Privacy Notice

When you browse our Sites, we collect and process certain Behavioural Data and Technical Data to help us understand how you are using and navigating our Sites. We do this so that we can better understand which parts of our Sites are popular and improve the structure and navigation of our Sites.

Our legal basis for processing
It is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you in relation to any account you have with us, or it is in our legitimate interest or a third party’s legitimate interest to use personal data in such a way to ensure that we provide access to our Sites in a secure and effective way and so that we can maintain and improve our Sites.

You may be required to register an account with us in order to gain access to certain features and functionality of our Online Store and/or to receive certain offers and benefits. Account applicants will need to complete the registration form, providing your Identity Data, Contact Data and a password. We will use this data to process your registration. We may collect and process your personal data whether you are interacting with us on your own behalf or on behalf of any organisation you represent.
Once the account is registered, we will process your Identity Data, Contact Data and password to identify you when you log in to your account and access secure areas of our Online Store. We will also process certain Technical Data and Marketing and Communications Data so that we can administer your account and contact you about your account.
We will also collect and process Behavioural Data and Technical Data when you use certain features and functionality on our Online Store. This data helps us understand how you use our Online Store so that we can improve it.
Please also see the section above entitled “If you browse our Sites” for more general information about how we process your personal data when you use our Sites.

Our legal basis for processing
It is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you in relation to your account and any Products, or it is in our legitimate interest to use personal data in such a way to ensure that we provide access to the Online Store and our Products in a secure and effective way and so that we can make improvements to our Online Store.

When you purchase Products through our Online Store, we collect and maintain personal data that you submit to us via the Online Store for the purpose of supplying our Products to you. We may collect and process your personal data whether you are interacting with us on your own behalf or on behalf of any organisation you represent.
The personal data we process may include your Identity Data, Contact Data, Profile Data, Financial Data and Transaction Data (where applicable). If you make a purchase through your account on our Online Store, we will process your Identity Data, Contact Data and password when you log in to your account.
We process this information so that we can process your order, take your payment and deliver the Products to you. We will also process your personal data for the purpose of any returns, to maintain our customer databases and to keep a record of your Product purchases.
If you purchase Products on our Online store, our Online Store Terms of Sale will also apply to you.

Our legal basis for processing
It is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you for the Products, or it is in our legitimate interest or a third party’s legitimate interest to use personal data in such a way to ensure that we provide our Products, and make them available for sale, in an effective, safe and efficient way.

We use your Identity Data and Contact Data to send you our brochures and other publications when you request them.

Our legal basis for processing
It is in our legitimate interest or a third party’s legitimate interest to use your personal data in the ways described above to ensure that we are able to help with your request and provide a good standard of service.

If you click on one of the social media links on our Sites or otherwise interact with our social media pages such as on Facebook, Twitter, YouTube, Instagram or LinkedIn (including interacting with any “like” or similar embedded features on our Sites or social media accounts), we and the relevant social media platform may receive information relating to such interaction and may share your personal data in connection with this purpose, such as certain Behavioural Data and Technical Data. For more information about how we use this personal data, please see the “Insight, analysis and retargeting through Cookies” section below.
The relevant social media platform may also be a controller in respect of the personal data that is collected via your use of our social media pages and may use that personal data for additional purposes. For details of how the relevant social media platform uses your personal data, please see the privacy notice of the relevant social media platform.

Our legal basis for processing
It is in our legitimate interest or a third party’s legitimate interest to use personal data in the ways described above to ensure that we provide our Sites in an effective way and to promote our Sites via social media.

 If you wish to open a trade account with us, you will be required to complete a new account application form and provide the applicable Registration Data. We may collect and process your personal data whether you are interacting with us on your own behalf or on behalf of any organisation you represent.
The Registration Data we collect depends on the nature of your trading status but will generally include your trading name, trading address, delivery address, landline, mobile and fax numbers, email address and your bank details (bank name, address, sort code, account number and/or IBAN number).
If you are applying for a trade account on behalf of a limited company, we will also collect your contact name, the company’s registration number and registered office address. For sole traders, partners in a partnership and any other non-company applicant, we will also collect your name, date of birth and home address. [Applicants will also need to provide a photo ID (passport or driving licence) to enable us to identify the applicant or, if applicable, a relevant company director.]
We will use your personal data for the purpose of processing your application for a trade account and, once your account is open, we will process your personal data so that we can administer your account, make our account features and benefits available to you and communicate with you about your account, any orders you have placed and any important information that may affect you or your use of our Products.
If you have applied for credit terms or you wish to change an existing credit limit, we will process your personal data to carry out credit checks through credit reference agencies.
In the case of non-payment, we may process your personal data for the purpose of debt recovery action.

