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Privacy Policy

Privacy policy

 

1. Introduction

 

We take your privacy very seriously and are committed to protecting your personal data.  This Privacy Policy details how we, Aspect Online Limited of Milton House, Gatehouse Road, Aylesbury, Buckinghamshire, United Kingdom, HP19 8EA (we, us) collect, use and process personal data. 

 

This Privacy Policy affects your legal rights and obligations so please read it carefully. If you do not agree to be bound by this Privacy Policy, please do not provide personal data to us. 

 

We may update this Privacy Policy from time to time at our discretion and in particular to reflect any changes in applicable laws. If we do so, and the changes substantially affect your rights or obligations, we shall notify you if we have your email address. Otherwise, you are responsible for regularly reviewing this Privacy Policy so that you are aware of any changes to it.


2. Data Controller

 

We are the controller of the personal data provided to us for the purposes of applicable data protection legislation.

 

If you have any questions on this Privacy Policy or otherwise relating to how we process your personal data you can contact us at hello@aspect-online.co.uk


3. What personal data do we collect?

 

By personal data we mean identifiable information about you. Generally, this is likely to include information such as your name, email address, correspondence address and your IP address if you access our website. 

 

We may collect, use, store and transfer different kinds of personal data about you:

  • Contact Data includes data such as your email address, telephone number, geographical address and billing address
  • Identity Data includes data such as first name, last name, username or similar identifier, date of birth;
  • Financial Data includes details you provide to us so that we can process your payments through our payment provider, Shopify;
  • Transaction Data includes details of products you have purchased and payments made; 
  • Technical Data includes data such as internet protocol (IP) address, your login data, browser type and version, cookies, 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 any communications we may send to you.
  • Usage Data includes information about how you use our website such as information about your visit to our website, including the full Uniform Resource Locators (URL) clickstream to and through, pages you viewed or searches you made, page response times, download errors, length of visit, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.
  • Marketing Data includes your preferences in receiving marketing from us.

 

We 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 it does not directly or indirectly identity you.  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 Policy.

  

We do not knowingly collect personal data of children.  Please do not provide personal data to us unless you are at least 18 years old.

 

Personal data you provide to us

 

From time to time you may provide to us personal data. This may be because: 

  • You access and interact with our website;
  • You create an account on our website;
  • You purchase products on our website;
  • You apply to work with us as an employee or a consultant;
  • You provide feedback or reviews to us;
  • You respond to a survey or questionnaire or enter a promotion or competition;
  • You sign up for our newsletter;
  • You otherwise contact us including with queries, comments or complaints. 

 

We shall process all such personal data in accordance with this Privacy Policy. Certain personal data is mandatory to be provided to us in order that we can fulfil your request, for example to purchase products on our website, and we shall make this clear to you at the point of collection of the personal data.

 

All personal data that you provide to us must be true, complete and accurate.  If you provide us with inaccurate or false data, and we suspect or identify fraud, we will record this and we may also report this to the appropriate authorities.   

 

When you contact us by email or post, we may keep a record of the correspondence and we may also record any telephone call we have with you.

 

Personal data we automatically collect about you

 

When you use our website, we may automatically collect and store information about your Technical Data and Usage Data for the purposes of research and analysis.

 

Some of this information is collected using cookies and similar tracking technologies. If you want to find out more about the types of cookies we use, why, and how you can control them, please see our Cookies Policy.

 

Personal data we receive from others

 

 

If we reasonably believe that any of the personal data you have provided to us is inaccurate, we may receive further personal data from third parties, such as credit reference agencies and the electoral register, to try to confirm your identity.

 

We may also receive personal data about you from our third party service providers, including our payment service providers and our analytic service providers.

 

4. Legal basis for processing your personal data

 

We will only use your personal data where we have a lawful basis to do so.  The lawful purposes that we rely on under this Privacy Policy are: 

  • consent (where you choose to provide it);
  • performance of a contract with you;
  • compliance with legal requirements; and
  • legitimate interests.    When we refer to legitimate interests we mean our legitimate business interests in the normal running of our business which do not materially impact your rights, freedom or interests.

 

PURPOSE/ACTIVITY

TYPE OF DATA

LAWFUL BASIS FOR PROCESSING INCLUDING BASIS OF LEGITIMATE INTEREST

To register you as a  customer and/or create your account

(a) Contact
(b) Identity

Performance of a contract with you

To manage your account including managing payments, returns and refunds

(a) Contact
(b) Identity

(c) Financial
(d) Transaction

(a) Performance of a contract with you
(b) Legitimate interests (fraud-checking)

To manage our relationship with you such as notifying you about changes to our terms or this Privacy Policy

(a) Contact
(b) Identity
   

(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests

To administer and protect our business and this website (including improving and fixing our service, analysis, testing, system maintenance, support, reporting)

(c) Technical

a) Necessary for our legitimate interests (for running our business security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure and understand the effectiveness of the advertising we serve to you

(a) Contact
(b) Identity
(d) Usage
(d) Marketing 

(e) Technical

Necessary for our legitimate interests (to analyse how customers use our website and manage our business accordingly)

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

(a) Technical
(b) Usage

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

 


5. Who do we share your data with?

 

Our website is hosted by Shopify, Inc. They provide us with the e-commerce platform that allows us to sell our products to you.  Accordingly Shopify, Inc. stores your personal data for this purpose.

