We respect your concerns about privacy and follow strict procedures to protect customer information and ensure that your personal information is handled in a responsible manner.
Website privacy notice
This policy explains how Commprex Limited (“We”) collects personal data from you, why we collect it, how we process it and where we may disclose it to other entities.
We are committed to complying with the Data Protection Act 1998 and the EU General Data Protection Regulation (GDPR) for the purposes of data protection and privacy.
We are registered as a data controller under the terms of the Data Protection Act 1998 and the EU GDPR with the UK Information Commissioner’s Office (ICO). Details of our registration may be found at [link].
From 25th of May 2018, the EU GDPR replaces the Data Protection Act 1998. This gives you new rights in relation to the privacy of your personal information; this policy provides a brief explanation of those rights.
In the case of any request involving one of your rights, you should contact the Data Controller at email@example.com. We will respond to your request as quick as we can and at most within twenty working days of receipt of your request. We may extend this time period by up to two months if your request is particularly complex.
Right of access
Subject Access Requests (SAR) allow your right to obtain a copy of the information that we hold about you. You have the right to ask us to provide you with this information free of charge. However, should the request be deemed to be manifestly excessive, unfounded or repetitive, then we are permitted to charge a reasonable fee for providing the information. In such circumstances, and as an alternative, we can refuse to comply with the request. If this is the case, we will let you know the reasons for us refusing to comply. You have a right to appeal this decision via the UK ICO.
Right to rectification
You are entitled to have the information that we hold about you rectified if it is inaccurate or incomplete. If you believe that the information that we hold about you is inaccurate, incomplete or out of date then please advise the Data Controller. We will also inform any third parties of the rectification so they can update their records too.
Right to erasure
You have the right to request that we delete the personal information that we hold about you where we have no compelling reason for its continued processing. This right will apply:
• Where retention of the data is no longer necessary for the purposes that it was originally collected or processed.
• Where you have withdrawn consent.
• Where you object to us processing the data and there is no overriding legitimate interest for us to continue to do so.
• When the personal data has to be erased for us to comply with a legal obligation.
• When the data has been unlawfully processed.
• Where the data relates to a child.
This right shall not apply:
• Where we are exercising the right of freedom of expression and information.
• Where we are complying with a legal or statutory obligation.
• Where we are archiving data in the public interest, for scientific research or for statistical purposes.
• When we need the data to exercise or defend a legal or statutory claim.
We will also inform any third parties of the request so they can erase their records too.
Right to restrict processing
You can request that we restrict the processing of your information. This means that you may have requested one of your other rights, where until the request is concluded that we suspend the processing of your data. If we have passed your data to a third party, we will also inform them that they must restrict the processing of your data. This right will apply:
• Where you contest the accuracy of the information that we hold about you and you request that we restrict processing while we investigate.
• You object to us processing your personal data, but we believe that processing is in the public interest or the performance of our legitimate interests and that these are legitimate grounds to override your interest.
• Where you believe that processing is unlawful and you request restriction instead of deletion.
• Where we no longer need that data, but you require the data stored in order to pursue a legal claim.
Right to data portability
You have the right to request the information that we hold on you be supplied to you in a portable format. This allows you to take your information from our IT environment to another organisation’s IT environment. The format in which we supply your data will be as a Microsoft software file.
Right to object
You have the right to object to your personal information being processed by us. This means:
• If you object to us processing your data for marketing purposes then let us know and we/our third parties will stop sending you marketing material.
• If you object to us processing your data at all (i.e. where you have an account with us) let us know and we will completely remove your personal information from our systems.
If you choose the second option and then change your mind at a later date, then you will need to set up a new account to resume shopping with us.
We use data profiling to make the content of our communications to you more interesting and relevant. This means you’ll receive details of our offers that are tailored to you which allows us to not waste your time by offers that are unlikely to be of interest.
You have the right not to be subject to a decision based solely on automated processing. This includes decisions based on profiling. If you choose to exercise this right, then you will no longer receive offers from us as we base our mailing list on our customers’ purchase history. Contact the Data controller if you object to this.
