Privacy Policy - Introduction

Welcome to Ali Brookes’ Privacy Policy.

Ali Brookes respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data which you provide to us when you enter into a contract with us to purchase or supply a product or service (whether on behalf of an organisation or personally), make payment to us, make an enquiry to us, visit the website at www.alibrookes.com (regardless of where you visit it from) or otherwise. This privacy notice will also tell you about your privacy rights and how the law protects you. In case of conflict, this privacy notice shall prevail over any contract with Ali Brookes to purchase or supply a product or service. Whenever you give Ali Brookes personal data, you are consenting to its collection and use in accordance with this privacy notice, including our use of cookies. If you give us personal data on behalf of someone else, you are confirming that you have given them the information in this privacy notice and that they have agreed for Ali Brookes to use their personal data in the way described in this privacy notice. Please use the Glossary to understand the meaning of some of the terms used in this privacy notice.

1. Important information and who we are

Purpose of this privacy policy

This privacy policy aims to give you information on how Ali Brookes collects and processes your personal data which you provide to us when you enter into a contract with us to purchase or supply a product or service (whether on behalf of an organisation or personally), make payment to us, make an enquiry to us, visit our website (regardless of where you visit it from) or otherwise.

We do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Controller

Ali Brookes is the controller and is responsible for your personal data (collectively referred to as the “Company,” "we," "us," or "our" in this privacy notice).

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

Contact details
Our contact details are:
Ali Brookes – for the attention of the data privacy manager
ali@alibrookes.com

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, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy notice and your duty to inform us of changes

This version was last updated in May 2018 and historic versions can be obtained by contacting us. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links on our website

Our 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.

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store, and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data

Includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, and gender.

Contact Data

Includes billing address, delivery address, email address, and telephone numbers.

Financial Data

Includes bank account and payment card details.

Transaction Data

Includes details about payments to and from you and other details of products and services you have purchased from us or supplied to us.

Technical Data

Includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our website and systems.

Profile Data

Includes your username and password, purchases or orders made by you or with you, your interests, preferences, feedback, and survey responses.

Usage Data

Includes information about how you use our website, products, and services.

Marketing and Communications Data

Includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We may also collect, use, and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific feature of our website. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we will treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this 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). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with products or services). In this case, we may have to cancel a contract you have with us but we will notify you if this is the case at the time.

3. How is your personal data collected?

We may use different methods to collect data from and about you including through:

Direct interactions

You may give us your Identity, Contact, and Financial Data by filling in forms or by corresponding with us by post, phone, email, or otherwise. This includes personal data you provide when you:

• apply for our products or services or to supply us with products or services;

• create an account with us (on our website or otherwise);

• subscribe to our service or publications;

• request marketing to be sent to you;

• enter a competition, promotion, or survey; or

• give us some feedback.

Automated technologies or interactions

As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions, and patterns. We may collect this personal data by using cookies, server logs, and other similar technologies.

Third parties or publicly available sources

We may receive personal data about you from various third parties and public sources. We may also record phone conversations we have with you.

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• 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.

• 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 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.

Purposes for which we will use your personal data

We have set out below, a description of all the ways we plan to use your personal data. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data.

• Register you as a new customer, supplier, or other contact

• To manage our relationship with you which may include: notifying you about changes to our terms or privacy policy, asking you to leave a review or take a survey

• To administer and protect our business and website

• To deliver relevant website content and adverts and measure the success of this

• To use data analytics to improve our website, products/services, marketing, customer relationships, and experiences

• To make suggestions to you about products/services that may be of interest to you.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage, and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services, offers, and other information (such as in respect of events we may run or news updates we may provide) may be relevant for you (we call this marketing). You may receive marketing communications from us if you have requested information from us, purchased products or services from us or supplied them to us, or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

Opting out

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.

If you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience, or other transactions.

5. Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in section 4 above:

• Internal Third Parties
  Other companies in our group acting as joint controllers or processors and who are based in the UK and/or the European Economic Area (EEA).

• External Third Parties
  Service providers acting as processors who provide IT and system administration services.
  Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors, and insurers.
  Regulators and other authorities acting as processors or joint controllers based in the UK or EEA who require reporting of processing activities in certain circumstances.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International transfers

We do not transfer your personal data outside the UK or EEA.

7. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, accessed, altered, or disclosed in an unauthorised way. We also limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

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

8. Data retention

We will only retain your personal data for as long as necessary to fulfill 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 personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law we have to keep basic information About Clients, Suppliers, and Contacts (e.g., contact details, financial information, transaction history) for six years after they cease being a client, supplier, or other contact. In some cases, we may need to retain certain information for longer periods if required to comply with legal or regulatory obligations.

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These rights are described below:

Access

You have the right to request access to your personal data. This is commonly known as a Subject Access Request (SAR). You can request a copy of the personal data we hold about you and certain information about how we use it.

Correction

You have the right to request that we correct any inaccuracies in your personal data.

Erasure

You have the right to request that we delete your personal data where it is no longer necessary for us to retain it or if you have withdrawn consent on which the processing is based.

Restriction

You have the right to request that we restrict the processing of your personal data in certain circumstances, such as if you contest the accuracy of the data or if the processing is unlawful.

Data Portability

You have the right to request that we transfer your personal data to another organization or to you, in a structured, commonly used, and machine-readable format, where the processing is based on your consent or a contract and is carried out by automated means.

Objection

You have the right to object to the processing of your personal data based on legitimate interests or the performance of a task carried out in the public interest or in the exercise of official authority. You also have the right to object to processing for direct marketing purposes.

Withdraw Consent

If we rely on your consent to process your personal data, you have the right to withdraw that consent at any time. This will not affect the lawfulness of processing based on consent before its withdrawal.

10. Glossary

LAWFUL BASIS

• Legitimate Interest
  This means the interest of our business in conducting and managing our operations to provide you with the best service/product and the best and most secure experience. We ensure we balance any potential impact on you (both positive and negative) and your rights before processing your personal data for our legitimate interests.

• Performance of Contract
  Processing is necessary for the performance of a contract to which you are a party, or to take steps at your request before entering into such a contract.

• Comply with a Legal or Regulatory Obligation
  Processing is necessary to comply with a legal or regulatory obligation.

THIRD PARTIES

• Internal Third Parties
  Other companies in our group, acting as joint controllers or processors.

• External Third Parties

  • Service Providers
    Acting as processors who provide IT and system administration services.

  • Professional Advisers
    Acting as processors or joint controllers including lawyers, bankers, accountants/auditors, marketing advisers, human resources advisers, and insurers.

  • Regulators and Other Authorities
    Acting as processors or joint controllers who require reporting of processing activities in certain circumstances.

YOUR LEGAL RIGHTS

You have the following rights in relation to your personal data:

• Request Access
  To receive a copy of the personal data we hold about you and to verify that we are processing it lawfully.

• Request Correction
  To have any incomplete or inaccurate data corrected.

• Request Erasure
  To have your personal data deleted where there is no good reason for us to continue processing it.

• Object to Processing
  To object to the processing of your personal data where we are relying on legitimate interests or for direct marketing purposes.

• Request Restriction
  To request the suspension of processing your personal data in certain situations.

• Request Data Portability
  To request that we transfer your personal data to you or a third party in a structured, commonly used, and machine-readable format.

• Withdraw Consent
  To withdraw consent where we rely on it to process your personal data, although this will not affect the legality of any processing carried out before you withdraw your consent.

If you wish to exercise any of these rights or have any questions, please contact us using the details provided in Section 1.

For further information on your rights and how to exercise them, please contact us directly.

If you need any more information or have questions about our privacy policy, please contact us at ali@alibrookes.com.