Privacy Policy
Privacy Policy
This Privacy Policy
sets out how we, Outdoors & Active, collect, store and use information
about you when you use or interact with our website, www.outdoorsandactive.co.uk and
where we otherwise obtain or collect information about you. This Privacy Policy
is effective from 01 August 2019.
Contents
·
Summary
·
Our details
·
Information we collect when you visit our website
·
Information we collect when you contact us
·
Information we collect when you interact with our website
·
Information we collect when you place an order on our
website
·
Our use of automated decision-making and profiling
·
How we collect or obtain information about you from third
parties
·
Disclosure and additional uses of your information
·
How long we retain your information
·
How we secure your information
·
Transfers of your information outside the European
Economic Area
·
Your rights in relation to your information
Your right to object to
the processing of your information for certain purposes
·
Sensitive Personal Information
·
Changes to our Privacy Policy
·
Children’s Privacy
·
California Do Not Track Disclosures
Summary
This section summarises how we obtain, store and use information about you.
It is intended to provide a very general overview only. It is not complete
in and of itself and it must be read in conjunction with the corresponding full
sections of this Privacy Policy.
·
Data controller: Paul Batts
·
How we collect or obtain information about you:
·
when you provide it to us (e.g. by contacting us, placing
an order on our website or signing up to our newsletter)
·
from your use of our website, using cookies and similar
technologies, and
·
occasionally, from third parties.
·
Information we collect: name, contact details, IP address, information
from cookies, information about your computer or device (e.g. device and
browser type), information about how you use our website (e.g. which pages you
have viewed, the time when you view them and what you clicked on, the
geographical location from which you accessed our website (based on your IP
address)
·
How we use your information: for administrative and business purposes
(particularly to contact you), to improve our business and website, to fulfil
our contractual obligations, to advertise our goods and services, to analyse
your use of our website.
Disclosure of your information to third
parties: only to the extent
necessary to run our business, to our service providers, to fulfil any
contracts we enter into with you, and where required by law or to enforce our
legal rights.
·
Do we sell your information to third parties (other than
in the course of a business sale or purchase or similar event): No
·
How long we retain your information: for no longer than necessary, taking into
account any legal obligations we have (e.g. to maintain records for tax
purposes), and any other legal basis we have for using your information (e.g.
your consent, performance of a contract with you or our legitimate interests as
a business). For specific retention periods in relation to certain information
which we collect from you, please see the main section below entitled: How
long we retain your information
·
How we secure your information: using appropriate technical and
organisational measures such as storing your information on secure servers,
encrypting transfers of data to or from our servers using Secure Sockets Layer
(SSL) technology, and only granting access to your information where necessary.
·
Use of cookies: we use cookies on our website including essential,
functional and analytical cookies. For more information, please visit our
cookies policy
·
Transfers of your information outside the European
Economic Area: we will only transfer
your information outside the European Economic Area if we are required to do so
by law
Use of automated decision making and
profiling: we do not use
automated decision making or profiling
·
Your rights in relation to your information
·
to access your information and to receive information
about its use
·
to have your information corrected and/or completed
·
to have your information deleted
·
to restrict the use of your information
·
to receive your information in a portable format
·
to object to the use of your information
·
to withdraw your consent to the use of your information
·
not to have significant decisions made about you based
solely on automated processing of your information, including profiling
·
to complain to a supervisory authority
·
Sensitive personal information: we do not knowingly or intentionally
collect what is commonly referred to as ‘sensitive personal information’.
Please do not submit sensitive personal information about you to us. For more
information, please see the main section below entitled Sensitive Personal
Information.
Our details
The data controller in
respect of our website is Paul Batts of Outdoors & Active. You can contact
the data controller by writing to The Data Controller, Outdoors & Active,
29-31 Meadow Street, Weston-super-Mare, North Somerset, BS23 1QQ or sending an
email to Paul@outdoorsandactive.co.uk.
If you have any
questions about this Privacy Policy, please contact the data controller.
Information we collect when you visit our
website
We collect and use
information from website visitors in accordance with this section and the
section entitled Disclosure and additional uses of your information.
Web server log information
We use a third party
server to host our website called Rackspace, the privacy policy of which is
available here: www.rackspace.com/en-gb/information/legal/privacystatement.
