PROTECTING YOUR PRIVACY
Introduction
This Privacy Notice explains in detail the types of personal data we may collect about you when you interact with us. It also explains how we’ll store and handle that data and keep it safe.
Our website and related systems have been reviewed for GDPR and we take these regulations very seriously. We are continuously looking at ways to improve all aspects of our service and should you believe that anything represented on this website contravenes GDPR, please contact us about it immediately. For further information about GDPR and your rights, please visit the Information Commissioner’s Office website – https://ico.org.uk
We may need to update this Privacy Notice from time to time. We’ll notify you of any significant changes, but you’re welcome to come back and check it whenever you wish.
1. Explaining the legal bases we rely on
The law on data protection sets out a number of different reasons for which a company may collect and process your personal data, including:
Consent
In specific situations, we can collect and process your data with your consent.
For example, when you tick a box to receive email newsletters.
When collecting your personal data, we’ll always make clear to you which data is necessary in connection with a particular service.
Contractual obligations
In certain circumstances, we need your personal data to comply with our contractual obligations.
For example, if you order an item from us for delivery, we’ll collect your address details to deliver your purchase, and pass them to our courier.
Legal compliance
If the law requires us to, we may need to collect and process your data.
For example, we can pass on details of people involved in fraud or other criminal activity affecting BWT to law enforcement .
Legitimate interest
In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests.
For example, we may use your purchase history to send you or make available personalized offers.
We also anonymously combine the sales history of many customers to identify trends and ensure we can keep up with demand, or develop new products/services.
We may also use your address details to send you direct marketing information by post, telling you about products and services that we think might interest you.
If you believe that consent has not been given for an activity that utilizes your personal data, please contact us immediately stating your concerns.
2. When do we collect your personal data?
•When you visit our website, to make an enquiry or create an account to buy products and services
•When you purchase a product or service when visiting us, by phone or online.
•When you engage with us on social media.
•When you contact us by any means with queries, complaints etc.
•When you ask one of our sales personal to email you information about a product or service.
•When you enter prize draws or competitions.
•When you fill in any forms. For example, if an accident happens on our premises we may need to collect your personal data.
•When you’ve given a third party permission to share with us the information they hold about you.
•We collect data from publicly-available sources (such as Land Registry) when you have given your consent to share information or where the information is made public as a matter of law.
3.What sort of personal data do we collect?
•If you have an account with us: your name, billing/delivery address, email address, telephone numbers and details of previous orders and enquires. For your security, we’ll also keep an encrypted record of your login password.
•Your phone number when you call us with an enquiry.
Information gathered by the use of cookies in your web browser. Learn more about how we use cookies in our “ How do we use Cookies” section below.
•Your comments and product reviews.
•Your image may be recorded on CCTV when you visit our premises
•Your social media username, if you interact with us through those channels, to help us respond to your comments, questions or feedback.
4. How and why do we use your personal data?
We want to give you the best possible customer experience. One way to achieve that is to get the richest picture we can of who you are by combining the data we have about you.
We then use this to offer you promotions, products and services that are most likely to interest you.
The data privacy law allows this as part of our legitimate interest in understanding our customers and providing the highest levels of service.
Of course, if you wish to change how we use your data, you’ll find details in the ‘What are my rights?’ section below.
Remember, if you choose not to share your personal data with us, or refuse certain contact permissions, we might not be able to provide some services you’ve asked for.
For example, if you’ve asked us to let you know when an item comes into stock, we can’t do that if you’ve withdrawn your general consent to hear from us.
Here’s how we’ll use your personal data and why:
•To process any orders that you make by using our website, visiting us or by phone. If we don’t collect your personal data we won’t be able to process your order and comply with our legal obligations.
For example, your details may need to be passed to a third party to supply or deliver the product or service that you ordered, and we may keep your details for a reasonable period afterwards in order to fulfil any contractual obligations such as refunds, and warranties.
•To respond to your queries and complaints. Handling the information, you sent enables us to respond. We may also keep a record of these to inform any future communication with us and to demonstrate how we communicated with you throughout. We do this on the basis of our contractual obligations to you, our legal obligations and our legitimate interests in providing you with the best service and understanding how we can improve our service based on your experience.
•To protect our customers, premises, assets and employees from crime, we operate CCTV systems on our premises which record images for security. We do this on the basis of our legitimate business interests.
•To process payments and to prevent fraudulent transactions. We do this on the basis of our legitimate business interests. This also helps to protect our customers from fraud.
•If we discover any criminal activity or alleged criminal activity through our use of CCTV, fraud monitoring and suspicious transaction monitoring, we will process this data for the purposes of preventing or detecting unlawful acts. We aim is to protect the individuals we interact with from criminal activities.
•With your consent, we will use your personal data, preferences and details of your transactions to keep you informed by email, web, text, telephone. Of course, you are free to opt out of hearing from us by any of these channels at any time.
•To send you relevant, personalized communications by post in relation to your orders, updates, offers, services and products. We’ll do this on the basis of our legitimate business interest. You are free to opt out of hearing from us by post at any time.
•To send you communications required by law or which are necessary to inform you about our changes to the services we provide you. For example, updates to this Privacy Notice, product recall notices, and legally required information relating to your orders. These service messages will not include any promotional content and do not require prior consent when sent by email or text message. If we do not use your personal data for these purposes, we would be unable to comply with our legal obligations.
•To administer any of our prize draws or competitions which you enter, based on your consent given at the time of entering.
•To develop, test and improve the systems, services and products we provide to you. We’ll do this on the basis of our legitimate business interests.
•To comply with our contractual or legal obligations to share data with law enforcement.
