It contains important information on who we are and how and why we collect, store, use and share your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint.
We collect, use and are responsible for certain personal information about you. When we do so we are subject to data protection laws which apply across the European Union and the United Kingdom and we are responsible as ‘controller’ of that personal information for the purposes of those laws.
By providing us with your data, you warrant to us that you are over 13 years of age.
Alex Karjalainen trading as Alex Jaron
Email address: email@example.com
Postal address: Office 46732, PO Box 6945, London, W1A 6US
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). However, we care deeply about your data protection rights and we would appreciate the chance to deal with your concerns before you approach the ICO so please contact us using the details above in the first instance.
Personal data, or personal information, 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).
· Identity Data includes first name, last name, username or similar identifier, title, date of birth and gender.
· Contact Data includes billing address, delivery or postal address, email address and telephone numbers.
· Financial Data includes bank account and payment card details.
· Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
· Technical Data includes 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 this website.
· Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
· Usage Data includes information about how you use our website, products and services.
· Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature.
Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data, and criminal convictions and offences.
We do not collect any sensitive data about you.
· Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you (where applicable):
· apply for our products or services;
· create an account on our website;
· subscribe to our service or publications;
· request marketing to be sent to you;
· enter a competition, promotion or survey; or
· give us some feedback or contact us.
· Analytics We may receive technical personal data about you from analytics providers such as Google.
· We may receive Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Paypal.
· 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.
· Where we need to comply with a legal or regulatory obligation.
To keep you updated about our products and services where you have consented to this. We shall send this information to you by email. You have the right to withdraw consent to marketing at any time by contacting us using the contact details in clause 1 above and by clicking on the ‘unsubscribe’ button in our emails.
We have set out a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
You can view the table of descriptions here. (Will open in a new window).
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. Our lawful ground for processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business).
Under the Privacy and Electronic Communications Regulations, we may send you marketing communications from us if (i) you made a purchase or asked for information from us about our goods or services or (ii) you agreed to receive marketing communications and in each case you have not opted out of receiving such communications since. Under these regulations, if you are a limited company, we may send you marketing emails without your consent. However, you can still opt out of receiving marketing emails from us at any time.
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 and, in each case, you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any third party.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us using the contact details in clause 1 above.
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.
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.
· External Third Parties such as service providers, professional advisers, HMRC and regulators; and
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.
To deliver services to you, it is sometimes necessary for us to share your personal information outside the European Economic Area (EEA), eg:
• with our service providers located outside the EEA;
• if you are based outside the EEA;
• where there is an international dimension to the services we are providing to you.
These transfers are subject to special rules under European and UK data protection law.
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. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
• 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 Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
• Where we use providers based in the US, 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 Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
If you would like further information, please contact us using the contact details in clause 1 above.
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 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. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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.
If you are not a customer we shall retain your data for 1 year following your last engagement with us.
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.
· Request access to your personal data.
· Request correction of your personal data.
· Request erasure of your personal data.
· Object to processing of your personal data.
· Request restriction of processing your personal data.
· Request transfer of your personal data.
· Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us using the contact details in clause 1 above.
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 may refuse to comply with your request in these circumstances.