1. Important information and who we are
2. The data we collect about you
3. How is your personal data collected?
4. How we use your personal data
5. Disclosures of your personal data
6. International transfers
7. Data security
8. Data retention
9. Your legal rights
1. Important Information and Who We Are
Data Privacy Manager: Greg Allsopp
Full name of legal entity: Securian Industries Limited
Email address: email@example.com (marked for the attention of Mr Allsopp)
Postal address: 1 Mariner Court, Calder Business Park, Wakefield, WF4 3FL.
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 Date 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 first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Contact Data includes billing address, delivery address, email address and telephone numbers.
- Financial Data includes bank account and payment card details to the extent this is provided to us by you or via the payment processing systems we use.
- 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, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, phone or laptop details and information about other technology on the devices you use to access this website.
- 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.
- Security Data includes records of access to certain premises including time and ID number, CCTV images, passwords or other access codes you set up and details of third parties authorised to act on your behalf.
We try not to collect any Special Categories of Personal Data about you. Special Categories 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. We do not collect any information about your criminal convictions and offences.
If you give us information on behalf of somebody else as an alternate contact, referee or next of kin, you confirm that the other person has agreed that you can:
- give consent on his/her behalf to the processing of his/her personal data; and
- receiving on his/her behalf any data protection notices.
We do not knowingly collect personal data relating to children under the age of 16. If you are a parent or guardian of a child under the age of 16 and think that we may have information relating to that child, please contact us. We will ask you to prove your relationship to the child but if you do so you may (subject to applicable law) request access to and deletion of that child’s personal data.
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 the products or services ordered by you or to confirm a booking for the provision of services by us or our authorised third parties). In this case, we may have to cancel an order or a booking 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, Security, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, and email or otherwise. This information will include matters such as your name, postal address, email address, phone number(s), date of birth, personal identification (such as driving licence and recent utility/bank statement which sets out your postal address) bank account/payment card information. This includes personal data you provide when you:
- enquire or apply for our products;
- sign any disclaimers or waivers in connection with our products;
- subscribe to our service or publications;
- request marketing to be sent to you;
- enter a competition, promotion or survey; or
- give us feedback or contact us.
- Third parties or publicly 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:
(a) analytics providers such as Google based outside or inside the EU; and
(b) search information providers such as Google based inside or outside the EU.
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
- Identity and Contact Data from data brokers or aggregators such as Experian based inside the EU.
- Identity and Contact Data from publicly available sources based inside the EU such as the Electoral Register.
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; or
- Where we need to protect your vital interests or the vital interests of others.
You can read our Glossary and the table below 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.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To provide you with information, pricing, availability etc when you enquire about our services. This includes registering or recording you in our software and IT systems and following up with you in relation to such enquiries.||(a) Identity (b) Contact||Necessary for our legitimate interests (for running our business and provision of services)|
|To register you as a new customer and to confirm your identity. This includes registering or recording you as a customer or user in our software and IT systems as a customer or prospective customer. It will also enable us to do a credit check on you (see credit checking section below), allow us to identify you for the terms of the contract between us and allow us to deal with any payments/deposits and related actions in relation to the contract we enter into between us.||(a) Identity (b) Contact (c) Financial||(a) Performance of a contract with you. (b) Necessary to comply with any legal obligation. (c) Necessary for our legitimate interests (to ensure our services are provided securely and restricting access where required).|
|To manage your purchase and contact history with us||(a) Identity (b) Contact (c) Financial (d) Transaction||(a) Performance of a contract with you. (b) Necessary to comply with any legal obligation. (c) Necessary for our legitimate interests (to ensure our services are provided securely and restricting access where required).|
|To help us review, develop and improve the products and services we offer. For example, we may send you market research requests via email (which you can opt out of via that email).||(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications||(a) Necessary for our legitimate interests (to ensure our services are provided securely and restricting access where required).|
|To provide a safe service to you and others.||(a) Identity (b) Contact (c) Safety||(a) Performance of a contract with you. (b) Necessary to comply with a legal obligation. (c) Necessary for our legitimate interests (to ensure our services are provided safely and to provide appropriate insurance). (d) Your express consent where applicable. (e) For another purpose in an emergency situation where you are unable to give consent, such as if we have to assist emergency services to protect your vital interests or the vital interests of others. (f) as may be necessary in relation to dealing with actual or potential legal claims|
|To process and deliver your order or to enable the provision of goods to you including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us (c) registration of any warranties connected to our products (d) to manage or address any claims against us||(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications||(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us)|
|To manage any insurance matters relating to you.||(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications (f) Safety||(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests. (d) For another purpose in an emergency situation where you are unable to give consent, such as if we have to assist emergency services to protect your vital interests or the vital interests of others. (e) as may be necessary in relation to dealing with actual or potential legal claims.|
|To enable you to partake in a prize draw, competition or complete a survey or to have access to discounts or offers (from time to time).||(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications||(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)|
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity (b) Contact (c) Technical (d) Safety||(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, promotional literature and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical||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 provide you with copies of our newsletters, offers, discounts or other information about our products or our marketing campaigns or promotional literature||(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical||(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)|
|Generally (without limiting any other of reason for using your data set out in this document) to improve and measure the effectiveness of our marketing communications, including online advertising. We sometimes compare limited information that we hold about you (for example, your email address or mobile phone number) with third parties that also hold your information or have an existing online relationship with you in order to identify you as our customer and to enable us (or third parties on our behalf) to provide you with relevant marketing online. For example, we may compare your information with the information that social networking sites such as Twitter, Instagram, and Facebook hold on you, so that they can identify you as a customer and hence tailor the Securian marketing you receive via their sites and products||(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical||(a) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)|
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences||(a) Technical (b) Usage||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||(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications||Necessary for our legitimate interests (to develop our products/services and grow our business)|
|To carry out security checks to protect against fraudulent transactions and to prevent and detect criminal activity||(a) Identity (b) Contact (c) Financial||(a) Performance of a contract with you. (b) Necessary to comply with any legal obligation. (c) Necessary for our legitimate interests (to ensure our services are provided securely and restricting access where required).|
We may do a credit check on you so that we can make credit decisions about you and people or businesses associated with you. These checks may also be used to help prevent and detect fraud and money laundering. Our search will be recorded on the files of the credit reference agency.
