Privacy Policy
1. Introduction
1.1 We are committed to safeguarding the privacy of our
website visitors and service users.
1.2 This policy applies where we are acting as a data
controller with respect to the personal data of our website visitors and
service users; in other words, where we determine the purposes and means of the
processing of that personal data.
1.3 We will ask you to consent to our use of cookies in
accordance with the terms of this policy when you first visit our website where
applicable.
2. Credit
2.1 This document was created using a template from SEQ
Legal (https://seqlegal.com)
3. How we use your personal data
3.1 In this Section 3 we have set out:
(a) the general categories of personal data that we may
process;
(b) the purposes for which we may process personal data;
and
(c) the legal bases of the processing.
3.2 Where applicable we may process data about your use of
our website and services ("usage data"). The usage
data may include your IP address, geographical location, browser type and
version, operating system, referral source, length of visit, page views and
website navigation paths, as well as information about the timing, frequency
and pattern of your service use. The source of the usage data is our analytics
tracking system. This usage data may be processed for the purposes of analysing
the use of the website and services. The legal basis for this processing is our
legitimate interests, namely monitoring and improving our website and services.
The usage data is anonymous and cannot be traced back to you in person.
3.3 We may process your account data ("account
data"). The account data includes your name, address, telephone
number and email address as provided by you. The account data may be processed
for the purposes of operating our website, providing our services, ensuring the
security of our website and services, maintaining back-ups of our databases and
communicating with you. The legal basis for this processing is our legitimate interests,
namely the proper administration of our website and business or the performance
of a contract between you and us and/or taking steps, at your request, to enter
into such a contract. You can view your account data and edit existing data held
by visiting the ‘My Account’ section of our website and signing in using your
email address and password you created upon signing up.
3.4 We may process your personal data that are provided in
the course of the use of our services ("service data").
The service data may include your name and contact details provided by you upon placing an order with us. The
service data may be processed for the purposes of operating our website,
providing our services, ensuring the security of our website and services,
maintaining back-ups of our databases and communicating with you. The legal
basis for this processing is our legitimate interests, namely the proper
administration of our website and business or the performance of a contract
between you and us and/or taking steps, at your request, to enter into such a
contract. If you signed up and hold an account with us you can view your service
data and edit existing data held by visiting the ‘My Account’ section of our website
and signing in using your email address and password you created upon signing
up. You can also view any previous orders in your ‘Order History’.
3.5 We may process information contained in any enquiry
you submit to us regarding goods and/or services ("enquiry data").
The enquiry data may be processed for the purposes of offering, marketing and
selling relevant goods and/or services to you. The legal basis for this
processing is consent or the performance of a contract between you and us
and/or taking steps, at your request, to enter into such a contract.
3.6 We may process information that you provide to us for
the purpose of subscribing to our email notifications and/or newsletters
("notification data"). The notification data may be
processed for the purposes of sending you the relevant notifications and/or
newsletters. The legal basis for this processing is consent or the performance
of a contract between you and us and/or taking steps, at your request, to enter
into such a contract.
3.7 We may process information contained in or relating to
any communication that you send to us ("correspondence data").
The correspondence data may include the communication content and metadata
associated with the communication. Our website will generate the metadata
associated with communications made using the website contact forms. The
correspondence data may be processed for the purposes of communicating with you
and record-keeping] The legal basis for this processing is our legitimate
interests, namely the proper administration of our website and business and
communications with users.
3.8 We may process any of your personal data identified in
this policy where necessary for the establishment, exercise or defence of legal
claims, whether in court proceedings or in an administrative or out-of-court
procedure. The legal basis for this processing is our legitimate interests,
namely the protection and assertion of our legal rights, your legal rights and
the legal rights of others.
3.9 We may process any of your personal data identified in
this policy where necessary for [the purposes of obtaining or maintaining
insurance coverage, managing risks, or obtaining professional advice. The legal
basis for this processing is our legitimate interests, namely the proper
protection of our business against risks.
3.10 In addition to the specific purposes for which we may process
your personal data set out in this Section 3, we may also process any of your
personal data] where such processing is necessary for compliance with a legal
obligation to which we are subject, or in order to protect your vital interests
or the vital interests of another natural person.