Our website server automatically logs the IP address you use to access our
website as well as other information about your visit such as the pages
accessed, information requested, the date and time of the request, the source
of your access to our website (e.g. the website or URL (link) which referred
you to our website), and your browser version and operating
Our servers are located
in the UK and Republic of Ireland
Use of website server log information for IT security purposes
We do not access log
data from our website server our third party hosting provider collect(s) and
store(s) server logs to ensure network and IT security and so that the server
and website remain uncompromised. This includes analysing log files to help
identify and prevent unauthorised access to our network, the distribution of
malicious code, denial of services attacks and other cyber attacks, by
detecting unusual or suspicious activity.
Unless we are
investigating suspicious or potential criminal activity, We do not make, nor do
we allow our hosting provider to make, any attempt to identify you from the
information collected via server logs.
Legal basis for processing: compliance with a legal obligation to which we
are subject (Article 6(1)(c) of the General Data Protection Regulation).
Legal obligation: recording access to our website using server log files
is an appropriate technical measure to ensure a level of security appropriate
to protect information collect by our website under Article 32(1) of the
General Data Protection Regulation.
Legal basis for processing: our legitimate interests (Article 6(1)(f)
of the General Data Protection Regulation).
Legitimate interest: improving our website for our website users and getting
to know our website users’ preferences so our website can better meet their
needs and desires.
Cookies and similar technologies
Cookies are data files
which are sent from a website to a browser to record information about users
for various purposes.
We use cookies on our
website, including essential, functional and analytical cookies
You can reject some or
all of the cookies we use on or via our website by changing your browser
settings but doing so can impair your ability to use our website or some or all
of its features. For further information about cookies, including how to change
your browser settings, please visit www.allaboutcookies.org
or see our cookies policy.
Information we collect when you contact us
We collect and use
information from individuals who contact us in accordance with this section and
the section entitled Disclosure and additional uses of your information.
Email
When you send an email
to the email address displayed on our website we collect your email address and
any other information you provide in that email (such as your name, telephone
number and the information contained in any signature block in your email).
Legal basis for processing: our legitimate interests (Article 6(1)(f)
of the General Data Protection Regulation).
Legitimate interest(s): responding to enquiries and messages we receive
and keeping records of correspondence.
Legal basis for processing: necessary to perform a contract or to take steps at
your request to enter into a contract (Article 6(1)(b) of the General Data
Protection Regulation).
Reason why necessary to perform a contract: where your message relates
to us providing you with goods or services or taking steps at your request
prior to providing you with our goods and services (for example, providing you
with information about such goods and services), we will process your
information in order to do so).
Transfer and storage of your information
We use a third party
email provider to store emails you send us. located in UK. Their privacy policy
is available here: www.rackspace.com/en-gb/information/legal/privacystatement
Emails you send us will
be stored within the European Economic Area on our third party email provider’s
servers in UK For further information please see the section of this privacy
policy entitled Transfers of your information outside the European Economic
Area.]
Contact form
When you contact us
using our contact form, we collect name, contact details, We also collect any
other information you provide to us when you complete the contact form.
If you do not provide
the mandatory information required by our contact form, you will not be able to
submit the contact form and we will not receive your enquiry.
Legal basis for processing: our legitimate interests (Article 6(1)(f)
of the General Data Protection Regulation).
Legitimate interest(s): responding to enquiries and messages we receive
and keeping records of correspondence.
Legal basis for processing: necessary to perform a contract or to take steps at
your request to enter into a contract (Article 6(1)(b) of the General Data
Protection Regulation).
Reason why necessary to perform a contract: where your message relates
to us providing you with goods or services or taking steps at your request
prior to providing you with our goods and services (for example, providing you
with information about such goods and services), we will process your
information in order to do so).
Transfer and storage of your information
Messages you send us
via our contact form will be stored within the European Economic Area on our
third party hosting servers in UK and Ireland Our third party hosting provider
is Rackspace Their privacy policy is available here: www.rackspace.com/en-gb/information/legal/privacystatement
Phone
When you contact us by
phone, we collect your phone number and any information provide to us during
your conversation with us.
We do not record phone
calls.
Legal basis for processing: our legitimate interests (Article 6(1)(f)
of the General Data Protection Regulation)
Legitimate interest(s): responding to enquiries and messages we receive
and keeping records of correspondence.
Legal basis for processing: necessary to perform a contract or to take steps at
your request to enter into a contract (Article 6(1)(b) of the General Data
Protection Regulation).
