- Policy Statement
1.1. Logo That Polo is committed to protecting our customer privacy and takes its responsibility regarding the security of customer information very seriously. We will be clear and transparent about the information we are collecting and what we will do with that information.
1.3. This Policy sets out the following:
(a) What personal data we collect and process about you in connection with your relationship with us as a customer and through your use of our website;
(b) Where we obtain the data from;
(c) What we do with that data;
(d) How we store the data;
(e) Who we transfer/disclose that data to;
(f) How we deal with your data protection rights;
(g) And how we comply with the data protection rules.
(h) All personal data is collected and processed in accordance with EU data protection laws.
- Contact Details
2.1. You can contact us by post at the below address, by email at firstname.lastname@example.org or by telephone on 01304330715.
2.2. The contact details of our Data Representative are:
2 Carlsden Close
- What Personal Data we collect
3.1. We may collect and process the following data about you:
(a) information we collect: this is information about you that you give us by filling in forms on our site or by corresponding with us by phone, e-mail or otherwise. It includes information you provide if you register to use our site, subscribe to our service, and when you report a problem with our site. The information you give us may include your
iii. e-mail address
- Phone number.
- Technical information (such as IP address)
Your name and surname and your contact details
(email address, telephone number and postal address) When you create an account on our website
When you request information
When you take part in our competitions, or
When you choose an offer we make available on our website
Information about your transaction, including your payment card details when you purchase products or services.
The communications you exchange with us (for example, your emails, letters, calls, or your messages) When you contact us or you are contacted by us
Your posts and messages on social media directed to us. When you interact with us on social media
Your feedback When you reply to our requests for feedback or participate in our customer surveys
Information about how you use our website when you navigate on our website
Information that relates to your memberships/account. When you open an account
- How do we use your Personal Data?
4.1. information you give to us: We may use this information:
(a) to contact you, respond to any correspondence, email or call you have made to us or to provide the information you have requested from us;
(b) to notify you about changes to our service; and
(c) to ensure that content from our site is presented in the most effective manner for you and for your computer.
4.2. information We collect about you: We may use this information:
(a) to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
(b) to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
(c) to allow you to participate in interactive features of our service, when you choose to do so;
(d) as part of our efforts to keep our site safe and secure;
(e) to measure or understand the effectiveness of advertising We serve to you and others, and to deliver relevant advertising to you; and
(f) to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.
(g) information We receive from other sources: We may combine this information with information you give to us and information We collect about you. We may use this information and the combined information for the purposes set out.
4.3. We will only process your personal data where we have a legal basis to do so. The legal basis will depend on the reasons we have collected and need to use your personal data for.
4.4. We may also process your personal data for one or more of the following:
(a) To comply with a legal obligation
(b) You have consented to us using your personal data (e.g. for marketing related uses);
(c) To protect your vital interests or those of another person
(d) It is in our legitimate interests in operating as a business (e.g. for administrative purposes).
- Sensitive Information
5.1. We ask that you not send or disclose any sensitive personal information to us either through our website, post, email, text message, telephone call or by any other method. For clarity, sensitive personal information means information related to racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background or trade union membership.
- How long do we keep your Personal Data?
6.1. We will not retain your data for longer than is necessary to fulfil the purpose it is being processed for. To determine the appropriate retention period, we consider the amount, nature and sensitivity of the personal data, the purposes for which we process it and whether we can achieve those purposes through other means.
6.2. We must also consider periods for which we might need to retain personal data to meet our legal obligations or to deal with complaints and queries.
6.3. When we no longer need your personal data, we will securely delete or destroy it. We will also consider if and how we can minimise over time the personal data that we use, and if we can anonymise your personal data so that it can no longer be associated with you or identify you, in which case we may use that information without further notice to you.