 

For our legitimate interests, we may share any of personal data with our service providers, sub-contractors, consultants and agents that we may appoint to perform functions on our behalf and in accordance with our instructions, including IT service providers, group companies, accountants, auditors and lawyers.      

 

We shall provide our service providers, sub-contractors, consultants and agents only with such of your personal data as they need to provide the service for us and if we stop using their services, we shall request that they delete your personal data or make it anonymous within their systems.

 

If we need to use your personal data to comply with any legal obligations, demands or requirements, for example, as part of anti-money laundering processes or to protect a third party’s rights, property, or safety then in doing so, we may share your personal data with third party authorities and regulatory organisations and agencies.

 

If we choose to merge, sell assets, consolidate or restructure, finance, or sell of all or a portion of our business by or into another company then the new owners may use your personal data in the same way that we do as set out in this Privacy Policy.

 

6. Where we hold and process your personal data

 

Some or all of your personal data may be stored or transferred outside of the United Kingdom and/or European Economic Area (the EEA) for any reason, including for example, if our email server is located in a country outside the United Kingdom  or the EEA or if any of our service providers are based outside of the United Kingdom or the EEA.

 

Where your personal data is transferred outside the United Kingdom and/or the EEA, it will only be transferred to countries that have been identified as providing adequate protection for personal data or to a third party where we have approved transfer mechanisms in place to protect your personal data – i.e., by entering into the European Commission’s Standard Contractual Clauses, or by ensuring the entity is Privacy Shield certified (for transfers to US-based third parties). 

 

7. Security 

 

We shall process your personal data in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage.  In particular, access is restricted to employees who need to know your personal data, and we use appropriate password protection and appropriate strong encryption electronic measures within our electronic data management systems.

 

However, unfortunately, because of the nature of electronic storage,  we cannot promise that your personal data or any other data you provide to us will always remain secure.   If there is a security breach, we will do all that we can as soon as we can to stop the breach and minimise the loss of any data.

 

8. Marketing

     

    You may consent to receive marketing email messages from us about our website and our services, website, events, sales and business.  You can choose to no longer receive marketing emails from us by contacting us or clicking unsubscribe from a marketing email.  Please note that it may take us a few days to update our records to reflect your request.

     

    If you ask us to remove you from our marketing list, we shall keep a record of your name and email address to ensure that we do not send to you marketing information.  If you still have an account with us, we shall continue to email you in relation to your account only.

     

    9. Your Rights

      

    You have a number of rights under applicable data protection legislation. Some of these rights are complex, and not all of the details have been included below. Further information can be found here

    • Right of access:  You have the right to obtain from us a copy of the personal data that we hold for you.
    • Right to rectification: You can require us to correct errors in the personal data that we process for you if it is inaccurate, incomplete or out of date. 
    • Right to portability: You can request that we transfer your personal data to another service provider if you initially provided consent for us to use the personal data or where we used the personal data to perform a contract with you.
    • Right to restrict or object to processing:  In certain circumstances, you have the right to require that we restrict the processing of your personal information. If you believe our processing impacts on your fundamental rights and freedoms.  However, we may demonstrate that we have legitimate grounds to process your personal data not withstanding your rights and freedoms.
    • Right to be forgotten: You also have the right at any time to require that we delete the personal data that we hold for you, where it is no longer necessary for us to hold it.  However, whilst we respect your right to be forgotten, we may still retain your personal data in accordance with applicable laws and when we respond to your request we shall notify you of any specific legal reasons that we have to retain your personal data
    • Right to stop receiving marketing information: You can ask us to stop sending you information about our services, but please note we shall continue to contact you in relation to any matters relating to your account, if you have one.

     

    We reserve the right to charge an administrative fee if your request in relation to your rights is manifestly unfounded or excessive, and we may ask for identification from you before we can fully respond to your request.

     

    If you have any complaints in relation to this Privacy Policy or otherwise in relation to our processing of your personal data, please tell us. We shall review and investigate your complaint and try to get back to you within a reasonable time.  You do also have the right to contact the Information Commissioner, see www.ico.org.uk or if you are based outside of the United Kingdom, please contact your local regulatory authority.

     

    10. Retention of personal data

       

      Subject to the provisions of this Privacy Policy, we will retain personal data in accordance with applicable laws. 

      We may also be required to retain personal data for a particular period of time to comply with legal, auditory or statutory requirements, including requirements of HMRC in respect of financial documents and in order to deal with any dispute you might raise.  To determine the appropriate retention period for personal data, we consider the type of the personal data, the potential risk of harm from unauthorised use or disclosure of the  personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means.