Reason why necessary to perform a contract: where your message relates
to us providing you with goods or services or taking steps at your request
prior to providing you with our goods and services (for example, providing you
with information about such goods and services), we will process your
information in order to do so).
Transfer and storage of your information
Post
If you contact us by post, we will collect any information you provide to
us in any postal communications you send us.
Legal basis for processing: our legitimate interests (Article 6(1)(f)
of the General Data Protection Regulation)
Legitimate interest(s): responding to enquiries and messages we receive
and keeping records of correspondence.
Legal basis for processing: necessary to perform a contract or to take steps at
your request to enter into a contract (Article 6(1)(b) of the General Data
Protection Regulation).
Reason why necessary to perform a contract: where your message relates
to us providing you with goods or services or taking steps at your request
prior to providing you with our goods and services (for example, providing you
with information about such goods and services), we will process your
information in order to do so).
Information we collect when you interact
with our website
We collect and use information from individuals who interact with
particular features of our website in accordance with this section and the
section entitled Disclosure and additional uses of your information.
E-Newsletter
When you sign up for
our e-newsletter on our website or opt to receive news and offers from us
by entering your name and email address
and clicking subscribe or ticking a box at checkout indicating that you would
like to receive our e-newsletter, we
collect your name and email address
Legal basis for
processing: your consent
(Article 6(1)(a) of the General Data Protection Regulation).
Consent: you give your consent to us sending you our e-newsletter by
signing up to receive it using the steps described above.
Transfer and storage of your information
We may use a third
party service to send out our e-newsletter and administer our mailing list,
MailChimp. Their privacy policy is available here: https://mailchimp.com/legal/privacy/
Information you submit to subscribe for our e-newsletter will be stored
outside the European Economic Area on our third party mailing list provider’s
servers in USA. For further information about the safeguards used when your
information is transferred outside the European Economic Area, see the section
of this privacy policy below entitled Transfers of your information outside
the European Economic Area.
Use of web beacons in
emails
We use technologies
such as web beacons (small graphic files) in the emails we send to allow us to
assess the level of engagement our emails receive by measuring information such
as the delivery rates, open rates and click through rates which our emails achieve.
We will only use web beacons in our
emails if you have consented to us doing so.
For more information on
how we use web beacons in our e-newsletter emails, see our cookies policy.
[For more information
about our third party mailing list provider and they use web beacons, please
see their privacy policy which is available here https://mailchimp.com/legal/privacy/
Registering on our website
When you register and
create an account on our website, we collect the following information: name, email address, IP address and
any other information you provide to us when you complete the registration form
If you do not provide
the mandatory information required by the registration form, you will not be
able to register or create an account on our website.
[Legal basis for
processing: necessary to perform a contract [or to take steps at
your request prior to entering into a contract] (Article 6(1)(b) of the
General Data Protection Regulation).
Reason why necessary to perform a contract: creating an account on our
website is necessary to allow you to access the goods and services you have
purchased from us]
[Legal basis for processing: our legitimate interests
(Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: registering and administering accounts on our
website to [insert purpose e.g. to provide access to content]
[and facilitate the running and operation of our business
Transfer and storage of your information
Information you submit
to us via the registration form on our website will be stored within the
European Economic Area on our Rackspace servers in UK and Republic of Ireland.
Our third party hosting provider is Rackspace Their privacy policy is available
here: https://www.rackspace.com/en-gb/information/legal/privacystatement
[For further information
about the safeguards used when your information is transferred outside the
European Economic Area, see the section of this privacy policy below entitled Transfers
of your information outside the European Economic Area.]
Information we collect when you place an
order on our website
We collect and use
information from individuals who place an order on our website in accordance
with this section and the section entitled Disclosure and additional uses of
your information.
Information collected when you place an order
Mandatory information
When you place an order
for goods or services on our website, we collect [your name,] [email address,]
[billing address,] [shipping address,] [company name (if applicable),] [VAT
number (if applicable), If you do not provide this information, you will not be
able to purchase goods or services from us on our website or enter into a
contract with us.
Legal basis for processing: necessary to perform a contract (Article 6(1)(b)
of the General Data Protection Regulation).
Reason why necessary to perform a contract: we need the mandatory
information collected by our checkout form to establish who the contract is
with and to contact you to fulfil our obligations under the contract, including
sending you receipts and order confirmations.
Legal basis for processing: compliance with a legal obligation (Article 6(1)(c) of
the General Data Protection Regulation).
