Changes to the privacy policy and your duty to inform us of changes
This version was last updated on 2nd April 2019 and historic versions can be obtained by contacting us.
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
Our 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.
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 as follows:
- Identity & Contact Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, gender, job title and employer, address, email address and telephone number.
- Transaction Data includes bank account and payment card details, details about your financial position and credit-worthiness, 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 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.
- 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 personal 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 policy.
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.
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 Transaction Data by filling in forms or by corresponding with us by post, phone, email, live chat or otherwise, including face-to-face contact.
- 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 cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details and information about the effect of blocking cookies.
- Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
- Providers of technical, IT, payment & delivery services;
- Publicly available sources of information;
- Reference agencies (which may, where applicable, include some of our competitors).
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.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email, post 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 the main ways we plan (or may in the future 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. 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 or account holder, and to process your orders and collect/recover payments.
To provide customer service and troubleshoot issues. | (a) Identity & Contact
(b) Transaction
(c) Marketing & Communications
| a) Performance of a contract with you
(b) Necessary for our legitimate interests (including to recover debts due to us)
|
| To manage our relationship with you including notifying you of updated policies/terms and obtaining your feedback. | (a) Identity & Contact
(b) 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, and to administer and grow our business)
|
| To administer, operate and protect our business and our website (including troubleshooting, data analysis/analytics, testing, system maintenance, support, reporting, hosting of data, provision of advertising (not comprising direct electronic marketing)) | (a) Identity & Contact
(b) Technical
(c) Transaction
(d) Marketing and Communications
| (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud, in the context of a business reorganisation or group restructuring exercise, to grow our business and inform our strategy)
(b) Necessary to comply with a legal obligation
|
| To send you marketing messages via email, text, post or phone call (on condition of your consent to receive these). | (a) Marketing and Communications | (a) To notify you of the latest news from Turnbull online and in branch including new products, offers, events and more |
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. It is entirely your choice whether you consent to us providing you with direct marketing – we will only do so where there are lawful bases for us to do so or you have given us your consent to do so.
Where we have consent, we may send you marketing messages by email, text message, or post regarding online and in branch news, offers, events, new product offerings and more.
Promotional offers from us
We may use your Identity & Contact, Technical and Transaction 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 only if you have requested information from us or signed up to do so. You may have also provided us with your details when you entered a competition or registered for a promotion and, in each case, you have opted in to receiving that marketing.
The marketing messages you receive can be through direct email marketing, text messages or post.
Third-party marketing
We will get your express opt-in consent before we share your personal data with any other company for their marketing purposes.
Opting out
You can ask us to stop (and to ask third parties to whom we have provided your personal data to stop) sending you marketing messages by contacting us at any time by the means below:
- Clicking ‘unsubscribe’ in the footer of marketing emails sent to you;
- Replying to the stop code in text messages sent to you;
- Through written request to FAO: Accounts, Turnbull & Co ltd, 95 Southgate, Sleaford, Lincs, NG34 7RQ;
- By contacting your local branch;
- Managing your account online through the ‘My Account’ button in the header of every webpage.
Please note that if you chose to unsubscribe from marketing communications from us, you will continue to receive service messages from us in order for us to fulfil our contractual obligation to you. These may include but are not limited to: order confirmations; invoices, statements and other account information; confirmation of changes to your account; updates to terms of service; and more.
We aim to action your request promptly however it can take up to 14 days for all our systems to be updated and during this time you may still receive marketing messages from Turnbull.
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
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.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We may transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the 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.
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.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. If you wish to exercise any of those rights (as further detailed in the Glossary), please contact us.
No fee usually required
You will not usually 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). 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).
Performance of Contract means processing your data where necessary for the performance of a contract with you 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 who provide payment, delivery, IT and system administration services
- Professional advisers including lawyers, bankers, auditors and insurers
- Regulators, industry bodies and other authorities
- Manufacturers of goods which we sell
YOUR LEGAL RIGHTS
Please contact us for further information about, or to exercise, these rights. You have the right to:
Request access to your personal data (commonly known as a “data subject access request”).
Request correction of the personal data that we hold about you.
Request erasure of your personal data. 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 in certain circumstances. 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. 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.
Request the transfer of your personal data to you or to a third party. 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.
