Back Four Ltd is committed to protecting the privacy and security of your personal data. This Privacy Notice describes how we collect, use and look after your personal data when you visit our website (regardless of where you visit it from), including when you purchase our services or register as a user of our portal. It also tells you about your rights and how the law protects you.
1. Important information
Our website and portal are not intended for children and we do not knowingly collect data relating to children.
Back Four Ltd is the controller and responsible for your personal data (we, us or our).
To assist you further in understanding this Privacy Notice, we have set out in the Schedule a glossary of terms used, examples of types of personal data we collect, how we use it, the lawful basis for processing such data and further details of your rights.
We have appointed a data privacy manager (DPM). If you have any questions about this Privacy Notice, including any requests to exercise your legal rights, please contact our DPM in writing, either:
by email to: firstname.lastname@example.org
by post to: Data Privacy Manager, Back Four Brand Protection, 316 Blackpool Road, Fulwood, Preston Lancashire PR2 3AE.
You have the right to make a complaint at any time to the ICO (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.
Your duty to inform us of changes
It is important that the data we hold about you is accurate and current, therefore please keep us informed of any changes to your personal data.
Our website and portal may include links to third-party websites, plug-ins and applications. By clicking on these links or enabling connections you may be allowing third parties to collect or share your personal data. We have no control these third-party websites, plug in or applications and are not responsible for their privacy notices, therefore you should also read their privacy notices to understand what personal data they collect about you and how they use it.
2. The data we collect about you
We may collect, use, store and transfer the types of personal data about you listed in “Part 1 Types of personal data”.
We also collect, use and share aggregated data. However, if we combine aggregated data with your personal data so that it can directly or indirectly identify you, we treat this as your personal data.
We do not collect any special categories of personal data or any information about criminal convictions and offences.
Failure to provide personal data
If we are required by law, or under the terms of a contract we have with you, to collect your personal data and you fail to provide it, we may not be able to enter into perform the contract with you and, we may have to cancel a product or service. We will notify you of this at the relevant time.
3. How personal data is collected
We collect personal data in the following ways:
|direct interactions||you may provide personal data when you complete online forms, request products/services, create a user account, or otherwise or correspond with us (by post, phone or email)|
|automated technology||we automatically collect personal data (technical and usage) when you browse or interact with our website, by using cookies, and other similar technologies. We may also receive technical data about you if you visit other websites which use our cookies. Please see our cookie notice for further details|
|publicly available sources||we may collect personal data from publicly availably sources such as Companies House and the Electoral Register such publicly available sources may be based inside and outside the EU|
|third parties||we may receive personal data from: (a) analytics providers based outside the EU (such as Google); (b) search information providers based inside and outside the EU; (c) our suppliers, such as payment providers, delivery services, website support and maintenance providers|
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:
• to perform the contract, we are to enter into or have entered into with you;
• to comply with a legal obligation; and
• where it is necessary to carry out our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
“Part 2 Lawful basis for processing and processing activities” sets out the lawful basis we will rely on to process your personal data.
Please 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 information.
Change of purpose
We will only use your personal data for the purpose that we originally collected it for, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
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 use your personal data in this manner.
We may process your personal data (without your knowledge or consent) where this is required or permitted by law.
5. Disclosure of your personal data
We may have to share your personal data with third parties, further details of which are set out in of. 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. They can only process your personal data for specified purposes and in accordance with our instructions.
6. International transfers
Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Generally, if we transfer your personal data out of the EEA, we will ensure a similar degree of protection is afforded to it by ensuring that we:
• only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; or
• use specific contracts approved by the European Commission which give personal data the same protection it has in Europe with our services providers, including to the US providers under the Privacy Shield.
However, in certain circumstances we may transfer personal data outside of the EEA without such protections in place where we are permitted to do so in accordance with any derogations set out in data protection legislation, where the transfer relates to a limited number of data subjects and we have compelling legitimate interests to purse in transferring the personal data.
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. We also limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know and they can only process your personal data on our instructions and will be subject to a duty of confidentiality.
We have procedures in place 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
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.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us. However, we are legally required 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.
We may also anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes. We can use anonymised information indefinitely without further notice to you.
9. Your legal rights
You have certain rights in certain circumstances under data protection law. These are set out in full in “Part 1 Types of personal data”. If you wish to exercise any of your rights, please contact our DPM.
You will not have to pay a fee to exercise any of your rights. However, if your request is clearly unfounded, repetitive or excessive, we may charge a reasonable fee for this information or refuse to comply with your request.
We may request specific information from you to help us confirm your identity when you contact us and ensure. This is a security measure to ensure that personal data is not disclosed to any person who does not have the right to receive it.
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.