Legal obligation: we have a legal obligation to issue you with an
invoice for the goods and services you purchase from us where you are VAT
registered and we require the mandatory information collected by our checkout
form for this purpose. We also have a legal obligation to keep accounting
records, including records of transactions
Optional information
We may also collect
optional information from you, such as [your phone number,] [information about
how you heard about us]. [We may also ask you if you would like to receive
marketing communications from us. For further information, see ‘Marketing
communications’ in this section below.
Legal basis for processing: your consent (Article 6(1)(a) of the
General Data Protection Regulation).
Legitimate interests: you consent to us processing any optional
information you provide by submitting that information to us.
Processing your payment
After you place an
order on our website you will need to make payment for the goods or services
you have ordered. In order to process your payment we use a third party payment
processor Paypal. Your payment will be processed by Paypal via a payment
gateway
Paypal collects, uses
and processes your information, including payment information, in accordance
with their privacy policies. You can access their privacy policies via the
following link(s): www.paypal.com
Transfer and storage of your information
Paypal is located in Luxembourg. Information relating to the processing of
your payment is stored within the European Economic Area on Paypal’s servers in
The United States of America.
Legal basis for processing: necessary to perform a contract (Article 6(1)(b)
of the General Data Protection Regulation).
Reason why necessary to perform a contract: to fulfil your contractual
obligation to pay for the goods or services you have ordered from us.
Marketing communications
At checkout you will have the option of receiving marketing communications
from us.
Our similar goods and
services
You can opt-out from
receiving marketing communications in relation to our goods and which are
similar to those which you purchase from us, by ticking a box
We may send you
marketing communications in relation to similar goods and services if you do
not opt out from receiving them.
Legal basis for processing: our legitimate interests (Article 6(1)(f)
of the General Data Protection Regulation).
Legitimate interests: direct marketing and advertising our products and
services
Our goods and services
You can opt in to
receiving marketing communications from us in relation to our goods and
services by email, text message, phone, and post by ticking a box indicating
that you would like to receive such communications.
We will send you
marketing communications in relation to our goods and services only if you
opt-in to receive them.
Legal basis for
processing: consent
(Article 6(1)(a) of the General Data Protection Regulation).
Consent: you give your consent to us sending you information about our
goods and services by signing up to receive such information in accordance with
the steps described above.
Information collected or obtained from third
parties
This section sets out
how we obtain or collect information about you from third parties.
Information received from third parties
Generally, we do not
receive information about you from third parties.
It is possible that
third parties with whom we have had no prior contact may provide us with
information about you.
Information we obtain
from third parties will generally be your name and contact details, but will
include any additional information about you which they provide to us.
Legal basis for
processing: necessary to
perform a contract or to take steps at your request to enter into a contract
(Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: where a third party has
passed on information about you to us (such as your name and email address) in
order for us to provide services to you, we will process your information in
order to take steps at your request to enter into a contract with you and
perform a contract with you (as the case may be).
Legal basis for
processing: consent
(Article 6(1)(a) of the General Data Protection Regulation).
Consent: where you have asked that a third party to share information
about you with us and the purpose of sharing that information is not related to
the performance of a contract or services by us to you, we will process your
information on the basis of your consent, which you give by asking the third
party in question to pass on your information to us.
Legal basis for
processing: our legitimate
interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interests: where a third party has shared information about
you with us and you have not consented to the sharing of that information, we
will have a legitimate interest in processing that information in certain
circumstances.
For example, we would
have a legitimate interest in processing your information to perform our
obligations under a sub-contract with the third party, where the third party
has the main contract with you. Our legitimate interest is the performance of
our obligations under our sub-contract.
Similarly, third parties
may pass on information about you to us if you have infringed or potentially
infringed any of our legal rights. In this case, we will have a legitimate
interest in processing that information to investigate and pursue any such
potential infringement.
Where we receive information about you in
error
If we receive information about you from a third party in error and/or we
do not have a legal basis for processing that information, we will delete your
information.
Our use of automated decision-making and
profiling
We use do not use automated decision making and profiling on our website.
Disclosure and additional uses of your
information
This section sets out
the circumstances in which will disclose information about you to third parties
and any additional purposes for which we use your information.
Disclosure of your information to service providers
We use a number of
third parties to provide us with services which are necessary to run our
business or to assist us with running our business and who process your
information for us on our behalf. These include the following:
·
Telephone provider(s)
·
Email provider(s)
·
IT service provider(s)
·
Web developer(s)
·
Hosting provider(s)
Our third party service
providers are located in UK and Republic of Ireland
Your information will
be shared with these service providers where necessary to provide you with the
service you have requested, whether that is accessing our website or ordering
goods and services from us.
