1. TFS Buying Limited Privacy Statement
2. Our data protection obligations to you
TFS Buying Limited will process your personal data in accordance with the law. For the purposes of data protection legislation, we are the data controller and we will process your personal data in accordance with the General Data Protection Regulation (EU) 2016/679 and national laws which relate to the processing of personal data.
3. The data controller
TFS Buying Limited is registered as a data controller with the Information Commissioner’s Office under Company registration number: 06789840 as ICO registration reference:ZA003280.
You can contact our Data Protection Officer by writing to the registered address at Churchill Point Lake Edge Green, Trafford Park Road, Manchester M17 1BL or by sending an email to email@example.com.
4. The data protection lead for TFS Buying Limited
5. How we collect or obtain personal information about you
We collect personal information about you when you provide it to us, such as through your use of our website and its features, when you contact us directly by email, phone, via social media, in writing, in store in person and by connecting to our in-store wifi, when you order goods and services, when you use any of our other websites or applications or any other means by which you provide personal information to us.
You can reject some or all of the cookies we use on or via our website by changing your browser settings, but doing so may 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
We use Google Analytics on our website to understand how you engage and interact with it. For information on how Google Analytics collects and processes data using cookies, please visit www.google.com/policies/privacy/partners/. You can opt out of Google Analytics tracking by visiting: tools.google.com/dlpage/gaoptout
Website Links - our Site may, from time to time, contain links to and from the websites of third parties. Please note that if you follow a link to any of these websites, such websites will apply different terms to the collection and privacy of your personal data and we do not accept any responsibility or liability for these policies. When you leave our Site, we encourage you to read the privacy notice/policy of every website you visit.
6. Personal information we collect or obtain about you
The type of information we collect about you may include (but is not limited to) information such as:
· your name;
· your email address;
· your address;
· your phone number;
· your age;
· your payment information (e.g. your credit or debit card details);
· information about your computer (e.g. your IP address and browser type);
· information about how you use our website (e.g. which pages you have viewed, the time you viewed them and what you clicked on);
· information about your mobile device (such as your geographical location);
· information on your purchases;
· information about your device (e.g. MAC address, manufacturer, operating system);
· information on your social profile(s).
Information we obtain from third parties will generally be your name and contact details, but may include any additional information they provide to us, including (but not limited to) any of the types of information set out in the list above.
We may also obtain personal information about you from certain publicly accessible sources, including (but not limited to) the electoral register, online customer databases, business directories, media publications, social media, websites and other publicly accessible sources.
· you already have the information;
· providing you with the information would prove impossible or would involve a disproportionate effort;
· we are under an EU or EU member state law obligation to obtain or disclose the information which provides appropriate measures to protect your legitimate interests; or
· we are obliged to keep the information confidential as a result of an obligation of professional secrecy regulated by EU or EU member state law.
· if we intend to use your personal information to communicate with you, at the point when we first communicate with you;
· if we envisage that we will disclose your personal information to a third party, when we disclose your personal information to that third party (at the latest); and
· in any other circumstances, within a reasonable period after obtaining your personal information (and in any event within one month at the latest), taking into account the specific circumstances in which we use your personal information.
7. How we use your personal information
We may use your personal information for one or more of the following purposes in our legitimate interests or in the legitimate interests of third parties:
· Administering, running and improving our website, apps, and business, including personalising our website experience for you. This is necessary for our legitimate interest of better understanding our other customers’ and potential customers’ preferences and tailoring our website, products and services to their needs and preferences.
· Communicating directly with you in relation to updates to the website, your purchase(s) of our products or services, and in response to enquiries we receive from you. This will be necessary either to update you from time to time about changes to our website, to perform a contract which we have entered into with you (or to take steps, at your request, to enter into a contract with you) or for our legitimate interest of satisfying and confirming your requirements in order to provide you with our products or services and to answer questions we receive from you.
· Protecting our business and our business interests, including for the purposes of credit and background checks, fraud prevention and debt recovery. This is necessary for our legitimate interests of preventing criminal activity such as fraud or money laundering, for ensuring that our website and services are not misused and protecting our business. We will only carry out such checks to the extent that we are permitted or authorised by law to do so.
· Displaying advertisements to you and analysing the information we receive in relation to those advertisements. This is necessary for our own and for third parties’ legitimate interests of direct marketing and advertising our and their respective products and services.
· Providing you with offers relating to our products and services which relate to products and services you purchased from us or were in negotiations to purchase from us (provided that you did not opt out from receiving such communications either at the time or subsequently). This is necessary for our legitimate interest of direct marketing and advertising our products and services.
· Communicating with our business advisors and legal representatives. This is necessary for our legitimate interests of obtaining legal or professional business advice, and we will only share your personal information where it is necessary to do so, to the minimum extent necessary and on an anonymised basis wherever possible.
