We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are, and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint.
We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation (UK GDPR) and we are responsible as controller of that personal data for the purposes of those laws.
1. Key Terms
It would be helpful to start by explaining some key terms used in this policy:
| We, us, our | Spares4appliances Limited (trading as Spares4Appliances). We are a company registered in England (company number 14702046) |
| Data Protection Manager | The person responsible for ensuring we look after your data |
| Personal data | Any information relating to an identified or identifiable individual |
| Special category personal data | Personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership
Genetic and biometric data Data concerning health, sex life or sexual orientation |
| Data Subject | The individual who the personal data relates to |
2. Personal data we collect about you
The personal data we collect about you depends on the products and services we provide to you. We will collect and use the following personal data about you:
- your name and contact information, including email address and telephone number;
- your account details, such as username and login details;
- location data, if you choose to give this to us;
- your billing information, transaction and payment card information;
- your contact history, purchase history and saved items;
- information from accounts you link to us;
- information to enable us to undertake credit or other financial checks on you;
- information about how you use our website, applications, IT, communications and other systems; and
- your responses to surveys, competitions and promotions.
We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below. If you do not provide personal data we ask for, it may delay or prevent us from providing our services to you.
3. How your personal data is collected
We collect most of this personal data directly from you —in person, by telephone, text or email and/or via our website. However, we may also collect information:
- directly from a third party;
- from a third party with your consent;
- from cookies on our website – for more information on our use of cookies, please see our Cookie Policy (accessible here); and
- via our IT systems e.g., automated monitoring of our websites and other technical systems, such as our computer networks and connections, communications systems, email and instant messaging systems.
4. How and why we use your personal data
Under data protection law, we can only use your personal data if we have a proper reason for doing so, e.g.:
- where you have given consent;
- to comply with our legal and regulatory obligations;
- for the performance of our contract with you or to take steps at your request before entering into a contract such as creating your account with us; or
- for our legitimate interests or those of a third party.
A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own.
The table below explains what we use (process) your personal data for and our reasons for doing so:
| What we use your personal data for | Our reasons |
|---|---|
| To provide products and services to you | For the performance of our contract with you or to take steps at your request before entering a contract |
| To prevent and detect fraud against you, us or the third parties we work with | For our legitimate interests or those of a third party, i.e., to minimise fraud that could be damaging for us and for you |
| Conducting checks to identify our customers and verify their identity
Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business |
Depending on the circumstances:
|
| To enforce legal rights or defend or undertake legal proceedings | Depending on the circumstances:
|
| Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies | To comply with our legal and regulatory obligations |
| Aggregating data to determine trends and patterns | For our legitimate interests or those of a third party i.e., to assess and improve our products and services |
| Ensuring business policies are adhered to e.g., policies covering security and internet use | For our legitimate interests or those of a third party i.e., to make sure we are following our own internal procedures so we can deliver the best products and services to you |
| Operational reasons, such as improving efficiency, training and quality control | For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best products and service to you |
| Ensuring the confidentiality of commercially sensitive information | Depending on the circumstances:
|
| Statistical analysis to help us manage our business e.g., in relation to our financial performance, customer base, product range or other efficiency measures | For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best products and services to you |
| Preventing unauthorised access and modifications to systems | Depending on the circumstances:
|
| Protecting the security of systems and data used to provide our products and services | To comply with our legal and regulatory obligations
We may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests, i.e., to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us |
| Updating and enhancing customer records | Depending on the circumstances:
|
| Statutory returns | To comply with our legal and regulatory obligations |
| Ensuring safe working practices, staff administration and assessments | Depending on the circumstances:
|
Marketing our products and services and those of selected third parties to:
|
For our legitimate interests or those of a third party i.e. to promote our business to existing and former customers |
| Credit reference checks via external credit reference agencies | For our legitimate interests or those of a third party, i.e., to ensure our customers are likely to be able to pay for our products and services |
| External audits and quality checks | Depending on the circumstances:
|
| To share your personal data with members of our group and third parties that will or may take control or ownership of some or all of our business (and professional advisors acting on our or their behalf) in connection with a corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency
In such cases information will be anonymised where possible and only shared where necessary |
Depending on the circumstances:
|
The above table does not apply to special category personal data. Where we process special category personal data, we will also ensure we are permitted to do so under data protection laws, e.g.:
- we have your explicit consent;
- the processing is necessary to protect your (or someone else’s) vital interests where you are physically or legally incapable of giving consent; or
- the processing is necessary to establish, exercise or defend legal claims.
5. How and why we use your personal data – sharing
See ‘Who we share your personal data with’ for further information on the steps we will take to protect your personal data where we need to share it with others.
6. Marketing
We will use your personal data to send you updates (by email, telephone or post) about our products and/or services including offers, promotions or new products.
We have a legitimate interest in using your personal data for marketing purposes (see above How and why we use your personal data). This means we do not usually need your consent to send you marketing information. If we change our marketing approach in the future so that consent is needed, we will ask for this separately and clearly.
You have the right to opt out of receiving marketing communications at any time by:
- contacting us at dataprotection@spares4appliances; or
- using the ‘unsubscribe’ link in emails; or
- where available, updating your marketing preferences on your registered account.
We may ask you to confirm or update your marketing preferences if you ask us to provide further products and/or services in the future, or if there are changes in the law, regulation, or the structure of our business.
7. Who we share your personal data with
We routinely share personal data with:
- companies within our group;
- third parties we use to help deliver our products to you, e.g., payment service providers, product suppliers, warehouses and delivery companies;
- other third parties we use to help us run our business, e.g., marketing agencies or website hosts;
- third parties approved by you;
- credit reference agencies; and
- our bank.