3.11 Please do not supply any other person's personal data to us,
unless we prompt you to do so.
4. Providing your personal data to
others
4.1 We may disclose your personal data to other members of
our company insofar as reasonably necessary for the purposes, and on the legal
bases, set out in this policy.
4.2 We may disclose your personal data to our insurers
and/or professional advisers insofar as reasonably necessary for the purposes
of obtaining or maintaining insurance coverage, managing risks, obtaining
professional advice, or the establishment, exercise or defence of legal claims,
whether in court proceedings or in an administrative or out-of-court procedure.
4.3 Financial transactions relating to our website and
services will be handled by our payment services providers. We will share
transaction data with our payment services providers only to the extent
necessary for the purposes of processing your payments, refunding such payments
and dealing with complaints and queries relating to such payments and refunds.
4.4 In addition to the specific disclosures of personal
data set out in this Section 4, we may disclose your personal data where such
disclosure is necessary for compliance with a legal obligation to which we are
subject, or in order to protect your vital interests or the vital interests of
another natural person. We may also disclose your personal data where such
disclosure is necessary for the establishment, exercise or defence of legal
claims, whether in court proceedings or in an administrative or out-of-court
procedure.
5. Retaining and deleting personal data
5.1 This Section 5 sets out our data retention policies
and procedure, which are designed to help ensure that we comply with our legal
obligations in relation to the retention and deletion of personal data.
5.2 Personal data that we process for any purpose or
purposes shall not be kept for longer than is necessary for that purpose or
those purposes.
6. Amendments
6.1 We may update this policy from time to time by
publishing a new version on our website.
6.2 You should check this page occasionally to ensure you
are happy with any changes to this policy.
7. Your rights – access to your data
7.1 You may instruct us to provide you with any personal
information we hold about you; provision of such information will be subject to
the supply of appropriate evidence of your identity (for this purpose, we will
usually accept a photocopy of your passport certified by a solicitor or bank
plus an original copy of a utility bill showing your current address).
7.2 We may withhold personal information that you request
to the extent permitted by law.
7.3 You may instruct us at any time not to process your
personal information for marketing purposes.
7.4 In practice, you will usually either expressly agree
in advance to our use of your personal information for marketing purposes, or
we will provide you with an opportunity to opt out of the use of your personal
information for marketing purposes.
7.5 You can view and edit existing
data held by us by visiting the ‘My Account’ section of our website and signing
in using your email address and password you created upon signing up.
8. Your rights under data protection law
- summary
8.1 In this Section 8, we have summarised the rights that
you have under data protection law. Some of the rights are complex, and not all
of the details have been included in our summaries. Accordingly, you should
read the relevant laws and guidance from the regulatory authorities for a full
explanation of these rights.
8.2 Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
8.3 You have the right to confirmation as to whether or
not we process your personal data and, where we do, access to the personal
data, together with certain additional information. That additional information
includes details of the purposes of the processing, the categories of personal
data concerned and the recipients of the personal data. Providing the rights
and freedoms of others are not affected, we will supply to you a copy of your
personal data. The first copy will be provided free of charge, but additional
copies may be subject to a reasonable fee
8.4 You have the right to have any inaccurate personal
data about you rectified and, taking into account the purposes of the
processing, to have any incomplete personal data about you completed.
8.5 In some circumstances you have the right to the
erasure of your personal data without undue delay. Those circumstances include:
the personal data are no longer necessary in relation to the purposes for which
they were collected or otherwise processed; you withdraw consent to
consent-based processing; you object to the processing under certain rules of
applicable data protection law; the processing is for direct marketing
purposes; and the personal data have been unlawfully processed. However, there
are exclusions of the right to erasure. The general exclusions include where
processing is necessary: for exercising the right of freedom of expression and
information; for compliance with a legal obligation; or for the establishment,
exercise or defence of legal claims.