· Sharing your personal information with third parties which are either related to or associated with us (including to third parties within our corporate group from time to time) such as our business partners, service review providers, affiliates, associates, suppliers, independent contractors, delivery agents, email providers and IT service providers. This will be necessary either to perform a contract which we have entered into with you (or to take steps, at your request, to enter into a contract with you), for our legitimate interest of market research, for our legitimate interest of running and managing our business effectively, for compliance with a legal obligation to which we are subject, or for our own direct marketing purposes. Where we share your personal information, we will do so strictly on a need-to-know basis, subject to appropriate confidentiality restrictions, on an anonymised basis as far as possible and only to the extent strictly necessary for any of these purposes.
· Enforcing our legal rights. This is necessary for our legitimate interest of protecting our business and enforcing our contractual and other legal rights.
· Ensuring physical, network and information security and integrity. This is necessary for our legitimate interest of ensuring that our IT systems and networks are secure and uncompromised, including, for example, preventing malware, viruses, bugs or other harmful code, preventing unauthorised access to our systems, and any form of attack on, or damage to, our IT systems and networks.
· In connection with disclosure requests and in the case of a business or share sale or sale or purchase of a business and/or assets, whether actual or potential. This is necessary for our legitimate interests of selling and/or ensuring and promoting the success of our business.
· Providing statistical information to third parties such as Google Analytics. This is necessary for our and third parties’ legitimate interests of processing personal information for research purposes, including market research, better understanding our respective customers, and tailoring our respective products and services to their needs.
· Indicating possible criminal acts or threats to public security to a competent authority. This is necessary for our legitimate interest of promoting the success of our business, preventing crime, for compliance with a legal obligation to which we are subject, in the general public interest or for the legitimate interests of governmental bodies and competent authorities that prevent crime.
· In connection with any legal or potential legal dispute or proceedings. This is necessary for our legitimate interest of promoting and ensuring the success of our business, resolving disputes and making such disclosures as are required by law or which we consider, acting reasonably, are required by law.
We may also collect or process your personal information for the following purposes:
· Entering into and performing a contract with you. Where you wish to purchase products or services from us, we require, for online and certain other transactions, such as but not limited to subscribing in-store to a contract requiring recurring delivery, your personal information in order to enter into and perform a contract with you. If you do not provide your personal information to us when it is required for such a purpose, we will not be able to enter into or perform a contract with you or to provide you with the products or services you have requested. We may also postpone or cancel any orders you place and enforce our legal rights against you (for example, where we have incurred costs or expenses in preparing or fulfilling any orders placed by you but are unable to deliver the order due to your failure to provide the necessary personal information).
· Complying with laws, regulations and other legal requirements. We may need to use and process your personal information in order to comply with legal obligations to which we are subject. For example, we may require your personal information pursuant to a statutory obligation to conduct anti-money-laundering checks or to disclose your information to a court following receipt of a court order or subpoena. We may also need your personal information to comply with ongoing legal obligations, such as tax laws and regulations to which we are subject.
We may process your personal information for the following purpose(s) where we have obtained your consent to do so:
· To provide you with offers relating to goods and services we offer from time to time and those of selected third parties.
· To provide you with news and information on our activities and outlets where our products can be purchased via a newsletter, email, SMS or other such communication.
· Transferring your personal information to third parties (including to third parties within our corporate group from time to time) for their marketing purposes or for the purposes of marketing their own goods and services such as our business partners, affiliates, associates, suppliers, independent contractors, list providers and joint venture partners.
Where we process your personal information on the basis of your consent, you can withdraw your consent to such processing at any time by emailing us at firstname.lastname@example.org or by writing to us at TFS Buying Ltd, Churchill Point Lake Edge Green, Trafford Park Road, Manchester M17 1BL.
In addition to the uses described above, where you indicate you would like to receive marketing correspondence from us, subscribe to our mailing lists or newsletters, enter into any of our competitions or provide us with your details at networking events we may use your personal data for our legitimate interests in order to provide you with details about our goods, services, business updates and events which we think may be of interest.
You have the right to opt-out of receiving the information detailed above at any time. To opt-out of receiving such information you can:
• tick the relevant box situated in the form on which we collect your information;
• clicking the unsubscribe button contained in any such communication received; or
• email us at email@example.com providing us with your name and contact details
9. Automated processing
We do not undertake automated decision making with your personal data.
10. Legal basis for processing your personal data
We will only use your personal data where the law allows us to. Most commonly, we will use your personal data in the following circumstances:
• for performance of a contract we enter into with you;
• where necessary for compliance with a legal or regulatory obligation we are subject to; and
• for our legitimate interests (as described within this policy) and your interests and fundamental rights do not override these interests
11. Disclosure of personal data to third parties
In addition to the third parties mentioned above, we may disclose your information to third parties for our following legitimate interests as follows:
- to staff members in order to facilitate the provision of goods or services to you
- to our affiliated entities to support internal administration;
- IT software providers that host our website and store data on our behalf;
- third party research providers who will capture your feedback on transactions to improve our services;
- professional advisers including consultants, lawyers, bankers and insurers who provide us with consultancy, banking, legal, insurance and accounting services;
- HM Revenue and Customs, regulators and other authorities who require reporting of processing activities in certain circumstances; and
We may disclose personal data to the police, regulatory bodies, legal advisors or similar third parties where we are under a legal duty to disclose or share personal data in order to comply with any legal obligation, or in order to enforce or apply our website terms and conditions and other agreements; or to protect our rights, property, or safety of our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
We will not sell or distribute personal data to other organisations without your approval
12. How long we store your personal information
We will store your information for no longer than necessary, taking into account the following:
· the purpose(s) for which we are processing your personal information, 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 for our legitimate interests;
· whether we have any legal obligation to continue to process your information, such as any record-keeping obligations imposed by applicable law; and
· whether we have any legal basis to continue to process your personal information, such as your consent.