We do not display the
identities of [all of] our service providers publicly by name for security and
competitive reasons. If you would like further information about the identities
of our service providers, however, please contact us directly on paul@outdoorsandactive.co.uk and
we will provide you with such information where you have a legitimate reason
for requesting it (where we have shared your information with such service
providers, for example).
Legal basis for
processing: legitimate
interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest relied on: where we share your information with
these third parties in a context other than where is necessary to perform a
contract (or take steps at your request to do so), we will share your
information with such third parties in order to allow us to run and manage our
business efficiently.
Legal basis for processing: necessary to perform a contract and/or to take
steps at your request prior to entering into a contract (Article 6(1)(b) of the
General Data Protection Regulation).
Reason why necessary to perform a contract: we may need to share
information with our service providers to enable us to perform our obligations
under that contract or to take the steps you have requested before we enter
into a contract with you.
Disclosure of your information to other third parties
We disclose your
information to other third parties in specific circumstances, as set out below.
Providing information to third parties such
as Google Inc, Google collects information through our use of Google
Analytics on our website. Google uses this information, including IP addresses
and information from cookies, for a number of purposes, such as improving its
Google Analytics service. Information is shared with Google on an aggregated
and anonymised basis. To find out more about what information Google collects,
how it uses this information and how to control the information sent to Google,
please see the following page: https://www.google.com/policies/privacy/partners/
Legal basis for processing: our legitimate interests (Article 6(1)(f)
of the General Data Protection Regulation).
Legitimate interest(s): meeting our contractual obligations to Google
under our Google Analytics Terms of Service (https://www.google.com/analytics/terms/us.html)
You can opt out of
Google Analytics by installing the browser plugin here: https://tools.google.com/dlpage/gaoptout
Transfer and storage of your information
Information collected
by Google Analytics is stored outside the European Economic Area on Google’s
servers in the United States of America.
For further information
about the safeguards used when your information is transferred outside the
European Economic Area, see the section of this privacy policy below entitled Transfers
of your information outside the European Economic Area.]
Sharing your information with third parties, which are either related to or
associated with the running of our business, where it is necessary for us to do
so. These third parties include our accountants, advisors, independent
contractors, insurers. Further information on each of these third parties is
set out below. Further information on each of these third parties is set out
below.
Legal basis for processing: our legitimate interests (Article 6(1)(f)
of the General Data Protection Regulation).
Legitimate interest: running and managing our business efficiently.
Accountants
We share information
with our accountants for tax purposes. For example, we share invoices we issue
and receive with our accountants for the purpose of completing tax returns and
our end of year accounts.
Our accountants are
located in England.
Advisors
Occasionally, we obtain
advice from advisors, such as accountants, financial advisors, lawyers and
public relations professionals. We will share your information with these third
parties only where it is necessary to enable these third parties to be able to
provide us with the relevant advice.
Our advisors are
located in England.
Business partners
Business partners are
businesses we work with which provide goods and services which are complementary
to our own or which allow us to provide goods or services which we could not
provide on our own. We share information with our business partners where you
have requested services which they provide whether independently from, or in
connection with or own services.
Our business partners
are located in England.
Independent contractors
We use independent
contractors in our business. Your information will be shared with independent
contractors only where it is necessary for them to perform the function we have
hired them perform in relation to our business.
Our independent
contractors are located in England.
Insurers
We will share your
information with our insurers where it is necessary to do so, for example in
relation to a claim or potential claim we receive or make or under our general
disclosure obligations under our insurance contract with them.
Our insurance brokers
are located in England.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the
General Data Protection Regulation).
Legitimate interest: running and managing our business effectively.
AND
Legal basis for processing: necessary to perform a contract [or to take
steps at your request prior to entering into a contract] (Article
6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: we need to share your
information with other companies in order to be able to meet our contractual
obligations to you [or to take steps at your request prior to entering a
contract.], for example because of the services or information you have
requested.
We do not display the
identities of all of the other third parties we may share information with by
name for security and competitive reasons. If you would like further
information about the identities of such third parties, however, please contact
us directly via our contact form or by email to paul@outdoorsandactive.co.uk
and we will provide you with such information where you have a legitimate
reason for requesting it (where we have shared your information with such third
parties, for example).
