2) Explaining the legal bases we rely on
3) When do we collect your personal data?
4) What sort of personal data do we collect?
5) How and why do we use your personal data?
6) Combining your data for personalised direct marketing
7) How we protect your personal data
8) How long will we keep your personal data?
9) Who do we share your personal data with?
10) Where your personal data may be processed
11) What are your rights over your personal data?
12) How can you stop the use of your personal data for direct marketing?
13) Contacting the Regulator
14) Any questions?
1. Introduction – What is ‘GDPR’?
The GDPR stands for the General Data Protection Regulation, which is a part of EU law on data protection and privacy for all individuals within the European Union. As the UK is currently still in the EU, the GDPR regulations are being incorporated into British law from May 25th 2018.
Therefore, we’ve adjusted our policies and processes in order to comply with the GDPR. For the purposes of GDPR, Pitchmark is classified as a Data Controller.
If you would like any more information, or if there’s anything you would just like us to clarify a bit further, please get in touch with us at firstname.lastname@example.org or +44 (0)1454 776666.
2. Why are we allowed to collect and keep your data?
There are a number of reasons why a company such as Pitchmark would collect and use your personal data. These include:
- Consent – if you tell us that we are allowed to collect and use your data specifically.
- For example, if you visit one of our websites and tick a box to receive our newsletter.
- Contractual Obligations – if we need to collect data in order to fulfil a contract with you.
- For example, if you order something from us, then we have a contractual obligation to collect details like your address or phone number, and pass that over to a third-party courier, in order to deliver your goods.
- Legal compliance – if the law requires we collect or process your data.
- For example, we would need to hand over details of an individual involved in fraud or other criminal activity.
- Legitimate interest – if there is a strong likelihood that the collection and use of a limited amount of your data is used in a reasonable way.
- For example, we may send you a newsletter or marketing email if we feel there are products you have previously purchased or shown an interest in, and it is something you might reasonably expect to receive.
3. When do we collect your personal data?
- When you visit any of our websites and use your account to buy products and services in a shop or online.
- When you make an online purchase and check out as a guest (in which case we just collect transaction-based data).
- When you create an account with us.
- When you purchase a product or service in store or by phone but don’t have (or don’t use) an account.
- When you engage with us on social media.
- When you download or install our app.
- When you join our PitchPoints loyalty programme.
- When you choose to sign up to our newsletter.
- When you contact us by any means with queries, complaints etc.
- When you enter prize draws or competitions.
- When you book any kind of appointment or demonstration with us.
- When you request a quote for goods or services.
- When you choose to complete any surveys we send you.
- When you comment on or review our products and services.
- When you’ve given a third-party permission to share with us the information they hold about you.
- When you use our car park which has a CCTV system operated for the security of both customers and staff. These systems may record your image during your visit.
4. What sort of personal data do we collect?
- If you have an account with us: your name, job role, company, billing/delivery address, orders and receipts, email addresses and telephone numbers. If you have a web account for your security we’ll also keep an encrypted record of your login password.
- Details of your interactions with us through either face-to-face meetings or appointments, in our office, on the phone, online or by using our app.
- For example, we collect notes from our conversations with you, details of any complaints or comments you make, details of purchases you made, items viewed or added to your basket, voucher redemptions, web pages you visit and how and when you contact us.
- When ordering online, we record the location (IP address) from which you placed the order.
- Details of your visits to our websites or apps, and which site you came from to ours.
- Payment card information. However, this is only used to process a payment immediately, and is never stored.
- Your comments and product reviews.
- Your image may be recorded on CCTV when you visit our warehouse and offices.
5. 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. In the case of PitchPoints loyalty scheme members, we’ll also offer you relevant rewards.
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 back 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 websites, app, over the phone or in person. If we don’t collect your personal data during checkout, 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, guarantees and so on.
- To respond to your queries, refund requests 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 business and your account from fraud and other illegal activities. This includes using your personal data to maintain, update and safeguard your account. We’ll also monitor your browsing activity with us to quickly identify and resolve any problems and protect the integrity of our websites. We’ll do all of this as part of our legitimate interest.
- For example, by checking your password when you login and using automated monitoring of IP addresses to identify possible fraudulent log-ins from unexpected locations.
- To protect our customers, premises, and staff from crime, we operate CCTV systems at our business 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. Our 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, and telephone about relevant products and services including tailored special offers, discounts, promotions, events, competitions and so on.
- Of course, you are free to opt out of hearing from us by any of these channels at any time.
