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GDPR Privacy Policy (Trade Customers)

 

R.H Smith & Sons (Wigmakers) Limited, trading as Smiffys (“we”, “us” or “our”) is committed to protecting your privacy and meeting its data protection obligations under the General Data Protection Regulation (“GDPR”).

 

This Privacy Policy (together with our Terms of Use http://trade.smiffys.com/Info/t-termsofuse)

and any other documents referred to in it) (“Policy”) sets out the basis on which any personal data we collect from or about you, as a result of your use of our website http://trade.smiffys.com/ (“our website”) or when you communicate with us in person, by telephone, email or post will be processed by us.

 

This Policy only applies to our use of ‘personal data’ about ‘data subjects’ (as defined by data protection law) which includes personal data relating to our customers and prospective customers who are sole traders, non-limited partnerships and corporate contacts at limited companies (“you” or “your”). This Policy does not apply to information which you provide to us or which we collect about limited companies.

 

We will be the data controller of your personal data which you provide, or which is collected by us via our website or when you communicate with us by telephone, email or post. This means that we are responsible for deciding how we hold and use personal information about you and that we are required to notify you of the information contained in this Policy. It is important that you read this Policy so that you are aware of how and why we are using such information and how we will treat it.

 

You can contact us using the details provided at the end of this Policy in the “Contacting Us” section.

 

THE TYPE OF INFORMATION WE COLLECT FROM YOU AND HOW WE WILL USE IT

We will collect various types of personal information from you when use our website and when you communicate with us in person, via telephone, post and email. Further details of the personal data we collect and how we use it are set out below.

 

In this section, we have indicated with asterisks whether we need to process your personal data:

 

         * = to enter into and/or perform our contract with you to provide the products or services you request from us;

         ** = to pursue legitimate interests of our own or of third parties, provided your interests and fundamental rights do not override those interests;

         *** = to enable us to comply with our legal obligations; and/or

         ****= with your consent.

 

When you complete our Trade Account Request Form

 

When you make a request to open a trade account with us, we will need to collect the personal data listed below via our Trade Account Request Form in order to decide whether to allow you to open a trade account with us** and, if your request to open a trade account with us is successful, to create and to administer your trade account*. If you do not provide this personal data to us, you will be unable to submit a request to open a trade account with us. 

 

         Name of individual making the request;

         Email address;

         Telephone number; and

         Subject and details of enquiry.

 

When you open a trade account with us

 

You will need to complete our New Business Form in order to open a trade account with us. We will provide you with a separate Privacy Notice at that point which explains how and why we will use the personal data collected in that form and that notice should be read alongside this Policy.

 

When you apply to open a credit account with us

 

To apply to open a credit account with us, you will need to complete our Credit Application Form. The Privacy Notice provided within the Credit Application Form explains how and why we will process the personal data collected in that form and should be read alongside this Policy.

 

 

When you contact us

 

When you use the form on our website to contact us, we will collect the details set out above [in the ‘When you complete our Trade Account Request Form’ section.

 

When you contact us by telephone, email or post, we will need to collect from you your account number or, if you cannot provide your account number, your postcode or email address to allow us to locate your account and deal with your enquiry, together with any information you provide us with.

 

We will only use this information for the purpose of responding to and, to the extent possible, dealing with your enquiry**.

 

Other Uses of our website

 

We will also process personal information about you to:

 

       process your order, take payment, arrange delivery, raise invoices, keep records of payments and carry out analysis for financial purposes*/**;

 

       allow you to participate in interactive features of our service, when you choose to do so*/**;

 

       allow you to access offers and promotions or enter competitions via our website provided by third parties**;

 

         provide you with information about our products, offers, events or promotions we feel may interest you where permitted by law**/****;

 

         notify you about changes to the services provided through our website**;

 

         ensure that content from our website is presented in the most effective manner for you and your device**;

 

         personalise our website to you and provide you with targeted offers**;

         carry out debt collection activities**; and

 

         deal with any complaints or claims made by you**/***.

 

Automatic Personal Data Collection

 

When you visit our website we will automatically collect technical information relating to the operating system, platform and device you use via behavioural cookies as is detailed further in our Cookie Policy.

 

We will use the above information in order to:

 

         to administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes to comply with our legal obligations**/***;

 

         to improve our website to ensure that content is presented in the most effective manner for you and for your computer / device**; and

 

         as part of our efforts to keep our website safe and secure to comply with our legal obligations**/***.

 

We will not carry out any solely automated decision-making using your personal data.

 

Change of Purpose

 

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 usually notify you and we will explain the legal basis which allows us to do so.

