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This privacy statement applies to the websites www.clarkeinternational.com
& www.clarkeservice.co.uk, operated by:
Clarke International Ltd
Tel: 01992 565333Email: firstname.lastname@example.org
We hope the following sections will answer any questions you have but if not, please do get in touch with us.
This privacy statement provides information on how we process personal information. We may update this policy from time to time and therefore advise that you should periodically review this page.
1.1 Clarke International Ltd is committed to safeguarding the privacy of visitors through our website, trade counters and telesales teams. Please read the following policy to understand how your information will be treated. You are not required to provide any personal information on the public areas of our websites. However, you may choose to do so by completing the contact / enquiry forms on our sites or contacting us at a trade counter or over the phone.1.2 Clarke International Ltd acknowledges that the information you provide may be confidential. We will maintain the confidentiality of and protect your information in accordance with the firm’s normal procedures and all applicable laws.
1.3 Clarke International Ltd has a legal obligation to ensure that your information is kept accurate and up to date. Please assist us to comply with this obligation by ensuring that you inform us of any changes to your information. You have the right to request details of the information we hold about you and to delete or rectify any inaccurate information about you by sending us a written request.
1.4 Clarke International Ltd does not disclose information to other companies for their commercial use.
2. Explaining the legal bases we rely onThe law on data protection sets out a number of different reasons for which a company may collect and process your personal data. In this section we have set out the legal bases that we rely on including:
In specific situations, we can collect and process your data with your consent, for example, when you tick a box to receive email newsletters.
When collecting your personal data, we’ll always make clear to you which data is necessary in connection with a particular service.
2.2 Contractual obligations
In certain circumstances, we need your personal data to comply with our contractual obligations, for example, if you order an item from us for delivery, we’ll collect your address details to deliver your purchase, and pass them to our courier.
2.3 Legal compliance
If the law requires us to, we may need to collect and process your data, for example, we can pass on details of people involved in fraud or other criminal activity affecting Clarke International Ltd to law enforcement.
2.4 Legitimate interest
In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests. For example, we will use your purchase history to send you or make available, personalised offers.
We will also combine the shopping history of many customers to identify trends and ensure we can keep up with demand.
We will also use your address and phone details for direct marketing purposes informing you about products that we think might interest you.
3. How we collect or obtain your personal data?
In this section we have listed where we collect user information and when we collect your personal data:
3.1 When you visit any of our websites or request services through our online forms.
3.2 When you contact us on the phone, at a trade counter or online.
3.3 When you create an account with us.
3.4 When you purchase a product or service at a trade counter or by phone using your account.
3.5 When you purchase a product or service at a trade counter or by phone and provide your personal information to Clarke International Ltd but do not open an account with us.
3.6 When you engage with us on social media.
3.7 When you contact us by any means with queries, complaints etc.
3.8 When you enter prize draws or competitions.
3.9 When you comment on or review our products and services.
3.10 When you choose to complete any surveys we send you.
3.11 When you fill in any forms. For example, a request for a brochure. 3.12 When you have given a third party permission to share with us the information they hold on you.
3.13 We collect data from publicly-available sources when you have given your consent to share information or where the information is made public as a matter of law (such as Companies House or Credit references agencies).3.14 When you use our car parks / trade counters or visit our distribution centres which usually have CCTV systems operated for the security of both customers and colleagues. These systems record your image during your visit.
We may process the following categories of Personal Information about you:
4.1 , such as your name, title, gender, billing/delivery address, orders and receipts, email and telephone number, areas or product categories of interest.
4.2 : gender; salutation; job title, company information.
4.3 : postal address; telephone and/or mobile number; email address.
4.4 Copies of documents you provide to prove your age or identity where the law requires this, or if you apply for finance through one of our nominated partners, (including your passport and driver's licence). This will include details of your full name, address, date of birth and facial image. If you provide a passport, the data will also include your place of birth, gender and nationality.
4.5 : records of any consent/s you may have given, together with the date and time, means of consent.
4.6 : records of purchases and prices; invoice records; payment records; billing address; payment method; cardholder or accountholder name; payment amount; and payment date.
4.7 To deliver the best possible web experience, we collect technical information about your internet connection and browser as well as the country and telephone code where your computer is located, the web pages viewed during your visit, the advertisements you clicked on, and any search terms you entered.
4.8 Details of your visits to our websites or apps, and which site you came from to ours.
4.10 : any views and opinions that you or other users choose to send to us, or publicly post about us on social media platforms.
4.11 Device type, settings and software used.
4.12 Log files, which may include IP addresses, browser type, ISP referring/exit pages, operating system, date/time stamps and/or clickstream data, including any clicks on customized links.
4.13 Web Beacons, which are electronic files that allow a website to count users who have visited that page or to access certain cookies.
Mobile analytics to understand the functionality of our mobile applications and software on your phone.
