PRIVACY

Personal Data Protection Policy

Introduction
This privacy notice provides you with details of how we collect and process your personal data through your use of our site www.connollyengland.com Connolly Retail Limited is the data controller and we are responsible for your personal data (referred to as “Connolly”, “we”, “us” or “our” in this privacy notice) and is located at 1 Avery Row, London, W1K 4AJ. (Company Registered Number: 208 1017, ICO Reference Number: ZA427190)

It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at [email protected]

This Privacy Policy does not apply to websites that you may be able to access via links on the Website and/or activities offered by third parties. Please ensure you review any relevant policies on any third party websites before proceeding. Connolly is not responsible for the collection or use of your personal information from these third party websites.

What data do we collect about you, for what purpose and on what grounds we process it.
Personal data means any information capable of identifying an individual. It does not include anonymised data.

We may process the following categories of personal data about you:

Communication Data that includes any communication that you send to us whether that be through the contact form on our website, through email, text, social media messaging, social media posting or any other communication that you send us. We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defence of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.

Customer Data that includes data relating to any purchases of services such as your name, title, billing address, delivery address email address, phone number, contact details, purchase details and your card details. We process this data to supply the goods and/or services you have purchased and to keep records of such transactions. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract.

User Data that includes data about how you use our website and any online services together with any data that you post for publication on our website or through other online services. We process this data to operate our website and ensure relevant content is provided to you, to ensure the security of our website, to maintain back- ups of our website and/or databases and to enable publication and administration of our website, other online services and business. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business.

Technical Data that includes data about your use of our website and online services such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is from our analytics tracking system. We process this data to analyse your use of our website and other online services, to administer and protect our business and website, to deliver relevant website content and advertisements to you and to understand the effectiveness of our advertising. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business and to grow our business and to decide our marketing strategy.

Marketing Data that includes data about your preferences in receiving marketing from us and our third parties and your communication preferences. We process this data to enable you to partake in our promotions such as competitions, prize draws and free give-aways, to deliver relevant website content and advertisements to you and measure or understand the effectiveness of this advertising. Our lawful ground for this processing is our legitimate interests which in this case are to study how customers use our products/services, to develop them, to grow our business and to decide our marketing strategy.

— We may use Customer Data, User Data, Technical Data and Marketing Data to deliver relevant website content and advertisements to you (including Facebook adverts or other display advertisements) and to measure or understand the effectiveness of the advertising we serve you. Our lawful ground for this processing is legitimate interests which is to grow our business. We may also use such data to send other marketing communications to you. Our lawful ground for this processing is either consent or legitimate interests (namely to grow our business).

Sensitive Data
We do not collect any Sensitive Data about you. 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. We do not collect any information about criminal convictions and offences.

Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have ordered but if we do, we will notify you at the time.

We will only use your personal data for a purpose it was collected for or a reasonably compatible purpose if necessary. For more information on this please email us at [email protected] In case we need to use your details for an unrelated new purpose we will let you know and explain the legal grounds for processing.

We may process your personal data without your knowledge or consent where this is required or permitted by law.

We do not carry out automated decision making or any type of automated profiling.

How We Collect Your Personal Data
We may collect data about you by you providing the data directly to us (for example by filling in forms on our site or by sending us emails). We may automatically collect certain data from you as you use our website by using cookies and similar technologies. Please see our cookie policy for more details about this www.connollyengland.com/privacy/.

We may receive data from third parties such as analytics providers such as Google based outside the EU, advertising networks such as Facebook based outside the EU, such as search information providers such as Google based outside the EU, providers of technical, payment and delivery services, such as data brokers or aggregators.

Marketing Communications
Our lawful ground of 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.

Before we share your personal data with any third party for their own marketing purposes we will get your express consent.

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 emailing us at [email protected] at any time.

If you opt out of receiving marketing communications this opt-out does not apply to personal data provided as a result of other transactions, such as purchases, warranty registrations etc.

Disclosures of your personal data
We may have to share your personal data with the parties set out below:

— Service providers who provide IT and system administration services.
— Professional advisers including lawyers, bankers, auditors and insurers
— Government bodies that require us to report processing activities.
— Third parties to whom we sell, transfer, or merge parts of our business or
our assets.

