This is a website operated by Sandhills East Limited, Germany Branch (“We”). We are a private limited liability company registered with the commercial register of Hamburg with number HRB 150302 and have our registered address at Hamburg Millerntor, 6th Floor, Millerntorplatz 1, 20359 Hamburg, Germany.
WHY DO WE HAVE THIS POLICY?
We will only collect, use and otherwise handle your personal information that we will use for the purposes set out in this policy, as long as, in each case, we have a legitimate interest in doing so and such interest is in line with applicable law and your legal rights and freedoms, in particular:
- where you have agreed to this for specified, express and legitimate purposes; or
- where this is necessary for legal obligations which apply to us.
1. What INFORMATION do we collect and when?
We only collect information that we will use for the purposes set out in this policy, In particular, we collect:Information you submit to us You can submit information to us in the following ways:
- Through forms, for example signing up to an offer, news or a competition;
- By sending us emails and text messages (SMS or MMS)
- By adding posts, reviews and other comments to the Websites, any Sandhills' mobile phone applications, or other community forums;
- By interacting with us on social media platforms (such as Facebook or Twitter);
- By speaking to us over the telephone; or
- By registering accounts on the Websites or any Sandhills' mobile phone applications, including setting up passwords and preferred user names, contact details, account details, your preferences and interests.
- (Please note: If you submit details to us of any other person (e.g. a friend), please make sure you have their permission before doing so.)
- Information we collect about you
- Full details of the purchases you make on the Websites or on the telephone, including the time and date of purchase, the products you purchase from us, any relevant delivery address and details of any relevant payment card.
- Information on what you search for, view, click on and access in and through the Websites, our marketing emails and text messages (SMS or MMS). We may collect the time and geographic location of your device when you do so. This information may also include where you came to the Websites from, and where you went when you left it. We also track how often you visit and use the Websites. We do this through the use of email and website cookies (see our Cookies Policy for more information).
- Technical information about the devices you use to access the Websites. We collect each device’s unique identifying code (MAC address), relevant IP address, operating system and version, web browser and version, and geographic location
- Your social media content (where this is in the public domain) and any messages you send us via social media. This information can include posts, comments, pictures and video (see paragraph 4 for more information)
- Information from banking, credit card and credit reference agencies about your financial status and the status of any payment card presented to us (for example, if it has been reported stolen) to check we are likely to be paid for any transaction and to reduce the risk of fraud.
- Profile information and insight from companies who already have information on you, such as credit reference agencies (customer insight companies). They give us their views on what your household may look like, your status, likely preferences and behaviours.
2. HOW DO WE USE YOUR INFORMATION?
We use the information we collect for the following purposes:
- To provide you with the Websites, which requires a certain amount of technical information to be collected in order to work properly
- To power security measures and related services relating to your access to the Websites for example to enable us to recognise your username and password and reset these if you forget them.
- To enable you to order products from us on the Websites, which again requires a certain amount of information to be collected, for example your payment card details so we can take payment and the products you buy so we can provide you with an invoice and receipt.
- To enable us to run competitions and offers for which you have signed up, about which we need to be able to communicate with you.
- To gather feedback from you about the Websites, our products, other services and activities from time to time. We may invite you to provide this feedback on occasion, for example by emailing you to ask if you would like to review a product you have bought. We may use independent research and feedback providers to do so on our behalf.
- To contact you from time to time about things you have told us you want to hear about, for example our products, news, offers, new competitions and sponsored events.
- To respond to any questions, suggestions, issues or complaints you have raised with us.
- To respond to any social media posts or other public comments you make where these are made to or about us, the Websites, our products, services or other activities.
- To perform any contract we have entered into with you but also to enforce a contract against you if you do not honour it, including seeking to collect any debts that you may owe us.
- To gather statistics about how you and other people use the Websites, and what you think of our adverts, offers, news, product information, competitions, sponsored events, social media and other digital content. We then analyse these statistics to understand if these things meet most people's needs, or if they should be improved, and if so, what design or other changes (for example, around the nature and timing of communications) would be most beneficial for our customers and our business.
- To check that you have or are likely to have the means to pay us for any products you have ordered from us on the Websites.
- To monitor use of the Websites to see if it is being abused or threatened for example by people posting inappropriate comments in review areas or by potential hackers looking to undermine their security.
- To protect you and our business against any other criminal behaviour , including identity theft and fraud.
- To understand you better and, in particular, your habits, your location from time to time and your personal circumstances.