- To send you relevant, personalised communications by post in relation to 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 display the most interesting content to you on our websites or app, we’ll use data we hold about your favourite products and so on. We do so on the basis of your consent to receive app notifications and/or for our website to place cookies or similar technology on your device.
- For example, we might display a list of items you’ve recently looked at, or offer you recommendations based on your purchase history and any other data you’ve shared with us.
- 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.
- For example, we’ll record your browser’s Session ID to help us understand more when you leave us online feedback about any problems you’re having
- To comply with our contractual or legal obligations to share data with law enforcement.
- For example, when a court order is submitted to share data with law enforcement agencies or a court of law
- 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 from across our websites and app, 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.
- For example, by combining this data, this will help us personalise your experience and decide which inspiration or content to share with you. We also use anonymised data from customer purchase histories to identify trends. This may then guide which products we display online.
- To process your booking, demonstration or appointment requests (for example with one of our technical sales managers). Sometimes, we’ll need to share your details with a third party who is providing a service (such as delivery couriers). We do so to maintain our appointment with you. Without sharing your personal data, we’d be unable to fulfil your request.
6. Combining your data for personalised direct marketing
We want to bring you offers and promotions that are most relevant to your interests at particular times. To help us form a better, overall understanding of you as a customer, we combine your personal data gathered across as described above, for example your shopping history. For this purpose, we also combine the data that we collect directly from you with data that we obtain from third parties to whom you have given your consent to pass that data onto us.
7. 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.
We secure access to all transactional areas of our websites and apps using secure ‘https’ technology.
Access to your personal data is password-protected, and sensitive data (such as payment card information) is secured to ensure it is protected.
We regularly monitor our system for possible vulnerabilities and attacks, and for any improvements we can make to our processes to further strengthen security.
8. How long will we keep your personal data?
Whenever we collect or process your personal data, we’ll only keep it for as long as is necessary for the purpose for which it was collected.
At the end of that retention period, your data will either be deleted completely or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning.
Some examples of customer data retention periods:
- When you place an order, we’ll keep the personal data you give us for five years so we can comply with our legal and contractual obligations.
- If your order included a warranty, the associated personal data will be kept until the end of the warranty period.
9. Who do we share your personal data with?
We sometimes share your personal data with trusted third parties. For example, delivery couriers, review platforms, 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 organisations 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.
- Google to show you products that might interest you while you’re browsing the internet. This is based on either your marketing consent or your acceptance of cookies on our websites. See our Cookies Notice for details.
- Data insight companies to ensure your details are up to date and accurate.
- 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.
10. Where your personal data may be processed
Sometimes we will need to share your personal data with third parties and suppliers outside the European Economic Area (EEA), such as Australia or the USA.
Protecting your data outside the EEA:
- The EEA includes all EU Member countries as well as Iceland, Liechtenstein and Norway. We may transfer personal data that we collect from you to third-party data processors in countries that are outside the EEA.
- For example, this might be required in order to fulfil your order, process your payment details or provide support services.
- If we do this, we have procedures in place to ensure your data receives the same protection as if it were being processed inside the EEA. For example, our contracts with third parties stipulate the standards they must follow at all times. If you wish for more information about these contracts please contact our Data Protection Officer.
11. What are your rights over your personal data?
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.
- Review by a member of staff of any decision made based solely on automatic processing of your data (i.e. where no human has yet reviewed the outcome and criteria for the decision).
- You have the right to request a copy of any information about you that the Partnership holds at any time, and also to have that information corrected if it is inaccurate.
- To ask for your information, please contact Data Protection Officer, Pitchmark, Unit 8, Ram Hill Business Park, Ram Hill, Coalpit Heath, Bristol, South Gloucestershire, BS36 2TX, or email email@example.com.
- To ask for your information to be amended, please update your online account, or contact our Customer Services team.
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.
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.
12. 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.
- If you have an account, log in and visit the ‘My Account’ area and change your preferences.
- In our app, you can manage your preferences and opt-out from one or all of the different push notifications by selecting or deselecting the relevant options in the ‘Settings’ section.
- Write to Pitchmark, Unit 8, Ram Hill Business Park, Ram Hill, Coalpit Heath, Bristol, South Gloucestershire, BS36 2TX.
- Email firstname.lastname@example.org.
Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated.
13. 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 http://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.
14. Any questions?
If you have any questions that haven’t been covered, please contact our Data Protection Officer who will be pleased to help you:
Email us at email@example.com
Or write to us at Data Protection Officer, Pitchmark, Unit 108, Longmead Road, Emerald Park East Emersons Green, Bristol, BS16 7FG