PRIVACY NOTICE FOR CUSTOMERS
In accordance with the General Data Protection Regulation (GDPR), we have implemented this privacy notice to inform you, our customers, of the types of data we process about you. We also include within this notice the reasons for processing your data, the lawful basis that permits us to process it, how long we keep your data for and your rights regarding your data.
This notice applies to all customers of Hail Mary Ltd.
1) DATA PROTECTION PRINCIPLES
Under GDPR, all personal data obtained and held by us must be processed according to a set of core principles. In accordance with these principles, we will ensure that:
1.1) Processing is fair, lawful and transparent
1.2) Data is collected for specific, explicit, and legitimate purposes
1.3) Data collected is adequate, relevant and limited to what is necessary for the purposes of processing
1.4) Data is kept accurate and up to date. Data which is found to be inaccurate will be rectified or erased without delay
1.5) Data is not kept for longer than is necessary for its given purpose
1.6) Data is processed in a manner that ensures appropriate security of personal data including protection against unauthorised or unlawful processing, accidental loss, destruction or damage by using appropriate technical or organisation measures
1.7) We comply with the relevant GDPR procedures for international transferring of personal data
2) TYPES OF DATA HELD
We keep several categories of personal data on our customers in order to carry out effective and efficient processes. We keep this data in a customer database relating to each customer and we also hold the data within our computer systems, for example, our E-commerce system.
Specifically, we hold the following types of data:
2.1) Personal details such as name, address, phone numbers
2.2) Purchase history such as items purchased and amount spent
2.3) Payment details required for payment (held securely by Secure Trading)
2.4) Activity on our website
3) COLLECTING YOUR DATA
Your data is collected when you shop with us.
When purchasing online, you will required to input your personal data, such as name and address, to qualify for delivery. If you choose to pay by credit card ‘Sage Pay’ will securely capture your payment information and handle the transaction. Very little is transferred to Hail Mary Ltd in this instance.
4) LAWFUL BASIS FOR PROCESSING
The law on data protection allows us to process your data for certain reasons only. We process your data in order to comply with legal requirements or in order to effectively manage any transactions we have with you.
The information below categorises the types of data processing we undertake and the lawful basis we rely on.
|Activity requiring your data||Lawful basis|
|Ensuring you receive your purchased items||Legal requirement|
|Ensuring we can contact you regarding errors, faults or damages||Our legitimate interests|
|Ensuring we can fulfil warranty claims, discounts and sales objectives||Our legitimate interests|
|Allowing us to market our products to you via mailing lists||Our legitimate interests|
|Ensuring we can review sales data vital for business development and analysis||Our legitimate interests|
|Dealing with legal claims made against us||Our legitimate interests|
|Preventing fraud||Our legitimate interests|
|Ensuring our administrative and IT systems are secure and robust against unauthorised access||Our legitimate interests|
5) SPECIAL CATEGORIES OF DATA
We do not process any special categories of data for customers who shop with Hail Mary Ltd.
6) FAILURE TO PROVIDE DATA
Your failure to provide us with data may mean that we are unable to fulfil our requirements for transactions and purchasing from our site. This could include being unable to offer you service, or assist with queries or warranty information.
7) WHO WE SHARE YOUR DATA WITH
Employees within our company will have access to your data which is relevant to their function. All employees with such responsibility have been trained in ensuring data is processing in line with GDPR.
Data is shared with third parties for the following reasons:
Ecommerce sales records
Email Campaigns (MailChimp)
We may also share your data with third parties as part of a Company sale or restructure, or for other reasons to comply with a legal obligation upon us. We have a data processing agreement in place with such third parties to ensure data is not compromised. Third parties must implement appropriate technical and organisational measures to ensure the security of your data.
8) PROTECTING YOUR DATA
We are aware of the requirement to ensure your data is protected against accidental loss or disclosure, destruction and abuse. We have implemented processes to guard against such.
9) RETENTION PERIODS
We only keep your data for as long as we need it for. Some data retention periods are set by the law. Retention periods can vary depending on why we need your data.
We keep records of our registered and E-commerce customers personal information indefinitely, or until the data is requested to be erased.
10) AUTOMATED DECISION MAKING
Automated decision making means making decisions about you using no human involvement e.g. using computerised filtering equipment. No decision will be made about you solely on the basis of automated decision making (where a decision is taken about you using an electronic system without human involvement) which has a significant impact on you.
11) CUSTOMER RIGHTS
You have the following rights in relation to the personal data we hold on you:
11.1) The right to be informed about the data we hold on you and what we do with it.
11.2) The right of access to the data we hold on you. More information on this can be found in the section headed “Access to Data” below and in our separate policy on Subject Access Requests”.
11.3) The right for any inaccuracies in the data we hold on you, however they come to light, to be corrected. This is also known as ‘rectification’.
11.4) The right to have data deleted in certain circumstances. This is also known as ‘erasure’.
11.5) The right to restrict the processing of the data.
11.6) The right to transfer the data we hold on you to another party. This is also known as ‘portability’.
11.7) The right to object to the inclusion of any information.
11.8) The right to regulate any automated decision-making and profiling of personal data.
Where you have provided consent to our use of your data, you also have the right to withdraw that consent at any time. This means that we will stop processing your data.
13) MAKING A COMPLAINT
If you think your data rights have been breached, you are able to raise a complaint with the Information Commissioner (ICO). You can contact the ICO at Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF or by telephone on 0303 123 1113 (local rate) or 01625 545 745.
14) DATA PROTECTION COMPLIANCE
Our Data Protection Officer is:
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Cookie Type Reference:
|COOKIE NAME||COOKIE DESCRIPTION|
|CART||The association with the customer’s shopping cart.|
|CATEGORY_INFO||Stores the category info on the page to load pages faster.|
|COMPARE||The items in the customer’s Compare Products list.|
|CUSTOMER||An encrypted version of the shopper’s customer ID.|
|CUSTOMER_AUTH||Indicates if the customer are currently logged in to the store.|
|CUSTOMER_INFO||An encrypted version of the shopper’s customer group.|
|EXTERNAL_NO_CACHE||Indicates if caching is disabled or enabled.|
|FRONTEND||The customer’s session ID.|
|GUEST-VIEW||Determines if guests can edit their orders.|
|LAST_CATEGORY||The last category visited by the shopper.|
|LAST_PRODUCT||The most recent product viewed by the shopper.|
|NEWMESSAGE||Indicates whether a new message has been received.|
|NO_CACHE||Indicates if the cache can be used to store information.|
|PERSISTENT_SHOPPING_CART||A link to information about the shopper’s cart/viewing history.|
|RECENTLYCOMPARED||Items recently compared b the shopper.|
|STF||Information on products the shopper has emailed to friends.|
|STORE||The store view or language chosen by the shopper.|
|USER_ALLOWED_SAVE_COOKIE||Indicates if the shopper allows cookies to be saved.|
|VIEWED_PRODUCT_IDS||The products recently viewed by the shopper.|