Customer Privacy Notice
This Customer Privacy Notice sets out what personal data we, Bangor Auctions, hold about you and how we collect and use it. It applies to new and existing customers (together referred to as Customers’ or ‘you’).
Looking after the personal information you share with us is very important, and we want you to be confident that your personal data is kept safely and securely and to understand how we use it to offer you a better and more personalised shopping experience.
We have published this notice to help you understand
how and why Bangor Auctions collect information from you;
who we share your information with, why and on what basis; and
what your rights are.
This Privacy Notice applies from 25 May 2018, when the General Data Protection Regulation comes into force. We may update this Privacy Notice at any time, if we make changes to this notice we will notify you by updating it on our website.
Who is the controller?
Bangor Auctions is the “controller” for the purposes of data protection law. This means that we are responsible for deciding how we hold and use personal data about you.
Our Data Protection Team will act as your first point of contact if you have any questions or concerns about data protection.
Should you need to contact us please write to:
Data Protection Team, Bangor Auctions, 1 Green Way, Conlig, County Down, UK, BT27 7SU or via email@example.com quoting Security and Privacy Enquiry.
What type of personal data do we hold about you?
Personal data means any information relating to a living individual who can be identified (directly or indirectly) in particular by reference to an identifier (e.g. name, email address, address). It can be factual (e.g. contact details or date of birth), an opinion about an individual’s actions or behaviour.
Data we may collect:
If you have an account with us: your name, gender, billing/delivery address, orders and receipts, email and telephone number. For your security, we’ll also keep an encrypted record of your login password.
Details of your interactions with us through contact centres, in store, online or by using one of our apps.
For example, we collect notes from our conversations with you, details of any complaints or comments you make, details of purchases you made, items viewed or added to your basket, gift list and wish list choices, voucher redemptions, brands you show interest in, web pages you visit and how and when you contact us.
Details of your shopping preferences.
Details of your visits to our websites or apps, and which site you came from to ours.
Personal details which help us to recommend items of interest.
For example, you might tell us your clothing size, which we’ll use to guide our suggested items.
We’ll only ask for and use your personal data collected for recommending items of interest and to tailor your shopping experience with us. Of course, it’s always your choice whether you share such details with us.
Payment card information.
Your comments and product reviews.
Your image may be recorded on CCTV when you visit our premises or car park.
Your car number plate may be recorded at our car park to manage parking restrictions.
To deliver the best possible web experience, we collect technical information about your internet connection and browser as well as the country and telephone code where your computer is located, the web pages viewed during your visit, the advertisements you clicked on, and any search terms you entered.
Your social media username, if you interact with us through those channels, to help us respond to your comments, questions or feedback.
Why do we hold your personal data and on what legal grounds?
The law on data protection sets out a number of different reasons for which a company may collect and process your personal data, including:
In specific situations, we can collect and process your data with your consent.
For example, when you tick a box to receive email newsletters.
When collecting your personal data, we’ll always make clear to you which data is necessary in connection with a particular service.
In certain circumstances, we need your personal data to comply with our contractual obligations.
For example, if you order an item from us for home delivery, we’ll collect your address details to deliver your purchase, and pass them to our courier.
If the law requires us to, we may need to collect and process your data.
For example, we can pass on details of people involved in fraud or other criminal activity affecting the Partnership to law enforcement.
In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests.
For example, we will use your purchase history to send you or make available personalised offers.
We also combine the shopping history of many customers to identify trends and ensure we can keep up with demand, or develop new products/services.
We will also use your address details to send you direct marketing information by post, telling you about products and services that we think might interest you.
How/when do we collect your personal data?
You provide us with most of the personal data about you that we hold and use. Other personal data about you we hold and use is generated by you in the course of interacting with Bangor Auctions. For example, during email correspondence or when visiting our websites.
Some of the personal data about you that we hold and use may come from external sources. For example: if you visit our website from a search engine, we may hold the search terms that you used.
When you visit any of our websites, and use your account to buy products and services, or redeem vouchers from the Bangor Auctions on the phone, in a shop or online.
When you make an online purchase and check out as a guest (in which case we just collect transaction-based data).
When you create an account with us.
When you purchase a product or service in store or by phone but don’t have (or don’t use) an account.
When you engage with us on social media.
When you download or install one of our apps.
When you contact us by any means with queries, complaints etc.
When you ask one of our Partners to email you information about a product or service.
When you enter prize draws or competitions.
When you book any kind of appointment with us or book to attend an event, for example a season showcase.
When you choose to complete any surveys we send you.
When you comment on or review our products and services. Any individual may access personal data related to them, including opinions.
When you fill in any forms.