Our legal basis for processing
It is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you for the Products or in relation to your trade account, or it is in our legitimate interest or a third party’s legitimate interest to use your personal data in the ways described above to ensure that we are able to administer your account, make our account features and benefits available to you, ensure that we provide a good standard of service and to help us improve our customer service and our Products.

We collect and maintain personal data that you submit to us for the purpose of supplying Products that you have requested from us using your trade account with us. We may collect and process your personal data whether you are interacting with us on your own behalf or on behalf of any organisation you represent.
You may place orders for Products in a variety of ways, including where an SOP representative attends your premises, where you attend our premises or by distance communication such as email, telephone or a mobile messaging service. The personal data we process in connection with your order will therefore depend on how and where you are interacting with us but will generally include your Identity Data and Contact Data, as well as certain Registration Data, Profile Data and Financial Data (where applicable).
We process this information so that we can process your order, take your payment and deliver the Products to you. We will also process your personal data for the purpose of any returns, maintaining our customer databases and to keep a record of your Product purchases.
If you purchase Products through your trade account with us, our trade account Terms and Conditions of Sale will also apply to your purchase.

Our legal basis for processing
It is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you (or the organisation you represent) for the Products you have requested, or it is in our legitimate interest or a third party’s legitimate interest to use personal data in such a way to ensure that we provide our Products in an effective, safe and efficient way.

 There are various ways in which you are able to contact us (see the “How to contact us” section above). In particular, our Sites feature a “Contact Us” page, which invites you to contact us via an online enquiry form. From time to time, you may also be able to submit specific enquiries on other pages of our Sites, including in secure account areas.
When you make an enquiry, we will collect and process your Identity Data and Contact Data (either your telephone number or your email address, depending on how you would like us to respond), as well as any other personal data you volunteer that is relevant to your enquiry. We use this information to manage and respond to your enquiry.
We may also record your enquiry (including voice recordings of telephone conversations) and use the information referred to above to train our personnel so that they are able to deal with enquiries in an effective way.

Our legal basis for processing
It is in our legitimate interest or a third party’s legitimate interest to use your personal data in the ways described above to ensure that we are able to help you with your enquiry, provide a good standard of service and improve our customer services and staff training.

If you wish to return any Products you have purchased from us, we will collect and process your Identity Data and Contact Data and, if applicable, certain Registration Data, Profile Data, Payment Data and Transaction Data, as well as any other personal data you volunteer that is relevant to your return. We use this information to assist you with the processing of your return (where we accept your return request).
If you purchase Products through your trade account with us, our Terms and Conditions of Sale will also apply to any return request you make. If you purchase Products on our Online store, our Online Store Terms of Sale will apply.

Our legal basis for processing
It is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you for the Products, or it is in our legitimate interest or a third party’s legitimate interest to use personal data in such a way to ensure that we are able to help you with your return or cancellation, provide a good standard of service and improve our processes and customer services.

From time to time, we may invite you to provide general feedback about us, our Sites and our Products in the form of online, email or postal surveys. We will collect and process your Identity Data, Contact Data and, if applicable, certain Registration Data, Profile Data and Transaction Data, as well as any other personal data you choose to volunteer in your feedback or survey response.
You can also voluntarily provide feedback in person at our premises or by telephone, post or email or via our online enquiry form (please see the “Customer service and enquiries” section above for more details).
We use feedback and the information obtained through surveys to help us monitor and improve our Sites and our Products, to assist with the selection of future product and service lines, to train our personnel and to improve the quality of our customer service.

Our legal basis for processing
It is in our legitimate interest or a third party’s legitimate interest to use the personal data provided by you so that we can improve our Sites, Products, staff training and customer services and provide them in an effective way.

 If we become aware of a product safety issue relating to any of our Products, we will investigate the problem and, where necessary, recall the Product. We will process certain personal data such as your Identity Data and Contact Data and any relevant Registration Data, Profile Data and Transaction Data to identify purchasers of the Product in question and to arrange a recall.

