PRIVACY POLICY
Your privacy and personal information
1.1 Your privacy and personal information are important to us. Any personal information that you provide to us will be dealt with in line with this Privacy Policy which explains what personal information we collect from you, how and why we collect, store, use and share such information, your rights in relation to your personal information and how to contact us in the event you have a query or complaint about the use of your personal information.
1.2 We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share any information relating to you (your personal data) in connection with your use of our website. It also explains your rights in relation to your personal data and how to contact us in the event you have a complaint9.3 We collect, use and are responsible for certain personal data about you. When we do so we are subject to any prevailing data laws in any jurisdiction.
1.3 Given the nature of our website, we do not expect to collect the personal data of anyone under 13 years old. If you are aware that any personal data of anyone under 13 years old has been shared with our website please let us know so that we can delete that data.
1.4 This version of our privacy policy is primarily written for adults, including parents and guardians of child users. If you are a child (under 18 years old) you are welcome to read this policy if you find it useful, but we recommend you to contact us for information on minors for minors.
This privacy policy is divided into the following sections:
• What this policy applies to
• Personal data we collect about you
• How your personal data is collected
• How and why we use your personal data
• Marketing
• Who we share your personal data with
• How long your personal data will be kept
• Cookies [ and other tracking technologies]
• Your rights
• Keeping your personal data secure
• How to complain
• Changes to this privacy policy
• How to contact us
1.5 What this policy applies to
This privacy policy relates to your use of our website only. Throughout our website we may link to other websites owned and operated by certain trusted third parties Those third party websites may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to those third party websites, please consult their privacy policies as appropriate.
1.6 Personal data we collect about you
The personal data we collect about you depends on the particular activities carried out through our website. We may collect and use the following personal data about you:
• [your name, address and contact information, including email address and telephone number [and company details]]
• [any delivery addresses specified for your order]
• [information to check and verify your identity, eg date of birth]
• [your gender[, if you choose to give this to us]]
• [location data[, if you choose to give this to us]]
• [your billing information, transaction and payment card or other payment method information]
• [bank account and payment details]
• [details of any information, feedback or other matters you give to us by phone, email, post or via social media]
• [your account details, such as username and login details]
• [your activities on, and use of, our website]
• [your personal[ or professional] interests]
• [your professional online presence, eg LinkedIn profile]
• [information about the services we provide to you]
• [your contact history, purchase history and saved items]
• [information about how you use our website and technology systems]
• [your responses to surveys, competitions and promotions]
You must provide this personal data to use our website and the services on it unless we tell you that you have a choice.
Sometimes you can choose if you want to give us your personal data and let us use it. Where that is the case we will tell you and give you the choice before you give the personal data to us. We will also tell you whether declining to share that personal data will have any effect on your use of our website or any services on it.
We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below.
1.7 How your personal data is collected
We collect personal data from you:
• directly, when you enter or send us information, such as when you [ eg register with us, contact us (including via email), send us feedback, purchase products or services via our website, post material to our website and complete customer surveys or participate in competitions via our website], and
• indirectly, such as your browsing activity while on our website; we will usually collect information indirectly using the 8 technologies explain in the section on ‘Cookies[ and other tracking technologies]’below
We also collect personal data about you from other sources including but not limited to :
• the various online portals we are listed on
1.8 How and why we use your personal data
We only use your personal data if we have a proper reason, eg:
• where you have given consent
• to comply with our legal and regulatory obligations
• for the performance of a contract with you or to take steps at your request before entering into a contract, or
• for our legitimate interests or those of a third party A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You can obtain details of this assessment by contacting us (see ‘How to contact us’ below).
9.10 Marketing
We will use your personal data to send you updates (by email, text message, telephone or post) about our products AND/OR services, including exclusive offers, promotions or new products AND/OR services.
We have a legitimate interest in using your personal data for marketing purposes (. This means we do not need your consent to send you marketing information. If we change our marketing approach in the future so that consent is needed, we will ask for this separately and clearly.
You have the right to opt out of receiving marketing communications at any time by:
• contacting us
• using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts, or
• updating your marketing preferences on our [insert link to preference centre]
We may ask you to confirm or update your marketing preferences if you ask us to provide further products AND/OR services in the future, or if there are changes in the law, regulation, or the structure of our business.
We will always treat your personal data with the utmost respect and never sell OR share it with other organisations for marketing purposes.
For more information on your right to object at any time to your personal data being used for marketing purposes, see ‘Your rights’ below.