- Where we store your Personal Data
7.1. The data that we collect from you will be stored in the European Union (EU). It may also be processed by staff operating outside the EU who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with the appropriate EU General Data Protection Regulation Article, including Article 45 – Adequacy Decision, Article 46 – Appropriate Safeguards, Article 47 – Binding Corporate Rules, Article 49 (1) – Specific Situation Exemption or Article 49(2) – Transfer to the Data Subject.
7.2. Where we have given you (or where you have chosen) a password which enables you to access certain parts of the website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
7.3. We use physical, technological and administrative safeguards to protect your personal information against loss, misuse or alteration. All your personal information is stored securely and may only be accessed by employees with a legitimate business need to access the information. Unfortunately, the transmission of information via the internet is not completely secure and we cannot guarantee the security of your data transmitted to the website. Any transmission is at your own risk.
- Security of your Personal Data
8.1. We follow strict security procedures in the storage and disclosure of your personal data, and to protect it against accidental loss, destruction or damage.
- Data Processor
9.1. Where we are a Data Processor for your data, we will:
(a) only act on the written instructions of the controller
(b) not use a sub-processor without the prior written authorisation of the controller
(c) co-operate with supervisory authorities (such as the ICO)
(d) ensure the security of its processing
(e) keep records of its processing activities
(f) notify any personal data breaches to the controller
- Your Data Protection Rights
10.1. Under certain circumstances, by law you have the right to:
(a) Request information about whether we hold personal information about you, and, if so, what that information is and why we are holding/using it.
(b) Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
(c) Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
(d) Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).
(e) Object to processing of your personal information 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. You also have the right to object where we are processing your personal information for direct marketing purposes.
(f) Object to automated decision-making including profiling, that is not to be subject of any automated decision-making by us using your personal information or profiling of you.
(g) Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
(h) Request transfer of your personal information in an electronic and structured form to you or to another party (commonly known as a right to “data portability”). This enables you to take your data from us in an electronically useable format and to be able to transfer your data to another party in an electronically useable format.
(i) Withdraw consent. In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
10.2. If you want to exercise any of these rights, then please contact our DPO by post at 2 Carlsden Close, DOVER CT17 0SD.
10.3. You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
10.4. We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
- Direct Marketing Communications
11.1. We may use your data to enable us to send you post and emails with information about our goods and services that we believe may be of interest to you.
11.2. You have the right to withdraw from or amend the receipt of direct marketing communications. If you would like to do this, then simply contact the Data Controller and let us know. If you do decide to do this, then you will miss out on news that we would like to make you aware of.
- Opt -Out
12.1. You can also choose to opt out from receiving marketing communications at any time, by clicking on the relevant unsubscribe link at the bottom of any marketing related email you may receive from us.
12.2. If you prefer, you can also send an email to email@example.com with the header “Unsubscribe”.
13.1. A cookie is a small file of letters and numbers that we may store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.
13.2. Cookies make it easier for you to log on to and use websites. Any aggregate information collected permits us to analyse traffic patterns on our Website. This helps us to provide you with a good experience when you browse our Website and also allows us to improve our Website. By continuing to browse our Website, you consent to any use by us of cookies in accordance with this cookies policy.
- What Cookies do we use?
14.1. We may use the following cookies:
(a) strictly necessary cookies: these are required for the operation of our site. For example, cookies that enable you to log into secure areas of our site;
(b) analytical/performance cookies: they allow us to recognise and count the number of visitors and to see how visitors move around our site when they are using it. This helps us to improve the way our website works by ensuring that users are finding what they are looking for easily;
(c) functionality cookies: these are used to recognise you when you return to our site. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region); and
(d) targeting cookies: these record your visit to our site, the pages you have visited and the links you have followed. We may use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
- How do I accept or reject Cookies?
15.1. Unless you indicate to the contrary, your use of our Website indicates your consent to any use by us of cookies in accordance with our cookies policy.
15.2. You may block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.
Should you need any further information you can contact us by post, by email at firstname.lastname@example.org or by telephone on 01304330715.