We may also disclose information about how you conduct your account to credit reference agencies and your information may be linked to records relating to other people living at the same address or who are financially linked to you. Other credit businesses may use your information to make credit decisions about you and the people with whom you are financially associated, trace debtors, and prevent and detect fraud and money laundering.
If you provide false or inaccurate information to us and we suspect fraud, we will record this.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. Where relevant, we will provide unsubscribe links in our emails and you can update your preferences when it comes to what kind of marketing you receive from us by contacting us at any time.
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 any goods or services from us and you have not opted out of receiving that marketing.
Seeing adverts from us online
As noted above, we use online advertising to keep you up to date with the latest from Securian. Like many companies, we target our advertisements to you based on your behaviour online. We do this using a variety of digital marketing networks and ad exchanges, and we use a range of advertising technologies like pixels, ad tags, cookies, and mobile identifiers, as well as specific services offered by some sites and social networks (and example of this would be Facebook’s Custom Audience service).
The banners and ads you see will be based on information we hold about you, or your previous use of Securian, its products or its website (for example, your Securian purchase history, and the content you read on our site).
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes. We may use your personal information to send you promotional information about third parties which we think you may find interesting.
You can ask us or third parties to stop sending you marketing messages by contacting us at any time by email to info@Securian.store (marked for the attention of the privacy manager named in this policy).
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 (if applicable), 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.
5. Disclosures of Your Personal Data
We may share your personal data with the parties set out below for the purposes set out in the table Purposes for which we will use your personal data above.
- Internal Third Parties as set out in the Glossary.
- External Third Parties as set out in the Glossary.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. International Transfers
We do not physically transfer your personal data outside the European Economic Area (EEA), but in some circumstances we may use secure remote connections to access this data from outside the EEA where this is required to carry out our services in the way we set out in this policy.
7. Data Security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other 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.
8. Data Retention
How long will you use my personal data for?
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.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.
By law we have to keep basic information about our customers (including Contact, Safety, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes and to deal with potential legal claims.
Where you are under the age of 18, because the law which limits the time you can bring a claim against us runs from the time you reach the age of 18, we may need to keep your Personal Data for up to 7 years after you reach the age of 18.
In some circumstances you can ask us to delete your data: see your legal rights below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
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 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 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 (up to 3 months in some cases) 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.
For the purposes of this policy:
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 safe and 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.
Internal third parties
Other companies in the Venturian Group Limited acting as joint controllers or processors and who are based the EEA and who manage the running of Group companies provide IT and system administration services and undertake leadership reporting.
External third parties
- Service providers acting as processors based in the United Kingdom who provide IT, payment gateway, stock and order/returns management services, logistics or distribution services or system administration services (including those providing payment management services for us, debt collection services or payroll services). For example this would include service providers to us like Shopify or PayPal as well as any third parties we engage or whom provide services to us to manage stock, fulfil orders, deliver packages, deal with returns, send postal mail, SMS text messages and email, maintain and update our databases of customer details (including the removal of repetitive or incorrect information), analyse data to help us develop, provide and improve our services, provide marketing assistance, process payments and refunds, carry out surveys, provide customer service and handle claims. These third parties have access to personal information needed to perform their functions, but may not use it for other purposes. We may use the information we receive from third parties to supplement, improve and add to our databases of customer details, and for purposes such as credit checking and fraud prevention.
- Any person or entity appointed by us to provide goods or services to you in connection with our products.
- Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
- Service providers or regulatory bodies providing fraud prevention services or credit/background checks (such as the police, government bodies and commercial enterprises such as Experian or similar).
- Any person or agency if we need to share that information to comply with the law or to enforce any agreement we may have with you or to protect the health and safety of any person.
- Any person who you have named as a person we can contact to discuss your account or who is otherwise your alternate contact.
- Any person who is your agent or representative, such as the holder of a power of attorney, a legal guardian, a person administering a will, a liquidator, administrator, trustee in bankruptcy or similar official.
- Credit referencing agents or providers (see Credit checking section above)
- Our insurers and insurance brokers if you take out insurance cover through us. If we pass data on to insurers, they may enter your data onto a register of claims which is shared with other insurers to prevent fraudulent claims
- Trade associations of which we are a member.
- Any person who we are negotiating with as a potential buyer of our business or property or if we are proposing to merge our business with another business.
- Credit Card associations if specifically required.
Your legal rights
You have the right to:
1. Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
2. Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
3. Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
4. Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
5. Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data’s accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
6. Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
7. Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
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