Sharing your information with a prospective or actual purchaser or seller
in the context of a business or asset sale or acquisition by us, a merger or
similar business combination event, whether actual or potential.
Legal basis for
processing: legitimate
interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s): sharing your information with a prospective
purchaser, seller or similar person in order to allow such a transaction to
take place.
Disclosure and use of your information for legal reasons
Indicating possible criminal acts or threats to public security to a
competent authority
If we suspect that
criminal or potential criminal conduct has been occurred, we will in certain
circumstances need to contact an appropriate authority, such as the police.
This could be the case, for instance, if we suspect that we fraud or a cyber
crime has been committed or if we receive threats or malicious communications
towards us or third parties.
We will generally only
need to process your information for this purpose if you were involved or
affected by such an incident in some way.
Legal basis for processing: our legitimate interests (Article 6(1)(f)
of the General Data Protection Regulation).
Legitimate interests: preventing crime or suspected criminal activity
(such as fraud).
In connection with the enforcement or potential enforcement our legal
rights
We will use your
information in connection with the enforcement or potential enforcement of our
legal rights, including, for example, sharing information with debt collection
agencies if you do not pay amounts owed to us when you are contractually
obliged to do so. Our legal rights may be contractual (where we have entered
into a contract with you) or non-contractual (such as legal rights that we have
under copyright law or tort law).
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the
General Data Protection Regulation).
Legitimate interest: enforcing our legal rights and taking steps to
enforce our legal rights.
In connection with a legal or potential legal dispute or proceedings
We may need to use your
information if we are involved in a dispute with you or a third party for
example, either to resolve the dispute or as part of any mediation, arbitration
or court resolution or similar process.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General
Data Protection Regulation).
Legitimate interest(s): resolving disputes and potential disputes.
For ongoing compliance with laws, regulations and other legal requirements
We will use and process
your information in order to comply with legal obligations to which we are
subject. For example, we may need to disclose your information pursuant to a
court order or subpoena if we receive one or to the National Crime Agency in connection
with suspected or potential money laundering matters
Legal basis for processing: compliance with a legal obligation (Article
6(1)(c) of the General Data Protection Regulation).
Legal obligation(s): legal obligations to disclose information which
are part of the laws of England and Wales or if they have been integrated into
the United Kingdom’s legal framework (for example in the form of an
international agreement which the United Kingdom has signed).
Legal basis for processing: our legitimate interests (Article 6(1)(f)
of the General Data Protection Regulation).
Legitimate interest: where the legal obligations are part of the laws of
another country and have not been integrated into the United Kingdom’s legal
framework, we have a legitimate interest in complying with these obligations.
How long we retain your information
This section sets out how long we retain your information. We have set out
specific retention periods where possible. Where that has not been possible, we
have set out the criteria we use to determine the retention period.
Retention periods
Server log information: we retain information on our server logs for 3 months
Order information: when you place an order for goods and services, we
retain that information for six years following the end of the financial year
in which you placed your order, in accordance with our legal obligation to keep
records for tax purposes.
Correspondence and
enquiries: when you make an
enquiry or correspond with us for any reason, whether by email or via our
contact form or by phone, we will retain your information for as long as it
takes to respond to and resolve your enquiry, and until such time that you
request in writing that we delete your information
E-Newsletter: we retain the information you used to sign
up for our e-newsletter for as long as you remain subscribed (i.e. you do not
unsubscribe) or if we decide to cancel our e-newsletter service, whichever
comes earlier.
Criteria for
determining retention periods
In any other
circumstances, we will retain your information for no longer than necessary,
taking into account the following:
·
[the purpose(s) and use of your information both now and
in the future (such as whether it is necessary to continue to store that
information in order to continue to perform our obligations under a contract
with you or to contact you in the future);
·
whether we have any legal obligation to continue to
process your information (such as any record-keeping obligations imposed by
relevant law or regulation);
·
whether we have any legal basis to continue to process
your information (such as your consent);
·
how valuable your information is (both now and in the
future);
·
any relevant agreed industry practices on how long
information should be retained;
·
the levels of risk, cost and liability involved with us
continuing to hold the information;
·
how hard it is to ensure that the information can be kept
up to date and accurate; and
·
any relevant surrounding circumstances (such as the
nature and status of our relationship with you).]