Our legal basis for processing
It is in our legitimate interest or a third party’s legitimate interest to use your personal data in the ways described above to ensure that we are able to help resolve any issues with our Products, maintain the safety of our Products and provide a good standard of customer service. We also have certain legal obligations in relation to product safety and may need to process personal data to comply with those legal obligations.

 From time to time, we may organise and host (whether alone or jointly with others) or sponsor events for the purpose of promoting our business or for charitable causes or other reasons. We may process your Identity Data and Contact Data to communicate with you about such events where you have specifically requested information about such events or where we have another lawful basis for sending that information to you.
If you attend one of these events, we may use your Identity Data, Contact Data and certain Profile Data to record your attendance at the event and for related record-keeping purposes. If relevant, we may also collect and process any dietary requirements you may have. You may also feature in photographs taken at such events and such photographs may appear in publications and PR materials that we make available online and in print.

Our legal basis for processing
It is necessary for us to use your personal data in this way to perform our obligations in accordance with any contract that we may have with you where you have signed up to attend an event, or it is in our legitimate interest or a third party’s legitimate interest to use personal data in such a way to ensure that the event is operated in an effective way.
We may specifically ask your permission to use your photographs, quotes, testimonials, or other content that you make available or publish at the event. Where this is the case, our processing of your such personal data will be based on your consent.

 From time to time, we may run prize draws, prize competitions and other promotions on our Sites and/or on our social media accounts. For the purposes of administering such promotions, we may process your Identity Data and Contact Data, certain Registration Data, Profile Data and Transaction Data (where applicable) and any other personal data volunteered by you in relation to your promotion entry.
Our promotions are subject to separate terms and conditions, which you may be required to accept as a condition of entry. Such terms and conditions will be made available to you in the promotional materials relevant to the promotion.

Our legal basis for processing
It is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you (e.g. the promotion terms and conditions) or it is in our legitimate interest or a third party’s legitimate interest to use your personal data to enable us to administer our promotion fairly and effectively and to ensure that we comply with any self-regulatory codes governing the operation of promotions.

From time to time, we receive requests for charitable donations. If you make a request, your request will include personal data, such as your Identity Data and Contact Data, as well as any other personal data you may include in your request. If your request is successful, we will ask you to complete a form, setting out the name of the organisation which is to receive the charitable donation and Financial Data such as the organisation’s bank account details. As part of the application process, we may also ask you for further information about your request and your response may include additional personal data.
We will use the information obtained through the application process to help us administer the process and to assess the merits of the specific request. We will use your name and contact details to communicate with you in relation to your request and, if the request is successful, we will process the bank account details provided to enable us to process our payment to the recipient. We also retain any personal data for record-keeping purposes.

Our legal basis for processing
It is in our legitimate interest or a third party’s legitimate interest to use personal information in the ways described above to ensure that we are able to process and administer requests for charitable donations fairly and efficiently.

From time to time, we may offer financial support to organisations through sponsorship and other initiatives. We may occasionally publicise our involvement by publishing news and photographs about our sponsorship activities on our website and social media, as well as in other print and online media. If you feature in such news and/or photographs, we will process your personal data (which may include your Identity Data and any other relevant information) for the purpose of publicising our sponsorship and other charitable activities.

Our legal basis for processing
It is in our legitimate interest or a third party’s legitimate interest to use personal information in the ways described above to ensure that we are able to promote our business and our sponsorship and charitable activities. If it is not within our legitimate interest, we will contact you to ask your permission, in which case our processing of such personal data will be based on your consent.

 We and our third-party partners use cookies, web beacons, pixels, tags and other similar technologies (which we generically refer to as “Cookies”) to collect data from the devices that you use to access our Sites and our Products [and any emails that you receive from us]. The data that is collected includes Behavioural Data and Technical Data, and certain Profile Data and Transaction Data. Please see our Cookie Notice for further information, including details of our third-party partners.
We and our third-party partners use this data to analyse how you use our Sites and our Products and the effectiveness of our Sites and our Products, including:

• for the purposes described in the “If we carry out any online personalised advertising”, “If we advertise to you on social media and other platforms”, and the “If we advertise to other people who share similar interests and characteristics to you” sections below;
• to analyse how you use, and the effectiveness of, our Sites;
• to count users who have visited our Sites [or opened an email] and collect other types of information, including insights about visitor browsing habits, which helps us to improve our Sites, our Products and the effectiveness of our emails;
• to measure the effectiveness of our content;
• to learn what parts of our Sites are most popular and what kind of features and functionalities our visitors like to see;
• to help us understand the type of marketing content that is most likely to appeal to our visitors and customers; and
• to help us with the selection of future product and service lines, website design and to remember your preferences.