 

DISCLOSURE OF YOUR INFORMATION

 

We will share your data with the service providers listed below. These third parties process your personal data when providing services to us such as collating product reviews, advertising and marketing, providing IT support, processing deliveries and payments, debt collection and accounting services.

 

We enter into agreements with such third parties to ensure that they respect the security of your data and use it only in accordance with data protection laws.

 

We will also disclose your personal information to third parties:

 

         in the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets;

 

         if R.H Smith & Sons (Wigmakers) Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets; and/or

 

         if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms of Supply to Trade Customers (http://trade.smiffys.com/Info/t-termsofsale) and other agreements; or to protect the rights, property, or safety of R.H Smith & Sons (Wigmakers) Limited our customers or others.

 

STORAGE OF YOUR PERSONAL DATA

 

Some of our service providers may be based outside of the European Economic Area or may transfer or allow access to personal data outside of the European Economic Area. Countries located outside the EEA are not governed by European Union (EU) data protection laws. However your personal information will be protected by the safeguards required by EU data protection laws. Details of the non-EEA countries which your personal data may be processed in and the safeguards in place (including how to obtain a copy of them) are provided at below.

 

In addition, your personal data may be shared with our Australian group company for our internal business purposes. As a result, when you become our customer, the information provided by you may be transferred to Australia which is outside of the European Economic Area and not subject to EU data protection laws. However, your data is protected when it is accessed by our Australian group company, by the commitments made by that company in the standard contractual clauses (Model Clauses) which they have entered into with us. You can request a copy of these Model Clauses by contacting us using the details provided at the end of this Policy.

 

We will only keep your personal data for as long as we need to in order to fulfil the relevant purpose(s) it was collected for, as set out above in this Policy, and for as long as we are required to keep it for legal purposes. If you are a customer, we will keep your personal data for seven years from the date on which you close your account with us for legal and tax purposes.

 

We do not store your payment details, other than the last four digits of the card number which we store for the purposes of identifying which card we should instruct our payment provider to take payment from when you place an order over the telephone.

 

Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access, such as password protection, access controls, firewalls, encryption and anti-virus protection. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website; any transmission is at your own risk.

 

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.

 

YOUR RIGHTS

 

Data protection laws provide you with the following rights to:

 

         request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it;

 

         request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected;

 

         request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below);

 

         request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it;

 

         transmit personal data you submitted to us back to you or to another organisation in certain circumstances; and

 

         complain to the supervisory authority, which in the United Kingdom is the Information Commissioner’s Office.

 

You also have the right to object to the processing of your personal information 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. You also have the right to object where we are processing your personal information for direct marketing purposes.

 

You will not have to pay a fee to access your personal information (or to exercise any of the other rights above). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

 

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.

 

If we rely on your consent to process your personal data, (for example if we need your consent to send you direct marketing), you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact us using any of the details set out below in the “Contacting Us” section. Once we have received notification that you have withdrawn your consent, we will stop processing your information for the purpose(s) you originally agreed to, unless we have legal basis for doing so.

 

CHANGES TO OUR POLICY

 

Any changes we make to our Policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our Policy.

 

RECIPIENTS OF PERSONAL DATA

In order to provide the Website and/or related services, R.H Smith & Sons (Wigmakers) Limited, trading as Smiffys, share your personal data with the following recipients:

 

Company Name

 

Does this company transfer   this data outside of the EU/EEA?

Safeguards which are in place to protect your personal data in line with Article 46 of the GDPR

IT Suppliers

Cato Networks Limited

Yes

EU approved model data protection clauses are place with this supplier

dotMailer Limited

Yes

This supplier utilises EU approved model data protection clauses or US Privacy Shield Certification.

 

ZAP Technology Pty Ltd

 

Yes

This supplier utilises the US Privacy Shield certification

Secura Hosting Limited

No

N/A

Verifone Systems Inc.

 

Yes

This supplier utilises EU approved model data protection clauses, US Privacy Shield Certification or Binding Corporate Rules.

NetEDI Limited

 

No

N/A

Payment Solutions Limited

 

TBC

TBC

Income Systems Limited

No

N/A

K3 Business Technology Group Limited

This supplier may transfer data outside of the EEA.

This supplier utilises EU approved model data protection clauses, US Privacy Shield Certification or Binding Corporate Rules.

 

Bank of America Merrill Lynch

Yes

TBC

Google Inc

Yes

This supplier utilises EU approved model data protection clauses or the US Privacy Shield Certification.

Parcel Delivery and Logistics Service Providers

DPDgroup UK Limited

 

Yes

This supplier utilises EU approved model data protection clauses or US Privacy Shield Certification.

 

Royal Mail Group Limited

 

Yes

This supplier utilises EU approved model data protection clauses or US Privacy Shield Certification.

