Collection of your personal information
Information you give us.
This is information about you that you give us by filling in forms on our sites (the Website) or by corresponding with us by phone, e-mail, post or otherwise. It includes information you provide when you register to use our site, subscribe to our service, search for a product, place an order on our site, completing an enquiry form on our site enter a competition, promotion or survey and when you report a problem with our site. The information you give us may include your name, address, e-mail address and phone number, financial and credit card information, personal description and photograph.
Information we collect about you. With regard to each of your visits to our site we may collect the following information about you:
- your name, age/date of birth and gender;
- your contact details: postal address including billing and delivery addresses, telephone numbers (including mobile numbers) and e-mail address;
- purchases and orders made by you;
- your on-line browsing activities on our Website;
- your password(s);
- when you make a purchase or place an order with us, your payment card details;
- your communication and marketing preferences;
- your interests, preferences, feedback and survey responses;
- your location;
- your correspondence and communications with us; and
- other publicly available personal data, including any which you have shared via a public platform (such as a Twitter feed or public Facebook page).
Our Website is not intended for children and we do not knowingly collect data relating to children.
This list is not exhaustive and, in specific instances, we may need to collect additional data for the purposes set out in this Policy. Some of the above personal data is collected directly, for example when you set up an on-line account on our Website, or send an email to our customer services team. Other personal data is collected indirectly, for example your browsing or shopping activity. We may also collect personal data from third parties who have your consent to pass your details to us, or from publicly available sources.
Information we receive from other sources. This is information we receive about you if you use any of the other Websites we operate or the other services we provide. In this case we will have informed you when we collected that data if we intend to share those data internally and combine it with data collected on this site. We will also have told you for what purpose we will share and combine your data. We are working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies). We will notify you when we receive information about you from them and the purposes for which we intend to use that information.
Sharing of your personal information
We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
We may give information we hold about you to third parties as part of the process of selling one or more of our businesses. We may disclose your personal information to third parties in the event that (i) we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets, (ii) if we or substantially all of our assets (or that of any Group company) are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
We may share your information with selected third parties including (i) business partners, distributors, suppliers and sub-contractors for the performance of any contract we enter into with them or you, (ii) advertisers and advertising networks that require the data to select and serve relevant adverts to you and others (iii) analytics and search engine providers that assist us in the improvement and optimisation of our website.
Uses made of the information
We use information held about you in the following ways:
Information you give to us.
We will use this information for the following reasons:
· to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
· to provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about;
· to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you. If you are an existing customer, we may contact you by electronic means (e-mail or SMS), phone or by post with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you. If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this. If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please tick the relevant box situated on the form on which we collect your data (the order form or registration form);
· to notify you about changes to our service;
· to ensure that content from our site is presented in the most effective manner for you and for your computer.
Information we collect about you.
We will use this information for the following reason:
· to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
· to manage any registered account(s) that you hold with us;
· to verify your identity;
· for crime and fraud prevention, detection and related purposes;
· to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
· to allow you to participate in interactive features of our service, when you choose to do so;
· as part of our efforts to keep our site safe and secure;
· to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
· to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.
Information we receive from other sources. We will combine this information with information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).
Disclosure of your information
You acknowledge that we have the right to share your personal information with:
· Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
· Selected third parties including:
· business partners, suppliers and sub-contractors for the performance of any contract we enter into with you;
· advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers, but we will provide them with aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in SW1). We may make use of the personal data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience;
· analytics and search engine providers that assist us in the improvement and optimisation of our site;
· credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you.
· Solicitors or debt collection agents in the event of a breach of contract or other such legal proceedings.
We will disclose your personal information to third parties:
· In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
· If any Group company or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
Data Storage and how we protect your Data
All information you provide to us is stored on our secure servers or within secure filing systems. Any payment transactions will be encrypted. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Legal basis for us processing customer personal data
We collect and use customers’ personal data because it is necessary for the pursuit of our legitimate interests (as set out below), the purposes of complying with our duties and exercising our rights under a contract for the sale of goods to a customer or complying with our legal obligations.
We may contact you in relation to any similar products or services we have previously supplied. Otherwise, we would rely on consent as a legal basis for processing in relation to sending direct marketing communications to customers via email or text message. Customers have the right to withdraw consent at any time. Where consent is the only legal basis for processing, we will cease to process data after consent is withdrawn.
Our normal legal bases for processing customer data, is that it will be necessary for (i) our legitimate interests (ii) performance of a contract, (iii) to take steps at the request of the data subject prior to entering into a contract, and (iv) compliance with our legal obligations and the administration of justice.
Examples of why we will process customer data are for:
- selling and supplying goods and services to our customers;
- protecting customers, employees and other individuals and maintaining their safety, health and welfare;
- promoting, marketing and advertising our products and services;
- sending promotional communications which are relevant and tailored to individual customers;
- understanding our customers’ behaviour, activities, preferences, and needs;
- improving existing products and services and developing new products and services;
- complying with our legal and regulatory obligations;
- preventing, investigating and detecting crime, fraud or anti-social behaviour and prosecuting offenders, including working with law enforcement agencies;
- handling customer contacts, queries, complaints or disputes;
- managing insurance claims by customers;
- protecting us, our employees and customers, by taking appropriate legal action against third parties who have committed criminal acts or are in breach of legal obligations to us;
- effectively handling any legal claims or regulatory enforcement actions taken against us; and
- fulfilling our duties to our customers, colleagues, shareholders and other stakeholders.
You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us using the contact details on our Contact Us page.
You have the right to ask what personal data that we hold about you at any time, subject to a fee specified by law. In addition you have the right to ask us to update and correct any out-of date or incorrect personal data that we hold about you free of charge.
If you wish to exercise any of the above rights, please contact us using the contact details set out on our Contact Us page.
You have the right to request the deletion of data where we would otherwise require consent to use it.
Access to information
You have the right to request a copy of the personal information that we hold about you and to have any inaccuracies corrected. We will ask for confirmation of identity before we disclose any personal information. Please address requests to the Data Protection Officer, GAP Convenience Distribution Limited, Lancashire Way, Preston, PR2 5PB.