We respect your privacy and are determined to protect your personal data. The purpose of this privacy notice is to inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from). We’ll also tell you about your privacy rights and how the data protection law protects you.
This privacy notice is provided in a layered format so you can scroll down to the specific areas set out below.
- WHO WE ARE AND IMPORTANT INFORMATION
- THE PERSONAL DATA WE COLLECT ABOUT YOU
- HOW WE COLLECT YOUR PERSONAL DATA
- HOW WE USE YOUR PERSONAL DATA
- WHO WE SHARE YOUR PERSONAL DATA WITH
- INTERNATIONAL TRANSFERS
- DATA SECURITY
- DATA RETENTION
- YOUR LEGAL RIGHTS
- CHANGES TO THIS NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
- QUERIES, REQUESTS OR CONCERNS
1. WHO WE ARE AND IMPORTANT INFORMATION
What is the purpose of this privacy notice?
This privacy notice aims to give you information on how we collect and process your personal data through your use of this website, including any data you may provide through this website when you place an order on our website, place an order over the telephone, place an order by email, place an order by fax, place an order by post, request a quotation, attempt to place an order in any way, sign up to our website by creating a user account, sign up to our newsletter, or download a guide, document or other media that requires you to submit your details.
This website is not intended for children and we do not knowingly collect data relating to children.
You must read this privacy notice together with any other privacy 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.
Sterlinx Global Ltd is the controller and responsible for your personal data (collectively referred to as “Business”, “we”, “us” or “our” in this privacy notice).
Our contact details are:
Sterlinx Global Ltd,
The Hub, 3A Bridgewater Street,
Sterlinx Global Ltd is the controller and responsible for this website.
Third-party links outside of our control
This 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 PERSONAL DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. You can find out more about personal data from the Information Commissioners Office.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data which includes first name, last name, salutation/title, shipping first name, shipping last name, shipping salutation/title and date of birth (where purchasing an age restricted product)
- Contact Data which includes billing address, shipping/delivery address, email address, telephone number and company name
- Financial Data which includes payment card details, fraud check details, payment method details, bank account details (if provided for refund)
- Order Details such as reference numbers or words that you have added to your order that may refer to personal details
- Transaction Details which include details about payments to and from you, details of products and services you have purchased from us, age verified status (where appropriate)
- Profile Data which includes your email address, password, purchases or orders made by you, your feedback via review
- Usage Data which includes information about how you use our website and the products, services and pages viewed
- Marketing and Communication Data which includes your preferences in relation to receiving marketing or information emails from us and third parties, and feedback request emails
- VAT relief details which include your (or the person you are claiming VAT relief on behalf of’s) name, address, declaration of chronic illness or disability and signature
- Technical details including your device, IP address location, IP address, hostname/server, registration date and time, last visit to the website date and time
- Email content, postal content and telephone content data which includes information that you have provided or that we have requested from you by email, post or telephone
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 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 website feature. However, if we combine or connect aggregate data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any of the following 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, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
We will only collect information about your health when you submit a VAT relief form to us, and by completing and signing the VAT relief form you are providing us with permission to collect and process this special category of personal data.
If you fail to provide personal data
Where we need to collect your 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 goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
3. HOW WE COLLECT YOUR PERSONAL DATA
We use different methods to collect data from and about you including through:
- Directly: You may give us your identity, contact, financial, profile, VAT relief and email data by filling in forms or by corresponding with us by post, telephone, email or otherwise. This includes personal data you provide when you:
- Purchase a product or service
- Create an account on our website
- Subscribe to a service or publication
- Sign up to our newsletters
- Correspond with us by email, telephone, post or fax
- Request marketing information or literature to be sent to you
- Request a quotation
- Submit a review
- Complete and send us a VAT relief form
- Third parties or publicly available sources: we may receive personal data about you from various third parties and public sources as set out below:
- Technical data from the following parties:
- Analytics providers such as Google and Bing based outside of the EU
- Search information providers such as Google and Bing based outside of the EU
- Age and identity data from Experian based inside the EU
- Identity and contact data from publicly available sources such as Companies House and the Electoral Register based in the EU
- Fraud risk data from providers of payment support such as Sage Pay based in the EU
- Payment and address data from Paypal based outside of the EU
- Address details from address lookup providers such as PCA Predict based in the EU
- Address details from Royal Mail based in the EU
- Technical data from the following parties:
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:
- Performance of Contract: this means processing your data where it 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.
- Legitimate Interest: this means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting Raj Ali via [email protected].
- Comply with a legal or regulatory obligation: this means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending our marketing and promotional communications as well as third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing and promotional emails at any time by contacting us. Please email Raj Ali at [email protected] to withdraw consent at any time.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below, in a table format, a description of all the ways we plan to use your personal data, with the legal bases we rely on to do so.
