1. Important notice

This Privacy Policy describes how we obtain and use your personal data, why we are allowed to do so by the law, who has
access to your personal data and what your rights are. Please review it carefully.

We take your privacy seriously and use your personal data as further explained in this Privacy Policy. We are the
“controller” of the personal data you provide to us.

You have the right to object to us processing your personal data for our legitimate business interests or for direct
marketing purposes (including any related profiling). For more information about your rights and how you can
exercise them, please see the section Your rights

2. Personal Data we may collect and why

Personal data is any information which identifies you personally whether directly (for example, your name) or indirectly (for
example, information about your use of our products and services).

We may collect the following data about you:

  • Contact details: your name, email address, and telephone number so that we can contact you in response to an enquiry
    you make via our Site or in relation to the products and services that we have from time to time agreed to provide to you;
  • Correspondence:we collect any additional personal data you may provide to us from time to time if you contact us by
    email, letter or telephone, through our Site, by submitting a comment on our Site, or by any other means;
  • Survey responses:information from surveys that we use for research purposes, if you choose to respond to them;
  • Transaction details:we or our third party providers will collect information relating to transactions you carry out through
    our Site and for the purposes of fulfilling your orders;
  • Details of visits to the Sites:details of your visits to our Site, including, but not limited to, traffic data, location data,
    weblogs and other communication data, whether this is required for our own billing purposes or otherwise and the
    resources that you access.

3. Cookies

What are Cookies?

We collect information about your use of our Site through cookies. Cookies are information that files stored on your
computer, tablet or smartphone that help websites remember who you are and information about your visit. Cookies can
help to display the information on our Site in a way that matches your interests. Most major websites use cookies.

a. What cookies are used on this Site?

The cookies we and our business partners use on our Site are broadly grouped into the following categories:

  • Essential– Some of the cookies on our Site are essential for us to be able to provide you with a service you have
    requested. An example of this could be a cookie used to enable you to log into your account on our Site or which allows
    communication between your browser and our Site. Our cookie preference cookie described in the section “How can I
    reject or opt out of receiving cookies?” is also an essential cookie. You may not be able to use our Site without these
    cookies.
  • Analytics– We use analytics cookies to helps us understand how users engage with our Site. An example is counting the
    number of different people coming to our Site or using a particular feature, rather than the total number of times the site or
    feature is used. Without this cookie, if you visited our Site once each week for three weeks we would count you as three
    separate users. We would find it difficult to analyse how well our Site was performing and improve it without these cookies.
  • User Cookies– We use cookies to improve your experience by remembering your preferences so we know how you like to
    use our Site. Examples of this would be remembering you so that you are served with the same content or to remember
    you when you come back to our Site.
  • Social Sharing– We use third party cookies to allow you to share content directly on the social networking/sharing sites
    like Facebook, Twitter or Google+. Examples would be if you wanted to “like” or “tweet” about us or our products or
    services. Please see our “Third Party Cookies” section below for more details.

b. How can I reject or opt out of receiving cookies?

You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of
cookies. However, if you select this setting, you may be unable to access certain parts of our Site. Unless you have
adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you use our Site. The “Help”
menu of the toolbar on most browsers will tell you how to prevent your browser from accepting new cookies, how to have
the browser notify you when you receive a new cookie, or how to disable cookies altogether. For more information about
cookies and how to stop cookies being installed or how to delete existing cookies from your hard drive visit the following
website: http://www.allaboutcookies.org

c. Third party cookies

Some of the cookies described in the “What Cookies are used on our Site” section above are stored on your machine by
third parties when you use our Site. Third parties may also read cookies on your browser to collect information or to serve
content or advertisements to you. We have no control over these cookies or how the third parties use them. They are used
to allow that third party to provide a service to us, for example analytics. For more information on these cookies and how to
disable them, please see:

  • Internet Advertising Bureau website at http://www.youronlinechoices.com/where you will be able to opt-out of receiving
    Interest-Based Advertising cookies from some of the third parties listed below; and/or
  • If you want to know more about how cookies work and how to manage or delete them, visit the
    World Wide Web Consortium’s website

4. How we use your personal data

We use your personal data for the following purposes:

 

To track your usage of our website, communications, products and services
We use cookies and similar technologies to track your activity on our Site so that we can provide important features and
functionality on our Site, monitor its usage, and provide you with a more personalised experienced.

To provide and improve customer support
We use your personal data to be able to provide and improve the customer support we provide to you (for example, where
you have questions about our products and services).

To maintain our records and improve data accuracy
Like any business, we process personal data in the course of maintaining and administering our internal records. This
includes processing your personal data to ensure that the information we hold about you is kept up to date and accurate.

To respond to enquiries, complaints and disputes
We use the personal data we hold about you to help us respond to any enquiries or complaints you have made, or deal with
any dispute which may arise in the course of us providing our products and services to you, in the most effective manner.

To investigate, detect and prevent fraud and comply with our legal obligations
In certain circumstances, we use your personal data only to the extent required in order to enable us to comply with our
legal obligations, including for fraud detection, investigation and prevention purposes. This may require us to provide your
personal data to law enforcement agencies if they request it.