      Where we have no legal basis for continuing to process your personal data, we shall either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

       

      For the avoidance of doubt, we may use anonymous data, such as usage data for research or statistical purposes indefinitely without further notice to you.

       

      11. General

       

      Our website may contain links to third party websites, plug-ins and applications.  We are not responsible for the content of such third party content, or their privacy statement.  If you provide any information to the third party, then you should check the third party website to find the applicable privacy policy.

       

      If any provision of this Privacy Policy is held by a court of competent jurisdiction to be invalid or unenforceable, then such provision shall be construed, as nearly as possible, to reflect the intentions of the parties and all other provisions shall remain in full force and effect. 

       

      This Privacy Policy shall be governed by and construed in accordance with English law and you agree to submit to the exclusive jurisdiction of the English Courts.

       

      This Privacy Policy was last updated on 28 August  2020.  You may contact us if you wish to review any previous version.

      Cookies Policy

      What are cookies?

      We use cookies on our website. Cookies are small pieces of data that are stored on your computer, mobile phone or other device.

       

      We also use pixels which are small blocks of code on web pages that do things like allow our server to measure viewing of our webpage and often are used in connection with cookies.

       

      We also use other tracking technologies like web beacons (sometimes called “tracking beacons” or “clear gifs”) and local storage. These are tiny graphics files that contain a unique identifier that enable us to recognise when someone has visited our website or opened an email that we have sent them.

       You can find more information about cookies at http://www.allaboutcookies.org/.

      How we use cookies.

      Cookies help us to operate our website and provide services to you.  In particular, they can:

      • make your online experience more efficient and enjoyable, including by recognising you when you return to our website and to customise the website according to your individual interests;
      • enhance and customise your experience across our website including by speeding up your searches;
      • enable us to perform research and carry out analytics; and
      • deliver advertising and marketing that is relevant to you.

      Third party cookies enable third party features or functionality to be provided on or through our website, such as advertising, interactive content and analytics.  These third-parties are responsible for the cookies they set on our website and we have no control over them

       

      What cookies do we use?

      We use the following cookies:

      • Operationally necessary cookies. These are cookies that are required for the operation of our website. For instance, cookies to enable you to log in to access our services, or cookies that are needed to take advantage of our e-billing services.
      • Performance cookies. These cookies allow us to track how our users use our website, the number of visits on each page, and behaviour on each page. This helps us optimise our website so you can find the things you are looking for and have the best experience possible.
      • Functionality cookies. These cookies allows us to recognise you by name and create a more personalised experience for you.
      • Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you may have clicked. We will use this information to curate services and content based on your needs. This information may also be shared with third-party providers.
      • Advertising cookies. We use cookies to help us show adverts to you for other websites across the internet based on your actions on our website and elsewhere. If you would like more information on behavioural advertising/retargeting, including how to opt out of it, please visit youronlinechoices.com.
      • Tracking cookies. We use cookies to enable us to track links in our emails that are opened by you.

       

      We also use Google Analytics to monitor how our website is used. Google Analytics collects information anonymously and generates reports detailing information such as the number of visits to the system, where visitors generally came from, how long they stayed on the system, and which pages they visited. Google Analytics places several persistent cookies on your computer’s hard drive.  These do not collect any personal data. If you do not agree to this you can disable persistent cookies in your browser. This will prevent Google Analytics from logging your visits. 

       

      We also use social media buttons and/or plugins on this site that allow you to connect with your social network in various ways. For these to work the relevant social media sites will set cookies through our site which may be used to enhance your profile on their site or contribute to the data they hold for various purposes outlined in their respective privacy policies.

       

       

      What technical information do we collect about your device?

       

      We  collect the following information about the device you are using to access our website:

      • the type of device you use;
      • a unique device identifier, for example, your device's IMEI number;
      • network information;
      • your operating system;
      • your IP address;
      • the browser you are using and what version it is; and
      • your time zone setting.

       

      Usage data

       

      We collect usage data about your activities on our website, including:

      • The full Uniform Resource Locators (URL) clickstream to, through and from our online properties (including date and time);
      • The different types of services/products you viewed or searched for;
      • page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page;
      • any phone number used to call our customer service number.

       

      How can you control cookies?

      You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. However, if you select this setting you may be unable to access certain parts of our online services.  Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you log on to our online properties.

       

      To change your cookie settings, or if you want to be notified each time a cookie is about to be used, you should amend the settings provided in your web browser to prevent us from storing cookies on your computer hard drive. 

      Most advertising networks also offer you the option to opt out of targeted advertising. For more info, visit http://www.aboutads.info/choices/ or http://www.youronlinechoices.com.

      You can manage your cookie settings by following your browser's instructions. Here are some links that might be of assistance:

       

       

      Last updated: 28 August 2020

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