Privacy Policy

Date Published: 24th April 2018

Introduction

Criterion Systems Limited understands that your information is important and in the wrong hands it poses a risk to your rights and freedoms. In order to help you protect your information this notice will explain what information we collect, why we collect it, what we do with it, how long we keep it for, who can access it and what your rights are. We hope the following sections will answer any questions you have but if not, please do get in touch with us.

Explaining the legal bases we rely on

The law on data protection sets out a number of different reasons for which a company may collect and process your personal data. These include:

Consent

In such situations e.g. when you sign up to receive our newsletters or product catalogue, we can collect and process your data with your consent.

Contractual obligations

In certain situations, e.g. when you order from our website, we’ll collect your name and address details to deliver your item and forward them to our courier for delivery.

Legal compliance

If the law requires us to, e.g. to pass on details of people involved in fraud affecting Criterion Systems Limited to law enforcement, we may need to collect and process your data.

Legitimate interest

In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests. For example, we will use your purchase history to send you or make available specific offers. We will also use your address details to send you direct marketing information by post, such as our Annual Product Catalogue to inform you about products and services that we think might be of interest to you.

When do we collect your personal data?

• When you visit any of our websites and use your account to buy products and services.
• When you make an online purchase and check out as a guest (in which we just collect transaction-based data).
• When you create an account with us.
• When you purchase a product or service by phone but don’t have (or don’t use) an account.
• When you engage with us on social media
• When you download any of our product information guides
• When you contact us by any means with any queries, complaints or suggestions etc
• When you ask us to email or send you information about a product or service.
• When you book any kind of appointment with us or book to attend an event or exhibition.
• When you choose to complete any surveys, we send you.
• When you comment on or review our products and services
• When you fill in any forms.
• When you’ve given a third-party permission to share with us the information they hold about you.
• What sort of personal data do we collect?

We need to collect data in a variety of situations, for example if you have a web account with us:

• Name
• Billing/Delivery Address
• Orders and receipts
• Phone Number
• Email Address
• For your security we’ll also keep an encrypted record of your login password
• Details of your interactions with us through our contact centres, online or in person

For example, we collect notes from our conversations with you, details of any comments, complaints, suggestions you make, details of purchases you made, items viewed or added to your basket, wish list choices, brands and products you show interest in, web pages you visit and how and when you contact us.

• Copies of documents you provide to prove your age or identity where the law requires this. (including your passport and driver’s licence). This will include details of your full name, address, date of birth and facial image.
• Details of your purchase and shopping preferences
• Details of your visits to our websites and which site you came from to ours.
• Information gathered by the use of cookies in your web browser.
• Personal details which help us to recommend items of interest. We’ll only ask for and use this information to tailor your purchasing experience with us. It’s always your choice whether you share such details with us.
• Payment card information (To process payments quickly and securely via our payment processor partners, data is secure with level 1 PCI DSS certification.

Your comments and product reviews

To deliver the best possible web experience, we collect technical information about your internet connection and browser as well as the country and telephone code where your computer is located, the web pages viewed during your visit, the advertisements you clicked on, and any search terms you entered. Your social media username, if you interact with us through those channels, to help us respond to your comments, questions or feedback.

How and why do we use your personal data

• We want to give you the best possible customer experience.
• The data privacy law allows us as part of our legitimate interest to combine data we have about you.
• For example, if you’ve asked us to let you know when an item is back in stock, we can’t do that if you’ve withdrawn your general consent to hear from us.

Here’s how we’ll use your personal data and why:

