1. Important information and who we are
This website is not intended for children and we do not knowingly collect data relating to children.
We are the Controller
Full name of legal entity: Smart Carrier Bags Ltd
For the attention of: Data Privacy Manager
Email address: firstname.lastname@example.org.
Postal address: 101 Lockhurst Lane, Coventry, West Midlands, CV6 5SF
Telephone number: 02476 582 102
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.
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.
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 your first name, maiden name and last name.
- Contact Data includes your billing address, delivery address, email address and telephone numbers.
- Financial Data includes your bank account details in the event we need to refund you any monies.
- 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 and any 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.
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/or Financial Data by filling in enquiry forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- purchase goods and services from us;
- contact us with an enquiry or in response to a communication from us;
- subscribe to our publications.
- Third parties or publically available sources: We will 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 Lead Forensics Limited;
- social media advertising networks.
- Identity and Contact Data from publicly available sources [such as Companies House and the Electoral Register based inside the EU].
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:
• 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 obligation.
Click here [insert link to paragraph 11] to find out more about the types of lawful basis that we will rely on to process your personal data.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before 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.
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.
Type of data we process
Lawful basis for processing including the basis of legitimate interest
To respond to an online enquiry made by you
Necessary for our legitimate interests (to provide you with a quote for our services or further information about the product you require)
To process and deliver your order including:
(a) Receive payments, fees and charges
(d) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to receive payments due to us)
To manage our relationship with you which will include:
(b) Asking you to leave a review
(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 communications
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
(f) Marketing and communications
Necessary for our legitimate interests (to develop our products/services and grow our business)
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
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 and 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 third party for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time 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.
- To help us to identify accounts, services and/or products which you could have from us or selected partners from time to time. We may do this by automatic means using a scoring system, which uses the Personal Data you have provided and/or any information we hold about you and Personal Data from third party agencies (including credit reference agencies).
- To allow us to carry out marketing analysis and customer profiling (including with transactional information), conduct research, including creating statistical and testing information.
- To allow us to contact you in any way (including mail, email, telephone, visit, text or multimedia messages) about products and services offered by us where
- these products are similar to those you have already purchased from us,
- you were given the opportunity to opt out of being contacted by us at the time your Personal Information was originally collected by us and at the time of our subsequent communications with you, and
- you have not opted out of us contacting you.
In connection with any transaction which we enter into with you:
- We may carry out with one or more licensed credit reference and fraud prevention agencies:
- credit checks where you have given us your express consent, and
- fraud prevention checks.
We and they may keep a record of the search. Information held about you by these agencies may be linked to records relating to other people living at the same address with whom you are financially linked. These records will also be taken into account in credit and fraud prevention checks. Information from the application and payment details of your account will be recorded with one or more of these agencies and may be shared with other organisations to help make credit and insurance decisions about you and members of your household with whom you are financially linked and for debt collection and fraud prevention. This includes those who have moved house and who have missed payments.
If you provide false or inaccurate information to us and we suspect fraud, we will record this and may share it with other people and organisations. We, and other credit and insurance organisations, may also use technology to detect and prevent fraud.
5. Disclosures of your Personal Data
We do not and will not sell your personal data to anyone. We may share your personal data with the following types of parties, or in the following circumstances:
- Service providers:
- MediaWorkx Ltd who provides consultancy and management services for Smart Carrier Bags’ website, digital marketing and social media.
- Trust Pilot who procures customer feedback.
- Professional advisors such as accountants, lawyers, banker, auditors and insurers based in the UK who provide accounting, legal, banking, consulting and consultancy services.
- Delivery companies: We may disclose your personal data to industry accredited logistics companies to ensure you receive your products in a safe and timely manner.
- Fraud Prevention: We may disclose your personal information for fraud detection or prevention purposes.
- The disclosure required by law: When we are under a legal obligation, or it is strictly necessary for the performance of a contractor to protect our rights, we may disclose your personal data to law enforcement or other authorities if required by law, or as otherwise required legally.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. To the extent our third parties are data processors and act in accordance with our instructions, we do not allow our third-party service providers to use your personal data for their own purposes. Other third parties, who may act as data controllers, may engage with you directly to procure your consent.
6. International Transfers
We do not transfer your personal data outside of the European Economic Area.
7. How we protect your Personal Data
We have appropriate security measures to protect your personal data and prevent it from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We limit access to your personal data to those employees, agents, contractors and 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.
We protect your personal data in the following ways:
- We work to protect the security of your information during transmission by using Secure Sockets Layer (SSL) software, which encrypts information you input.
- We reveal only the last five digits of your credit card numbers when confirming an order. Of course, we transmit the entire credit card number to the appropriate credit card company during order processing.
- We maintain physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of personally identifiable customer information. Our security procedures mean that we may occasionally request proof of identity before we disclose personal information to you.
- It is important for you to protect against unauthorised access to your password and to your computer. Be sure to sign off when you finish using a shared computer.
8. Data Retention
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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, regulatory, tax, accounting or other requirements.
9. Your Legal Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
- Request access to your personal data
- Request correction of your personal data
- Request erasure of your personal data
- Object to the processing of your personal data
- Request restriction of processing your personal data
- Request transfer of your personal data
- Right to withdraw consent
If you wish to exercise any of the rights set out above, [please see paragraph X for details on how to contact us
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 could 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 could 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. Contact Us
- We aim to keep the Personal Data we hold about you accurate and up to date. If you tell us that we are holding any inaccurate Personal Data about you, we will delete it or correct it promptly. Please email us at email@example.com or write to us at the address above to update your Personal Data.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and 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 us.
Performance of Contract 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.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.