- To maintain administrative and legal records about our business to enable us to understand what we have sold, how, when, where and at what price and account to HM Revenue & Customs or other tax authorities for the related taxes that we have to pay.
- To enable us and our third party service providers to plan and manage our day-to-day business and related services as effectively as possible , for example in predicting likely sales volumes of each product, so we can try and make sure we have enough stock to meet likely demand.
- To enable us to understand what our customer and user base looks like across our business. We do this by combining your information with information about our other customers and users of the Website, so we can spot trends and common factors.
- To enable us to conduct focused market research based on trends that we identify, which we can then use to further improve our products and services for all our customers.
- In the process of anonymising your information so that you are no longer identifiable to us.
- To test new systems and processes as we roll them out to make sure they work and will meet the high expectations we set for ourselves.
- To assist us in the development of new products and services over time , for example to gauge whether a new product is likely to appeal to a large proportion of our customer base.
- To analyse whether the money we spend on advertising on trade publications and trade websites, online and in search engines represents good value.
- To combine information that you have provided to us with other information that we already hold about you and which we have collected for a compatible purpose where permissible under applicable laws.
3. WHO DO WE SHARE YOUR INFORMATION WITH?
- Sandhills Group Companies and Brands and Services We do so because we hope to have a relationship with you across all these different brands and businesses, if not now, then in the future, and we want to be able to provide you with the same value and high quality of experience wherever you choose to interact with us.
- Other people and businesses who help us provide the Websites, and related services to you , for example, information technology companies who design and host the Websites and payment services companies who enable you to use payment cards with us.
- Advertiser and advertising networks which require the data to select and serve relevant adverts to you and others. We may use the information we have collected from you to enable us to comply with our advertisers' wishes by displaying their advert to that target audience.
- Analytics and search engine providers who assist us in the improvement and optimisation of the Websites.
- Our insurers and insurance brokers where required in order for us to be able to obtain insurance against risks we face in running our business. They may retain this information for the purpose of ongoing risk assessment and insurance broking and underwriting services.
- Banks and finance companies where we have allowed them to offer you the possibility of purchasing our products on credit or through a loan arranged online. They may retain this information, for example if you take any service they offer, for the purpose of providing you with that service.
- Credit reference agencies who provide anti-fraud and credit score information to us, central and local government departments, for example the Driver Vehicle Licensing Agency (DVLA) and local authorities who run the UK electoral rolls, banks and finance companies who also provide anti-fraud services and customer insight companies (as set out above), in each case as necessary in order to benefit from their services. Where we do so for anti-fraud purposes, the recipient organisation may hold your information on file for the purpose of their fraud prevention services in future.
- Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you.
- The prospective buyer of any part of our business or assets that we may sell.
- Our professional advisers for example our lawyers, accountants and technology consultants when they need it to provide advice to us.
- The police, local authorities, HM Revenue & Customs (HMRC), the courts and any other central or local government bodies where they request it and we may lawfully disclose it, for example for the prevention and detection of crime.
- Other people who make a subject access request to us , where we are allowed to do so by law (see Managing Your Information below for what we mean by a subject access request).request).
We may also share the information we collect where we are legally obliged to do so, where necessary for the purposes of preventing and detecting fraud, other criminal offences and/or to ensure network and information security, for example, to comply with a court order.
4. SOCIAL MEDIA, BLOGS, REVIEWS, AND SIMILAR SERVICES
Our Website offers the possibility to share content on the following social media platforms:
- [email protected]
We have integrated opportunities for interaction with the above mentioned social media platforms into our websites by using plug-ins. If you are also logged into a relating platform at that time, your visit to our site is allocated to your account with the relating platform. By interacting with the plug-ins (for example, clicking the “like” button or adding commentary) your browser also transfers that information directly to the relevant social media platform, where it is transmitted to and stored on servers in the United States (as for Facebook, Twitter ..). If you want to prevent this you have to log out before you access our websites.
Any posts or comments you make to us on social media will be shared under the terms of the relevant social media platform on which they are made and could be made public by that platform. These platforms are controlled by other people, not us, so we are not responsible for this sharing. You should review the terms and conditions and privacy policies of the social media platforms you use to ensure you understand how they will use your information, what information relating to you they will place in the public domain and how you can stop them from doing so if you are unhappy about it.
Any blog, review or other posts or comments you make about us, our products and services on any of our blog, review or user community services will be shared with all other members of that service and the public at large.