Information we may collect from you
We use the EU GDPR definition of personal data. This is any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
We may collect and process the following data about you:
• Information that you provide by filling in forms on the website at www.makties.com, www.makties.co.uk as well as information provided via live chat, newsletter subscriptions, through our telephone lines, email and our social media channels. This includes information provided at the time of registering to use the website, subscribing to our service, posting material or requesting further services. We may also ask you for information when you report any problems.
• If you contact us, we may keep a record of that correspondence.
• If you telephone us, we may keep recordings of the call for training, fraud prevention, servicing your account and regulatory consent.
• Details of transactions you carry out through the website and of the fulfilment of your orders.
• Details of your visits to the website including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.
• We may also receive your information from another organisation that you have consented for them to share your data.
Use of our services by children
Our website is not intended for the use of children under the age of sixteen so they should not provide personal information to us. If we become aware that we have collected personal information from a child under the age of sixteen, then we will delete that information from our records.
Where we store your personal data
The data that we collect from you may be transferred to, and stored at, a destination outside the European Union (“EU”). It may also be processed by staff operating outside the EU who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with the appropriate EU GDPR Article, including Article 45 – Adequacy Decision, Article 46 – Appropriate Safeguards, Article 47 – Binding Corporate Rules, Article 49 (1) – Specific Situation Exemption or Article 49(2) – Transfer to the Data Subject.
Where we have given you (or where you have chosen) a password which enables you to access certain parts of the website, you are responsible for keeping this password confidential; do not share your password.
We use physical, technological and administrative safeguards to protect your personal information against loss, misuse or alteration. All your personal information is stored securely and may only be accessed by employees with a legitimate business need to access the information. Unfortunately, the transmission of information via the internet is not completely secure and we cannot guarantee the security of your data transmitted to the website. Any transmission is at your own risk.
How we use your information
We use information held about you in the following ways:
• To ensure website content is presented in the most effective manner for you and for your computer.
• To carry out our obligations arising from any contracts entered between us both.
• To allow you to participate in interactive features of our service, when you choose to do so.
• To notify you about changes to our service.
Direct marketing communications
We may use your data to enable us to send you post, emails and phone messages with information about our goods and services that we believe may be of interest to you.
You have the right to withdraw from or amend the receipt of direct marketing communications. If you decide to opt out then you will miss out exclusive offers that we would like to make you aware of.
Customer feedback surveys
We may contact you via telephone, email or SMS to ask you to complete surveys and feedback forms. We do this to improve our customer service and the products we offer. Sometimes we will nominate a representative to do this on our behalf. You are under no obligation to respond to such requests.
Disclosure of your information
We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006 or one of our connected companies.
We may disclose your personal information to third parties:
• In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
• If Commprex or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, enforce or protect any other agreements or rights, property or safety of Commprex, our customers, or others.
In addition to the information that we share in order to comply with our legal obligations, we also may share or disclose the information:
• To third parties that process data on our behalf.
• To any other party with your prior consent.
We may also exchange your information with other companies and organisations for the purposes of fraud protection and credit risk reduction. Where false information or fraud is suspected, we may pass this information to fraud prevention and law enforcement agencies.
Retention of data
We retain your information for as long as you hold a relationship or account with us. This enables us to maintain an ongoing relationship with you and allows us to service the orders that you place with us. We follow a data retention schedule; this has been put in place to ensure that we retain the minimum amount of personal data about you.
We ask that you not send or disclose any sensitive personal information to us either through our website, post, email, text message, live chat, telephone call or by any other method. For clarity, sensitive personal information means information related to racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background or trade union membership.
In the unlikely event that information you have supplied us is compromised then we shall notify both you and the UK ICO. This notification will be made without due delay.
Changes to this privacy notice
We review this notice at least annually or after any significant change to our website, processes, systems or because of government regulations. This policy will be dated and we recommend that you visit this page occasionally to view any changes we may have made.
Date: 27 August 2020
If you have a complaint relating to our data protection or data privacy then please contact us. If you are unhappy with our final response in relation to a complaint, then you have the right to complain to our supervisory authority – the UK ICO at https://ico.org.uk/concerns/.
Our Data Controller and Data Officer may be contacted in writing by email at firstname.lastname@example.org.