GDPR Privacy Policy 2018

GDPR PRIVACY NOTICE

Introduction

This document refers to personal data, this is defined as information concerning any living person from which that person can be identified (who hereafter will be called the Data Subject) It does not include anonymous data – where the Data Subject’s identity has been removed.

The Data Protection Act (DPA), Privacy and Electronic Communications Regulations (PECR) and The General Data Protection Regulations (GDPR) which is EU wide and far more extensive, seek to protect and enhance the rights of data subjects. These rights cover the safeguarding of personal data, protection against the unlawful processing of personal data and the unrestricted movement of personal data within the EU. It should be noted that GDPR does not apply to information already in the public domain such as Companies House data.

The Activity Superstore Ltd (ASL) is pleased to provide the following GDPR information:

Who we are

ASL is a Gift Experience company principally involved in the B2B and B2C sectors.

Personal Data

ASL uses the information collected from you to provide information, make telephone contact and to email you Gift Experience information or queries which it believes is necessary or of interest to you.. In you making initial contact you consent to ASL maintaining a marketing and fulfilment dialogue with you until you either optout (which you can do at any stage) or we decide to desist in promoting our products. ASL also acts on behalf of its clients in the capacity of data processor. When working exclusively as a data processor, ASL will be acting on the instruction of its client, and will work hard to ensure that the client is fully GDPR compliant.

Some personal data may be collected about you from the forms you complete online, from records of our correspondence and phone calls and details of your visits to our website, including but not limited to personally-identifying information like Internet Protocol (IP) addresses. ASL may from time to time use such information to identify its visitors. ASL may also collect statistics about the behaviour of visitors to its website.

ASL website uses cookies, which is a string of information that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns. Software is used to help ASL identify and track visitors and their website access preferences. ASL website visitors who do not wish to have cookies placed on their computers should set their browsers to refuse cookies before using ASL website.

Any information ASL holds about you and your business encompasses all the details we hold about you and any sales transactions including any third-party information we have obtain about you from public sources and our own suppliers such Gift Experience providers.

ASL will only collect the information needed so that it can provide you with a marketing and fulfilment information, ASL does not sell or broker your data, although coincidentally there may be times when your information could be contained in data that ASL has purchased from a third-party list broker.

Legal basis for processing any personal data

To meet ASL contractual obligations to purchaser, gift recipients and to also respond to marketing enquiries.

Legitimate interests pursued by ASL and/or its clients

To facilitate the fulfilment element of contractual obligation and keep customers up to date with latest information.

Consent

Through agreeing to this privacy notice you are consenting to ASL processing your personal data for the purposes outlined. You can withdraw consent at any time by completing the online form GDPR Checklist or by phoning 0044 (0) 1763264500 or writing to us, see last section for full contact details.

Disclosure

ASL may on occasions pass your Personal Information to third parties exclusively to process contractual obligations regarding fulfillment on its behalf e.g. experience providers, Service providers acting as processors based in the EU who provide IT, system administration and marketing agency services. ASL requires these parties to agree to process this information based on our instructions and requirements consistent with this Privacy Notice and GDPR. ASL do not broker or pass on information gained from your engagement with the agency without your consent. However, ASL may disclose your Personal Information to meet legal obligations, regulations or valid governmental request. The agency may also enforce its Terms and Conditions, including investigating potential violations of its Terms and Conditions to detect, prevent or mitigate fraud or security or technical issues; or to protect against imminent harm to the rights, property or safety of ASL, its clients and/or the wider community. ASL may pass your data to 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.

Retention Policy

ASL will process personal data during the duration of any contract and will continue to store only the personal data needed for six years after the contract has expired to meet any legal obligations. After six years any personal data not needed will be deleted.

Data storage

Data is held primarily in the United Kingdom and also the EU, using different (multiple) servers. ASL does not store personal data outside the EEA.

Your rights as a data subject

At any point whilst ASL is in possession of or processing your personal data, all data subjects, have the following rights:

• Right of access – you have the right to request a copy of the information that we hold about you.
• Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
• Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
• Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
• Right of portability – you have the right to have the data we hold about you transferred to another organisation.
• Right to object – you have the right to object to certain types of processing such as direct marketing.
• Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.

In the event that ASL refuses your request under rights of access, we will provide you with a reason as to why, which you have the right to legally challenge.

ASL at your request can confirm what information it holds about you and how it is processed.

You can request the following information:

• Identity and the contact details of the person or organisation (ASL) that has determined how and why to process your data.
• Contact details of the data protection officer, where applicable.
• The purpose of the processing as well as the legal basis for processing.
• If the processing is based on the legitimate interests of ASL or a third party such as one of its clients, information about those interests.
• The categories of personal data collected, stored and processed.
• Recipient(s) or categories of recipients that the data is/will be disclosed to.
• How long the data will be stored.
• Details of your rights to correct, erase, restrict or object to such processing.
• Information about your right to withdraw consent at any time.
• How to lodge a complaint with the supervisory authority (ICO).
• Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
• The source of personal data if it wasn’t collected directly from you.
• Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.

To access what Personal data is held, identification will be required

ASL will accept the following forms of ID when information on your personal data is requested:

A copy of your driving licence, passport, birth certificate and a utility bill not older than three months. A minimum of one piece of photographic ID listed above and a supporting document is required. If ASL is dissatisfied with the quality, further information may be sought before personal data can be released.

All requests should be made to the GDPR@activitysuperstore.com or by phoning 0044 (0) 1763264500 or writing to us at the address further below.

Complaints

In the event that you wish to make a compliant about how your personal data is being processed by ASL or its partners, you have the right to complain to The Activity Superstore Ltd Financial Director. If you do not get a response within 30 days you can complain to the ICO.

The details for each of these contacts are:

The Activity Superstore Ltd
Attention of the Financial Director
41-45 High Street
Saffron Walden
Essex
CB10 1AR

Telephone 0044 (0) 1763 264502 or email head.office@activitysuperstore.com

ICO

Wycliffe House, Water Lane, Wilmslow, SK9 5AF

Telephone 0303 123 1113 or contact via: https://ico.org.uk/make-a-complaint/