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

International Transfers
We are subject to the provisions of the General Data Protection Regulations that protect your personal data. Where we transfer your data to third parties outside of the EEA, we will ensure that certain safeguards are in place to ensure a similar degree of security for your personal data. As such:

— We may transfer your personal data to countries that the European Commission have approved as providing an adequate level of protection for personal data by; or
— If we use US-based providers that are part of EU-US Privacy Shield, we may transfer data to them, as they have equivalent safeguards in place; or
— Where we use certain service providers who are established outside of the EEA, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe.

If none of the above safeguards is available, we may request your explicit consent to the specific transfer. Y ou will have the right to withdraw this consent at any time.

Data Security
We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorisation. We also allow access to your personal data only to those employees and partners who have a business need to know such data. They will only process your personal data on our instructions and they must keep it confidential.

We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to.

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.

When deciding what the correct time is to keep the data for we look at its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.

For tax purposes the law requires us to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers.

In some circumstances we may anonymise your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Your Legal Rights
Under data protection laws you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent.

You can see more about these rights at:

https://ico.org.uk/for-organisations/guide-to-the-general-data-protectionregulation-gdpr/individual-rights/

If you wish to exercise any of the rights set out above, please email us at [email protected]

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 or refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

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.

If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.

Third Party Links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

Cookies
We use certain tools, such as cookies, to collect data about your visit to the Website such as device ID or unique identified, device type, computer and connection information, statistics on page views, traffic to and from the Website, referring URL, Internet Protocol (“IP”) address and standard web log information.

A cookie is a small text file that is used to store information on your browser or your computer’s hard drive when you visit a website, such as the Website. A cookie does not contain information that identifies a person, but it allows for the linking of your computer to the information provided by you on the Website (such as, for example, linking your IP address and other information about your experience on the Website to your preferences expressed while choosing services and purchasing products offered through the Website).

Cookies are disseminated by servers and no one may gain access to information contained therein. The information stored in cookies is gathered directly and automatically by the Website and is processed in an aggregate and anonymous manner.

The use of cookies and other automatic data collection tools is necessary for the proper functioning of the Website and its services. However, you can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. If you block all cookies (including essential cookies), Connolly cannot ensure that all web pages of the Website will be displayed and/or that certain services will be supplied.

Connolly uses the following types of cookies:

Strictly Necessary Cookies: These cookies are essential in order to enable you to browse the Website. Without these cookies, services offered by the Website (such as use of the shopping bag or access to your order history) cannot be provided.
Analytical Cookies: These cookies are used to measure and analyse how the visitors use the Website (for example site traffic, total sales through the Website, the pages visitors go to most often and pages from which the visitors get error messages) in order to continuously improve the Website and the shopping experiences offered through the Website. All information collected by these cookies is in an anonymous form (even if passed onto third parties) and are not used to identify you.
Functionality Cookies: These cookies are not necessary for the functioning of the Website but allow the Website to remember the choices and/or the preferences (such as your username, language or the region you are located) in order to offer you some advanced, simplified and personalised features.
Targeting and Advertising Cookies: Targeting and advertising cookies may be used to deliver personalised advertisements that are more relevant to you and your interests. These cookies may collect quite detailed information about your browsing habits through the Website, such as products you have clicked on or put in your shopping bag. These cookies allow us to personalise any direct marketing communication (i.e. email) or to limit the number of times you see an advertisement or to help us to measure the effectiveness of our advertising campaigns. They also may enable us (or third-party advertising services we work with) to track the actions of users online over time and across different websites or platforms to measure statistics of our marketing efforts, and to deliver electronic advertisements that may be more relevant to individual consumers and that will improve the overall consumer experience. We do not currently respond to web browser “do not track” signals or other mechanisms that provide a method to opt out of the collection of information across the networks of websites and online services in which we participate. If we do so in the future, we will describe how we do so in this Privacy Policy.
Third Party Cookies and Social Media Access:
Please note that if you share content from the Website through third party websites (i.e. social networking websites) you may be sent cookies from these websites. This occurs where you choose to log in to our Website using your social media profile information. Your activity on our Website then becomes subject to the privacy policies of those other social media websites/services. Connolly does not control the setting of such cookies and encourages you to refer to the relevant social media provider’s websites for more information about their cookies and how to manage them. You should also look at the privacy policies of those websites and how they handle information to which they gain access as a result of your decision to log into our Website using your social media profile information.

For more detailed information about cookies and how they can be managed and deleted, please visit www.allaboutcookies.org.