1.10 Who we share your personal data with
We routinely share personal data with: • third parties we use to help deliver our products AND/OR services to you, eg payment service providers, warehouses and delivery companies
• other third parties we use to help us run our business, eg [marketing agencies or] website hosts and website analytics providers
• our bank[s] •
any organization that falls in the regular course of business.
We only allow those organisations to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on them to ensure they can only use your personal data to provide services to us and to you.'
We or the third parties mentioned above occasionally also share personal data with:
• our [and their ]external auditors, eg in relation to the audit of our[ or their] accounts, in which case the recipient of the information will be bound by confidentiality obligations
• our and their professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations
• law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations
• other parties that have or may acquire control or ownership of our business (and our or their professional advisers) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised but this may not always be possible. The recipient of any of your personal data will be bound by confidentiality obligations
1.11 Who we share your personal data with—further information
If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).
1.12 How long your personal data will be kept
We will not keep your personal data for longer than we need it for the purpose for which it is used.
Different retention periods apply for different types of personal data. If you stop using your account we will delete or anonymise your account data after seven years.
Following the end of the of the relevant retention period, we will delete or anonymise your personal data.
1.13 Cookies[ and other tracking technologies]
A cookie is a small text file which is placed onto your device (eg computer, smartphone or other electronic device) when you use our website. We use cookies on our website. These help us recognise you 11 and your device and store some information about your preferences or past actions.
For example, we may monitor [insert details, eg how many times you visit the website, which pages you go to, traffic data, location data and the originating domain name of your internet service provider]. This information helps us to [insert details, eg build a profile of our users]. [Some of this data will be aggregated or statistical, which means that we will not be able to identify you individually].
Please read this cookie policy carefully as it contains important information on who we are and how we use cookies on our website.. Throughout our website we may link to other websites owned and operated by certain trusted third parties for example to make additional products and services available to you. These other third party websites may also use cookies or similar technologies in accordance with their own separate policies. For privacy information relating to these other third party websites, please consult their policies as appropriate.
1.14 Consent to use cookies and changing settings
We will ask for your consent to place cookies or other similar technologies on your device, except where they are essential for us to provide you with a service that you have requested.
You can withdraw any consent to the use of cookies or manage any other cookie preferences It may be necessary to refresh the page for the updated settings to take effect.
1.15 How to turn off all cookies and consequences of doing so
If you do not want to accept any cookies, you may be able to change your browser settings so that cookies (including those which are essential to the services requested) are not accepted. If you do this, please be aware that you may lose some of the functionality of our website.9.17 Your rights
You generally have the following rights, which you can usually exercise free of charge:
| Access to a copy of your personal data | The right to be provided with a copy of your personal data |
| Correction (also known as rectification) | The right to require us to correct any mistakes in your personal data |
| Erasure (also known as the right to be forgotten) | The right to require us to delete your personal data—in certain situations |
| Restriction of use | The right to require us to restrict use of your personal data in certain circumstances, eg if you contest the accuracy of the data |
| Data portability | The right to object: —at any time to your personal data being used for direct marketing (including profiling) —in certain other situations to our continued use of your personal data, eg where we use your personal data for our legitimate interests unless there are compelling legitimate grounds for the processing to continue or the processing is required for the establishment, exercise or defence of legal claims |
| Not to be subject to decisions without human involvement | The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you We do not make any such decisions based on data collected by our website |
| The right to withdraw consents | If you have provided us with a consent to use your personal data you have a right to withdraw that consent easily at any time You may withdraw consents by [insert details as relevant depending on consents] Withdrawing a consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn. |
For further information on each of those rights, including the circumstances in which they do and do not apply, please contact us (see ‘How to contact us’ below).
If you would like to exercise any of those rights, please email, call or write to us—see below: ‘How to contact us’. When contacting us please:
• provide enough information to identify yourself [(eg your full name, address and customer or matter reference number)] and any additional identity information we may reasonably request from you, and
• let us know which right(s) you want to exercise and the information to which your request relates.
1.17 Keeping your personal data secure
We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine need to access it.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
1.18 How to complain
Please contact us if you have any queries or concerns about our use of your personal data (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.
1.19 Changes to this privacy policy
We may change this privacy policy from time to time—when we make significant changes we will take steps to inform you.
1.20 How to contact us
You can contact usby post, email or telephone if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.
Our contact details are shown below:
| Name | contact details |
| Neil Dawes Bhutani | 129 Saidulajiab, M.B Road, New Delhi 110030 ndb@dawesco.com |