Thank you for visiting www.portfoliohome.com (our “Site”). We appreciate the opportunity to interact with you on the Internet and we are committed to protecting and safeguarding your privacy. The purpose of this Privacy Notice is to inform you about the types of information we might collect about you, how we may use that information and whether we disclose that information to anyone. It also tells you about your rights and how the law protects you.
To assist you further in understanding this Privacy Notice, we have set out in the Schedule a glossary of terms used in this Privacy Notice, examples of types of personal data we collect, how we use it, the lawful basis for processing such data and further details of your rights.
by email to: email@example.com
by post to: Portfolio Home, Parkway, Denton, M34 3SG
or, by using the “Contact Us” submission form on our Site.
You have the right to make a complaint at any time to the ICO (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Your duty to inform us of changes
Our Site may include links to third-party websites, plug-ins and applications. By clicking on these links or enabling connections you may be allowing third parties to collect or share your personal data. We have no control these third-party websites, plug-ins or applications and are not responsible for their privacy notices, therefore you should also read their privacy notices to understand what personal data they collect about you and how they use it.
We may collect, use, store and transfer the types of personal data about you listed in Part 1 of Schedule 1.
We also collect, use and share aggregated data. However, if we combine aggregated data with your personal data so that it can directly or indirectly identify you, we treat this as your personal data.
We do not collect any special categories of personal data or any information about criminal convictions and offences.
Failure to provide personal data
If we are required by law, or under the terms of a contract we have with you, to collect your personal data and you fail to provide it, we may not be able to enter into perform the contract with you and, we may have to cancel a product or service. We will notify you of this at the relevant time.
We collect personal data in the following ways:
|direct interactions||you may provide personal data when you complete online forms (including through our “Contact Us” page and our Track Systems Order Form), place an order for our products, create a user account, log in to our customer portal, join our mailing list, complete surveys or otherwise or correspond with us (by post, phone or email)|
|publicly available sources||we may collect personal data from publicly availably sources such as credit reference agencies.|
|third parties||we may receive personal data from: (a) analytics providers based inside or outside the EU (such as Google); (b) advertising networks outside the EU; and (c) search information providers outside the EU; (d) our suppliers such as payment providers, delivery services, website and hosting support and maintenance providers.|
- How we use your personal data
- to perform the contract we are to enter into or
have entered into with you;
- to comply with a legal obligation; and
- where it is necessary to carry out our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Part 2 of Schedule 1 sets out the lawful basis we will rely on to process your personal data.
We may analyse your personal data to form a view on what products we think may be of interest to you. You will only receive marketing communications from us, if you have requested information from us or purchased goods from us, if you consent to marketing at the time we collect your personal data and you have not subsequently opted out or withdrawn your consent or if we have another basis to send you the marketing communications (which includes “soft opt-in” where we have provided products to you in the past and you have not opted-out).
We will not share your personal data with third parties for their marketing purposes.
You can opt out of email marketing by clicking the unsubscribe button within the particular marketing email. You can also withdraw your consent to marketing at any time by contacting us using the contact details set out at the start of this Policy.
Even if you opt out of receiving marketing, we may still use your personal data for other purposes provided we have a lawful basis to do so.
We will only use your personal data for the purpose that we originally collected it for, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
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 use your personal data in this manner.
We may have to share your personal data with third parties further details of which are set out in Part 4 of Schedule 1. 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. They can only process your personal data for specified purposes and in accordance with our instructions.
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 leastone of the following safeguards is implemented:
- we will only transfer your personal data to
countries that have been deemed to provide an adequate level of protection for
personal data by the European Commission;
- we use specific contracts approved by the European Commission which give personal data the same protection it has in Europe with our services providers;
- we may transfer data to US based service providers under 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.
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. We also limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know and they can only process your personal data on our instructions and will be subject to a duty of confidentiality.
- Data retention
We may update our retention practices from time to time and you can request more details from us by contacting us. However, we are legally required to keep basic information about our customers (including contact, identity, financial and transaction data) for six years after they cease being customers, for tax purposes.
We may also anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes. We can use anonymised information indefinitely without further notice to you.
You will not have to pay a fee to exercise any of your rights. However, if your request is clearly unfounded, repetitive or excessive, we may charge a reasonable fee for this information or refuse to comply with your request.
We may request specific information from you to help us confirm your identity when you contact us and ensure. This is a security measure to ensure that personal data is not disclosed to any person who does not have the right to receive it.
