2. What is personal data
Personal Data is information that can be used directly or indirectly to identify you. Personal data also includes anonymous information that is linked to information that can be used to directly or indirectly identify you. Personal Data does not include information that has been irreversibly anonymised or aggregated so that it can no longer enable us, whether in combination with other information or otherwise, to identify you.
3. Why we collect personal data
Our legal grounds for collecting your Personal Data is because either you provided your express consent (written, verbal or online) to the processing of your Personal Data, it is necessary for our contractual relationship (“contractual necessity”), the processing is necessary for us to comply with our legal or regulatory obligations or we have a legitimate interest in carrying out the processing for the purpose of managing, operating or promoting our business.
4. Personal data we collect
5. Cookies and similar technologies
6. How we use your personal data
7. Retention period
Trading data We do not, and will never, procure, sell, lease or rent your Personal Data. Automated profiling and decision making We do not use any Personal Data for automated decision making or profiling nor is such data subject to automated decision making or profiling. Legal requirements We may disclose your Personal Data if required to do so by law in order to, for example, respond to a request from law enforcement, a court or a government agency, including in response to public authorities to meet national security or law enforcement requirements, or in the belief that such action is necessary to (a) comply with a legal obligation, (b) protect or defend our rights, interests or property or that of third parties, (c) prevent or investigate possible wrongdoing in connection with our Services, (d) act in urgent circumstances to protect the personal safety of our Customers or the public, or (e) protect against legal liability. Mergers and aquisitions In the event of any sale, consolidation or reorganisation of our businesses (for example mergers and acquisitions), we may disclose your Personal Data to prospective or actual purchasers or their advisers, where appropriate. Third party service providers We may pass limited information to some Third Party Service Providers who we have engaged for the purpose of providing you with our Services and any other contractual obligations we have established with you. Such disclosures may include transferring your Personal Data to payment processors, companies that facilitate your orders, delivery companies and customer service teams. We also share information with analytics providers that assist us in the improvement and optimisation of Our Websites. This analysis data is aggregated and does not identify you. We have verified that these Third Party Service Providers are GDPR compliant and are certified under the EU-US Privacy Shield Framework where these organisations are based outside of the European Union.
10. Your legal rights
You have certain rights concerning the information we hold about you, as defined under the General Data Protection Regulation (“GDPR”). If you have any difficulty in accessing and/or managing your options please contact us by email in the first instance at firstname.lastname@example.org. 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. Choose to decline You may choose not to provide your Personal Data to us. Note that some features of our Services may not be fully available to you if you choose not to provide us with your Personal Data. For example, we may not be able to process your orders without the necessary details. Choose to opt in By choosing to contract business with us, subscribe to any of our marketing and communication Services and register an account on Our Websites you will be given prior informed opportunity to provide the minimum Personal Data required and consent to our retention of same. Access, view, edit and update You have the right to request access to your Personal Data, together with information regarding the nature, processing and disclosure of that data, at any time. We hope to ensure that the Personal Data we possess is accurate at all times and therefore we encourage you to update us should any changes have occurred. As a registered and logged in account holder on Our Websites or authorised Third Party Service Providers websites, you can view and manage the information held on your account at any time. If you have additionally opted in to any of our marketing and communications Services you will find the links to update your information at the bottom of every communication you have previously received or displayed prominently on the relevant website where you signed up. Request correction You have the right to 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 copy You may request a copy of any data we hold about you. Expect our response within and up to 40 days of the date of your request. Upon request, we will provide you with an electronic file containing the Personal Data we hold on record about you. ETS members may request copy via their My Account page when logged in. For all other requests please contact us by email in the first instance at email@example.com. Note that there is a small fee for this service. Choose to opt out and be forgotten You may at any time decide to withdraw your consent to the processing of your Personal Data. If your consent is withdrawn, we will update our database promptly, however, it does not prevent us from processing your Personal Data based on other legal premises, such as fulfilling your orders and storing your order data as required by applicable law. You have the right to 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. Please note that withdrawal of consent does not affect the lawfulness of any processing performed prior to the date on which we receive notice of such withdrawal. We include an unsubscribe link in all electronic marketing messages we send to you and options to cancel your account on Our Websites. ETS members may request that their data is deleted forever via their My Account page when logged in. For all other requests please contact us by email in the first instance at firstname.lastname@example.org. Should you request that your Personal Data is deleted we will respond within 40 days. Object You may have the right to object, on legitimate grounds, to the processing of your Personal Data. Should you believe that our processing of your Personal Data is inaccurate or illegal, we are not processing your data in accordance with the processing purpose or you want to oppose the processing, please contact us by email in the first instance at email@example.com. We will investigate your request promptly before deciding what action to take. Should you believe that our processing of your Personal Data infringes your legal rights, you may lodge a claim with your local supervisory authority – National Data Protection Authorities Transfer You have the right to 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.
12. Changes to this policy