We only allow those organisations to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on them, where appropriate, to ensure they can only use your personal data to provide services and products to us and to you.
We or the third parties mentioned above occasionally also share personal data with:
- our and their external auditors, e.g., in relation to the audit of our or their accounts, in which case the recipient of the information will be bound by confidentiality obligations;
- our and their professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations;
- law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations; and
- other parties that have or may acquire control or ownership of our business (and our or their professional advisers) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised but this may not always be possible. The recipient of any of your personal data will be bound by confidentiality obligations.
There may be occasions where we share your data with other third parties and in circumstances not set out above, if that happens, we will only share your data if it is necessary.
If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).
8. Where your personal data is held
Personal data may be held at our offices and those of our group companies, third party agencies, service providers, representatives and agents as described above (see above Who we share your personal data with).
Some of these third parties may be based outside the UK. For more information, including on how we safeguard your personal data when this occurs, see below Transferring your personal data out of the UK.
9. How long your personal data will be kept
We will keep your personal data while you have an account with us or we are providing goods or services to you. Thereafter, we will keep your personal data for as long as is necessary to:
- respond to any questions, complaints or claims made by you or on your behalf;
- show that we treated you fairly; or
- keep records required by law and to protect our legal interests.
We will not retain your personal data for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal data.
When it is no longer necessary to keep your personal data, we will delete or anonymise it.
10. Transferring your personal data out of the UK
To deliver products and services to you, it is sometimes necessary for us to share your personal data outside the UK, e.g., with our service providers located outside the UK.
Under data protection law, we can only transfer your personal data to a country or international organisation outside the UK where:
- the UK government has decided the particular country or international organisation ensures an adequate level of protection of personal data (known as an ‘adequacy regulation’);
- there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for data subjects; or
- a specific exception applies under data protection law.
These are explained below.
Adequacy regulation
We may transfer your personal data to certain countries, based on an adequacy regulation. A list of countries the UK currently has adequacy regulations in relation to is available here.
The list of countries that benefit from adequacy regulations will change from time to time. We will always seek to rely on an adequacy regulation, where one exists.
Other countries we are likely to transfer personal data to do not have the benefit of an adequacy regulation. This does not necessarily mean they provide poor protection for personal data, but we must look at alternative grounds for transferring the personal data, such as ensuring appropriate safeguards are in place or relying on an exception, as explained below.
Transfers with appropriate safeguards
Where there is no adequacy decision, we may transfer your personal data to another country if we are satisfied the transfer complies with data protection law, appropriate safeguards are in place, and enforceable rights and effective legal remedies are available for data subjects.
The safeguards will usually include using legally approved standard data protection contract clauses.
Transfers under an exception
In the absence of an adequacy regulation or appropriate safeguards, we may transfer personal data to a third country or international organisation where an exception applies under relevant data protection law, e.g.:
- you have explicitly consented to the proposed transfer after having been informed of the possible risks;
- the transfer is necessary for the performance of a contract between us or to take pre-contract measures at your request;
- the transfer is necessary for a contract in your interests, between us and another person; or
- the transfer is necessary to establish, exercise or defend legal claims.
We may also transfer information for the purpose of our compelling legitimate interests, so long as those interests are not overridden by your interests, rights and freedoms. Specific conditions apply to such transfers and we will provide relevant information if and when we seek to transfer your personal data on this ground.
Further information
If you would like further information about data transferred outside the UK, please contact us (see ‘How to contact us’ below).
11. Your rights
You have the following rights, which you can exercise free of charge:
| Access | The right to be provided with a copy of your personal data (the right of access) |
| Rectification | The right to require us to correct any mistakes in your personal data |
| Erasure (also known as the right to be forgotten) | The right to require us to delete your personal data (in certain situations) |
| Restriction of processing | The right to require us to restrict processing of your personal data (in certain circumstances e.g., if you contest the accuracy of the data) |
| Data portability | The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party (in certain situations) |
| To object | The right to object:
|
| Not to be subject to automated individual decision making | The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you |
| The right to withdraw consents | If you have provided us with a consent to use your personal data you have a right to withdraw that consent easily at any time
You may withdraw consents by contacting us. Withdrawing a consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn |
For more information on each of those rights, including the circumstances in which they apply, please contact us (see ‘How to contact us’ below) or see the Guidance from the UK Information Commissioner’s Office on individuals’ rights.
If you would like to exercise any of those rights, please:
- email or write to us —see below: How to contact us; and
- let us have enough information to identify you (e.g., your full name and address) and any additional identity information we may reasonably request from you; and
- let us know what right you want to exercise and the information to which your request relates.
12. Keeping your personal data secure
We have appropriate security measures to prevent personal data from being accidentally lost or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your personal data will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
If you want detailed information from Get Safe Online on how to protect your personal data and other information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
13. How to complain
Please contact us if you have any query or concern about our use of your personal data (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.
You also have the right to lodge a complaint with the Information Commissioner. The Information Commissioner may be contacted at https://ico.org.uk/make-a-complaint or telephone: 0303 123 1113.
14. Changes to this privacy policy
This privacy notice was published in April 2023.
We may change this privacy notice from time to time. When we do, we will let you know via our website.
15. How to contact us
Please contact us by post or email if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.
Our contact details are shown below:
| Our contact details |
|---|
| Post: Data Protection Manager, Spares4appliances Limited, 4 Calder Close, Calder Park, Wakefield, West Yorkshire, England, WF4 3BA
Email: dataprotection@spares4appliances.co.uk |
16. Do you need extra help?
If you would like this notice in another format please contact us (see How to contact us above).
