“BRENMOOR” a trading division of a company registered in England and Wales with registration number 05445872 whose registered office is at 18 Ryefield Business Park, Silsden, West Yorkshire, BD20 0EE;
“Compliance Officer” the person referred to in Paragraph 3.4 (“Your Rights”) below appointed by us to deal with issues regarding our compliance with the DPA and the Privacy Regulations;
“Customer Services” the persons employed by us (or by our Data Processors on our behalf) or contracted to us to provide Customers and Users with help and assistance in respect of their dealings with, inter alia, us;
“DPA” the Data Protection Act 1998;
“Generic Data” anonymous information which does not specifically identify you;
“Privacy Regulations” the Privacy and Electronic Communications (EC Directive) Regulations 2003;
“Site” www.brenmoor.com, being the web site address operated by us;
“Terms and Conditions of Use”: our terms and conditions of use for the Site;
“User” a person who, for the purposes of a particular visit to the Site where he is not a Customer, uses the Website;
“we”, “us”, “our” BRENMOOR;
“you”, “your” a Member Customer, a Non Member Customer, a Member User or a Non Member User as the case may be.
“Sensitive Personal Data”.
The full text of these definitions can be obtained upon request. See Paragraph 3.7 (“Contact Information”) below for contact details.
We are the Data Controller in respect of Personal Data relating to you that we Process from time to time. We take the security and privacy of you and your Personal Data seriously and we are committed to safeguarding your privacy on line. Our primary reason for collecting your Personal Data is to enable us to fulfil our obligations to Customers in respect of Contracts and to make the service we provide for you more efficient. We do not anticipate collecting or processing Sensitive Personal Data about you.
3. OUR POLICY FOR PROCESSING YOUR PERSONAL DATA AND/OR SENSITIVE PERSONAL DATA
3.1. What Personal Data do we process about you and where do we get it from?
When you contact us through the “Contact Us” link on the Site or by telephone by E-mail or by post we may collect Personal Data from you (including in particular information such as your name, address, other contact details including your E-mail address and mobile telephone number, employment details) amongst others.
Notwithstanding the above your personal information may be obtained by us (or by a Data Processor on our behalf) in any of the following ways:-
(i) on-line forms from time to time;
(ii) through the “Contact Us” link on the Site;
(iii) notwithstanding (ii) above, through E-mail communications with you from time to time;
(iv) by dealing with one of our employees (or an employee of one of our Data Processors) over the telephone, by E-mail or by post;
(v) by telephone recording by us (or by a Data Processor on our behalf);
(vi) automatically by your internet browser;
(vii) from other sources: we might receive information about you from other sources. If so, we may add such information (or part of it) to the information we hold about you; and/or
(viii) by you replying to mailings and other promotions from time to time.
3.2 What do we do with your Personal Data?
We will process your Personal Data so that:
(i) we (or a Data Processor on our behalf) can learn about you to enable us to personalise and continually improve your shopping experience at the Site;
(ii) we (or a Data Processor on our behalf) can improve our site to prevent or detect fraud or abuses of the Site.
(iii) we (or a Data Processor on our behalf) can assist you through the “Contact Us” link on the Site or through the Customer Services service by telephone, by E-mail or by post in relation to any specific queries you may have from time to time in relation to us, a Contract or a proposed Contract, the Goods in question and/or the Site;
(iv) we (or a Data Processor on our behalf) can deal with general queries you raise from time to time through the “Contact Us” link on the Site or through the Customer Services service by telephone, by E-mail or by post;
(v) we can send you information (by post, email, by telephone) about (1) our products and services and provisions, (2) products, services and promotions of any companies which are part of the group of companies which we may be a part from time to time, and/or (3) products, services and provisions of other carefully selected companies, in each case that we think may be of interest to you. This is often referred to as “direct marketing” and “host mailing” respectively. If at any time you do not want to receive such information then please contact our Compliance Officer in accordance with Paragraph 3.4 (“Your Rights”) below or, if you are a Member, update your account preferences;
(vi) we can gather Generic Data about what pages you visit on the Site, how long you stayed on each page, and the route you took to navigate through the pages to help us monitor the accessibility of the Site and what your needs might be so that we can develop and improve the Site generally, in direct response to your requirements; and/or
Other purposes for which we will process your Personal Data are:
(xii) the general maintenance of our data base and other information databank by us or by a Data Processor on our behalf;
(xiii) for security purposes to protect your Personal Data and Sensitive Personal Data (if any) held and/or processed by us or by a Data Processor on our behalf in accordance with the DPA;
(xiv) for training our employees or those of our Data Processors in respect of providing our service to you; and/ or
(xv) for credit referencing in so far as your Personal Data and Sensitive Personal Data (if any) relating to a Contract or a proposed Contact will be processed by us or by a Data Processor on our behalf for credit referencing purposes.
