HomeGleamers Ltd are data controllers of your personal data. We respect your data and your privacy is important to us.
This Privacy Notice explains what personal data we collect and how it is used. This notice also explains what rights you have over your personal data and how you can use those rights.
You have the right to object to some of the processing which HomeGleamers Ltd carries out. More information about your rights and how to exercise these is set out in the “Your rights” section of this notice.
- Summary of how we use your data and your rights
- Information we collect from you
- Information we receive from third parties
- How we use information and the legal basis
- Data sharing
- International transfers
- Data retention
- Your rights
- Contact details
1. Summary of how we use your data and your rights
We use your data to provide and improve our products and services, including for marketing, research, feedback and enquiries, and for safety and security purposes.
We will use your data to comply with laws and regulations. We may use your data to prevent and detect crime, such as fraud.
You have the right to object to some of the processing HomeGleamers Ltd carries out. More information about your rights and how to exercise these is set out in the “Your rights” section of this notice.
When you give consent, you are able to withdraw that consent at any time, for instance by emailing email@example.com. You can also email firstname.lastname@example.org to exercise any other data rights, such as obtaining a copy of your data, correcting, deleting or restricting how we use your data. Please see “Your rights” for more information.
You can unsubscribe from marketing communications at any time. To opt out of marketing, including direct marketing purposes, you can either select “unsubscribe” in emails or email email@example.com.
2. Information we collect from you
We collect information when you enquire about our services or book an appointment to sign up for our services. This includes face to face meetings, using our websites, calling us or corresponding with us.
- We keep information you give us directly such as contact details (including name, email, address and telephone number), comments, date of birth, gender, region, frequency of visits, feedback, marketing opinions and competition entries.
- We record and analyse appointments, web visits, details of your bookings and where you take advantage of our promotions.
- If there is an incident, we may need to log information about it.
- If you engage with us online via our websites our cookies and similar technologies will capture your IP address, your location, and record how you use the site or app to help improve it and improve your user experience, where your browser settings or permission allows for this.
- If you post information online about us or provide feedback, we may keep a record.
- If you contact us directly and complain or give feedback, receive compensation, or enter a competition, we will record details and all related information such as emails, letters and phone calls.
3. Information we receive from third parties
We may receive your information from other people. This can happen when:
- Someone buys you a Gift Voucher. They give your name, address, contact details and email address, so either theyor we can send you the Gift Voucher.
- You participate in market research, such as focus groups or surveys.
4. How we use information and the legal basis
We are allowed to use your data only if we have a proper reason to do so such as:
- To fulfil a contract we have with you;
- When it is in our legitimate interest;
- When you consent to it; or
- To comply with the law.
A legitimate interest is when we have a business or commercial reason to use your data. This involves us making an assessment of when we can rely on our legitimate interests. For more information on this assessment please contact firstname.lastname@example.org .
We have set out below how and why we may use your personal information and the legal basis we rely on. This is also where we tell you what our legitimate interests are.
When you make an enquiry or book an appointment or buy something from us, or enter a competition we run, we use your information to fulfil our contract with you.
We take information to communicate with you, check your identity, take payment, and provide products and services.
To run our business and pursue our legitimate interests, we use your information.
Our legitimate interests include keeping our records up to date, fulfilling our legal, compliance and contractual duties, working out which of our products and services may interest you, improving our site and apps, and services, developing new products and services, and telling you about them and conducting market research.
Further details of our legitimate interests:
To run and promote our business, we use your information:
- To provide and improve our products and services and to respond to you if you contact us.
- To improve call centre communications, including incoming and outgoing calls and emails, for staff training, quality improvement purposes and establishing facts. Calls are not currently recorded but whilst training other staff members will hear the conversation and see any email interactions.
- When we monitor HomeGleamers websites, social media platforms such as Facebook and Twitter and online services including responses to email marketing. If you post comments online or in other media we may capture this information, contact you, and use it to improve our products and services.
- To run competitions and promotions and track which offers seem of interest to you.
- To understand you better as a customer by analysing your transactions and other information you provide to us or which we learn through your interactions with us.
- To send you emails including offers tailored to the information we hold on you. We record which emails seem to be of interest to you. You can subscribe or unsubscribe from our marketing communications at any time.
- To contact you where you provide us with market research feedback or pass this data to a third-party business partner of ours for panel market research analysis.
To prevent, investigate and/or report fraud, terrorism, misrepresentation, security incidents or crime, including where we are required to do so by law we may:
- Monitor HomeGleamers information, call centre communications and emails.
- Use other organisations to check the validity of the credit or debit card details you use to pay (for further details see “Data sharing” below).
To comply with law, assess and uphold legal or contractual rights and claims, and for monitoring, auditing and training on compliance matters:
- We keep records and pass your information to external companies and our insurers when necessary (for further details see Data sharing below).
- We monitor call centre communications, including incoming and outgoing calls and emails.
- We may verify your identity.
- We keep records to comply with health and safety legislation, including accounting for the number of individuals on our premises and logging accidents.
