WHO WE ARE
We are Ashley Wilde Group Limited. (“we/our/us”). We are a company based in England, registration company number 477955. Our registered office address is Emmanuel House, Travellers Close, Hatfield, AL9 7LD. Our registered VAT number is GB248211183.
For the purpose of the Data Protection Act 1998, the General Data Protection Regulation (Regulation (EU) 2016/679) and any amended, updated or subsequently implemented legislation in the UK and/or EU relating to the controlling and processing personal data (“Data Protection Legislation”) we are a data controller of personal data provided by you to us through use of our Website (as defined below). Where we consider it appropriate (and as further described in this policy) we may also provide third party data processors with such personal data for the purposes set out in this policy.
We are registered as a data controller with the UK Information Commissioner’s Office with registration number Z840936X.
ABOUT THIS POLICY
This policy sets out how, when and why we may collect, control, store, process and transfer personal data that you provide to us, or that we collect from you, when you correspond with us directly and/or enquire or place orders for products with us and/or provide personal data to us through using the www.ashleywildegroup.com website (the “Website”).
This policy also sets out your rights and our obligations in relation to collecting, controlling and processing such personal data.
Our main objective is for you to have absolute confidence in us when we collect, control and process your personal data. The Data Protection Legislation is not intended to prevent processing of personal data, however, but to ensure that such processing is done fairly and without adverse impact on your fundamental rights and freedoms.
Any third party data processors are obliged to comply with this policy when processing personal data on our behalf. Any breach of this policy by that third party may result in disciplinary action being taken against them.
WHAT IS PERSONAL DATA?
Personal data is information relating to an “identified” or “identifiable” living individual. An “identifiable” individual is one who can be identified, directly or indirectly, in particular reference to an identifier such as a name, an email address, a postal address, date of birth, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that person.
Sensitive personal data includes, but is not limited to, personal data which reveals racial or ethnic origin, and data concerning health or sex life and sexual orientation.
Further detail as to the specific types of personal data and sensitive personal data we may control and process is set out below.
For personal data to be processed lawfully by us they must be processed on the basis of one or more of the lawful processing bases set out in the Data Protection Legislation. The lawful bases include, but are not limited to:
- your freely given, specific, informed and unambiguous consent to the processing, given by a clear statement or affirmative action;
- that the processing is necessary for the performance of a contract to which you are a party;
- that the processing is necessary in order for us to take steps at your request prior to entering into a contract with you;
- that processing is necessary for compliance with a legal obligation to which you are subject; or
- where processing is in the legitimate interest of the data controller or the party to whom the data is disclosed.
As such, we do not always require consent from you in order to lawfully process your personal data – we will only obtain consent to processing where we are unable to rely on one of the other lawful bases for processing. However, if we collect sensitive personal data from you we will generally ask for explicit consent in order to process such sensitive personal data.
HOW WE COLLECT AND USE PERSONAL DATA
Personal data may be collected by us actively and passively. The specific types of personal data we may collect from you, and the manner in which such personal data may be collected, includes:
This is personal data that we collect from you when you register to use, or purchase goods (either as a registered user or as a guest) through, our Website, by phone, email or otherwise.
We will collect your name, email address, postcode, postal address, phone number, credit card details and the password you choose for your account, at the time of you setting up an account to use our Website. We may also collect other information, including your company name, if you choose to provide it to us at the time of setting up an account to use our Website.
How we will use Registration Data
We will use Registration Data for the purpose of reviewing, accepting, confirming, processing, taking payment for, and arranging delivery to you of, orders for goods you place through the Website, by phone, email or otherwise. In particular, we will use your name, company name, email address, and/or your customer number to identify you from other customers so that we can process your order properly. We will also use your email address in order to send communications to you relating to the progress of your order (including for the purpose of confirming that we have accepted your order).
We may also use Registration Data for the purpose of sending direct marketing emails to you relating to the goods and services we offer, as well as for the purpose of sending our newsletter to you, if you have opted-in for this service. You may unsubscribe from receiving such direct marketing emails at any time by following the “unsubscribe” link in such marketing emails.