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.
|contact data||billing address, delivery address, email address and telephone number|
|financial data||bank account and payment card details|
|identity data||first name, maiden name, last name, username or similar identifier|
|marketing and communication data||your preferences in receiving marketing from us and our group companies and your communication preferences|
|profile data||your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses|
|technical data||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 Site|
|transaction data||details about payments to and from you and other details of products you have purchased from us|
The lawful basis upon which we may rely on to process your personal data are:
|consent||you have given your express consent for us to process your personal data for a specific purpose.|
|contract||the processing is necessary for us to perform our contractual obligations with you under our contract, or because you have asked us to take specific steps before entering into a contract with you.|
|legal obligation||the processing is necessary for us to comply with legal or regulatory obligation.|
|legitimate interests||the processing is necessary for our or a third party’s legitimate interest e.g. in order for us to provide the best service to you via our Site. Before we process your personal data on this basis we make sure we consider and balance any potential impact on you, and we will not use your personal data on this basis where such impact outweighs our interest.|
Set out below are specific details of the processing activities we undertake with your personal data and the lawful basis for doing this.
|Purpose/Activity||Type of data||Lawful basis for processing|
|to register you as a new customer||identity & contact||to perform our contract with you|
|to process and deliver your order, manage payments, fees and charges and debt recovery||identity, contact, financial, transaction and marketing & communications||(i) to perform our contract with you; (ii) as necessary for our legitimate interest in recovering debts due to us.|
|to administer and protect our business and this Site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||identity, contact & technical||(i) as necessary for our legitimate interests in running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise (ii) as necessary to comply with any legal obligations|
|to deliver relevant website content/advertisements to you and measure or understand the effectiveness of our advertising||identity, contact, profile, usage, marketing & communications & technical||as necessary for our legitimate interests in studying how customers use our products, to develop them, to grow our business and to inform our marketing strategy|
|to use data analytics to improve our Site, products, marketing, customer relationships and experiences||technical & usage||as necessary for our legitimate interests to define types of customers for our products, to keep our Site updated and relevant, to develop our business and to inform our marketing strategy|
|to make suggestions and recommendations to you about goods that may be of interest to you, including promotional offers||identity, contact, technical, usage & profile||as necessary for our legitimate interests to develop our products and grow our business|
You have the following legal rights in relation to your personal data:
|access your data||you can ask for access to and a copy of your personal data and can check we are lawfully processing it|
|correction||you can ask us to correct any incomplete or inaccurate personal data we hold about you|
|erasure||you can ask us to delete or remove your personal data where: We may not always be able to comply with your request for specific legal reasons, which will be notified to you at the time of your request.|
|object||you can object to the processing of your personal data where: In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms and in such circumstances, we can continue to process your persona data for such purposes.|
|restrict processing||you can ask us to us to suspend or restrict the processing of your personal data, if:|
|request a transfer||you can request a transfer of your personal data which is held in an automated manner and which you provided your consent for us to process such personal data or which we need to process to perform our contact with you, to you or a third party. We will provide your personal data in a structured, commonly used, machine-readable format.|
|withdraw your consent||you can withdraw your consent at any time (where we are relying on consent to process your personal data). This does not affect the lawfulness of any processing carried out before you withdraw your consent.|
|service providers||acting as processors including delivery companies, IT support and system administration service providers, web hosting and data analytics service providers and marketing automation companies|
|professional advisors||acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services|
|HM Revenue & Customs, regulators and other authorities||acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances|
|group companies||other companies in the Evans Group of Companies acting as joint controllers or processors and who are based in the UK for system administration and business analysis purposes and for the purposes of offering similar products or service|
|third parties||third parties 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 Notice|
|aggregated data||information such as statistical or demographic data which may be derived from personal data but which cannot by itself identify a data subject|
|controller||a body that determines the purposes and means of processing personal data|
|data subject||an individual living person identified by personal data (which will generally be you)|
|personal data||information identifying a data subject from that data alone or with other data we may hold but it does not include anonymised or aggregated data|
|processor||a body that is responsible for processing personal data on behalf of a controller.|
|special categories of personal data||information about race, ethnicity political opinions, religious or philosophical beliefs, trade union membership, health, genetic, biometric data, sex life, sexual orientation.|
|ICO||Information Commissioner’s Office, the UK supervisory authority for data protection issues.|