Please use the Glossary to understand the meaning of some of the terms used in this privacy notice.
1. IMPORTANT INFORMATION AND WHO WE ARE
This privacy notice aims to give you information on how Ashton Bespoke Limited collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter, purchase a product or service or take part in a competition. This website is not intended for children and we do not knowingly collect data relating to children under the age of 13 years old. It is important that you read this privacy notice together with any other privacy notice or fair processing 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.
Ashton Bespoke Limited is the controller and responsible for your personal data (collectively referred to as “Ashton Bespoke Limited”, “we”, “us” or “our” in this privacy notice). We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.
Our full details are: ASHTON BESPOKE
Full name of legal entity: ASHTON BESPOKE
Name: Data privacy manager
Email address: firstname.lastname@example.org
Postal address: Ashton Bespoke Limited whose registered address is The Old Piggery, South Harting, Petersfield, Hampshire, GU31 5QG, UK.
Telephone number: 01730 779337
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
This version was last updated in April 2019.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
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 DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows: Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender. Contact Data includes billing address, delivery address, email address and telephone numbers. Financial Data includes bank account and payment card details. Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us. Technical Data includes internet protocol (IP) address, browser type and version, 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 this website. Profile Data includes purchases or orders made by you, your interests, preferences, feedback and survey responses. Usage Data includes information about how you use our website, products and services. Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences. 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 Aggregated 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 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, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect 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 IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
apply for our products or services;
create an account on our website;
subscribe to our service or publications;
request marketing to be sent to you;
enter a competition, promotion or survey; or
give us some feedback.
Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using Cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our Cookies (as defined below).
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:
(a) analytics providers such as Google based outside the EU; and
(b) search information providers such as Google based outside the EU.
Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as PayPal based outside the EU.
Identity and Contact Data from data brokers or aggregators based inside or outside the EU.
Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.
Essential Cookies. These are Cookies that are required for the operation of our website. They include, for example, Cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
Analytical/Performance Cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
Functionality Cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
Targeting Cookies. These Cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it, more relevant to your interests. We may also share this information with third parties for this purpose.
Cookie – Universal Analytics (latest version) & What we use them for
_ga – This is used by Analytics to calculate visitors, session, campaign data, etc. Expiration time is set to two (2) years and it resets each time when a visitor hits a page. No personal information or data is stored. Used to distinguish users. This cookie enables us to estimate our audience size and usage pattern See weblink below: https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage
_gat – Described by Google as “Used to throttle request rate”(no more information is available about this cookie). Expires in ten (10) minutes. This cookie enables us to limit the number of times information is recorded. See weblink below: https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage
_gid – This is used to distinguish users but has a 24hours expiration time. See weblink below: https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage
XSRF-Token – This cookie is written to help with site security in preventing Cross-Site Request Forgery attacks. It expires after the session.
Requestld – This cookies purpose is to tie together the logging generated by the web service to the logging from the requesting server.
SvSession – This is a sessions cookie that is deleted when you close your browser.
Hs – This is a sessions cookie that is deleted when you close your browser.
1P_JAR – Google advertising cookie used for user tracking and ad targeting purposes.
ANID – This cookie Google AdWords use to monitor performance of advertising and serve adverts to visitors based on the websites they have previously visited.
NID – This cookie sends requests to Google’s websites. The NID cookie contains a unique ID Google uses to remember your preferences and other information, such as your preferred language (e.g. English) and customisation.
DV – This cookie is used to collect information about how visitors use our website. This cookie collects information in an anonymous form, including the number of visitors to our website, where visitors have come to our website from and the pages they visited. See weblink: http://www.google.com/policies/privacy/.
HOW TO MANAGE COOKIES
Our Cookies do not store financial information, or information which is capable of directly identifying you (such as your name or address). Cookies simply allow our website to retrieve this information in order to personalise and improve your experience of our website. However, if you wish to restrict, block or delete Cookies provided by our site – or any other website – you can use your browser to do this. Each browser is different so check the ‘Help’ menu of your particular browser to learn how to change your cookie preferences, or use the following weblinks:
Microsoft Internet Explorer
How to manage Cookies in IE 11:
Our analytics partner also provides the ability for users to opt-out using the following links:
Further information on Cookies is available online at: www.aboutcookies.org . Please bear in mind that if you do this, certain personalised features of this website and others cannot be provided to you.
THIRD PARTY COOKIES
Third-party Cookies & What their Cookies are used for
Social Tools – We take advantage of social networks and like to share our content with friends across these networks, such as twitter, you may receive Cookies from these websites. We are not in control of these third-party Cookies, if you would like to learn more about them – visit their websites below:
Facebook – https://www.facebook.com/privacy/explanation
Twitter – https://twitter.com/en/privacy
Controlling your personal information
You may choose to restrict the collection or use of your personal information in the following ways:
- Whenever you are asked to fill in a form on the website, look for the box that you can click to indicate that you do not want the information to be used by anybody for direct marketing purposes.
- If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time and can contact us to let us know.
5. 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: Where we need to perform the contract we are about to enter into or have entered into with you. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. Where we need to comply with a legal or regulatory obligation. Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us at: email@example.com.
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, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. 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 us 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:
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:
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 (we call this marketing). You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or 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.
We will get your express opt-in consent before we share your personal data with any company outside of Goodall Fine Furniture Limited for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by going onto our website and checking the relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting us 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/service purchase, warranty registration, product/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 us. 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.
6. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the purposes set out in the table above. Internal Third Parties. Other companies in our group acting as joint controllers or processors and that provide IT and system administration services and undertake reporting.
External Third Parties. Including service providers acting as processors or hosts who provide IT and system administration services and service agents for support and delivery companies for the transportation of products.
Professional advisers acting as processors or joint controllers including solicitors, barristers, bankers, auditors and insurers based in the United Kingdom or EEA who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
Government Agencies for example for fraud or illegal activities.
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.
7. INTERNATIONAL TRANSFERS
Many of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
8. 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.
9. DATA RETENTION
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
How long will you use my personal data for?
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. By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six (6) years after they cease being customers for tax purposes. In some circumstances you can ask us to delete your data: see Request erasure of your personal data, 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.
10. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data as listed below:
- to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it.
- of your personal data where we are relying on a Legitimate Interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.
- of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- at any timewhere we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.
Please email us on firstname.lastname@example.org with your request in the title heading if you wish to exercise any of these rights.
NO FEE USUALLY REQUIRED
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 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 thirty (30) calendar days from the date of receipt of your request. Occasionally it may take us longer, 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. Where you are sending us a request via post rather than email we recommend you send it via recorded delivery to guarantee safe delivery.
Each of the clauses of these terms operates separately. If any court or relevant authority decides that any of them are unlawful unenforceable or illegal, the remaining clauses will remain in full force and effect.
Nothing herein contained shall give rise to a partnership or a contract of employment between you and us.
No waiver or affirmation of any breach of or non-compliance with any term hereof by the parties shall be deemed to be a waiver or affirmation of any preceding or succeeding breach of or non-compliance with the same or any other term.
If you wish to learn more information or have a question about your Personal Data or Cookies please email us on email@example.com with the title of your question in the email header.