Why we may lawfully process Registration Data
We may lawfully process Registration Data for the purpose of reviewing, accepting, confirming, processing, taking payment for, and arranging delivery to you of goods you have ordered on the basis that doing so is necessary for the performance of a contract to which you are a party, or is necessary in order to take steps at your request prior to entering into a contract.
We may also lawfully process your name and email address for the purpose of sending direct marketing and newsletter emails to you on the basis that we have a legitimate interest in doing so. We consider ourselves to have a legitimate interest as:
we are pursuing a lawful business interest in sending marketing materials to our existing contacts and customers; sending such marketing materials to you via email is the quickest and easiest way for us to pursue and manage this lawful business interest, so such processing is therefore necessary; and given that you may unsubscribe to such emails at any time and that we make you aware at the time of collecting your data as to how, when, where and why we will use Registration Data, we consider your fundamental rights and freedoms to be balanced with our interest in sending such direct marketing emails to you.
This is personal data we collect from you when you correspond with us, and or place orders with us for the goods and/or services we offer, as a retail reseller.
We may collect your name, email address, postcode, postal address, phone number, credit card details, company name, bank account details and the password you choose for your account (if applicable), at the time of you liaising with us in respect of (and/or placing an order for) the goods and/or services we offer. We may also collect other information, such as business interests.
How we will use Reseller Data
We will use Reseller Data for the purpose of reviewing, accepting, confirming, processing, taking payment for, and arranging delivery to you of, orders for goods you place. In particular, we will use your name and email address to identify you from other retail resellers so that we can process your order properly. We will also use your email address in order to send communications to you relating to your order for goods (including for the purpose of confirming that we have accepted your order).
We may also use Reseller Data for the purpose of sending our newsletter to you if you have subscribed to receive such communication, as well as for the purpose of sending direct marketing emails to you relating to similar goods and services we offer, which we consider may be of interest to you. You may unsubscribe from receiving such direct marketing emails at any time by following the “unsubscribe” link in such marketing emails.
This is data we may collect passively when you use our Website.
Website Data includes, but is not limited to, your device’s location at the time of using the Website, as well as information relating to when, where and how the Website is used by you, and how many times the Website is accessed by you.
Website Data may also include your device’s Internet Protocol (IP) address, cookies, device type and version, the areas of the Website you visit, the amount of time spent within particular areas of our Website, time zone settings, the time and date of your use of the Website and the operating system and version you use to access the Website, information about your use of the Website including (if applicable) the full Uniform Resource Locators (URL), clickstream to, through and from our Website (including date and time), any goods or services you have viewed or searched for, the Website response times, download errors, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.
How we will use Website Data
We will use Website Data for the purpose of tracking and analysing the popularity and performance of the Website, how it is used by users and for other purposes so that we can tailor, develop and improve the Website and performance of the Website for the benefit of Website users and our clients.
Why we may lawfully process Website Data for these purposes
We will lawfully process Website Data for such purposes on the basis that we consider ourselves to have a legitimate interest in doing so as:
we have lawful business interest in developing and improving the Website for the benefit of our users;
we may only pursue this interest by obtaining and analysing Website Data in this way, so our activities are necessary in pursuing our lawful business interest; and we also consider this interest to be balanced with your fundamental rights and freedoms given that we have informed you as to how, when, where and why such Website Data will be collected and processed in this manner, as well as given that us processing the Website Data in this manner will positively impact upon your user experience of the Website.
Where is Website Data stored?
Website Data is passively collected and stored on secure servers operated by Ashley Wilde Group Ltd. and a third-party processor who will collect Website Data as and when it arises through your use of the Website. This processor may subsequently provide the Website Data to us once they have collated and processed the Website Data.
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.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for at least seven years after they cease being customers for tax purposes.
In some circumstances, you can ask us to delete your data, and in some circumstances, we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
YOUR RIGHTS AND OUR OBLIGATIONS
In some circumstances, we may require explicit consent from you in order to process your personal data for a particular purpose/s. We will generally only obtain consent from you if we do not have another lawful basis for doing so, for example if we do not have a legitimate interest in doing so or such processing is not necessary to perform a contract to which you are a party.
We do not require consent in order to obtain and process your personal data for the purposes set out in the above “How We Collect and Use Personal Data”.