 

Direct Shot Distributing, Inc

Yes – awaiting further details from the supplier

TBC

Quality Freight Services Limited

TBC

TBC

Clipper Germany KG

TBC

TBC

Direct Shot Distributing, Inc

Yes – awaiting further details from the supplier

TBC

Quality Freight Services Limited

TBC

TBC

UPS Europe SA

Yes

This supplier utilises EU approved model data protection clauses, US Privacy Shield Certification or Binding Corporate Rules.

 

TNT Express Worldwide N.V.

Yes

TBC

Clipper Germany KG

Yes

TBC

Credit Check & Debt Collection Companies

Creditsafe Business Solutions Limited

 

Yes

This supplier utilises EU approved model data protection clauses, US Privacy Shield Certification or Binding Corporate Rules.

 

Credit Reform

TBC

TBC

Redwood Collections Limited

 

No

N/A

 

 

 

 

In addition, we may share your data with:

 

-        the organisation’s advisers, including accountants, auditors, lawyers, IT contractors, web development specialists and other external professional advisers;

-       government bodies and dispute resolution and law enforcement organisations, including tax authorities, trading standards and the courts.

If you would like more details about the relevant safeguards which we have put in place with the third parties listed above that transfer personal data outside of the EU/EEA please contact the Legal Department via Intellectualproperty@smiffys.com.

 

GDPR Cookie Policy

 

R.H. Smith & Sons (Wigmakers) Limited operate three websites under the Smiffys and Fever brands:

 

http://trade.smiffys.com/

https://www.smiffys.com/

https://www.fevercollection.com/

 

This cookie policy sets out our use of cookies on all three websites.  All information which we gather by cookies is anonymous, and we can’t use it to identify you personally.

 

The cookies that we use are listed below.  If you visit the following website it will provide you with more information about these types of cookies and give you details about how you can change your preferences: http://www.youronlinechoices.com/.

 

 

WHAT ARE COOKIES?

 

A cookie is a small text file of letters and numbers which are stored on your computer or mobile when you visit a website. They distinguish you from other users and usually just contain anonymous information. These cookies can be “session cookies” lasting for just the duration of your visit or they are “persistent cookies” which can remain on your computer for longer so that the site will remember you if you come back again.

 

Cookies carry out different functions like like storing your preferences, remembering that you've logged in or keeping your shopping basket up to date - generally making your experience online easier.

 

WE USE THE FOLLOWING COOKIES

         Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website.

         Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.

         Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you and remember your preferences (for example, your region).

         Targeting cookies. These cookies are used by carefully selected third parties to recognise that you have visited the website and help tailor advertising to your interests. To carry out this functionality we do share some personal information with third parties but, this is detailed in our privacy policy- please see [insert link].  You can find out how to turn these cookies off by visiting http://www.youronlinechoices.com/.

         Google Analytics. This is a web analytics service provided by Google, Inc. ("Google"). This service places cookies on your computer, to help the website analyse how users use the site. The information gathered about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States.

         Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website.  Additionally you can use this plugin: http://tools.google.com/dlpage/gaoptout?hl=en

You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

Cookie

Type

Purpose

More information

Google Tag Manager

Functionality cookies

Managing integrations

Provides us with a mechanism for managing 3rd party integration.

Google Analytics

Analytical/performance cookies

Tracking

These cookies collect information about how our visitors use our website. Please see above for further detauls

YouTube

Functionality cookies

Digital Asset Management; Images and Video

This allows our website visitors to be served product images.

Doubleclick

Analytical/performance cookies,

Tracking & personalisation

Shows us those visitors who use a search engine and click on a paid advertisement, helping us improve our online marketing channel and provide a better customer experience

For Smiffys.com only:

Nosto

Targeting cookies

Website Personalisation

Shows customers recommended products based on browsing history

Magento

Functionality cookies

Tracking user preferences, Persistent cart, Search history

 

Allows the website to store customer sessions and pass data to and from Magento, a system which enables us to send out email marketing to customers who have requested this

Stripe, PayPal

Strictly necessary cookies

Payment

Allows us to take payment for and complete your order.

 

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.

By using our website you expressly agree to the terms contained in this policy and consent to the use of cookies set out in this policy.

 

CONTACTING US

 

If you have any queries, comments or requests regarding this Policy or you would like to exercise any of your rights set out above, you can contact us in the following ways:

 

         by email to our Legal Department at intellectualproperty@smiffys.com;

         by telephone at +44 (0) 1427 619799- please ask to speak with the Legal Department; or

         by post at Revie Road Business Park, Elland Rd, Leeds LS11 8JT

 

Version 1_Created 9 May 2018