5. How and why do we use your personal data?
There are several grounds on which we may collect and use your data, depending on your relationship with us. We want to give you the best possible customer experience. One way to achieve that is to get the best picture we can of who you are by combining the data we have about you. We then use this to offer you products, promotions and services that are most likely to interest you.
The data privacy law allows this as part of our legitimate interest in understanding our customers.
Of course, if you wish to change how we use your data, you’ll find details in the ‘What are your rights over your personal data?’ section below.
Remember, if you choose not to share your personal data with us, or refuse certain contact permissions, we might not be able to provide some services you’ve asked for. For example, if you’ve asked us to let you know when an item comes back into stock, we can’t do that if you’ve withdrawn your general consent to hear from us.
Here’s how we’ll use your personal data and why:
5.1 To process any orders that you make through our telesales team or trade counters/departments: If we don’t collect your personal data, we won’t be able to process your order and comply with our legal obligations. For example, your details may need to be passed to a third party to supply or deliver the product or service that you ordered, and we may keep your details for a reasonable period afterwards in order to fulfil any contractual obligations such as refunds, guarantees, warranty and so on.
5.2 To respond to your queries, refund requests and complaints:
Handling the information you sent enables us to respond. We may also keep a record of these to inform any future communication with us and to demonstrate how we communicated with you throughout. We do this on the basis of our contractual obligations to you, our legal obligations and our legitimate interests in providing you with the best service and understanding how we can improve our service based on your experience.
To protect our business and your account from fraud and other illegal activities:
This includes using your personal data to maintain, update and safeguard your account. We’ll also monitor your browsing activity with us to quickly identify and resolve any problems and protect the integrity of our website.
We’ll do all of this as part of our legitimate interest.
5.3 To protect our customers, premises, and assets from crime, we operate CCTV systems at our trade counters, car parks and distribution centres which record images for security.
If we discover any criminal activity or alleged criminal activity through our use of CCTV, fraud monitoring and suspicious transaction monitoring, we will process this data for the purposes of preventing or detecting unlawful acts.
We do this on the basis of our legitimate business interests.
5.4 To process payments and to prevent fraudulent transactions:
We do this on the basis of our legitimate business interests. This also helps to protect our customers from fraud.
5.5 With your consent, we will use your personal data, preferences and details of your transactions to keep you informed by email, web, text, or through telephone about relevant products and services including special offers, promotions and so on.
5.6 To send you communications required by law or which are necessary to inform you about our changes to the services we provide you.
For example, updates to this Privacy Notice, product recall notices, and legally required information relating to your orders. These service messages will not include any promotional content and do not require prior consent when sent by email or text message. If we do not use your personal data for these purposes, we would be unable to comply with our legal obligations.
5.7 To administer any of our prize draws or competitions which you enter based on your consent given at the time of entering.
5.8 To develop, test and improve the systems, services and products we provide to you. We’ll do this on the basis of our legitimate interest.
5.9 To comply with our contractual or legal obligations to share data with law enforcement.
5.10 To send survey and feedback requests to help improve our services. These messages will not include any promotional content and do not require prior consent when sent by email or text message. We have legitimate interest to do so as this helps make out products and services more relevant to you.
5.11 To process your booking/appointment requests for product repairs and services. Sometimes we will need to share your details with a third party who is providing a service such as delivery couriers or an engineer visiting your place of business or home. We do so to maintain our appointment with you. Without sharing your personal data, we would be unable to fulfil your request.You are free to opt out of hearing from us by any of these channels at any time.
6. How we protect your personal data
We know how much data security matters to all our customers. With this in mind we will treat your data with the utmost care and take all appropriate steps to protect it.
Electronic access to your personal data is password-protected, physical access to your data is limited to authorised personnel only at secure sites, and sensitive data (such as payment card information) is secured by encryption.
We regularly monitor our system and storage facilities for possible vulnerabilities and attacks, and we constantly review our process to identify ways to further strengthen security.
7. How long will we keep your personal data?This section sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes. Whenever we collect or process your personal data, we’ll only keep it for as long as is necessary for the purpose for which it was collected.
At the end of that retention period, your data will either be deleted completely or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning.
In some cases it may not always be possible for us to specify in advance the periods for which your personal data will be retained, however, we will determine the period of retention based on the following criteria:
(a) We will retain information contained in any enquiry that you submit to us regarding products or services. In circumstances where you (or your business) have not become a customer of ours we would retain the information contained in the enquiry for our future reference for a period of five years;
(b) We will retain information that you provide to us for the purpose of subscribing to our offers and emails for as long as you have consented to receive such communications; and
(c) The period of retention of contractual data will be determined based on whether there is an ongoing relationship between us, a warranty period, and on our assessment of whether we may need that data to comply with our legal obligations or for our legitimate business interests.
8. Who do we share your personal data with?
We sometimes share your data with trusted third parties, for example delivery couriers, fraud management, to assist in handling customer enquiries/ complaints and to help us personalise our offers to you.
We respect your privacy and do not share your details with other retailers who may seek to use your details for commercial benefit.
