Introduction
Welcome to the Peel Group’s privacy notice.
Peel respects your privacy and is committed to
protecting your personal data. This privacy notice will inform you as to how we
look after your personal data when you visit our website (regardless of where
you visit it from) or after we have received it in any email
correspondence. It will tell you about your privacy rights and how the
law protects you.
The statement below is the
privacy notice for the Peel Group. Separate notices for businesses within the
group can be found on the relevant websites.
1. Important information and who
we are
Purpose of this privacy notice
This privacy
notice aims to give you information on how Peel collects and processes your
personal data through your use of our website,
or email.
Our websites are not intended for children and
we do not knowingly collect data relating to children.
It is
important that you read this privacy notice together with any other privacy
notice or fair processing notice we may provide on specific occasions when we
are collecting or processing personal data about you so that you are fully
aware of how and why we are using your data. This privacy notice supplements
the other notices and is not intended to override them.
Controller
Peel Group is
made up of different legal entities. This privacy notice is issued on behalf of
the Peel Group so when we mention "Peel", "we",
"us" or "our" in this privacy notice, we are referring to
the relevant company in the Peel Group responsible for processing your data.
We have
appointed a data privacy manager who is responsible for overseeing questions in
relation to this privacy notice. If you have any questions about this privacy
notice, including any requests to exercise your legal rights, please contact
the data privacy manager using the details set out below.
Contact
details
Peel Group
Group Company
Secretary
dataprotection@peel.co.uk
Peel Dome,
intu Trafford Centre,
TRAFFORDCITY, Manchester, M17 8PL
0161 629 8200
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.
Changes to the
privacy notice and your duty to inform us of changes
This version
was last updated in March 2018.
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 data 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 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.
- 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 email address, your
login data, browser type and version, time zone setting and location, browser
plug-in types and versions, operating system and platform and other technology
on the devices you use to access this website.
- Profile Data includes your
username and password, purchases or orders made by you, your interests,
preferences, feedback and survey responses
- 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.
We also collect, use and share Aggregated Data such as
statistical or demographic data for any purpose. Aggregated Data may be derived
from your personal data but is not considered personal data in law as this data
does not directly or indirectly
reveal your identity. For example, we may aggregate your Usage Data to
calculate the percentage of users accessing a specific website feature.
However, if we combine or connect Aggregated Data with your personal data so
that it can directly or indirectly identify you, we treat the combined data as
personal data which will be used in accordance with this privacy notice.
We do not collect any Special Categories of Personal Data about
you (this 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).
Nor do we collect any information about criminal convictions and offences.
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 goods or services). In this case, we
may have to cancel a product or service 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, Contact and Financial Data by
filling in forms or by corresponding with us by post, phone, email or
otherwise. This includes personal data you provide when you:
- apply for our products or services;
- interact with us
via electronic systems (such as email)
- create an account on our website;
- subscribe to our service or publications;
- request marketing to be sent to you;
- enter a competition, promotion or survey; or
- give us some feedback. - Automated technologies or interactions.
As you interact with our website, we may automatically collect Technical Data
about your equipment, browsing actions and patterns. We collect this personal
data by using cookies, [server logs] and other similar technologies. We may
also receive Technical Data about you if you visit other websites employing our
cookies. Please see our cookie policy for further details.
- Third parties or publicly available sources.
We may 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
the EU;
(b)
advertising networks based inside or outside the
EU; and
(c)
search information providers based inside or outside
the EU.
- Contact, Financial and Transaction Data from
providers of technical, payment and delivery services based inside or outside
the EU.
- Identity and Contact Data from data brokers,
aggregators or other referrers based
inside or outside the EU.
- Identity and Contact Data from publicly
availably sources such as Companies House and the Electoral Register based
inside the EU.
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 or
regulatory obligation.
Generally we do not rely on consent as a legal basis for
processing your personal data other than in relation to 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 at the address above.
5. 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 below.