• To process any orders that you make by using our websites or over the phone or in house. If we don’t collect your personal data during checkout, we won’t be able to process your order and comply with our legal obligations
• To respond to your queries, refund requests and complaints. Handling the information, you sent enables us to respond. We may also keep a record of these to inform any future communication with us and to demonstrate how we communicated with you throughout. We do this on the basis of our contractual obligations to you, our legal obligations and our legitimate interests in providing you with the best service and understanding how we can improve our service based on your experience.
• To protect our business and your account from fraud and other illegal activities. This includes using your personal data to maintain, update and safeguard your account. We’ll also monitor your browsing activity with us to quickly identify and resolve any problems and protect the integrity of our websites. We’ll do all of this as part of our legitimate interest. to general enquiries and providing additional details
• With your consent, we will use your personal data, preferences and details of your transactions to keep you informed by email, web, text, telephone and through our contact centres about relevant products and services including tailored special offers, promotions, events and so on.
• To process payments and to prevent fraudulent transactions. We do this on the basis of our legitimate business interests. This also helps to protect our customers from fraud.
• To send you relevant, personalised communications by post in relation to updates, offers, services and products. We’ll do this on the basis of our legitimate business interest.
• To send you communications required by law or which are necessary to inform you about our changes to the services we provide you. For example, updates to this Privacy Notice, product recall notices, and legally required information relating to your orders. These service messages will not include any promotional content and do not require prior consent when sent by email or text message. If we do not use your personal data for these purposes, we would be unable to comply with our legal obligations.
• To develop, test and improve the systems, services and products we provide to you. We’ll do this on the basis of our legitimate business interests.
• To comply with our contractual or legal obligations to share data with law enforcement.
• Enhance employee and customer engagement
• Provide confirmation of ownership in the case of warranty
• How we protect your personal data

We know the importance of data security and why it matters, which is why we treat your data with the utmost care and take all appropriate steps to protect it. We secure access to all transactional areas of our websites and apps using ‘https’ technology.

Access to your personal data is password-protected, and sensitive data (such as payment card information) is secured by SSL encryption. We regularly monitor our system for possible vulnerabilities and attacks, and we carry out penetration testing to identify ways to further strengthen security. We will not transfer your data to another country. We do not use automated decision making

How long do we keep your data?

Whenever we collect or process your personal data, we’ll only keep it for as long as is necessary for the purpose for which it was collected.

At the end of that retention period, your data will either be deleted completely or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning.

Do we share any personal data?

We sometimes share your personal data with trusted third parties. For example: delivery couriers, system engineers, fraud management, handling complaints, mailing houses and so on.

Who do we share your personal data with?

Here’s the policy we apply to those organisations to keep your data safe and protect your privacy:

• We provide only the information they need to perform their specific services.
• They may only use your data for the exact purposes we specify in our contract with them.
• We work closely with them to ensure that your privacy is respected and protected at all times.
• If we stop using their services, any of your data held by them will either be deleted or rendered anonymous.

Examples of the kind of third parties we work with are:

• IT companies who support our website and other business systems.
• Operational companies such as delivery couriers.
• Direct marketing companies who help us manage our electronic communications with you.
• Google/Facebook to show you products that might interest you while you’re browsing the internet. This is based on either your marketing consent or your acceptance of cookies on our websites. See our Cookies Notice for details.
• Data insight companies to ensure your details are up to date and accurate.

What are your rights?

You have the right to request:

• Access to the personal data we hold about you, free of charge in most cases.
• The correction of your personal data when incorrect, out of date or incomplete.
• For example, when you withdraw consent, or object and we have no legitimate overriding interest, or once the purpose for which we hold the data has come to an end (such as the end of a warranty).
• That we stop using your personal data for direct marketing (either through specific channels, or all channels).
• That we stop any consent-based processing of your personal data after you withdraw that consent.

You have the right to request a copy of any information about you that the company holds at any time, and also to have that information corrected if it is inaccurate.

To ask for your information or to make an amendment, please contact:

Data Protection Officer, Criterion Systems Limited, New Mansion House, Wellington Road South, Stockport. SK1 3UA.

If we choose not to action your request, we will explain to you the reasons for our refusal.

Your right to withdraw consent

Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent.

Where we rely on our legitimate interest

In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.

Direct marketing

You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We must always comply with your request.

Checking your identity

To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Notice. If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.

Contact information

We hope this Privacy Notice has been helpful in setting out the way we handle your personal data and your rights to control it.

If you have any questions that haven’t been covered, please contact our Data Protection Officer who will be pleased to help you:

Or write to us at: Data Protection Officer, Criterion Systems Ltd, Mansion House, Wellington Road South, Stockport, SK1 3UA

This notice was last updated on 24/04/2018