•To send you survey and feedback requests to help improve our services. These messages will not include any promotional content and do not require prior consent when sent by email or text message. We have a legitimate interest to do so as this helps make our products or services more relevant to you.
Of course, you are free to opt out of receiving these requests from us at any time by updating your preferences in your online account.
•To build a rich picture of who you are and what you like, and to inform our business decisions, we’ll combine data captured by ourselves, third parties and data from publicly-available lists as we have described in the section ‘What Sort of Personal Data do we collect?’ We’ll do this on the basis of our legitimate business interest.
5.How we protect your personal data
We know how much data security matters to all our customers. With this in mind we will treat your data with the utmost care and take all appropriate steps to protect it.
Our website has a secure certificate (SSL) using 2048bit encryption which means that data entered to and displayed from the website and your device is secured.
No payment method data e.g. card numbers are stored by the website – all such transactions are carried out by a separate payment provider with all relevant security and GDPR credentials.
Sensitive personal data such as passwords are stored in encrypted database fields.
6. Who do we share your personal data with?
We sometimes share your personal data with trusted third parties.
For example, delivery couriers, technicians visiting your site, for fraud management, to handle complaints, to help us personalise our offers to you and so on.
Here’s the policy we apply to those organizations to keep your data safe and protect your privacy:
•We provide only the information they need to perform their specific services.
•They may only use your data for the exact purposes we specify in our contract with them.
•We work closely with them to ensure that your privacy is respected and protected at all times.
•If we stop using their services, any of your data held by them will either be deleted or rendered anonymous.
Examples of the kind of third parties we work with are:
•IT companies who support our website and other business systems.
•Operational companies such as delivery couriers.
•Direct marketing companies who help us manage our electronic communications with you.
•Suppliers who have cashback schemes
Sharing your data with third parties for their own purposes:
We will only do this in very specific circumstances, for example:
•With your consent, given at the time you supply your personal data, we may pass that data to a third party for their direct marketing purposes.
•For fraud management, we may share information about fraudulent or potentially fraudulent activity in our premises or systems. This may include sharing data about individuals with law enforcement bodies.
•We may also be required to disclose your personal data to the police or other enforcement, regulatory or Government body, in your country of origin or elsewhere, upon a valid request to do so. These requests are assessed on a case-by-case basis and take the privacy of our customers into consideration.
•For further information please contact our Data Protection Officer.
7. How do we use Cookies?
Cookies are basically little parcels of data that are passed from a website to a user’s web browser if the user visits certain websites. If a user browses the same website again in the future, the data stored by the cookie is retrieved by the website, typically in order to provide changes to certain page views, displayed content or functionality relevant to the user’s previous activity.
Our Cookies
We utilise a session cookie to identify you – this is to assist with redirecting between the mobile and non-mobile versions of this website.
3rd Party Cookies
This website uses Google Analytics in order to collect site traffic and usage information and this data is anonymous. This is done for the purposes of improving your website user experience.
Managing Cookies
Users can disable cookies at any time by using the relevant options in their web browser. This may have a negative impact on the browsing experience of some websites. Refer to your browsers help system to find out how to disable cookies.
8. What are your rights over your personal data?
An overview of your different rights
You have the right to request:
•Access to the personal data we hold about you, free of charge in most cases.
•The correction of your personal data when incorrect, out of date or incomplete.
•For example, when you withdraw consent, or object and we have no legitimate overriding interest, or once the purpose for which we hold the data has come to an end (such as the end of a warranty).
•That we stop using your personal data for direct marketing (either through specific channels, or all channels).
•That we stop any consent-based processing of your personal data after you withdraw that consent.
Please contact us to exercise your rights in any of the above areas. We adhere to a strict 30-day limit for actioning these requests. In extraordinary cases, we may require more time and will follow ICO guidelines and communicate with you accordingly.
If we choose not to action your request we will explain to you the reasons for our refusal.
Your right to withdraw consent
Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent.
Where we rely on our legitimate interest
In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.
Direct marketing
You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We must always comply with your request.
Checking your identity
To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Notice. If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.
How can you stop the use of your personal data for direct marketing?
There are several ways you can stop direct marketing communications from us:
•Click the ‘unsubscribe’ link in any email communication that we send you. We will then stop any further emails from that particular division.
•Write to Will Brock, Brocks Wheel & Tyre, Cutlers Green, Thaxted, CB22 5BG
Contacting the Regulator
If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
You can contact them by calling 0303 123 1113.
Or go online to www.ico.org.uk/concerns (opens in a new window; please note we can’t be responsible for the content of external websites)
If you are based outside the UK, you have the right to lodge your complaint with the relevant data protection regulator in your country of residence. Details can be found in Section 16.
If you live outside the UK
For all non-UK customers
By using our services or providing your personal data to us, you expressly consent to the processing of your personal data by us or on our behalf. Of course, you still have the right to ask us not to process your data in certain ways, and if you do so, we will respect your wishes.
Sometimes we’ll need to transfer your personal data between countries to enable us to supply the goods or services you’ve requested. In the ordinary course of business, we may transfer your personal data from your country of residence to ourselves and to third parties located in the UK.
By dealing with us, you are giving your consent to this overseas use, transfer and disclosure of your personal data outside your country of residence for our ordinary business purposes.
This may occur because our information technology storage facilities and servers are located outside your country of residence, and could include storage of your personal data on servers in the UK.
We’ll ensure that reasonable steps are taken to prevent third parties outside your country of residence using your personal data in any way that’s not set out in this Privacy Notice. We’ll also make sure we adequately protect the confidentiality and privacy of your personal data.