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 Raj Ali at [email protected] if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Type of Data||Lawful Basis for Processing Including Basis of Legitimate Interest|
|To register you as a new user.||
|Necessary for our legitimate interests (to enable you to register with the business in anticipation of completing an order, enabling the formation and performance of a contract with you).|
|To register you as a new customer||
Performance of a contract with you
To process and deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey
(d) Marketing and communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network 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 or understand the effectiveness of the advertising we serve to you||
(e) Marketing and Communication
|Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences||
|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)|
|To make suggestions and recommendations to you about goods or services that may be of interest to you||
|Necessary for our legitimate interests (to develop our products/services and grow our business)|
|Enquiry handling and ongoing support||
|Necessary for our legitimate interests (to assist you with products and service selection, to recommend suitable products for your requirements, to assist and support you with your purchase, to provide the support that we aim to deliver to all customers, and to ensure the safety of our customers when using our products and services).|
Completed VAT relief forms detailing medical conditions are also processed and may contain a special category of personal information, namely medical or condition information. The information and grounds that we are relying on are detailed below:
|Purpose/Activity||Type of Data||Lawful Basis for Processing Including Basis of Legitimate Interest||Additional Condition For Processing|
|VAT relief claim handling||
(d) VAT Relief
|Tax refund processing/tax exemption processing, contract performance||Exercising specific rights and obligations of the controller (or of the data subject) in the field of contract performance, and the provision of a relief available to members of the public who are eligible for VAT relief and social assistance|
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
We have established the following personal data control mechanisms:
- At checkout, you are given the opportunity to actively opt in to marketing correspondence which may include special offers from us or carefully selected third parties, product information and promotional content. As a default, you are opted out of receiving these marketing and advertising emails and we respect your decision to stay opted out or to opt in of your own free will.
- If opting in to marketing and advertising emails, you have the ability and choice of opting out of these emails at a later date by signing in to your user registered user profile on our website and opting out of marketing and advertising content.
- At any time, you can contact us by email, post, fax or telephone to opt out of further marketing or promotional correspondence.
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 and offers may be relevant for you.
You will receive marketing and promotional communications from us if you have requested information from us or purchased goods or services from us, if you provided us with your details by subscribing to our newsletters or requesting a download (such as an e-book), 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 or promotional content
We will get your express opt-in consent before we share your personal data with any company outside the Business for marketing or promotional purposes.
You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and unchecking the relevant contact box in the Personal Information section of your account or by following the opt-out links on any marketing message sent to you or by emailing [email protected] with your request to opt out at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product or service purchase, a warranty registration, a product or service experience or other transactions.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact Raj Ali at [email protected].
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. WHO WE SHARE YOUR PERSONAL DATA WITH
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
- External Third Parties
- Providers acting as processors based in the UK who provide IT and system administration services.
- HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the UK who require reporting of processing activities in certain circumstances
- Third party suppliers or subcontractors based in the EEA that may dispatch goods or provide services directly to you in pursuance of an order placed with us. In this instance we may provide your name, address, email address and telephone number to a supplier in order for that third party supplier or subcontractor to deliver a product and service directly to you. As part of this delivery of product or service, your details may also be passed to a postal or courier service to effect delivery.
- Third party delivery providers based in the EEA. In this instance we may pass your details including name, address, email address and telephone number to the postal service or courier service to enable delivery of your product or service and in order to communicate delivery confirmations and/or estimated delivery times.
- Providers acting as processors based outside of the EEA who provide IT, system administration, email marketing and email service/hosting services.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
- Third parties to assist in the communication and execution of a product recall in exceptional 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
Several of our external third parties are based outside of the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside of the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by implementing safeguards:
- We select third parties that can provide sufficient guarantees that they will uphold the requirements of GDPR
- We conduct due diligence to ensure that external third parties comply with GDPR
Please contact us at [email protected] if you would like further information on the specific mechanism used by us when transferring your personal data out of the EEA.
7. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we 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 put in place procedures 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 fulfil 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.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by emailing [email protected].
In some circumstances you can ask us to delete your data: see 9. YOUR LEGAL RIGHTS below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
9. YOUR LEGAL RIGHTS
Unless subject to an exemption under the data protection laws, you have the following rights with respect to your personal data:
- The right of access;
- The right to be informed;
- The right to rectification;
- The right to erasure;
- The right to restriction of processing;
- Rights related to automated decision making (including profiling);
- The right to object to processing; and
- The right to data portability.
If you wish to exercise any of the rights set out above, please contact Raj Ali at [email protected].
No fee required – with some exceptions
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable admin fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
10. CHANGES TO THIS NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
This version was last updated on 9th August 2018.
Historic versions can be obtained by contacting us at [email protected].
Please keep us informed if your personal data changes during your relationship with us. It is important that the personal data we hold about you is accurate and current.
11. QUERIES, REQUESTS OR CONCERNS
To exercise all relevant rights, queries or complaints in relation to this policy or any other data protection matter between you and us, please in the first instance contact our Data Protection Officer, Raj Ali, by email at [email protected].
If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 03031231113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England, UK.