You should ensure that any comments you make on these services, and on social media in general, are fit to be read by the public, and in particular are not offensive or defamatory. You are responsible for ensuring that any comments you make comply with any relevant policy on acceptable use of those services.
5. SECURITY OF YOUR INFORMATION
Information provided through the Websites is stored on our secure servers or those of any third party we engage to provide our IT platform, and is encrypted using standard technology. However, as the transmission of information via the Internet is not completely secure, we cannot guarantee the security of your information transmitted to our Websites.
Where we have given you, or you have chosen, a password which enables you to access your account or certain parts of the Websites, you are responsible for keeping the password confidential and must not share it with anyone. You are responsible for any actions carried out using your password except where there has been fraud.
6. INTERNATIONAL TRANSFER OF YOUR INFORMATION
Although we are based in the European Economic Area, we occasionally need to use international suppliers to help ensure you receive the very best products and services from us as well as coordinate with our international Sandhills Group Companies.
To allow us to run our business on this basis, the information we collect may be transferred to, stored and used at premises in countries outside the European Economic Area, whose data protection laws may not be equivalent to those within the European Economic Area. If we do so, we will put in place appropriate measures for the protection of your personal information in such countries.
However, we will only transfer your personal information outside of the European Economic Area:
- where the transfer is to a place that is regarded by the European Commission as providing adequate protection for your personal information; or
- where we have put in place appropriate safeguards, for example by using a contract for the transfer which contains specific data protection provisions that have been adopted by the European Commission or a relevant data protection authority; or
- where you have consented to this, or there is another legal basis on which we are entitled to make the transfer
7. HOW LONG DO WE KEEP YOUR INFORMATION FOR?
In accordance with our legal data protection and privacy obligations, we will only retain your information for as long as we need it to achieve the purpose(s) for which we obtained it in the first place. We will then either securely delete it or anonymize it so that it cannot be linked back to you (see paragraph 2 for full details of those purposes). However, on occasion we may be obliged to store some data for a longer time, for example where a longer time period of storage is required by applicable laws. In this case, we will ensure that your personal data will continue to be treated in accordance with our legal data protection and privacy obligations.
8. MANAGING YOUR INFORMATION
You can contact us at any time using the details provided below if you want to know which information about you we have stored or to discuss your information.
It is very important to us that all the information we hold about you remains accurate and up to date to reduce the risk of a misunderstanding.
We need your help in doing so. If you have an online account with us, please ensure that the information (for example, contact information) you provide to us through that account remains accurate and up to date. Please review and update it regularly.
You have a number of rights which we respect and aim to uphold in everything we do. These rights include:
- Correcting inaccurate information If you have reason to believe any of the information we collect on your behalf may be inaccurate, and you cannot correct such inaccuracy yourself through your registered account with us, please contact us (see below for how to do this).
- Stopping our marketing We provide the means for you to stop all email and text (SMS or MMS) communications you receive from us – please see the "unsubscribe" link and "STOP" details we include in each email and text respectively. You can also contact us at any time using the details below and let us know what you would like us to change.
- Reviewing our use of automatic computer processing You can ask us to have one of our staff review a decision about you which has been taken automatically by computer. One common example is if we decline an order you place with us online for anti-fraud or credit check reasons. Please note that these decisions can come about due to policy decisions taken by banks, card and payment processing companies and credit reference agencies who independently hold information about you and to resolve them, you may have to speak to them directly.
Depending on your country of residence or domicile, you may have other legal rights over the information we collect from you and your devices. We will honour all such legal rights. We reserve the right to charge you a small administration fee to meet our costs in honouring your legal rights, where permitted by the relevant law.
We reserve the right not to comply with any requests we receive where we may lawfully do so, for example if we reasonably believe a request to be malicious, technically very onerous, to involve disproportionate effort or harmful to the rights of others.
If you have any questions or complaints about our use of your information, please Contact Us. We will do our very best to answer any question and resolve any complaint to your satisfaction. If, for whatever reason, you feel we do not meet the high standards we expect of ourselves, you have a right to complain to the authority responsible for data protection in the country that you are based. Contact details are available online, or alternatively you may ask us for assistance.
9. THIRD PARTY LINKS
The Websites may contain links to the websites of third parties. If you follow a link to any third party website, please note that these websites will have their own privacy policies and we do not accept any responsibility or liability in respect of the same.
10. CONTACT US - UPDATING YOUR PREFERENCES AND DETAILS
- no longer want to participate in our services; or
please let us know by Contacting Us.
Last updated May 23 2018
Copyright 2019 © Sandhills East Limited, Germany Branch