We apply the following policy whenever we deal with any third parties in order to maintain your privacy:
(a) We only provide them with information essential for their specific services.
(b) They may only use your data for the exact purposes we specify in our contract with them.
(c) Any third parties we deal with must provide proof of their compliance with the latest GDPR (General Data Protection Regulation).
(d) We work closely with them to ensure that your privacy is respected and protected at all times.
Examples of companies we work with:
- IT companies who support our business and website.
- Operational companies that help fulfil our contracts with the customers i.e. delivery companies and couriers.
- Data insight companies to ensure your details are up to date and accurate data.
- Direct marketing companies to ensure we can communicate our offers with you efficiently depending on your mailing preferences.
- Re-targeting companies to help show you products that might interest you while browsing the internet.
Sharing your data with third parties for their own purposes:
We will only do this in very specific circumstances, for example:
For fraud management, we may share information about fraudulent or potentially fraudulent activity in our premises or systems. This may include sharing data about individuals with law enforcement bodies.
- We may also be required to disclose your personal data to the police or other enforcement, regulatory or Government body, in your country of origin or elsewhere, upon a valid request to do so. These requests are assessed on a case-by-case basis and take the privacy of our customers into consideration.
To help personalise your journey through the Clarke International and Clarke Service websites we currently use the following companies who will process your personal data as part of their contracts with us:
· Cheetah Digital
· Google analytics
· Headland Ltd
· Survey Monkey
· AMS – Amazon Web Services· MailChimp
9. Where your personal data may be processed
Sometimes we will need to share your personal data with third parties and suppliers outside the European Economic Area (EEA).
The EEA includes all EU Member countries as well as Iceland, Liechtenstein and Norway. We may transfer personal data that we collect from you to third-party data processors in countries that are outside the EEA.
If you are based outside the UK and place an order with us, we will transfer the personal data that we collect from you, to us in the UK. For example, this might be required in order to fulfil your order, process your payment details or provide support services.
By using our services or providing your personal data to us, you expressly consent to the processing of your personal data by us or on our behalf. You still have the right to ask us not to process your data in certain ways, and if you do so, we will respect your wishes.
Sometimes, we’ll need to transfer your personal data to third parties in the UK or between countries to enable us to supply the goods or services you’ve requested.
By dealing with us, you are giving your consent to this overseas use, transfer and disclosure of your personal data outside your country of residence for our ordinary business purposes.
If we do this, we have procedures in place to ensure your data receives the same protection as if it were being processed inside the EEA. For example, our contracts with third parties stipulate the standards they must follow at all times.
Any transfer of your personal data will follow applicable laws and we will treat the information under the guiding principles of this Privacy Notice.
10. What are your rights over your personal data?
In this section, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries.
Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
10.1 Your principal rights under data protection law are:
- The right to be informed
- The right of access
- The right to rectification
- The right to erasure
- The right to restrict processing
- The right to data portability
- The right to object
- Rights in relation to automated decision making and profiling.
10.2 You have the right to confirmation as to whether or not we process your personal data.
10.3 You have the right to access your personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. Access to the personal data we hold about you, is free of charge in most cases.
10.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
10.5 In some circumstances you have the right to the erasure of your personal data without undue delay.
Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; the processing is for direct marketing purposes; and the personal data have been unlawfully processed.
However, there are certain general exclusions of the right to erasure. Those general exclusions include where processing is necessary: for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
10.6 In some circumstances you have the right to restrict the processing of your personal data.
Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection.
Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
10.7 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
10.8 To the extent that the legal basis for our processing of your personal data is consent, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
10.9 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
10.10 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
10.11 You may exercise any of your rights in relation to your personal data by written notice to us, in addition to the other methods specified in this section.
You have the right to request a copy of any information about you that Clarke International Ltd holds at any time and have that information corrected if it is inaccurate. To ask for your information, please contact us:
By email at: SAR@clarkeinternational.com
Or by Post at:
Subject Access Request
Clarke International Ltd
If we choose not to action your request we will explain to you the reasons for our refusal.
Checking your identity
To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Notice. If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.
You will need to complete a Subject Access Request form and supply proof of identity before any information can be supplied.
11. How can you stop the use of your personal data for direct marketing?
There are several ways you can stop direct marketing communications from us:
11.1 Click the ‘unsubscribe’ link in any email communication that we send you. We will then stop any further emails.
11.2 Write to Marketing Team - Unsubscribe, Clarke International Ltd, Hemnall Street, Epping, Essex. CM16 4LG.
Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated.
12. Contacting the Regulator
If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
13. Any questions?
We hope this Privacy Notice has been helpful in setting out the way we handle your personal data and your rights to control it.
If you have any questions that haven’t been covered, please contact our Data Protection representative who will be pleased to help you:
(1) Write to us at Data Protection, Clarke International Ltd, Hemnall Street, Epping, Essex. CM16 4LG.
This notice was last updated on May 2018 in accordance with Data Protection Regulation (General Data Protection Regulation (GDPR) (EU) 2016/679).