3.3 Who else gets to see your Personal Data?
In light of the different purposes highlighted in Paragraph 3.2 (“What do we do with your Personal Data”) above we will from time to time need to disclose your Personal Data to various third parties. These third parties are:
(i) our Data Processors (which may include without limitation: the persons who host the Site on our behalf; the persons who maintain, update and administer the Site on our behalf; the persons who maintain, update and administer the Membership on our behalf, the persons who carry out the Customer Services on our behalf; the persons who provide credit/debit card payment facilities (whether online or by telephone) on our behalf; the persons who help us fulfil Contracts for example: delivery, packaging, sending postal mail and E-mail and so on, the persons, unless you have notified us to the contrary, who carry out “direct marketing” and/or “host mailing” on our behalf; and/or the persons who carry out any training on our behalf);
(ii) our suppliers;
(iii) other companies which are part of the group of companies which we may be a part from time to time;
(iv) unless you have notified us to the contrary, other carefully selected companies who provide goods and services which we think may be of interest to you; and/or
(v) our authorised employees and/or authorised employees of our Data Processors; and/or
Otherwise we will not disclose your Personal Data to other third parties unless we have your permission to do so or where we are required by law to disclose such information.
3.4 Your rights
You have the right to object to your Personal Data being used for ‘direct marketing’ and/or “host mailing” purposes.
(i) by post to: BRENMOOR Ltd, Compliance Officer, Summit House, Riparian Way, Cross Hills, Keighley, West Yorkshire, BD20 7BW
(ii) or by email to: firstname.lastname@example.org
You have the right under the DPA to request from us information as to what Personal Data we (or our Data Processors in so far as they are processing your Personal Data on our behalf) are processing about you. Such requests should be made in writing to our Compliance Officer (see contact details above) and should be accompanied by a £10 fee. We will provide you with the relevant information within [40 days] of receipt of the said fee.
You have other rights under the DPA in relation to our processing of your Personal Data and other rights under the Privacy Regulations.
3.5 Maintenance of Your Personal Data
We are committed to the security of your Personal Data
We do not provide any on-line security when you actually provide us with your Personal Data. It is your responsibility to ensure that such information is not disclosed to third parties as you enter it into via any online application form or the “Contact Us” link on the Site which ever the case may be.
We do not provide any on-line security as your Personal Data is transmitted to us (or our Data Processor on our behalf) via the internet. This also applies to information provided to us (or our Data Processor on our behalf) through the “Contact Us” link on the Site.
Once your Personal Data is stored in our data base or otherwise in electronic form by us (or our Data Processor on our behalf) it is password-protected and is only accessible by our employees (or those of our Data Processor on our behalf) authorised to access such information. This also applies to information provided through the “Contact Us” link on the Site.
All of your Personal Data, which is stored our data base or otherwise in electronic form by us (or our Data Processor on our behalf) on a server, is kept in a locked data centre accessible only by swipe card (namely by our authorised employees (or those authorised employees of our Data Processor on our behalf) and monitored at all times by CCTV.
3.7 Contact information
If you have any questions or queries about our processing or use of your Personal Data you should write, in the first instance, to our Compliance Officer (see contact details at Paragraph 3.4 (“Your Rights”) above).
If you want to learn more about your rights regarding your Personal Data, you should contact the Information Commissioner’s office information line on:
+44 (0)1625 545745 or visit their website at www.ico.gov.uk.