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.