13. Securing your personal information
We take appropriate technical and organisational measures to secure your personal information and to protect it against unauthorised or unlawful use or processing as well as against the accidental loss or destruction of, or damage to, your personal information, including:
· only sharing and providing access to your personal 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 personal information;
· requiring proof of identity from any individual who requests access to personal information; and
· using Secure Sockets Layer (SSL) software or other similar encryption technologies to encrypt any payment transactions you make on or via our website.
Transmission of information (including personal 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 transmission of information to us by such means
14. Storing your personal data
TFS Buying Ltd has put in place appropriate technical and organisational measures to prevent accidental loss, damage or destruction of your personal data, and to protect your personal data against unauthorised, or unlawful use or theft. We put in place strict confidentiality agreements, including data protection obligations, with our third party service providers and data processors
15. Transfers of your personal information to other countries
We hold your data within the EU, but we may need to transfer your personal information outside of the country in which we collected or obtained it, including outside the European Economic Area or to an international organisation from time to time. Where we transfer your personal information outside the European Economic Area, the country to which it is transferred will either be subject to an adequacy decision by the European Commission, or if not (or if we transfer your personal information to an international organisation), we will ensure that the transfer takes place on the basis of one or more of the following safeguards:
· standard data protection clauses adopted by the European Commission or adopted by the Information Commissioner’s Office and approved by the European Commission in accordance with relevant law;
· where authorised by the Information Commissioner’s Office, contractual clauses between the data controller or processor and the data controller, processor or recipient of the personal information in the third country or international organisation
16. Access to, updating, deleting and restricting use of personal data
It is important that the personal data we hold about you is accurate and current. Please keep us informed if the personal data we hold about you changes.
Data protection legislation gives you the right to object to the processing of your personal data in certain circumstances or withdraw your consent to the processing of your personal data where this has been provided. You also have the right to access information held about you and for this to be provided in an intelligible form. In certain circumstances we reserve the right to charge a reasonable fee to comply with your request.
Where you request access to personal information, we are required by law to use reasonable means to verify your identity before doing so. In order for us to verify your identity, we require you to provide us with an original or certified copy of a document from each of the following two categories of documents:
• Category One: a full current signed UK or overseas passport, a full current UK or EU photocard driving licence or a national identity card.
• Category Two: a copy of your bank statement, utility bill (gas, electric, water, landline phone), TV licence renewal statement or council tax bill with your address, dated no earlier than three months before the date when you request access to your personal information.
Where you provide a certified copy of these documents, these must be certified by an appropriate professional such as a solicitor, accountant, the Post Office’s identity checking service, an official at a bank or building society or a regulated financial advisor.
We will not be able to provide you with access to your personal information until you provide us with your proof of identity as set out above and we have been able to successfully verify your identity
You can also ask us to undertake the following:
• update or amend your personal data if you feel this is inaccurate;
• remove your personal data from our database entirely;
• send you copies of your personal data in a commonly used format and transfer your information to another entity where you have supplied this to us, and we process this electronically with your consent or where necessary for the performance of a contract; or
• restrict the use of your personal data.
We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the personal data that we hold about you or make your requested changes. Data protection legislation may allow or require us to refuse to provide you with access to some or all the personal data that we hold about you or to comply with any requests made in accordance with your rights referred to above. If we cannot provide you with access to your personal data, or process any other request we receive, we will inform you of the reasons why, subject to any legal or regulatory restrictions.
Please send any requests relating to the above to our Data Protection Officer at TFS Buying Ltd, Churchill Point Lake Edge Green, Trafford Park Road, Manchester M17 1BL, or emailing us at firstname.lastname@example.org specifying your name and the action you would like us to undertake.
You also have the right to lodge a complaint with a supervisory authority, which, for the purposes of the UK, is the Information Commissioner’s Office (ICO), the contact details of which are available here: https://ico.org.uk/global/contact-us/
For further information about your rights in relation to your personal information, including certain limitations which apply to some of those rights, please see Articles 12 to 23 of the General Data Protection Regulation (GDPR), which is available here: http://ec.europa.eu/justice/data-protection/reform/files/regulation_oj_en.pdf
17. Consequences of not providing your personal information to us
Where you wish to purchase products or services from us online, or for recurring subscription contracts initiated in-store or over the phone, we require your personal information in order to enter into a contract with you. We may also require your personal information pursuant to a statutory obligation (in order to be able to send you an invoice for products and services you wish to order from us, for example).
In the above examples, if you do not provide your personal information, we will not be able to enter into a contract with you or to provide you with those products or services