[In some of our email messages, we use a “click-through URL” linked to certain websites administered by us or on our behalf. We may track click-through data to assist in determining interest in particular topics and measure the effectiveness of these communications.]

Our legal basis for processing
Where your data is collected through the use of non-essential cookies, we rely on consent to collect your personal data and for the onward processing purpose. Please see our Cookie Notice for further details.
In certain circumstances, we may rely on another lawful basis when we use your personal data collected via the use of Cookies. For example, where we use personal data collected through the use of analytics Cookies to analyse how you use our Sites, it is in our legitimate interest to use your personal data in such a way to improve our Sites and our Products.

 We use your Identity Data, Contact Data and Marketing and Communications Data to send you (or the organisation you represent) marketing communications by post and/or email/SMS. Our marketing will include press releases and information about us, our Sites, our Products, any events we may hold and the offers and promotions we offer from time to time.
Our marketing communications will include personalised and non-personalised marketing.
Personalised marketing has been specifically tailored to you and will include content that we think is most relevant to you, based on what we know about you. Personalised marketing would include emails about Products we know you have shown an interest in previously.
Non-personalised marketing is marketing that is not tailored to you and is sent to subscribers generally, such as an email about a seasonal sale or promotion we may be running and which will be of interest to all of our customers.
Where we are sending you personalised marketing, we may also use Profile Data, Transaction Data and Behavioural Data to help us decide what sort of personalised marketing to send you. Please see the “Insight, analysis and retargeting through Cookies ” section above for more details.

Our legal basis for processing
It is in our legitimate interest to use your personal data for marketing purposes, for example to decide what marketing content we think may appeal to you.
It is in our legitimate interest to use your personal data to send our marketing to you by post.
However, we will only send marketing communications to you by email and/or SMS where you have consented to receive such content by email and/or SMS, or where we have another lawful right to send marketing to you using email and/or SMS. For example, in certain circumstances we may rely on our legitimate interest to send marketing by email and/or SMS to customers who have purchased our Products. We may also rely on our legitimate interest to send marketing by email and/or SMS to certain business users of our Sites and our Products.

We and our third party partners may use your Profile Data, Behavioural Data and Technical Data, and other data that is collected through your interactions with third party websites and services, to provide you with, and analyse the effectiveness of, personalised ads when you visit other websites and/or use other services (including the social media and other platforms described in the “If we advertise to you on social media and other platforms ” section below).
By “personalised ads”, we mean advertisements for products and services that you have shown an interest in when you have used our Sites or which you otherwise might be interested in based on your browsing habits, although our third-party partners may use the data that is collected to show personalised ads for products and services offered by third parties.

Our legal basis for processing
Please see the “Insight, analysis and retargeting through Cookies ” section above to learn about the legal basis that we rely on to collect data via the use of Cookies.
Where we use your personal data to display online personal advertising to you, we rely on the consent that you have provided in respect of the collection of such data, or it is otherwise in our legitimate interests to promote our Sites and our Products to you.
Our third-party partners may rely on a different lawful basis in respect of their use of your personal data. Please read the privacy notice of the relevant third-party provider (see our Cookie Notice and/or our Cookie Preference Centre for details).

We share your email address and other identifiers such as your phone number or device ID (usually in an encrypted or ‘hashed’ form) with third-party providers of social media platforms and other services, such as Facebook and other similar platforms (“Social Platforms”), so that the third-party providers can try to “match” your data with the data of their registered users of their Social Platforms.
Where there is a successful match, we will display our advertising to you when you use the relevant Social Platform (e.g. on your Facebook newsfeed). This is known as “custom audience” advertising, because we “customise” the audience that we want to reach on the relevant service.
Some of the advertising that you see may be personalised to you. The data that we use to personalise our advertising, such as your Profile Data, Behavioural Data and Technical Data, will not be provided to the third-party providers of the Social Platforms for this purpose but please see the “Insight, analysis and retargeting through Cookies” section for details of where we may share such data.
This activity is also subject to the privacy choices you have elected to make on such Social Platforms.

