GDPR: DATA PRIVACY NOTICE FOR CLIENTS AND SUPPLIERS
Wiper and True ("We") are committed to protecting and respecting your privacy.
The rules on processing of personal data are set out in the General Data Protection Regulation (the “GDPR”).
Data controller - A controller determines the purposes and means of processing personal data.
Data processor - A processor is responsible for processing personal data on behalf of a controller.
Data subject – Natural person
Categories of data: Personal data and special categories of personal data
Personal data - The GDPR applies to ‘personal data’ meaning any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier (as explained in Article 6 of GDPR). For example name, passport number, home address or private email address. Online identifiers include IP addresses and cookies.
Special categories personal data - The GDPR refers to sensitive personal data as ‘special categories of personal data’ (as explained in Article 9 of GDPR). The special categories specifically include genetic data, and biometric data where processed to uniquely identify an individual. Other examples include racial and ethnic origin, sexual orientation, health data, trade union membership, political opinions, religious or philosophical beliefs.
Processing - means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Third party - means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.
Who are we?
Wiper and True is the data controller. This means we decide how your personal data is processed and for what purposes. Our contact details are: 2 York Street, St Werburgh’s Bristol BS2 9XT. For all data matters contact Michael Wiper our Data Representative on email@example.com.
The purpose(s) of processing your personal data
We use your personal data for the following purposes:
- To deliver and provide products or services;
- Establish and maintain customer accounts;
- To contact you about our products and services
- To maintain our own accounts and records;
- To inform individuals of products, news, events or activities;
- For business management, planning and forecasts, including accounting and auditing.
You may give us information about you by filling in forms on our site www.wiperandtrue.com (our site) or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you register to use our site, subscribe to our service, search for a product, place an order on our site, participate in discussion boards or other social media functions on our site, enter a competition, promotion or survey, and when you report a problem with our site.
The categories of personal data concerned
With reference to the categories of personal data described in the definitions section, we process the following categories of your data:
Personal data - Name, addresses, telephone number, email address, financial and credit card information, bank account details, gender, date of birth.
We have obtained your personal data from information that you have given us through, for example, buying our products, responding to a survey, entering a competition or emailing us.
We may also have obtained data from publically available information such as Companies House, Google or industry forums.
What is our legal basis for processing your personal data?
Personal data (article 6 of GDPR)
Our lawful basis for processing your general personal data:
- Consent of the data subject;
- Processing necessary for the performance of a contract with the data subject or to take steps to enter into a contract. For example: paying invoices, delivering products etc
- Processing necessary for compliance with a legal obligation. For example audits, HMRC compliance etc
- Processing necessary for the purposes of the legitimate interests of the data controller or a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of the data subject. For example to supply you with a product that you need as part of an ongoing/active relationship
Sharing your personal data
Your personal data will be treated as strictly confidential, and will be shared only according to our specified instructions with carefully selected third parties such as those involved in processing accounts and payments, professional advisors or when it is necessary to involve a third party service provider to facilitate or offer our services such as delivering your orders and booking tickets for events.
We will never share your personal information with a third party that is not directly related to us delivering on our obligation to you or to let you know about Wiper and True.
How long do we keep your personal data?
We keep your personal data for no longer than reasonably necessary according to our data retention policy and in order to fulfil our legal, operational or contractual commitment to you as a customer, client or supplier.
Providing us with your personal data
We require your personal data as it is a requirement necessary to enter into a contract with us.
Your rights and your personal data
Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data:
- The right to request a copy of the personal data which we hold about you;
- The right to request that we correct any personal data if it is found to be inaccurate or out of date;
- The right to request your personal data is erased where it is no longer necessary to retain such data;
- The right to withdraw your consent to the processing at any time, where consent was your lawful basis for processing the data;
- The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), (where applicable i.e. where the processing is based on consent or is necessary for the performance of a contract with the data subject and where the data controller processes the data by automated means);
- The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
- The right to object to the processing of personal data, (where applicable i.e. where processing is based on legitimate interests (or the performance of a task in the public interest/exercise of official authority); direct marketing and processing for the purposes of scientific/historical research and statistics).
Transfer of Data Abroad
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by implementing safeguard: any Third Party we work with must have an annually certified agreement that is GDPR compliant, such as the EU-U.S. Privacy Shield Framework. Please contact us on firstname.lastname@example.org if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
Automated Decision Making
We do not use any form of automated decision making in our business.
If we wish to use your personal data for a new purpose, not covered by this Data Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions.
How to make a complaint
To exercise all relevant rights, queries or complaints please in the first instance contact our Data Representative, Michael, on email@example.com.
If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 03031231113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England.