How we secure your information
We take appropriate technical and organisational measures to secure your
information and to protect it against unauthorised or unlawful use and
accidental loss or destruction, including:
·
only sharing and providing access to your information to
the minimum extent necessary, subject to confidentiality restrictions where
appropriate, and on an anonymised basis wherever possible;
·
using secure servers to store your information;
·
verifying the identity of any individual who requests
access to information prior to granting them access to information;
·
using Secure Sockets Layer (SSL) software to encrypt any
payment transactions you make on or via our website
Transmission of
information to us by email
Transmission of
information over the internet is not entirely secure, and if you submit any
information to us over the internet (whether by email, via our website or any
other means), you do so entirely at your own risk.
We cannot be
responsible for any costs, expenses, loss of profits, harm to reputation,
damages, liabilities or any other form of loss or damage suffered by you as a
result of your decision to transmit information to us by such means.
Transfers of your information outside the
European Economic Area
All of your information
is stored in the following European Economic Area (EEA) countries UK and
Republic of Ireland
Other than to comply
with any legal obligations to which we are subject (compliance with a court
order, for example), we do not intend to transfer your information outside the
EEA or to an international organisation. In the unlikely event that we are
required to transfer your information outside the EEA (or to an international
organisation) for such a purpose, we will ensure appropriate safeguards and
protections are in place.
[Google Analytics
[Information collected
by Google Analytics (your IP address and actions you take in relation to our
website) is transferred outside the EEA and stored on Google’s servers. You can
access Google’s privacy policy here: https://www.google.com/policies/privacy/
[Country of storage: United States of America. This country is
not subject to an adequacy decision by the European Commission.]
Safeguard(s) used: Google has self-certified its compliance
with the EU-U.S. Privacy Shield which is available here: https://www.privacyshield.gov/welcome.
The EU-U.S. Privacy Shield is an approved certification mechanism under Article
42 of the General Data Protection Regulation, which is permitted under Article
46(2)(f) of the General Data Protection Regulation. You can access the European
Commission decision on the adequacy of the EU-U.S. Privacy Shield here: http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm
Your rights in relation to your information
Subject to certain
limitations on certain rights, you have the following rights in relation to
your information, which you can exercise by writing to The
Data Controller, Outdoors & Active, 29-31 Meadow Street, Weston-super-Mare,
BS23 1QQ or paul@outdoorsandactive.co.uk:
·
to request access to your information and information related to our use and
processing of your information;
·
to request the correction or deletion of your information;
·
to request that we restrict our use of your information;
·
to receive information which you have provided to us in a
structured, commonly used and machine-readable format (e.g. a CSV file) and the right to have
that information transferred to another data controller (including a third
party data controller);
·
to object to the processing of your information for
certain purposes (for further information, see the section below entitled Your right to
object to the processing of your information for certain purposes); and
·
to withdraw your consent to our use of your information at any time where we rely on your consent to
use or process that information. Please note that if you withdraw your consent,
this will not affect the lawfulness of our use and processing of your information
on the basis of your consent before the point in time when you withdraw your
consent.
·
the right not to be subject to a decision based solely on
automated processing, including profiling which produces legal affects
concerning you or similarly significantly affects you
In accordance with
Article 77 of the General Data Protection Regulation, you also have the right
to lodge a complaint with a supervisory authority, in particular in the Member
State of your habitual residence, place of work or of an alleged infringement
of the General Data Protection Regulation.
For the purposes of the
UK, the supervisory authority is the Information Commissioner’s Office (ICO),
the contact details of which are available here: https://ico.org.uk/global/contact-us/
Further information on your rights in relation to your personal data as an
individual
The above rights are
provided in summary form only and certain limitations apply to many of these
rights. For further information about your rights in relation to your
information, including any limitations which apply, please visit the following
pages on the ICO’s website:
·
https://ico.org.uk/for-the-public/is-my-information-being-handled-correctly/
You can also find out
further information about your rights, as well as information on any
limitations which apply to those rights, by reading the underlying legislation
contained in Articles 12 to 22 and 34 of the General Data Protection
Regulation, which is available here: http://ec.europa.eu/justice/data-protection/reform/files/regulation_oj_en.pdf
Verifying your identity where you request access to your information
Where you request
access to your information, we are required by law to use all reasonable
measures to verify your identity before doing so.
These measures are
designed to protect your information and to reduce the risk of identity fraud,
identity theft or general unauthorised access to your information.
How we verify your identity
Where we possess
appropriate information about you on file, we will attempt to verify your
identity using that information.
