1. Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
“Account” means an account required to access and/or use certain areas and features of Our Site;
“Cookie” means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in Part 14, below; and
“Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;
2. Information About Us and How to Contact Us
Our High Road is owned and operated by Leapcog Ltd, a limited company registered in England under company number 12319223, whose registered address is 7 Bell Yard, London, WC2A 2JR. Our VAT number is 337522503. We are registered with the Information Commissioner’s Office as a data controller under registration number ZA768530.
For general enquiries, we can be contacted by email at firstname.lastname@example.org. To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the email address: email@example.com.
3. What Does This Policy Cover?
4. What Is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’. Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
5. What Are My Rights?
Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:
The right to access the personal data we hold about you. Part 13 will tell you how to do this.
The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 2 to find out more.
The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that We hold. Please contact us using the details in Part 2 to find out more.
The right to restrict (i.e. prevent) the processing of your personal data.
The right to object to us using your personal data for a particular purpose or purposes.
The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
Rights relating to automated decision-making and profiling.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 2.
It is important that your personal data is kept accurate and up-to-date. If any of the personal data We hold about you changes, please keep us informed as long as We have that data.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 2.
6. What Data Do You Collect and How?
Category of Data Collected: Examples of Data Collected
Identity Information: Name, title, date of birth
Contact information: Home address, shipping address, billing address, email address, telephone number
Business information: Contact name, business name, trading address, telephone number
Profile information: Login details, purchase history, marketing & communication preferences
Payment information: Payment card details including bank account and payment card details, bank account number, sort code, IBAN, BIC, and bank address, will be collected directly by our Third Party Payment Service Provider and we won’t receive them. However, in certain limited cases, we may receive bank account details in the context of administering refunds.
Technical information: IP address, browser type and version, operating system
7. How Do You Use My Personal Data?
Under the Data Protection Legislation, We must always have a lawful basis for using personal data. Our “legal basis” for processing your Personal Data will rely on one of the following legal bases:
Where we need to perform a contract we are about to enter into or have entered into with you ("Contractual Necessity”).
Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests (“Legitimate Interests”).
Where we need to comply with a legal or regulatory obligation (“Compliance with Law”).
We will use the information provided by you to:
communicate with you regarding orders, enquiries and complaints
notify you about changes to our service
provide you with information about other goods and services that the Sellers offer
provide you, or permit carefully selected third parties to provide you, with information about other goods or services we feel may interest you if you have agreed to receive such information
ensure that content from our Site is presented to you in the most effective way
With your permission and/or where permitted by law, We may also use your personal data for marketing purposes, which may include contacting you by email, mobile push notification, text message or post with information, news, and offers on our services. You will not be sent any unlawful marketing or spam.
We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out. We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time.
Third Parties whose content appears on our Site may use third-party Cookies, as detailed below in Part 14. Please refer to Part 14 for more information on controlling cookies. Please note that We do not control the activities of such third parties, nor the data that they collect and use themselves, and We advise you to check the privacy policies of any such third parties.
We may use automated system(s) for carrying out certain kinds of decision-making or profiling. If at any point you wish to query any action that We take on the basis of this or wish to request ‘human intervention’ (i.e. have someone review the action themselves, rather than relying only on the automated method), the Data Protection Legislation gives you the right to do so. Please contact us to find out more using the details in Part 2.
We will only use your personal data for the purpose(s) for which it was originally collected unless We reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If We do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 2.
If We need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, We will inform you and explain the legal basis which allows us to do so.
In some circumstances, where permitted or required by law, We may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.
8. How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. This general rule applies unless a longer retention period is required by law (for example for regulatory purposes). The Personal Data we process to provide you with services associated with Our Site will only be kept for so long as you have an open account on Our Site. When you close your account, we will delete or irreversibly anonymise your Personal Data within thirty (30) days. Please note that this data retention framework does not apply to Anonymised or Aggregated Data, which we may store for a longer period of time.
9. How and Where Do You Store or Transfer My Personal Data?
We share your data with external third parties, as detailed below in Part 10, that are based outside of the EEA. Where we transfer your data to a third party based in the US, the data may be protected if they are part of the EU-US Privacy Shield. This requires that third party to provide data protection to standards similar to those in Europe. More information is available from the European Commission.
The security of your personal data is essential to us, and to protect your data, We limit access to your Personal Data to those employees and other staff who have a business need to have such access. All such people are subject to a contractual duty of confidentiality. In certain circumstances (e.g., where we are legally required to do so) we may notify you of breaches affecting your Personal Data. By submitting your personal data, you agree to this transfer, storing or processing.
10. Do You Share My Personal Data?
In the provision of our services to you, we may share your personal data with selected third parties in the following instances:
the Sellers for the purposes of processing your order and delivering goods ordered by you, where appropriate.
our external website developers, analytics and search engine providers that assist us in the improvement and optimisation of our website.
any member of our group, which means our ultimate holding company and its subsidiaries.
If any of your personal data is shared with a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 9.
If We sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that We have used it, as specified in this Privacy & Cookies Policy.
In some limited circumstances, We may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
11. How Can I Control My Personal Data?
In addition to your rights under the Data Protection Legislation, set out in Part 5, when you submit personal data via our Site, you may be given options to restrict our use of your personal data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails and at the point of providing your Details, and by managing your Account).
12. Can I Withhold Information?
13. How Can I Access My Personal Data?
If you want to know what personal data We have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”. All subject access requests should be made in writing and sent to the email address shown in Part 2. There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within 21 days and, in any case, not more than one month of receiving it.
Normally, We aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date We receive your request. You will be kept fully informed of our progress.
By using our Site, you may also receive certain third-party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, and/or parties other than us. For more details on how Third-party Cookies are used on Our Site, please refer to the table below. These Cookies are not integral to the functioning of our Site and your use and experience of our Site will not be impaired by refusing consent to them.
All Cookies used by and on our Site are used in accordance with current Cookie Law.
Before Cookies are placed on your computer or device, you will be shown a pop-up prompt requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of our Site may not function fully or as intended.
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if We change our business in a way that affects personal data protection.