However, if we are controlling and processing your personal data on the sole basis of consent, we will ensure that such consent:
- is presented in a manner which is clearly distinguishable from the other matters, in an intelligible and easily accessible form, using clear and plain language. Any part of such a declaration which constitutes an infringement of the Data Protection Legislation will not be binding.
- can be easily withdrawn by you at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. Prior to giving consent, you shall be informed accordingly. It shall be as easy to withdraw as to give consent.
- is freely given. When assessing whether consent is freely given, we shall take account of whether the performance of a contract, including the provision of a service, is conditional on consent to the processing of personal data that is not necessary for the performance of that contract.
- is lawful where we intend to collect and process personal data children. Where the child is below the age of 16 years, such processing shall be lawful only if and to the extent that consent is given or authorised by the holder of parental responsibility over the child (and we shall make reasonable efforts to verify in such cases that consent is given or authorised by the holder of parental responsibility over the child, taking into consideration available technology).
You may exercise your right to withdraw consent to processing at any time by contacting us via email to GDPR@ashleywildegroup.com. However, such withdrawal of consent will not retrospectively render processing prior to withdrawal of consent as unlawful.
The Right to Erasure (also known as the “Right to be Forgotten”)
You also benefit from the right to erasure. This means that you have the right to request us to erase personal data we hold about you, and that we should erase such data without undue delay, provided that you are able to demonstrate one of the following to us:
(a) that our processing of the personal data is no longer necessary in relation to the purpose for which it was collected;
(b) that you withdraw your consent to the processing and there is no other legal ground for us to continue to process the data;
(c) that you object to the processing under the Data Protection Legislation and there are no overriding legitimate grounds for processing;
(d) that the personal data must be erased in order to comply with a national legal obligation; or
(e) the personal data in question belongs to a child under the age of 16 and no consent is given or authorised by the holder of parental responsibility over the child.
You also benefit from the right to rectify inaccurate personal data we hold which relates to you (also known as the “right to rectification”). This means that, taking into account the subject of the processing, you shall have the right to have incomplete personal data completed. You can exercise your right to rectification by contacting us via email to GDPR@ashleywildegroup.com.
Subject Access Requests
You as a data subject are entitled to make a formal request for information we hold about you. We must provide you with a copy of this information, the reasons it is being processed and whether it will be given to any other organisations or people provided that you make this request in writing.
SHARING AND TRANSFERRING PERSONAL DATA
We use industry standard encryption for transmission of data to our systems. Although we cannot guarantee the absolute safety of transmission of data via the internet, we adhere to industry standards to give your data the most appropriate protection possible.
We may provide your personal data to internal and external third parties in order for us to conduct our business services sufficiently. These may include:
External Third Parties
Service providers who may act as processors based inside or outside the EU and who provide IT, system administration and other services.
Professional advisers who may act as processors including lawyers, bankers, auditors and insurers based inside or outside the EU who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue & Customs, regulators and other authorities who may act as processors based inside or outside the EU who require reporting of processing activities in certain circumstances.
Other sharing of Personal Data
We may share personal data we hold with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries.
We may also disclose personal data we hold to third parties, with your consent, or on the basis of us an otherwise lawful basis under the Data Protection Legislation. For example, we may do so:
(a) in order to facilitate, provide and improve the Website and the goods and/or services we provide to you;
(b) in order to improve the functionality of the Website;
in order to analyse the manner in which our Website and goods/services are used by users;
in the event that we sell or buy any business or assets, in which case we may disclose personal data we hold to the prospective seller or buyer of such business or assets;
if we or substantially all of our assets are acquired by a third party, in which case personal data we hold will be one of the transferred assets; and
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 any contract with the data subject or other agreements; or to protect our rights, property, or safety of our employees, customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
CHANGES TO THIS POLICY
CONCERNS OR COMPLAINTS
If you have any concerns or complaints relating to this policy, its subject matter, or the manner in which we collect, control and/or process your personal data, please do let us know by sending an email to GDPR@ashleywildegroup.com.
You also have the right to lodge a complaint with a supervisory authority if you consider that the processing of your personal data has infringed the Data Protection Legislation. In the UK, the relevant supervisory authority is the Information Commissioner’s Office.