Updated Privacy Policy
This month we’re updating our privacy policy in preparation for the EU’s General Data Protection Regulations (GDPR) that comes into effect on 25th May. This is to make it easier for you to understand what information we collect, why we collect it and where we collected it from. We have also taken this opportunity to improve our privacy check-up and notices as well as other protocols which we take to safeguard your data and protect your privacy.
Just to clarify we are not asking to collect more data or use your personal data differently, we’re simply being more specific and transparent on exactly how we use the information we collect, how long we keep that data, and the rights you have regarding it.
We’re also updating our procedures and plans to help make it easier for you to control the usage of your personal data, request access or deletion of your personal data as well as offering help in regard to who you should contact and how to contact them with any queries on your personal data or GDPR in general.
Lastly, these updates will be providing more clarity and certainty around the legal bases being used when processing your information in compliance with the new GDPR
If you have any questions in regard to the updates, deleting or viewing your information, opting out of our mailing list or GDPR in general, please do not hesitate to contact us and we will be more than happy to help
Kind Regards
Prolight Direct Ltd
About this privacy policy
This updated privacy policy will detail the updates and amendments to our policies and procedures in compliance with the EU’s General Data Protection Regulations (GDPR). Most policies remain similar to those under the previous Data Protection Act 1998 with only slight changes. We take your privacy seriously and will only use your personal information to administer your account and to provide the products and services you have requested from us. We will never sell, share or use your personal information other than as described here.
Our Procedures
Now operating in compliance with EU GDPR [May 2018] data protection guidelines. We are committed to maintaining your personal rights and allow all data subjects to change or withdraw their opt-in options at any time. We will also advise you on how make a formal complaint to the relevant authorities, namely the Information Commissioner’s Office (ICO), if you feel that we have not dealt with your request in the correct manner.
Do we collect sensitive data?
We do not collect any Sensitive Data about you. Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We do not collect any information about criminal convictions and offences.
Our Lawful basis
This section describes the lawful basis for processing your data and applies to the information about yourself that you choose to provide us with, or that you allow us to collect. This includes
Information you provide during any registration process
Information we collect about how you use the website
Information relating to purchases and other transactions
Information given and stored as part of our ongoing relationship
Consent
By submitting your personal data, you are affirming your explicit consent for such information to be used in accordance with this privacy policy. You will be able to withdraw that consent at any time by the methods described.
Opting out at a later date
Once you have given your consent, you can amend or withdraw your consent at any time. We adhere to all user rights as defined in GDPR.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:
Request access to your personal data
Request correction of your personal data
Request erasure of your personal data
Object to processing of your personal data
Request restriction of processing your personal data
Request transfer of your personal data
Right to withdraw consent
You can see more about these rights at:
ICO – Individuals rights
If you wish to exercise any of the rights set out above, please contact us.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request, to speed up our response.
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.
If you have any comments or wish to complain, please visit lcauk.com or contact us anytime.
How we store and process your data
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we have 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. In some circumstances you can ask us to delete your data: see below for further information. We may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Your account data can be collected, stored and processed within the UK & Ireland only. Your data will be stored as described here or until you request removal of your personal data from our system. Please note that we will be unable to carry out your request to be removed if there are still any open transactions against your account. In order to provide updates and offers that may be of interest to you, we use recognised third parties to take payment, manage our company accounts and provide banking services. We will store transactions, payment (this does not include payment card data) and order data for up to 7 years, or for as long as required by UK financial authorities and company regulations. These third parties may operate outside the EU.
We will only use your personal data when legally permitted. The most common uses of your personal data are:
Where we need to perform the contract between us
Where it is necessary for our legitimate interests (or those of a third party) and your interests, and fundamental rights do not override those interests
Where we need to comply with a legal or regulatory obligation
Generally, we do not rely on consent as a legal ground for processing your personal data, other than in relation to sending marketing communications to you via email, post or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Set out below is a description of the ways we intend to use your personal data and the legal grounds on which we will process such data. We have also explained what our legitimate interests are where relevant.
We may process your personal data for more than one lawful reason, depending on the specific purpose for which we are using your data. Please email us if you need details about the specific legal reason we are relying on to process your personal data, where more than one ground has been set out in the table below.
Our Marketing communications
You will receive marketing communications from us if you have:
requested information from us or purchased goods or services from us; or
if you provided us with your details and ticked the box at the point of entry of your details for us to send you marketing communications
You can ask us to stop sending you marketing messages at any time by emailing us. Where you opt out of receiving our marketing communications, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
Our obligations
We are a data controller. In relation to the information that you provide to us, we are legally responsible for how that information is handled.
We will comply with the Data Protection Act 1998 and the GDPR [2018] in the way we use and share your personal data. Amongst other things, this means that we will only use your personal data:
Fairly and lawfully
As set out in the legislation and this policy
To the extent necessary for these purposes
We will process your personal data ourselves as the data processor. We will take reasonable precautions to safeguard the personal information that you supply
Third parties
Your data is not shared with any third parties other than as described here:
The data you submit during the purchase of your product.
By giving consent during the purchase of your product to send you marketing information about goods and services, that they think you may be interested in, as well as account management or, relationship management purposes.
In addition, we may have to share your personal data with the parties set out below for the purposes set out in the table above:
Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue & Customs, regulators and other authorities based in the United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances.
We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.
Security Process
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. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know such data. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. We will report any breaches or potential breaches to the appropriate authorities within 24 hours and to anyone affected by a breach within 72 hours.
Our websites may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
If you have any queries or concerns about your data usage, please contact us.
Exercising your information rights and complaints
If you have any questions or comments about this Privacy Policy, wish to exercise your information rights in connection with the personal data you have shared with us or wish to complain, please contact: admin@prolightdirect.co.uk and we will process Subject Access Requests (SARs) within 30 days, SAR responses are usually free, but we reserve the right to charge for excessive or unfounded requests. We fully comply with Data Protection legislation under Data Protection Act 1998 as well as now the EU General Data Protection Regulations (GDPR) and will assist in any investigation or request made by the appropriate authorities.
