STRUMIS Limited respects your privacy and is committed to protecting your personal data. This privacy notice is designed to inform you as to how we look after your personal data.
We know that there is a lot of information here, but we want you to be fully informed about your rights and how we use your data.
If you should need to contact us regarding this policy or to exercise any of the rights detailed within this policy please contact our data privacy manager:
We will need to use your personal information in order that we might properly deliver our goods and/or services to you. That may include information relating to any of the following:
• your name and date of birth;
• your address, email address and telephone number(s);
• includes details about payments you make and other details of products and services you have purchased from us;
• information relating to the manner in which and the devices you use to access our website;
• your preferences in receiving marketing from us and our third parties and your communication preferences; and
• any additional information we require in order to provide you with our products or services.
We use different methods to collect information from and about you. We may for example collect information: directly from you when you buy our products or services or provide information via our website; indirectly through third parties such as Google; or, through public sources such as Companies House.
2. How we use your personal data
The law requires that we have a legal basis to use (which may include store) your information. Most commonly, we will use your personal data:
• 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; We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your information for our legitimate interests. We do not use your information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law);
• 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.
Where we use information relating to a child under the age of 13 we will require the consent of the child's parent or guardian.
3. Purposes for which we will use your personal information
We may use your information to inform you of any of our products and services that we feel may be of interest to you. We will not however share your information with any third party without first getting your express permission to do so.
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 at any time.
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.
4. Disclosures of your personal data
We may have to share your information with third parties such as:
• third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your information and to treat it in accordance with the law. We do not allow our third-party service providers to use your information for their own purposes and only permit them to process your information data for specified purposes and in accordance with our instructions.
5. International transfers
We do not as a rule transfer your information outside the European Economic Area (EEA). If however it is necessary for us to do so we will ensure a similar degree of protection is afforded to it.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
6. Data security
We have put in place appropriate security measures to prevent your information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your information on our instructions and they are subject to a duty of confidentiality.
7. Data retention
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 information, the purposes for which we process your information and whether we can achieve those purposes through other means, and the applicable legal requirements.
8. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal information, including the right to:
• request access to your personal data - commonly known as a "data subject access request". 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 your personal data - this enables you to have any incomplete or inaccurate data we hold about you corrected;
• 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 use it. 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;
• object to processing of your personal data - 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object 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 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 transfer of your personal data - 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 - 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.
If you wish to exercise any of the rights set out above, please contact us.
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.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Whilst 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) we would appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Version 2 – 03/05/2018
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