The Retail Business Hub (hereafter referred to as TRBH) is committed to protecting the privacy and security of your personal information.
TRBH is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this policy.
This notice applies to current and former customers, suppliers, contractors and other third parties. This notice does not form part of any contract to provide services. We may update this notice at any time.
It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.
We will comply with data protection law. This says that the personal information we hold about you must be:
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 will collect, store, and use the following categories of personal information about you including, but not limited to, the following:
There are “special categories” of more sensitive personal data which require a higher level of protection and we do envisage that we will hold or process special categories of sensitive personal data. If we are required to process special categories of sensitive personal data, then we will contact you and obtain your explicit consent for us to process your special categories of sensitive personal data.
We collect most information from you. However, we may also collect information:
Under data protection law, we can only use your personal data if we have a proper reason for doing so, e.g.:
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
The table below explains the reasons what we use and process your personal data and our reasons for doing so:
|What we use your personal data for||Our reasons|
|To send products and services and deliver your purchases to you or someone you have duly nominated||For the performance of our contract with you or to take steps at your request before entering into a contract For our legitimate interests or those of a third party|
|Sending information about our products our products and services.||For our legitimate interests or those of a third party and we will only send this with your permission.|
|To prevent and detect fraud against you or TRBH.||For our legitimate interests or those of a third party, i.e. to minimise fraud that could be damaging for us and for you.|
|Ensuring business policies are adhered to, e.g. policies covering security and internet use||For our legitimate interests or those of a third party|
|Statistical analysis to help us manage our business, e.g. in relation to our financial performance, client base, work type or other efficiency measures||For our legitimate interests or those of a third party|
|Updating and enhancing customer records||For the performance of our contract with you or to take steps at your request before entering into a contract To comply with our legal and regulatory obligations For our legitimate interests or those of a third party|
|What we use your personal data for||Our reasons|
|Your date of birth||To prevent and detect fraud|
|Your payment information so that we can take payment.||For the performance of our contract with you or to take steps at your request before entering into a contract|
|Your business details||For the performance of our contract with you.|
|Marketing and communications of our products.||For the performance of our contract with you. For our legitimate interests or those of a third party.|
|Your purchase history||For the performance of our contract with you. For our legitimate interests or those of a third party|
The above table does not apply to special category personal data, which we will only process with your explicit consent.
Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.
We may use your personal data to send you updates (by email, text message, telephone, post or social media) about our products that might be of interest to you including exclusive offers, promotions or new products.
We have a legitimate interest in processing your personal data for promotional purposes (see above ‘How we will use information about you’). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.
We will always treat your personal data with the utmost respect and never sell OR share it with other organisations outside of TRBH for marketing purposes.
You have the right to opt out of receiving promotional communications at any time by following the opt-out links on marketing material or by contacting us by post or email by contacting us at email@example.com (see ‘How to contact us’).
We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.
This policy sets out how long information will normally be held by us and when that information will be confidentially destroyed.
We will keep your personal data after we have finished working with you. We will do so for one of these reasons:
We will not retain your data for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of data.
We will only retain your personal information 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.
In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer a customer we will retain and securely destroy your personal information in accordance with applicable laws and regulations.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we have to keep basic information about our customers (including contact, order history and contracts, financial) for legal, regulatory and tax purposes.
Information (hard copy and electronic) will be retained for at least the period specified in our Data Retention Period (see Appendix).
All information must be reviewed before destruction to determine if there are special factors that mean destruction should be delayed, e.g.:
We will endeavour to delete hard copy and electronically held documents and information at the end of the retention period.
|Your navigation history on our website and purchase||3 years or a date you notify us in writing to delete|
|Financial/Accounts records||6 years|
|Marketing||3 years unless you ‘opt out’ of the marketing material or exercise your right to withdraw in accordance with this policy.|
|Complaints records||1 year from the conclusion of the complaint|
If you fail to provide personal information
If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you, or we may be prevented from complying with our legal obligations.
We will only use your personal information 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 we need to use your personal information 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 information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Special categories” of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information.
As confirmed previously, we do not envisage that we will obtain, handle or process your sensitive personal information.
As highlighted above, we will never sell any of your data to a third party.
However, we may have to share your data with third parties to enable us to provide our services to you, such as:
We require third parties to respect the security of your data and to treat it in accordance with the law.
We may transfer your personal information outside the EU. If we do, you can expect a similar degree of protection in respect of your personal information.
All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
We may share your personal information with other third parties, for example in the context of the possible sale or a service provider to our business or restructuring of the business for example. We may also need to share your personal information with a regulator or to otherwise comply with the law.
With third party service providers, agents, or contractors. We use other companies, agents or contractors (“Service Providers”) to perform services on our behalf or to assist us with providing services to you. For example, we may engage Service Providers to process credit card transactions or other payment methods. Or, we may engage Service Providers to provide services such as marketing, advertising, communications, infrastructure and IT services, to provide customer service, to collect debts, and to analyse and enhance data (including data about users’ interactions with our service). These Service Providers may have access to your personal or other information in order to provide these functions. In addition, some of the information we request may be collected by third party providers on our behalf. We do not authorize them to use or disclose your personal information except in connection with providing their services.
Analytics: Specifically, for analytics providers, we use Google Analytics Google Analytics which is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
Please note at this time, we do not recognize automated browser signals regarding tracking mechanisms, which may include “do not track” instructions.
Facebook: You can learn more about interest-based advertising from Facebook by visiting this page:
To opt-out from Facebook’s interest-based ads follow these instructions from Facebook: https://www.facebook.com/help/568137493302217
To see more about Facebook’s participation in the Digital Advertising Alliance please visit the Choices section of this notice.
For more information on the privacy practices of Facebook, please visit Facebook’s Data Policy: https://www.facebook.com/privacy/explanation
Payment Providers: We may provide paid products and/or services within the site. When we do, we use third-party services for payment processing (e.g. payment processors). We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their own privacy notice. The payment processors we work with adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.
We have put in place measures to protect the security of your information.
Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions, and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
You have the following rights, which you can exercise free of charge:
|Access||The right to be provided with a copy of your personal data (the right of access)|
|Rectification||The right to require us to correct any mistakes in your personal data|
|To be forgotten||The right to require us to delete your personal data—in certain situations|
|Restriction of processing||The right to require us to restrict processing of your personal data—in certain circumstances, e.g. if you contest the accuracy of the data|
|Data portability||The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations|
|To object||The right to object: —at any time to your personal data being processed for direct marketing (including profiling); —in certain other situations to our continued processing of your personal data, e.g. processing carried out for the purpose of our legitimate interests.|
|Not to be subject to automated individual decision-making||The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you|
|To withdraw||In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact Ami, Director at THE RETAIL BUSINESS HUB firstname.lastname@example.org. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.|
For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please:
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.
If you have any questions about this privacy notice, please contact Ami, Director at email@example.com.
We hope that we can resolve any query or concern you may raise about our use of your information.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns or telephone: 0303 123 1113.
Our contact details are:
|The Retail Business Hub|
4 Dumbarton Way, Slough, SL3 7UR