Introduction

Lowes Hall Ltd ("We") are committed to protecting and respecting your privacy.

This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting http://www.loweshall.co.uk you are accepting and consenting to the practices described in this policy.

By using our website and agreeing to this policy, you consent to our use of cookies in accordance with the terms of this policy.

How we use your personal data

In this section we will set out:

(a) The categories of personal data that we may process;

(b) In the case of personal data that we did not obtain directly from you, the source and specific categories of that data;

(c) The purposes for which we may process personal data; and the lawful basis of the processing.

Usage Data

We may process data about your use of our website and services. The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. This usage data may be processed for the purposes of analysing the use of the website and services. The lawful basis for this processing is our legitimate interests, namely monitoring and improving our website and services.

Account Data

We may process your account data. The account data may include your name, telephone number and email address. The source of the account data is you or your employer. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The lawful basis for this processing is our legitimate interests, namely the proper administration of our website and business.

Enquiry Data

We may process information contained in any enquiry you submit to us regarding goods and/or services. The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is consent.

Transaction Data

We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website. The transaction data may include your contact details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The lawful basis for this processing is the performance of a contract between you and namely our interest in the proper administration of our business.

Marketing Data

We may process information that you provide to us for the purpose of subscribing to our email offers and/or newsletters. The Marketing data may be processed for the purposes of sending you the relevant offers and/or newsletters. The lawful basis for this processing is consent.

Employee Data

We may process information that our staff provides to us for the purpose of administering their employment. The employee data may be processed for the purposes of maintaining payroll, pension administration, sickness and holiday records. The lawful basis for this processing is the performance of a contract between our employees and namely our interest in the proper administration of our business. We also hold elements of employee’s special category data; our basis for processing this is the explicit consent of our employees.

Additional Processing

We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The lawful basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

In addition to the specific purposes for which we may process your personal data set out in this Section, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

Please do not supply any other person's personal data to us, unless we prompt you to do so.

Sharing your personal data with others

We may share your personal data with a number of 3rd Parties (data processors) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy. Where we share your data with a 3rd Party we will ensure that controls and contracts are in place to protect your privacy. The following is a list of the type of processors with whom we share your data, if we change this list we will update this policy and inform you of the changes:

Suppliers – We use a number of 3rd party suppliers, whom from time to time provide a direct delivery service to our customers. In these circumstances we will share your contact data in order to allow for successful delivery of products and services

Engage Gateway – We use this hosted marketing application to provide our customers with relevant offers and direct marketing emails.

PayPal – Financial transactions relating to our website and services are handled by our payment services providers, PayPal. You can find information about the payment services providers' privacy policies and practices at; https://www.paypal.com/ie/webapps/mpp/ua/privacy-full

Interactive Transaction Solutions (ITS) – We use this system to carry out all card transactions with our customers. This is PCI-DSS compliant system; you can find information about the payment services providers' privacy policies at; https://polnet.its-online-services.com/

Robson Laidler LLP – This is our Accountant, with whom we share data for the purpose of staff payroll and annual financial accounts. You can find further information and their Privacy policy at this location; https://robson-laidler.co.uk/privacy-policy/

In addition to the specific disclosures of personal data set out above, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

Retaining and deleting personal data

This Section sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes. We will retain your personal data as follows:

(a) All categories of data (with the exception of enquiry data) will be retained for at least 5 years following your last interaction with us, at the end of which it will be deleted from our systems.

(b) The period of retention of enquiry data will be determined based on your given consent.

Notwithstanding the other provisions of this Section, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

Amendments

We may update this policy from time to time by publishing a new version on our website, we will email you if this is the case. You should check this page to ensure you are happy with any changes to this policy.

Your rights

In this Section, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. You can read guidance from the Information Commissioner’s office at www.ico.gov.uk for a fuller explanation of your rights.

Your individual rights under data protection law are:

  • The right to be informed - Individuals have the right to be informed about the collection and use of their personal data. This is a key transparency requirement under the GDPR and is cover by this Privacy Policy
  • The right of access - Individuals have the right to access their personal data; this is commonly referred to as subject access request. You can make a request verbally or in writing and these will be free of charge. We will then have one month to respond.
  • The right to rectification – This includes a right for individuals to have inaccurate personal data rectified, or completed if it is incomplete
  • The right to erasure - The right to erasure is also known as ‘the right to be forgotten’. You can make a request for erasure verbally or in writing, we then have one month to respond to your request. This right is not absolute and only applies in certain circumstances.
  • The right to restrict processing - Individuals have the right to request the restriction or suppression of their personal data. This is not an absolute right and only applies in certain circumstances. When processing is restricted, we are permitted to store the personal data, but not use it. You can make a request for erasure verbally or in writing, we then have one month to respond to your request.
  • The right to data portability - The right to data portability allows individuals to obtain and reuse their personal data for their own purposes across different services, this only applies to data you have provided us. This will be provided in an open and accessible format.
  • The right to object - This gives individuals the right to object to the processing of their personal data in certain circumstances. You have an absolute right to stop you data being used for direct marketing purposes.
  • Rights in relation to automated decision making and profiling. – This is not something we do, see ICO for further details

Making a complaint

If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with the ICO (https://ico.org.uk/make-a-complaint/).

Withdraw Consent

To the extent that the lawful basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

Data protection officer

Our data protection officer's contact details are:

The DPO, Lowes Hall Ltd, 28 Limes Street, Newcastle upon Tyne, NE1 2PL or

Email: sales@loweshall.co.uk