1. We Care About Your Privacy
1.5. We take every measure to provide a comparable level of protection for Personal Information should the information be Processed by a Vendor.
2. About Information Collection
2.2. We provide you with information that explains why the Personal Information is needed and how the Personal Information will be processed.
3. Personal Information
3.1. In view of the definition of “Personal Data” as ascribed to it in the Personal Data Protection Act 2010, personal data may take various forms, including: a) Name b) Date of birth c) Passport or identity card number; d) Home address, telephone number, facsimile number or email address; e) Photograph; f) Age, gender, marital or family status; g) Ancestry, race, nationality, or national or ethnic origin; h) Religion or religious belief, association or activity; i) Blood type, finger prints or hereditary characteristics, DNA; j) Education, employment or occupation, or educational, employment or occupational history; k) Source of income or financial circumstances, activities or history; l) Criminal history including regulatory offences; and m) Personal health information about an individual: “Personal health information” means “recorded information about an identifiable individual that relates to: i. The individual’s health or “health care” history; ii. The provision of health care to the individual; or iii. Payment for health care provided to the individual, and includes; – The “Medical Record Number” and any other identifying number, symbol or particular assigned to an individual, and – Any identifying information about the individual that is collected in the course of, and is incidental to, the provision of health care or payment for health care. “Health Care” means any care, service or procedure i. Provided to diagnose, treat or maintain an individual’s physical or mental condition; ii. Provided to prevent disease or injury or promote health, or iii. That effects the structure or a function of the body, and includes the sale or dispensing of a drug, device, equipment or other item pursuant to a prescription. NOTE: This list is not exhaustive, as the word “including” is used, clauses (a) – (m) do not set out the only information which is personal information
3.2. We at the Group limit the amount and type of information that we collect to that which is necessary for the identified purposes and do not collect your Personal Information unless you (directly or indirectly) provide it to us voluntarily.
4. Collection of Non-Personal Information
4.1. Where we collect information through our website, as is the case with many other websites, we automatically collect certain non-personal information regarding website use that does not identify you. Examples include the Internet Protocol (IP) address of your computer, the IP address of your Internet Service Provider, the date and time you access the website, the internet address of the website from which you linked directly to our website, the operating system you are using, the sections of the website you visit, the website pages read and images viewed, and the content you download from our website.
4.2. We may use non-personal information to compile tracking information reports regarding site user demographics and site traffic patterns. None of the tracking information in the reports can or will be connected to the identities or other Personal Information of individual users.
4.3. In this way, your visit to our website will be logged; however, you will remain anonymous to us unless you specifically choose to share information with us. We use this information about the way in which our customers use our website to better understand which features are most popular and best meet the needs of our visitors.
5. Purposes and Use of Personal Information
5.1. We collect Personal Information that you provide to us voluntarily on the Group’s website, our customer loyalty schemes, customer feedback form and its other related channels and process it for the following purposes (“Purposes”):
5.1.1. to complete transactions with you and to administer and to manage/verify your membership with our preferred client services (if you are our preferred client), our subscription programmes (if you are a subscriber), our customer loyalty schemes (if you are a member);
5.1.2. to direct market to you;
5.1.3. to understand and analyse our services, and your needs and preferences;
5.1.4. to develop, enhance, market and provide products and services to meet your needs;
5.1.5. to enable you to participate in events, promotions and contests;
5.1.6. to enable you to participate in customer research or focus groups;
5.1.7. to personalize our services;
5.1.8. to improve the quality of our services;
5.1.9. to respond to requests or complaints; and
5.1.10. to manage and respond to enquiries, requests or complaints.
5.2. We only keep Personal Information for as long as is necessary to satisfy the specified Purposes, for which it was collected. We retain Personal Information in accordance with our own guidelines, procedures and principles and in line with applicable legislation.
5.4. We may disclose your Personal Information if we are required to do so by law or requirement of a competent authority.
5.5. In addition to the above, we may from time to time work on specific initiatives with carefully selected third party companies/organisations (outside of the Group) to share opportunities with you. If we do this, we will inform you at the time of such initiatives that, if you decide to submit any Personal Information, it will be shared with those selected companies/organisations and we will only do so with your prior consent.