5. Legal grounds for processing

Data protection law requires us to only process your personal data if we satisfy one or more legal grounds. These are set
out in data protection law and we rely on a number of different grounds for the processing we carry out. These are as
follows:
Consent

In certain circumstances, we process your personal data after obtaining your consent to do so for the purposes of:

  • sending you marketing communications about our products and services;
  • sharing your name, email address, postal address and telephone number with our trusted business partners so that they
    may market to you about their own similar products and services;
  • conducting marketing research;
  • obtaining your credit score so that we can establish the best possible payment terms we are able to offer to you.
    Necessary for the performance of a contract and to comply with our legal obligations

It is necessary for us to process your basic contact details, payment details and information about the business you
represent for the performance of the Trading Terms or Terms of Trading between us. In particular, we rely on this legal
ground to:

  • provide you with the products and services;
  • communicate with you about the products and services that we provide to you, including to let you know about major
    changes to those products and services or to the Trading Terms or Terms of Trading between us or to any related
    information;
  • provide and improve customer support; and
  • notify you about changes to our service
    If you choose not to give some or all of the aforementioned information to us, this may affect our ability to provide our
    products and services to you.

In certain circumstances, we also use your personal data only to the extent required in order to enable us to comply with
our legal obligations, including to detect, investigate and prevent fraud.

Necessary for the purposes of our legitimate business interests or those of a third party
It is sometimes necessary to collect and use your personal data for the purposes of our legitimate interests as a business,
which are to:

  • provide you with products and services that are as useful and beneficial as possible, including by personalising our contact
    with you and making sure we tell you about all the offers that are relevant to you;
  • better understand our customer base so that we can improve our products and services and marketing activities (which
    could also benefit you);
  • comply with our contractual obligations to third parties;
  • develop and improve our Site to enhance the customer experience;
  • train our staff so that we can provide you with a better customer service;
  • respond to any enquiries or complaints you have made, or deal with any dispute which may arise in the course of us
    providing our products and services to you; and
  • to ensure that content from our Site is presented in the most effective manner for you and for your computer;
  • ensure effective operational management and internal administration of our business, document retention, compliance with
    regulatory guidance and exercise or defence of legal claims.
    Where we think there is a risk that one of your interests or fundamental rights and freedoms may be affected we will not
    process your personal data unless there is another legal ground for us to do so (either that we have obtained your consent
    to the processing or it is necessary for us to perform our contract with you or to comply with our legal obligations).

6. Who we share your personal data with

We do not disclose your data with ANYONE.

8. Your rights

You have the following rights regarding your personal data:

Rights What does this mean?
1. Rights to be informed You have the right to be provided with clear, transparent and easily understandable information about how we use your personal data and your rights.
This is why we are providing you with the information in this Privacy Policy.
2. Right of access You have the right to obtain access to your personal data (if we are processing it)
and certain other information (similar to that provided in this Privacy Policy). This
is so you are aware and can check that we are using your personal data in
accordance with data protection law.
3. Right to rectification You are entitled to have your personal data corrected if it is inaccurate or
incomplete.
4. Right to erasure This is also known as ‘the right to be forgotten’ and, in simple terms, enable you to
request the deletion or removal of your personal data where there is no
compelling reason for us to keep using it. This is not a general right to erasure;
there are exceptions.
5. Right to restrict processing You have the right to ‘block’ or supress further use of your personal data in certain
circumstances. When processing is restricted, we can still store your personal
data, but may not use it further.
6. Right of data portability You have the right to obtain and reuse your personal data in a structured,
commonly used and machine-readable format in certain circumstances. In
addition, where certain conditions apply, you have the right to have such
information transferred directly to a third party.
7. Right to object to processing You have the right to object to us processing your personal data for our legitimate
business interests or for direct marketing purposes (including in each case any
related profiling).
8. Right to withdraw consent to
processing
If you have given your consent to us to process your personal data for a particular
purpose (for example, direct marketing), you have the right to withdraw your
consent at any time (although if you do so, it does not mean that any processing
of your personal data up to that point is unlawful).
9. Right to make a complaint to
the data protection authorities
You have the right to make a complaint to the Information Commissioner’s Office
(ICO) if you are unhappy with how we have handled your personal data or believe
our processing of your personal data does not comply with data protection law.

9. How to contact us

If you would like to exercise your data protection rights or if you are unhappy with how we have handled your personal data,
please feel free to contact us by using the details set out on our Site.

If you’re not satisfied with our response to any enquiries or complaint or believe our processing of your personal data does
not comply with data protection law, you can make a complaint to the Information Commissioner’s Office (ICO) by:

  • writing to: Information Commissioner’s Officer, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF;
  • calling: 0303 123 1113; or
  • submitting a message through the ICO’s website at: ico.org.uk

10. Links to other websites

Our website may contain hyperlinks to websites owned and operated by third parties. This Privacy Policy does not apply to
those other websites. We encourage you to read the privacy statements on the other websites you visit, as they will govern
the use of any personal data you provide when visiting those websites. We do not accept any responsibility or liability for
the privacy practices of such third party websites and your use of such websites is at your own risk.

11. Changes to this Privacy Policy

This Privacy Policy was last updated on 1 May 2018.

This Privacy Policy may be updated from time to time, so you may want to check it each time you provide personal data to
us.