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Privacy Notice for Great British Hair Limited

April 2018

Who are we?

Great British Hair Limited, a company registered in England & Wales (10659086) and trading at Unit 7 Silks Yard, Church Hill, Horsell GU21 3QE.

What is the purpose of this Privacy Notice?

Great British Hair Limited respects your privacy and is committed to protecting your personal data at all times and in accordance with the General Data Protection Regulation.

 

This Privacy Notice describes how we collect, use and process your personal data and how in doing so, we comply with our legal obligations to you.

 

What personal data do we collect?

Personal data 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).

During our communications with you – whether over the telephone, face to face, in written communications, via email or via our website at www.britishhair.com – we may collect from you and keep a record of the following personal data:

  • Identity Data including first name, maiden name, last name, username or similar identifier, title, date of birth, gender and occupation.
  • Contact Data including billing address, delivery address, email address and telephone numbers.
  • Financial Data including bank account and payment card details.
  • Transaction Data including details about payments to and from you and details of products you have purchased from us.
  • Technical Data including 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 our website.
  • Profile Data including purchases or orders made by you, your interests, preferences, feedback and survey responses.
  • Usage Data including information about how you use our website, products and services.
  • Marketing and Communications Data including your preferences in receiving marketing from us and our third parties and your communication preferences.

Please advise us at any time if your information changes or is inaccurate, so that we can update our records and systems.

 

How do we collect your personal data?

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 communicating with us by post, phone, email or otherwise. This includes personal data you provide when you: access our products or services; subscribe to our services, publications or mailing list; request marketing to be 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, server logs and other similar technologies.

 

  • Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:

 

  1. Technical Data from advertising networks, search information providers, analytics providers and website hosting providers;
  2. Identity, Contact, Financial and Transaction Data from providers of technical, payment, delivery, website hosting, marketing, banking and customer relationship management services;
  3. Identity and Contact Data from publicly available sources such as Companies House.

 

How do we use your personal data?

We will only use your personal data where 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, such as actioning a request for products and services pre-sales.

 

  • Where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to 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.

 

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

 

  1. 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 purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

 

  1. Third-party marketing
  • We will get your express opt-in consent before we share your personal data with any company outside Great British Hair Limited for marketing purposes.

 

  1. Opting out
  • You can ask us or third parties to stop sending you marketing messages 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.

 

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.

 

Who do we share your information with?

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.

Great British Hair Limited may share your personal data for the purposes set out in the table above with the following:

 

  1. Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets.
  2. Third parties based in the UK acting as processors who provide medical assistance in the event of an accident or injury.
  3. Service providers based in the UK, EEA and USA acting as processors who provide IT and system administration services.
  4. Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.
  5. HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the UK.
  6. Third party manufacturers, suppliers of products and component products and services, in each case acting as processors or joint controllers.
  7. Third party providers based in the UK and USA acting as processors or joint controllers for email marketing purposes.

 

International transfers of personal data

Some of our external third parties may be based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA. Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

 

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.

 

  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in the EEA.

 

  • Where we use providers based in the USA, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the EEA and the USA.

 

How secure is your data?

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.

 

How long do we keep your personal data?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements.

 

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 requirements.

 

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. This may include the right to:

  • Request access to your personal data – 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.

 

  • Request erasure of your personal data – where there is no good reason for us continuing to process it; 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.

 

  • Object to processing of your personal data – where we are relying on a legitimate interest and you feel it impacts on your fundamental rights and freedoms; or 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: (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.

 

  • 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.

 

Should you wish to discuss your rights please contact Great British Hair Limited at info@britishhair.com.

 

Where we need to collect personal data by law or under the terms of a contract we have with you and you do not provide the 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 a product or service you have with us but we will notify you if this is the case at the time.

 

Complaints Procedure

You have the right to lodge a complaint with a supervisory authority, the Information Commissioner’s Office (ICO), if you do not think we are handling your data correctly. The ICO can be contacted on 0303 123 1113. We would, however, appreciate the chance to deal with your concerns before you approach the ICO and so please contact us in this first instance.

 

Other websites

Our website contains links to other websites. This privacy policy only applies to this website so when you link to other websites you should read their own privacy policies.

 

Changes to our privacy policy

We keep our privacy policy under regular review and we will place any updates on our web site.