8.6 In some circumstances you have the right to restrict
the processing of your personal data. Those circumstances are: you contest the
accuracy of the personal data; processing is unlawful but you oppose erasure;
we no longer need the personal data for the purposes of our processing, but you
require personal data for the establishment, exercise or defence of legal
claims; and you have objected to processing, pending the verification of that
objection. Where processing has been restricted on this basis, we may continue
to store your personal data. However, we will only otherwise process it: with
your consent; for the establishment, exercise or defence of legal claims; for
the protection of the rights of another natural or legal person; or for reasons
of important public interest.
8.7 You have the right to object to our processing of your
personal data on grounds relating to your particular situation, but only to the
extent that the legal basis for the processing is that the processing is
necessary for: the performance of a task carried out in the public interest or
in the exercise of any official authority vested in us; or the purposes of the
legitimate interests pursued by us or by a third party. If you make such an
objection, we will cease to process the personal information unless we can
demonstrate compelling legitimate grounds for the processing which override
your interests, rights and freedoms, or the processing is for the
establishment, exercise or defence of legal claims.
8.8 You have the right to object to our processing of your
personal data for direct marketing purposes (including profiling for direct
marketing purposes). If you make such an objection, we will cease to process
your personal data for this purpose.
8.9 To the extent that the legal basis for our processing of your
personal data is:
(a) consent; or
(b) that the processing is necessary for the performance
of a contract to which you are party or in order to take steps at your request
prior to entering into a contract, and such processing is carried out by
automated means, you have the right to receive your personal data from us in a
structured, commonly used and machine-readable format. However, this right does
not apply where it would adversely affect the rights and freedoms of others.
8.10 If you consider that our processing of your personal information
infringes data protection laws, you have a legal right to lodge a complaint
with a supervisory authority responsible for data protection. You may do so in
the EU member state of your habitual residence, your place of work or the place
of the alleged infringement.
8.11 To the extent that the legal basis for our processing of your
personal information is consent, you have the right to withdraw that consent at
any time. Withdrawal will not affect the lawfulness of processing before the
withdrawal.
8.12 You may exercise any of your rights in relation to your personal
data by written notice to us.
9. About cookies
9.1 A cookie is a file containing an identifier (a string
of letters and numbers) that is sent by a web server to a web browser and is
stored by the browser. The identifier is then sent back to the server each time
the browser requests a page from the server.
9.2 Cookies may be either "persistent" cookies
or "session" cookies: a persistent cookie will be stored by a web
browser and will remain valid until its set expiry date, unless deleted by the
user before the expiry date; a session cookie, on the other hand, will expire
at the end of the user session, when the web browser is closed.
9.3 Cookies do not typically contain any information that
personally identifies a user, but personal information that we store about you may
be linked to the information stored in and obtained from cookies.
10. Cookies used by our service providers
10.1 Our service providers use cookies and those cookies may be stored
on your computer when you visit our website.
10.2 We use Google Analytics to analyse the use of our website. Google
Analytics gathers information about website use by means of cookies. The
information gathered relating to our website is used to create reports about
the use of our website. Google's privacy policy is available at:
https://www.google.com/policies/privacy/.
11. Managing cookies
12.1 Most browsers allow you to refuse to accept cookies and to delete
cookies. The methods for doing so vary from browser to browser, and from
version to version. You can however obtain up-to-date information about
blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647?hl=en
(Chrome);
(b)
https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
(Firefox);
(c) http://www.opera.com/help/tutorials/security/cookies/
(Opera);
(d)
https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies
(Internet Explorer);
(e) https://support.apple.com/kb/PH21411 (Safari); and
(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy
(Edge).
12.2 Blocking all cookies will have a negative impact upon the
usability of many websites.
12.3 If you block cookies, you may not be able to use all the features
on our website.
13. Our details
13.1 This website is owned and operated by the company at the address
given in the contact details of this website.
13.2 Our principal place of business is as given in the contact
details on this website.
13.4 You can contact us:
(a) by post, to the Troutflies UK Ltd, 221 Marine Road, Morecambe, LA4 4BU
(b) by telephone, on 01524 850575
(c) by email, on sales@troutflies.co.uk
14. Data protection officer
14.1 Our data protection officer's contact details are as given in the
contact details on this website. Please address all correspondence to “The Data
Protection Officer”.