5.7. If you do consent (opt in) to receive these communications you may unsubscribe at any point in the future by contacting us as provided at section 6.4 below.
6. Customer Consent (Opt In & Unsubscribe)
6.1. Opt In: We at the Group will not use your Personal Information for a purpose that has not previously been specified, unless we have previously obtained your consent or unless such purpose is required by law.
6.2. Consent to provide Personal Information is not a condition for our selling a product and/or services to you, unless the information requested is required to full fill an explicitly specified and legitimate purpose.
6.3. In particular we will generally seek your explicit prior consent (opt in) before sending to you marketing communications (see 5.1.2 above).
6.5. If you have previously opted into receiving commercial communications from us pursuant to 6.3 above, while also becoming a member of our loyalty scheme or a subscriber of our subscription programmes, should your membership to such scheme comes to an end for whatever reason, we will not take this to imply an automatic request to unsubscribe, and we will assume that we have your continued consent, unless you specifically unsubscribe, as is provided for in section 6.4.
7. Accuracy of Information
7.1. We at the Group keep Personal Information as accurate, complete and up-to-date as necessary, taking into account its use and the interests of our customers.
7.2. You are responsible for informing us about changes to your Personal Information and for ensuring that such information is accurate and current.
8. Accessing and Update Personal Information
8.1. Dependant on the legislation, some customers have a qualified right to access, rectify, delete, or object (to the processing of) your Personal Information stored by us and to receive an account of its use and disclosure. Where there is no such right provided by law, we may still allow access to such information. We recommend that all customer requests for access to Personal Information held by the Group be made in writing. However, we may require you to provide us with additional information reasonably necessary for us to satisfy your request. The Group reserves the right to charge you a reasonable fee for the processing of any data access request.
8.2. We amend the Personal Information contained in our database or elsewhere as required when an individual successfully demonstrates the inaccuracy or incompleteness of the Personal Information. An amendment may involve the correction, deletion or addition of information and notification to third party to whom the data have been disclosed.
9. Effective Date and Changes to the Policy
10. Security of Your Personal Information
10.1. We at the Group protect Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification with security safeguards appropriate to the sensitivity of the Personal Information, regardless of the format in which it is held.
10.2. We use various methods to safeguard Personal Information. They include:
10.2.1. Physical measures: locked filing cabinets, restriction of access to offices, and company alarm systems
10.2.2. Technical tools: passwords and encryption, using generally industry best practices. Only authorized personnel with user ID and password from the Group have access to the information.
10.2.3. Organisational controls: confidentiality agreements, limiting access on a need-to-know basis, staff training and security clearances.
10.3. Online security is also a priority. The Group incorporates security measures such as encryption and authentication tools to protect your Personal Information from unauthorized use. Firewalls are utilised to protect our servers and network from unauthorised users accessing and tampering with files and other information that we store.
10.4. We use Secure Sockets Layer (SSL) technology to protect your information online. Upon entering the checkout page your computer will begin communicating with our server in secure mode.
10.5. While the Group cannot guarantee that loss, misuse or alteration of data will not occur; the Group makes reasonable efforts to prevent such unfortunate occurrences.
10.6. You must remember to exit the browser window after use to disable any unauthorized party access. It is your responsibility at any time, not to divulge your personal user ID and password to any third party.
11. Links to Other Websites
11.1. This website or any of the Group’s various other websites may contain links to other third party owned and operated websites or internet resources. When you click on one of those links you are contacting another website or internet resource. We have no responsibility or liability for or control over those other websites or internet resources or their collection, use and disclosure (processing) of your Personal Information. The inclusion of third party websites on our site in no way constitutes an endorsement of such websites’ contents, actions or policies.
11.2. We encourage you to read the privacy policies of those other sites to learn how they collect and use information about you.
12.2. You may choose to accept or decline cookies if your browser permits, but declining cookies may affect your use of our website and your ability to access certain features of the site or to engage in transactions.
13. The Privacy of Children
13.1. We will never knowingly collect or solicit Personal Information from individuals under the age of eighteen (18) without first obtaining verifiable parental consent. If you are under the age of 18 you should not provide information to us. If we become aware that a person under 18 has provided Personal Information to us without verifiable parental consent (as may be the case where the information is provided via our website), we will remove such Personal Information from our files.
14. Contacting Us