Privacy Policy

18th February 2019

Introduction

Welcome to STF Solutions Limited’s privacy notice.

At STF we respect your privacy and are 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) and tell you about your privacy rights and how the law protects
you.

Please use the Glossary to understand the meaning of some of the terms used in this privacy
notice.

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
10. GLOSSARY

1. Important information and who we are

Purpose of this privacy notice

This privacy notice aims to give you information on how STF collects and processes your personal
data through your use of this website, including any data you may provide through this website
when you sign up to our newsletter, purchase a product or service or take part in a competition.

This website is 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

STF Solutions Limited is the controller and responsible for your personal data (collectively referred
to as “STF”, “we”, “us” or “our” in this privacy notice).

If you have any questions about this privacy policy, including any requests to exercise your legal
rights, please contact us using the details set out below.

Contact details

Our full details are:

Full name of legal entity: STF Solutions Limited (Company Registration Number: 06448676)

Point of Contact: John McGinnes

Email address: enquiries@stfsolutions.co.uk

Postal address: Unit 223 Lomeshaye Business Village, Turner Road, Nelson, Lancashire, England,
BB9 7DR

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 kindly
contact us in the first instance.

Changes to the privacy notice and your duty to inform us of changes

This version was last updated on 18th February 2019.

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.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those
links or enabling those connections may allow third parties to collect or share data about you. We
do not control these third-party websites and are not responsible for their privacy statements. When
you leave our website, we encourage you to read the privacy notice of every website you visit.

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, last name and title.
  • 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 login data, browser type andversion, 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 purchases or orders made by you, your preferences and feedback.
  • 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;
      • 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 server logs and other similar technologies.
  • Third parties or publicly available sources. We may receive personal data about you from
    various third parties and public sources as set out below:
  • Contact, Financial and Transaction Data from providers of technical, payment and delivery
    services based inside the EU.
  • Identity and Contact Data from publicly available 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. Please refer to the Glossary 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 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.

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 register you as a new customer (a) Identity

(b) Contact

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

(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 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

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

(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)

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

(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 (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

Necessary for our legitimate interests (to develop our products/services and grow our business)

 

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around
marketing and advertising. Please contact us if you would like to discuss your personal data use.

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 or if you provided us with your details when you entered a
competition or registered for a promotion and, in each case, you have not opted out of receiving that
marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any company
outside the STF group of companies for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following
the opt-out links on any marketing message sent to you 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.

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 have to share your personal data with the parties set out below for the purposes set out in
the table in paragraph 4 above.

  • External Third Parties as set out in the Glossary.
  • 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 policy.

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 transfer your personal data outside the European Economic Area (EEA).

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 necessary to fulfil the purposes we collected it
for, including for the purposes of satisfying any legal, accounting, or reporting 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.

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal
data. Please refer to the Glossary 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 may 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 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.

10. Glossary

LAWFUL BASIS

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 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 or regulatory obligation means processing your personal data where it is
necessary for compliance with a legal or regulatory obligation that we are subject to.

THIRD PARTIES

External Third Parties

  • Service providers acting as processors based in the UK who provide IT and system
    administration services.
  • Professional advisers acting as processors or joint controllers including lawyers, bankers,
    auditors and insurers based in the UK 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.

YOUR LEGAL RIGHTS

You have the right to:

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.

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.

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.

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.

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: (a) if you want us to establish the
data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c)
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; or (d) you have objected to our use of your data but we need to
verify whether we have overriding legitimate grounds to use it.

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.

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.