Part 1: Types of personal data
|contact data||billing address, delivery address, email address and telephone number|
|financial data||bank account and payment card details|
|identity data||first name, maiden name, last name, username or similar identifier|
|profile data||your username and password, preferences, feedback|
|technical data||internet protocol (IP) 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 our website|
Part 2: Lawful basis for processing and processing activities
The lawful basis upon which we may rely on to process your personal data are:
|consent||you have given your express consent for us to process your personal data for a specific purpose|
|contract||the processing is necessary for us to perform our contractual obligations with you under our contract, or because you have asked us to take specific steps before entering into a contract with you|
|legal obligation||the processing is necessary for us to comply with legal or regulatory obligation|
|legitimate interests||the processing is necessary for our or a third party’s legitimate interest e.g. in order for us to provide the best service to you via our website. Before we process your personal data on this basis we make sure we consider and balance any potential impact on you, and we will not use your personal data on this basis where such impact outweighs our interest|
Set out below are specific details of the processing activities we undertake with your personal data and the lawful basis for doing this.
|Purpose/Activity||Type of data||Lawful basis for processing|
|to register you as a new customer||identity & contact||to perform our contract with you|
|to process and deliver your order, manage payments, fees and charges and debt recovery||identity, contact, financial, transaction||(i) to perform our contract with you;|
(ii) as necessary for our legitimate interest in recovering debts due to us
|to manage our relationship with you, notifying you about changes to our Terms or Privacy Notice and ask you to leave a review||identity, contact, profile||(i) to perform our contract with you|
(ii) as necessary to comply with a legal obligation
(iii) as necessary for our legitimate interests in keeping our records updated and analysing how customers use our products/services.
|to administer and protect our business, website and portal (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data||identity, contact & technical||(i) as necessary for our legitimate interests in 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|
(ii) as necessary to comply with any legal obligations
|to deliver relevant website and portal content to you and measure or understand the effectiveness of our content||identity, contact, profile, usage, technical||as necessary for our legitimate interests in studying how customers use our website and portal, to develop them, to grow our business|
|to use data analytics to improve our website, portal, products/services, customer relationships and experiences||technical & usage||as necessary for our legitimate interests to define types of customers for our products and services, to keep our website and portal updated and relevant, to develop our business|
Part 3: Your legal rights
You have the following legal rights in relation to your personal data:
|access your data||you can ask for access to and a copy of your personal data and can check we are lawfully processing it|
|correction||you can ask us to correct any incomplete or inaccurate personal data we hold about you|
|erasure||you can ask us to delete or remove your personal data where:|
(a) there is no good reason for us continuing to process it;
(b) you have successfully exercised your right to object (see below);
(c) we may have processed your information unlawfully; or
(d) we are required to erase your personal data to comply with local law.
We may not always be able to comply with your request for specific legal reasons, which will be notified to you at the time of your request.
|object||you can object to the processing of your personal data where:|
(a) where we are relying on our legitimate interest (or those of a third party) as the basis for processing your personal data, if you feel it impacts on your fundamental rights and freedoms;
(b) 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 and in such circumstances, we can continue to process your personal data for such purposes.
|restrict processing||you can ask us to us to suspend or restrict the processing of your personal data, if:|
(a) you want us to establish the accuracy of your personal data;
(b) our use of your personal data is unlawful, but you do not want us to erase it;
(c) you need us to hold your personal data (where 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 personal data, but we need to verify whether we have overriding legitimate grounds to use it.
|request a transfer||you can request a transfer of your personal data which is held in an automated manner and which you provided your consent for us to process such personal data or which we need to process to perform our contact with you, to you or a third party. We will provide your personal data in a structured, commonly used, machine-readable format.|
|withdraw your consent||you can withdraw your consent at any time (where we are relying on consent to process your personal data). This does not affect the lawfulness of any processing carried out before you withdraw your consent.|
Part 4: Third Parties
|service providers||acting as processors or controllers based predominately in the EEA but also around the world who provide brand enforcement services and IT and system administration services.|
|professional advisors||acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.|
|HM Revenue & Customs, trading standards, regulators and other authorities (including the police)||acting as processors or joint controllers predominantly based in the EEA but also around the world who require reporting of processing activities in certain circumstances.|
|third parties||third parties 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|
Part 5: Glossary
|aggregated data||information such as statistical or demographic data which may be derived from personal data but which cannot by itself identify a data subject|
|controller||a body that determines the purposes and means of processing personal data|
|data subject||an individual living person identified by personal data (which will generally be you)|
|personal data||information identifying a data subject from that data alone or with other data we may hold but it does not include anonymised or aggregated data|
|processor||a body that is responsible for processing personal data on behalf of a controller.|
|special categories of personal data||information about race, ethnicity political opinions, religious or philosophical beliefs, trade union membership, health, genetic, biometric data, sex life, sexual orientation.|
|ICO||Information Commissioner’s Office, the UK’s supervisory authority for data protection issues.|