To register you as a new customer
Type of data:
(a) Identity
(b) Contact
Lawful basis for processing including basis of
legitimate interest:
Performance of a contract with you
To process and deliver your order including:
(a) Manage payments, fees and charges (b) Collect and recover money owed to us
Type of
data
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications
Lawful basis for processing including basis of
legitimate interest
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover
debts due to us)
To manage our relationship with you which will
include:
(a) Notifying you about changes to our terms or
privacy policy (b) Asking you to leave a review or take a survey
Type of data
a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications
Lawful basis for processing including basis of
legitimate interest
(a) Performance
of a contract with you
(b) Necessary to
comply with a legal obligation
(c) Necessary for
our legitimate interests (to keep our records updated and to study how
customers use our products/services)
(d) Necessary for our legitimate interests (to keep our records updated
and to manage our relationships with our suppliers and business contacts)
To enable you to partake in a prize draw, competition
or complete a survey
Type of data
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
Lawful basis for processing including basis of
legitimate interest
(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)
Type of data
(a) Identity
(b) Contact
(c) Technical
Lawful basis for processing including basis of
legitimate interest
(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 and
advertisements to you and measure or understand the effectiveness of the
advertising we serve to you
Type of data
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical
Lawful basis for processing including basis of
legitimate interest
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 use data analytics to improve our website,
products/services, marketing, customer relationships and experiences
Type of data
(a) Technical
(b) Usage
Lawful basis for processing including basis of
legitimate interest
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
Type of data
(a) Identity
(b) Contact
(c) Technical
(d)
Usage
(e) Profile
Lawful basis for processing including basis of
legitimate interest
Necessary for our legitimate interests (to
develop our products/services and grow our business)
6. Marketing
We strive to provide you with choices regarding certain personal
data uses, particularly around marketing and advertising
7. 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 goods or services from us and you have not
already opted out of marketing. This will be restricted to similar products or
services and is necessary for our legitimate interests (to develop our products
and services and grow our business).
If you
provided us with your details when you entered a competition, used our free wi-fi
services or registered for a promotion and in the process, have requested
marketing information, then you will continue to receive marketing communications
until you choose to opt-out.
8. Third-party marketing
We will get your express opt-in consent before we share your personal
data with any company outside the Peel group of companies for marketing purposes and we will explicitly tell you who these
companies are at the time.
9. Opting out
You can ask us or third parties to stop sending you marketing
messages at any time by logging into the website and checking or unchecking
relevant boxes to adjust your marketing preferences or by contacting
us at any time.
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, product/service experience or other
transactions.
10. Cookies
You can set your browser to refuse all or some browser cookies, or
to alert you when websites set or access cookies. If you disable or refuse
cookies, please note that some parts of this website may become inaccessible or
not function properly.
11. 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.
12. Disclosures of your
personal data
We may have to share your personal data with the parties set out
below for the purposes set out in the table in paragraph 4 above.
·
Internal Third Parties
·
External Third Parties
·
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.
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.
13. International transfers
There may be occasions where
we need to process your data internationally, if we do this regularly it will
be noted in this privacy statement. If we are to do this more
occasionally then this may be:
·
to third parties (such as advisers or
other Suppliers to our business);
·
to overseas clients
·
to clients within your
country who may, in turn, transfer your data internationally;
·
to a cloud-based storage provider; and
·
to other third parties, as referred
to here.
We want to make sure that your data are stored and
transferred in a secure way. We will therefore only transfer data outside of
the European Economic Area or EEA where it is compliant with data protection
legislation and the means of transfer provides adequate safeguards in relation
to your data, for example:
·
by way of data transfer agreement,
incorporating the current standard contractual clauses adopted by the European
Commission for the transfer of personal data by data controllers in the EEA to
data controllers and processors in jurisdictions without adequate data
protection laws; or
·
by signing up to the EU-U.S. Privacy
Shield Framework for the transfer of personal data from entities in the EU to
entities in the United States of America or any equivalent agreement in respect
of other jurisdictions; or
·
transferring your data to a country
where there has been a finding of adequacy by the European Commission in
respect of that country's levels of data protection via its legislation; or
·
where it is necessary for the
conclusion or performance of a contract between ourselves and a third party and
the transfer is in your interests for the purposes of that contract (for
example, if we need to transfer data outside the EEA in order to meet our
obligations under that contract if you are a Client of ours); or
·
where you have consented to the data
transfer.
14. 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.
15. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to
fulfil the purposes we collected it for, including for the purposes of
satisfying any legal, accounting, or reporting requirements.
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
requirements.
By law we have to keep basic information about our customers
(including Contact, Identity, Financial and Transaction Data) for six years
after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see Request
erasure below for further information.
In some circumstances we may 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.
16. Your legal rights
Under certain circumstances, you have rights under data protection
laws in relation to your personal data:
·
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.
17. 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
may refuse to comply with your request in these circumstances.
18. 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.
19. Time limit to respond
We try to respond to all legitimate requests within one month.
Occasionally it may take us longer than a month 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.