Data Protection Policy

1. PURPOSE OF DOCUMENT

The purpose of this document is to define the data protection procedures for Purbeck Systems Design Ltd (the company) and it’s retail outlet the Purbeck Mobility Centre.

2. INTRODUCTION

2.1 Changes to this privacy notice

We may change this privacy notice from time to time by updating this document in order to reflect changes in the law and/or our privacy practices. We encourage you to check this privacy notice for changes whenever you visit our website – www.purbeckmobility.com

2.2 Purbeck Systems Design Ltd and our Data Protection Officer

Our registered company name is Purbeck Systems Design Ltd, 25 Durberville Drive, Swanage BH19 1QN and we are a data controller of your personal data.

The company director(s) are data protection officers (“DPO”). You can contact the DPO by e-mailing shop@purbeckmobility.com or by writing to our company address and marking it for the attention of the DPO.

3. MANAGING YOUR PERSONAL DATA

3.1 What kinds of personal information about you do we retain?

Personal information that we’ll process and may retain in connection with our products and services, if relevant, includes:

• Personal and contact details, such as age, title, full name, contact details and contact details history
• Products and services you have purchased from us and the associated payment methods used – this is limited to method of payment (cash/cheque/BACS/Card) only.
• The usage of our products and services, including any installations or rentals, sales, call outs or repairs.
• Information about your health or if you are a vulnerable customer

3.2 What is the source of your personal information?

We’ll collect personal information from the following general sources:

• when you fill in a form on our website
• when you contact us by phone, email or in writing
• when you use post or react to our social media channels
• when you order goods or services from us

3.3 What do we use your personal data for?

We may use your personal data, including any of the personal data listed above, for the following purposes:

• Managing our products and services
• Updating your records, and recovering debt
• To perform and/or test the performance of, our products, services and internal processes
• To improve the operation of our business
• For management and auditing of our business operations including accounting
• For market research and analysis and developing statistics
• For direct marketing communications only if you have specifically authorised us to contact you for such purposes
• To develop new products and services and to review and improve current products and services
• To comply with legal and regulatory obligations, requirements and guidance
• To provide insight and analysis of our customers both for ourselves and for the benefit of business partners either as part of providing products or services, helping us improve products or services, or to assess or improve the operating of our business
• To share information, as needed, with business partners, service providers or as part of providing and administering our products and services or operating our business
• To facilitate the sale of one or more parts of our business

3.4 Legal grounds for our processing of your personal information

We rely on the following legal bases to use your personal data:

3.4.1 Where it is needed to provide you with our products or services, such as:

1. Updating your records, tracing your whereabouts to contact you about your account and doing this for recovering debt (where appropriate).
2. Sharing your personal information with business partners and services providers when you apply to purchase a product.
3. All stages and activities relevant to managing the product or service including enquiry, application, administration and management of accounts.

3.4.2 Where it is in our legitimate interests to do so, such as:

1. Managing your products and services relating to that, updating your records, tracing your whereabouts to contact you about your account and doing this for recovering debt (where appropriate).
2. To perform and/or test the performance of, our products, services and internal processes.
3. To follow guidance and recommended best practice.
4. For management and audit of our business operations including accounting.
5. To carry out monitoring and to keep records of our communications with you and our staff.
6. For market research and analysis and developing statistics.
7. For direct marketing communications only if you have specifically authorised us to contact you for such purposes.
8. Subject to the appropriate controls, to provide insight and analysis of our customers to business partners either as part of providing products or services, helping us improve products or services, or to assess or to improve the operating of our business.
9. Where we need to share your personal information with people or organisations in order to run our business or comply with any legal and/or regulatory obligations.

3.4.3 To comply with our legal obligations such as VAT exemption records compliance as determined by HMRC regulations.

3.5 When do we share your personal information with other organisations?

We may share information with the following third parties for the purposes listed:

1. Business partners or others who are a part of providing your products and services or operating our business.
2. Governmental and regulatory bodies such as the Information Commissioner’s Office and HMRC.
3. Other organisations and businesses who provide services to us such as debt recovery agencies, back up and server hosting providers, IT software and maintenance providers, and suppliers of other back office functions.

4. HOW AND WHEN YOU CAN WITHDRAW YOUR CONSENT

Where we’re relying upon your consent to process personal data, you can withdraw this at any time by contacting us using the details in section 2.2 for the DPO.

5. UPDATING YOUR PERSONAL INFORMATION

You should tell us so that we can update our records using the details in the Contact Us section of our website. We’ll then update your records if we can.

6. DO YOU HAVE TO PROVIDE YOUR PERSONAL INFORMATION TO US?

We’re unable to provide you with our products or services, particularly VAT exempt sales, if you do not provide certain information to us. In cases where providing some personal information is optional, we’ll make this clear.

7. MONITORING OF YOUR PERSONAL INFORMATION

We do not perform any monitoring by means of recording of calls or in person (face to face) meetings.

When you make a telephone payment we do not record the part of the conversation that includes your bank account number, sort code or payment card details.

We do not store electronically or otherwise within any of our premises or computer systems any specific details related to credit/debit cards or bank account information.

8. RETENTION OF PERSONAL INFORMATION

Unless we explain otherwise to you, we’ll hold your personal information based on the following criteria:

For as long as is necessary to fulfil any regulatory requirements that relate to the retention of your personal information, such as requirements to retain recordings of communications made using our systems.

For as long as we have reasonable business needs, such as managing our relationship with you and managing our operations or to communicate in relation to product recalls or training.

For as long as we provide goods and/or services to you.

9. YOUR RIGHTS

Here is a list of the rights that all individuals have under data protection laws. They don’t apply in all circumstances. The right of data portability is only relevant from May 2018.

• The right to be informed about the processing of your personal information
• The right to have your personal information corrected if it is inaccurate and to have incomplete personal information completed
• The right to object to processing of your personal information
• The right to restrict processing of your personal information
• The right to have your personal information erased (the “right to be forgotten”)
• The right to request access to your personal information and to obtain information about how we process it
• The right to move, copy or transfer your personal information (“data portability”)
• Rights in relation to automated decision making which has a legal effect or otherwise significantly affects you
• You have the right to complain to the Information Commissioner’s Office which enforces data protection laws: https://ico.org.uk/.

You have the right to object to certain purposes for processing, in particular to data processed for direct marketing purposes and to data processed for certain reasons based on our legitimate interests. You can contact us to exercise these rights.

10. MARKETING PREFERENCES

We will only use your home address, phone numbers, email address and social media or digital channels to contact you according to your marketing preferences. You can stop our marketing at any time by contacting us or by following the instructions in the communication.

11. CONTACT US

If you have any questions about this privacy notice, or if you wish to exercise your rights or contact the DPO, you can contact us by going to the Contact Us section of our website. Alternatively, you can write to Purbeck Systems Design Ltd, 25 Durberville Drive, Swanage, BH19 1QN marking it for the attention of the DPO.