When you give us information at Trade Shows or to our 3rd Party Agents/Sales Representatives.
When you’ve given a third party permission to share with us the information they hold about you.
When you use our car park which usually has CCTV in operation for the security of both customers and Partners. These systems may record your image during your visit.
If you give us someone else’s personal data
Sometimes, you might provide us with another person’s personal data – e.g. details of your delivery contact. In such cases, we require you to inform the individual what personal data of theirs you are giving to us. You must also give them our contact details and let them know that they should contact us if they have any queries about how we will use their personal data.
Who do we share your personal data with?
We will only share your personal data with trusted third parties where we have an appropriate legal ground under data protection law which permits us to do so. Commonly, this could include situations where we are legally obliged to provide the information (e.g. to authorities for fraud management), to comply with our contractual duties (e.g delivery couriers, for payment processing (third parties such as Stripe, Paypal, Banks), to handle complaints, where it is necessary in our legitimate interest (e.g. to an IT service provider for maintenance of our IT systems) or to help us personalise our offers to you and so on.
This is the policy we apply to those organisations to keep your data safe and protect your privacy:
We provide only the information they need to perform their specific services.
They may only use your data for the exact purposes we specify in our contract with them.
We work closely with them to ensure that your privacy is respected and protected at all times.
If we stop using their services, any of your data held by them will either be deleted or rendered anonymous.
Further details of who we share your personal data with, and our purposes and legal grounds for doing so, are set out in the Appendix to this Privacy Notice.
Consequences of not providing personal data
We only ask you to provide personal data when we have a good reason and there may therefore be consequences if you do not provide particular information to us.
If you choose not to provide us with personal data requested, we will tell you about the particular implications of any such decision at the relevant time.
Protecting your data outside the EEA
For example, this might be required in order to fulfil your order, process your payment details or provide support services.
If we do this, we have procedures in place to ensure your data receives the same protection as if it were being processed inside the EEA. For example, our contracts with third parties stipulate the standards they must follow at all times. If you wish for more information about these contracts please contact our Data Protection Team.
Any transfer of your personal data will follow applicable laws and we will treat the information under the guiding principles of this Privacy Notice.
How long will we keep your personal data?
We will not keep your personal data for longer than we need it for our legitimate purposes.
We take into account the following criteria when determining the appropriate retention period for Customers’ personal data:
the amount, nature, and sensitivity of the personal data
the risk of harm from unauthorised use or disclosure
the purposes for which we process your personal data and how long we need the particular data to achieve these purposes
how long the personal data is likely to remain accurate and up-to-date
for how long the personal data might be relevant to possible future legal claims
any applicable legal, accounting, reporting or regulatory requirements that specify how long certain records must be kept
Given the variety of Customers’ personal data that we use and the varying circumstances in which we use it, it is difficult to specify ahead of time precisely how long we will keep particular items of personal data. Where possible, the Tables in the Appendix to this Privacy Notice identify retention periods applicable to your personal data, which have been determined on the basis of the above criteria and which represent the longest period for which we will ordinarily keep it. We may often keep particular items of your personal data for less time. However, there may also be circumstances in which it is appropriate for us to keep particular items of your personal data for a longer period than that set out in the Tables. In particular, we will always keep your personal data for so long as we are required to do so under legal, accounting, reporting or regulatory requirements.
In addition, for some types of personal data, it is more appropriate to decide retention periods on a case by case basis (also using the criteria described above), and this is indicated in the Tables where applicable.
We will base these decisions on relevant circumstances, taking into account the criteria listed above.
You have a number of legal rights relating to your personal data, which are outlined here:
- The right to make a subject access request. This enables you to receive certain information about how we use your personal data, as well as to receive a copy of it and to check that we are lawfully processing it.
- The right to request that we correct incomplete or inaccurate personal data that we hold about you.
- The right to request that we delete or remove personal data that we hold about you 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 exercised your right to object to processing (see below).
- The right to object to our processing your personal data where we are relying on our legitimate interest (or those of a third party), where we cannot show a compelling reason to continue the processing
- The right to request that we restrict our processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
- The right to request that we transfer your personal data to you or to another party, in a structured format. This right applies in respect of data that you have provided where our legal ground for using the data is that it is necessary for the performance of a contract or that you have consented to us using it (this is known as the right to “data portability”).
If you would like to exercise any of the above rights, please contact the Data Protection Team (firstname.lastname@example.org) in writing. Note that these rights are not absolute and in some circumstances we may be entitled to refuse some or all of your request.
If you have any questions or concerns about how your personal data is being used by us, you can contact the Data Protection Team (email@example.com).
Note too that 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. Details of how to contact the ICO can be found on their website: https://ico.org.uk
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