PRIVACY POLICY
This privacy policy gives you information about how Stubbs&Co. (UK) Limited collects and uses your personal data through your use of this website, including any data you may provide when you apply for accreditation, register with us as a customer, sign up to receive our updates or purchase any products.
This website is not intended for children and we do not knowingly collect data relating to children.
To make it easier for you to read this policy, below are a number of links that will take you directly to particular sections.
2. The types of personal data we collect about you
3. How is your personal data collected?
4. What legal bases do we use for processing your personal data?
5. How long do you hold on to my personal data?
9. How to contact us and complaints?
1. About us
Stubbs&Co. (UK) Limited is the controller and responsible for your personal data (collectively referred to as “Stubbs&Co”, “we”, “us” or “our” in this privacy policy). The protection of your privacy and personal information is important to us. We make sure that not only do we have appropriate security measures in place, but that any other organisation we work with to provide a service also meets the same standard as us.
If you have any questions about this privacy policy, including any requests to exercise your legal rights (section 8), please contact our Data Manager Jay Patel by email jay@stubbs.co.uk or telephone +44 (0)20 7421 6900.
2. The types of personal data we collect about you
Personal data means any information about an individual from which that person can be identified.
We may collect, use, store and transfer different kinds of personal data about you as follows:
• The minimum information we need from you to apply for accreditation or register you as a customer is your full name, job title, company name and address, telephone number and email address.
• Details about orders made by you and other details about products and services you have purchased from us.
• Details about payments to and from us.
• Technical Data such as your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access this website.
• Information about how you interact with and use our website.
• Your preferences in receiving marketing from us and your communication preferences.
3. How is your personal data collected?
We collect information on you:
• when you contact us for information
• when you work with us in a commercial capacity, either as a customer or supplier
• when you sign up for our updates
• when you use our website
• if you complete your details on research questionnaires.
You may give us your personal data by filling in online or hardcopy forms or by corresponding with us by post, phone, email or otherwise.
As you interact with our website, we will automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy for further details.
4. What legal bases do we use for processing your personal data?
We use different legal bases depending upon the purpose for collecting your data in the first instance. We rely on one or more of the following legal bases:
• Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
• Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
• Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
• Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to receive our updates and offers.
For all data collected to register you as a new customer, provide you with a catalogue or other information that you have requested, or to process and deliver your order, our legal basis is performance of a contract. Please note that unless we say otherwise, you must answer all the registration questions otherwise we may not be able to perform the contract we are trying to enter into with you.
Where we use your personal data to manage our relationship with you (including managing payments, collecting and recovering money owed to us, and dealing with requests, complaints and queries) our legal basis is legitimate interest.
Where we process your personal data in the course of administering and protecting our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) our legal basis is legitimate interest.
Where we use your personal data to notify you about changes to our terms and conditions or privacy policy, our legal basis is legal obligation.
We will use your personal data to send you our latest updates on new products, promotions and service offers if you subscribe via the website. Our legal basis in this scenario is consent, You can opt-out at any time by clicking the unsubscribe link in the footer of any email you receive from us.
From time to time we may use some elements of the data you supply to target the messages we send you on the basis of legitimate interest. For example, we may send you information about new products or services we consider relevant based on your purchase history. None of this information is collated by wholly automated means and you can ask us to stop sending you such messages at any time by following the opt-out links within the relevant communication or by contacting our Database Manager Jay Patel by email jay@stubbs.co.uk or telephone +44 (0)20 7421 6900.
If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes, for example relating to order confirmations, updates to our Terms and Conditions and checking that your contact details are correct.
5. How long do you hold on to my personal data?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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, regulatory, tax, accounting or other requirements.
By law we have to keep basic information about our customers for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see section 8 below for further information.
In some circumstances we will 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.
6. Who we share data with?
We will not share your personal information with others for marketing purposes unless you have given us your express permission.
We may share your personal data where necessary with the parties set out below:
• Service providers who provide us with IT and system administration services and marketing services.
• Our professional advisors including lawyers, bankers, auditors, valuers and insurers who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
Any other organisations who access your information in the course of providing services on our behalf will be governed by strict contractual restrictions to make sure that they protect your information and comply with applicable data protection and privacy laws. We may also independently audit these service providers to make sure that they meet our standards.
7. International transfers
We do not transfer personal data outside of the UK.
8. Your legal rights
You have a number of rights under data protection laws in relation to your personal data.
You have the right to:
• Request access to your personal data (commonly known as a “subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
• You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
– If you want us to establish the data’s accuracy;
– Where our use of the data is unlawful but you do not want us to erase it;
– Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
– You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
If you would like to exercise any of the rights above, please contact the Data Manager Jay Patel by email jay@stubbs.co.uk or telephone +44 (0)20 7421 6900.
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 could 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 could 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.
9. How to contact us and complaints?
If you have any questions about this privacy policy or about the use of your personal data or you want to exercise your privacy rights, please Data Manager Jay Patel by email jay@stubbs.co.uk or telephone +44 (0)20 7421 6900.
If you are not satisfied with the way your request was handled, you have the right to lodge a complaint with the supervisory authority – details of which are given below:Information Commissioner’s Office
https://ico.org.uk/concerns/
Telephone: +44 303 123 1113
10. Changes to the privacy policy
We keep our privacy policy under regular review. This version was last updated on June 26, 2024. Historic versions can be obtained by contacting us.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address.
11. Third-party links
This website 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 policy of every website you visit.
What rights you have over your data
Suggested text: If you have an account on this site, or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.
Where we send your data
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