where we use any third-party to process personal information on our behalf (i.e. Payroll, Recruitment, Hosting etc), we have drafted compliant Processor Agreements and due diligence procedures for ensuring that they (as well as we), meet and understand their/our GDPR obligations. These measures include initial and ongoing reviews of the service provided, the necessity of the processing activity, the technical and organisational measures in place and compliance with the GDPR.
- Special Categories Data - where we obtain and process any special category information, we do so in complete compliance with the Article 9 requirements and have high-level encryptions and protections on all such data. Special category data is only processed where necessary and is only processed where we have first identified the appropriate Article 9(2) basis or the Data Protection Bill Schedule 1 condition. Where we rely on consent for processing, this is explicit and is verified by a signature, with the right to modify or remove consent being clearly signposted.
Data Subject Rights
In addition to the policies and procedures mentioned above that ensure individuals can enforce their data protection rights, we provide easy to access information of an individual’s right to access any personal information that All Outdoor Ltd processes about them and to request information about: -
- What personal data we hold about them
- The purposes of the processing
- The categories of personal data concerned
- The recipients to whom the personal data has/will be disclosed
- How long we intend to store your personal data for
- If we did not collect the data directly from them, information about the source
- The right to have incomplete or inaccurate data about them corrected or completed and the process for requesting this
- The right to request erasure of personal data (where applicable) or to restrict processing in accordance with data protection laws, as well as to object to any direct marketing from us and to be informed about any automated decision-making that we use
- The right to lodge a complaint or seek judicial remedy and who to contact in such instances
Information Security & Technical and Organisational Measures
All Outdoor Ltd takes the privacy and security of individuals and their personal information very seriously and take every reasonable measure and precaution to protect and secure the personal data that we process. We have robust information security policies and procedures in place to protect personal information from unauthorised access, alteration, disclosure or destruction and have several layers of security measures, including: website SSL, access controls, password policy, encryptions, and good practices.
GDPR Roles and Employees
All Outdoor Ltd a designated staff member as our Data Protection Officer (DPO) Appointed Person and have appointed a data privacy team to develop and implement our roadmap for complying with the new data protection Regulation. The team are responsible for promoting awareness of the GDPR across the organisation, assessing our GDPR readiness, identifying any gap areas and implementing the new policies, procedures and measures.
All Outdoor Ltd understands that continuous employee awareness and understanding is vital to the continued compliance of the GDPR and have involved our employees in our preparation plans. We have implemented an employee training program specific to the which will be provided to all employees prior to May 25th, 2018, and forms part of our induction and annual training program.
If you have any questions about our preparation for the GDPR, please email us via our Contact Us web-form and our currently appointed GDPR staff member will contact you back.