If it is not possible
to identity you from such information, or if we have insufficient information
about you, we may require original or certified copies of certain documentation
in order to be able to verify your identity before we are able to provide you
with access to your information.
We will be able to
confirm the precise information we require to verify your identity in your
specific circumstances if and when you make such a request.
Your right to object to the processing of
your information for certain purposes
You have the following rights in relation to your information, which you
may exercise in the same way as you may exercise by writing to The Data
Controller, Outdoors & Active, 29-31 Meadow Street, Weston-super-Mare, BS23
1QQ or sending an email to paul@outdoorsandactive.co.uk
·
to object to us using or processing your information
where we use or process it in order to carry out a task in the public
interest or for our legitimate interests, including ‘profiling’
(i.e. analysing or predicting your behaviour based on your information) based
on any of these purposes; and
·
to object to us using or processing your information for direct
marketing purposes (including any profiling we engage in that is related to
such direct marketing).
You may also exercise
your right to object to us using or processing your information for direct
marketing purposes by:
·
clicking the unsubscribe link contained at the bottom of any marketing
email we send to you and following the instructions which appear in your
browser following your clicking on that link;
·
sending an email to paul@outdoorsandactive.co.uk asking that
we stop sending you marketing communications or by including the words “OPT
OUT”.
For more information on
how to object to our use of information collected from cookies and similar
technologies, please see the section entitled How to accept or reject
cookies in our cookies policy, which is available on our website.
Sensitive Personal Information
‘Sensitive personal
information’ is information about an individual that reveals their racial or
ethnic origin, political opinions, religious or philosophical beliefs, or trade
union membership, genetic information, biometric information for the purpose of
uniquely identifying an individual, information concerning health or
information concerning a natural person’s sex life or sexual orientation.
We do not knowingly or
intentionally collect sensitive personal information from individuals, and you
must not submit sensitive personal information to us.
If, however, you
inadvertently or intentionally transmit sensitive personal information to us,
you will be considered to have explicitly consented to us processing that
sensitive personal information under Article 9(2)(a) of the General Data
Protection Regulation. We will use and process your sensitive personal
information for the purposes of deleting it.
Changes to our Privacy Policy
We update and amend our
Privacy Policy from time to time.
Minor changes to our Privacy Policy
Where we make minor
changes to our Privacy Policy, we will update our Privacy Policy with a new
effective date stated at the beginning of it. Our processing of your
information will be governed by the practices set out in that new version of
the Privacy Policy from its effective date onwards.
Major changes to our Privacy Policy or the purposes for which we process
your information
Where we make major
changes to our Privacy Policy or intend to use your information for a new
purpose or a different purpose than the purposes for which we originally
collected it, we will notify you by email (where possible) or by posting a
notice on our website.
We will provide you
with the information about the change in question and the purpose and any other
relevant information before we use your information for that new purpose.
Wherever required, we
will obtain your prior consent before using your information for a purpose that
is different from the purposes for which we originally collected it.
Children’s Privacy
Because we care about the safety and
privacy of children online, we comply with the Children’s Online Privacy
Protection Act of 1998 (COPPA). COPPA and its accompanying regulations protect
the privacy of children using the internet. We do not knowingly contact or
collect information from persons under the age of 18. The website is not
intended to solicit information of any kind from persons under the age of 18.
It is possible that we could receive
information pertaining to persons under the age of 18 by the fraud or deception
of a third party. If we are notified of this, as soon as we verify the
information, we will, where required by law to do so, immediately obtain the
appropriate parental consent to use that information or, if we are unable to
obtain such parental consent, we will delete the information from our servers.
If you would like to notify us of our receipt of information about persons
under the age of 18, please do so by sending an email to paul@outdoorsandactive.co.uk
California Do Not Track Disclosures
“Do Not Track” is a privacy
preference that users can set in their web browsers. When a user turns on a Do
Not Track signal in their browser, the browser sends a message to websites
requesting that they do not track the user. For information about Do Not Track,
please visit www.allaboutdnt.org
At this time, we do not respond to Do Not Track browser settings or
signals. In addition, we use other technology that is standard to the internet,
such as pixel tags, web beacons, and other similar technologies, to track
visitors to the website. Those tools may be used by us and by third parties to
collect information about you and your internet activity, even if you have
turned on the Do Not Track signal. For information on how to opt out from
tracking technologies used on our website, see our cookies policy which is
available on our website
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