We may, if you give us consent
- Use data for other purposes where we explain that purpose when we ask for your consent.
When you give consent, you are able to withdraw that consent at any time by contacting us, for instance by emailing email@example.com . If you do so we can only continue to use your data if another legal basis applies, such as when we’re required to do something by law.
Nevertheless, you have an absolute right to opt-out of direct marketing, including profiling for direct marketing purposes, at any time. You can opt out of marketing by selecting “unsubscribe” in emails, by emailing firstname.lastname@example.org, calling us on 01275 370573 or writing to us at: HomeGleamers, 8 Baltic Place, Pill, BS20 0EJ
When the law requires us to process your data we will do so. This can include
- Legal, compliance, regulatory and investigative purposes, including for government agencies and law enforcement.
- When you exercise your rights under data protection legislation, including when you ask to subscribe or unsubscribe from our marketing communications.
5. Data sharing
For some activities HomeGleamers uses third party service providers, for instance Worldpay process our card payments for us. When these service providers ask for customer data from you we may share information with them.
We use third party providers for the following services:
- Sending promotional offers
- Customer feedback surveys
- IT development, support, maintenance and hosting, including the provision of applications and website hosting
- Payments’ processing to enable you to pay by credit or debit card
If our business is to be integrated with another business or sold, your details would be shared with our advisers and any prospective purchaser’s advisers. Your information will be passed to the new owners and you would be notified.
Personal data may be shared with government authorities and/or law enforcement officials for the prevention or detection of crime, if required by law or if required for a legal or contractual claim.
6. International transfers
Sometimes we may need to send or store your data outside of the European Economic Area (the EU plus Iceland, Lichtenstein and Norway) (‘EEA’). For example, to follow your instructions, comply with a legal duty or to work with or receive services from our service providers who we use to help run your accounts and our services.
If we do transfer information outside of the EEA, we will make sure that it is protected by using one of these safeguards:
- Transfer it to a non-EEA country with privacy laws that give the same protection as the EEA. Some countries have been deemed adequate by the EU.
- Put in place a contract with the recipient that means they must protect it to the same standards as the EEA or use other mechanisms and measures to achieve adequate protection. We also may use the Standard Contractual Clauses published by the EU.
- Transfer it to organisations that are part of Privacy Shield. This is a framework that sets privacy standards for data sent between the US and EU countries. It makes sure those standards are similar to what is used within the EEA.
For further details on the mechanisms used please contact email@example.com.
Cookies are text files placed on your computer to collect standard internet log information and visitor behaviour information. This information is used to track visitor use of the Website and to compile statistical reports on website activity.
For further information visit www.aboutcookies.org or www.allaboutcookies.org . You can set your browser not to accept cookies and the above websites tell you how to remove cookies from your browser. However in a few cases some of our website features may not function as a result.
8. Data retention
We keep your data to enable us to fulfil our contract with you or to provide services, whilst you are an active customer, where required by law or to protect legal rights.
We always look to keep your data for the minimum time in line with data protection principles and our processes. For example, we keep:
- Information on HomeGleamers customers and prospects.
- Records of payment information in line with tax law and audit requirements.
- Customer feedback and correspondence with us for up to 5 years afterwards, depending on the nature of the interaction and any applicable law, such as health and safety. This enables us to respond to any questions or complaints.
- Information to maintain records according to rules that apply to us.
If you unsubscribe from marketing communications we keep a record of this request indefinitely to ensure we do not send you direct marketing again.
We may keep your data for longer if we cannot delete it for legal, regulatory or technical reasons.
9. Your rights
You have rights over your personal data.
- ask for a copy of your information;
- ask for information to be corrected;
- ask for information to be erased or deleted;
- ask for us to limit or restrict processing;
- object to us processing your data, in particular where we use the data for direct marketing, including profiling for direct marketing purposes. The right to object does not apply if we must process the data to meet a contractual or legal requirement;
- ask us to send you a copy in a structured digital format or ask for us to send it to another party.
Some rights, however, may be limited. We may be obliged by law or regulation to keep information. We must respect other people’s privacy as well, which means we may need to redact or remove information where it includes personal data about someone else, even if it is connected to your data. On occasion there may be a compelling legitimate interest to keep processing data.
If you want a copy of your data, to object to how we use your data, or ask us to delete it or restrict how we use it or, please see ‘Contact details’ below. To process a request from you, we may need to confirm your identity to ensure we’re accessing the right data.
You have a right to complain to an EU data protection authority. This can be where you live, work or where the matter occurred. In the UK, the authority is the Information Commissioner’s Office (the “ICO”).
10. Contact details
To exercise any of your rights or to withdraw consent you can email: firstname.lastname@example.org.
To discuss or change your details, including any marketing preferences contact customer services at email@example.com.
For any queries relating to data protection please contact firstname.lastname@example.org by writing to them at Privacy Request, HomeGleamers, 8 Baltic Place, Pill, BS20 0EJ.
If we make any changes or updates to this notice we will communicate these.
Copyright HomeGleamers Ltd 2018 Last Updated: 22 May 2018