Our legal basis for processing
We will only share your personal data with the third-party providers of the Social Platforms, so that we can advertise our Products to you when you use those Social Platforms, where you have provided your consent or where it is otherwise in our legitimate interests to do so in order to promote our Products.
Where this activity is undertaken through the use of Cookies, please see the “Insight, analysis and retargeting through Cookies” section to learn about the legal basis that we rely on.
You can opt-out of our sharing of your personal information with the third-party providers by exercising your rights as a data subject as set out below.

 We use your personal data for recruitment purposes, in particular, to assess your suitability for any of our positions that you apply for, whether such application has been received by us online, by email or by hard copy and whether submitted directly by you or by a third-party recruitment agency on your behalf. We also use your Identity Data and Contact Data to communicate with you about the recruitment process, to keep records about our recruitment process and to comply with our legal and regulatory obligations in relation to recruitment.
We will process any personal data about you that you volunteer, including during any interview, when you apply for a position with us. We may also process your personal data obtained from any third parties we work with in relation to our recruitment activities, including without limitation, recruitment agencies, background check providers, credit reference agencies and your referees.
The personal data we process may include your Identity Data, Contact Data, details of your education, qualifications and employment history, any other personal data which appears in your curriculum vitae or application, any personal data that you volunteer during an interview or your interactions with us, or any personal data which is contained in any reference about you that we receive. Such information may also include special categories of personal data (such as information about your health, any medical conditions and your health and sickness records) and information relating to criminal convictions and offences if that information is relevant to the role you are applying for.
We also use your personal data for the purposes of reviewing our equal opportunity profile in accordance with applicable legislation. We do not discriminate on the grounds of gender, race, ethnic origin, age, religion, sexual orientation, disability or any other basis covered by local legislation. All employment-related decisions are made entirely on merit.

Our legal basis for processing
Where we use your personal data in connection with recruitment, it will be in connection with us taking steps at your request to enter into a contract we may have with you or it is in our legitimate interest to use personal data in such a way to ensure that we can make the best recruitment decisions.
We will not process any special (or sensitive) categories of personal data or personal data relating to criminal convictions or offences except where we are able to do so under applicable legislation or with your explicit consent.

 If we have engaged you or the organisation you represent to provide us with products or services (for example, if you or the organisation you represent provide us with services such as IT support or financial advice), we will collect and process your personal data in order to manage our relationship with you or the organisation you represent, to receive products and services from you or the organisation you represent and, where relevant, to provide our Products to others. The personal data we collect from you may include your Identity Data and Contact Data and any other personal data you volunteer which is relevant to our relationship with you or the organisation you represent.

Our legal basis for processing
It is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you or the organisation you represent, or it is in our legitimate interest or a third party’s legitimate interest to use personal data in such a way to ensure that we have an effective working relationship with you or the organisation you represent and are able to receive the products and services that you or your organisation provides, and provide our Products to others, in an effective way.

 We have security measures in place at our premises, including CCTV and building access controls. Where relevant, there are signs in place showing that CCTV is in operation. The images captured are securely stored and only accessed on a need to know basis (e.g. to look into an incident). CCTV recordings are automatically overwritten after a short period of time unless an issue is identified that requires investigation (such as a theft).
We may require visitors to our premises to sign in on arrival and where that is the case we will keep a record of visitors for a short period of time. Our visitor records are securely stored and only accessible on a need-to-know basis (e.g. to look into an incident).

Our legal basis for processing
It is in our legitimate interest or a third-party’s legitimate interest to process your personal data so that we can keep our premises secure and provide a safe environment for our personnel and visitors to our premises.

 We may use your personal data: (i) to comply with our legal obligations; (ii) to exercise and enforce our legal rights; (iii) to protect the rights of third parties; (iv) to comply with any formalities for executing documents; and (v) in connection with a business transition such as a merger, reorganisation, acquisition by another company, or sale of any of our assets.

Our legal basis for processing
Where we use your personal data in connection with a business transition, to exercise and enforce our legal rights or to protect the rights of third parties, it is in our legitimate interest or the legitimate interest of a third party to do so. For all other purposes described in this section, we have a legal obligation to use your personal data to comply with any legal obligations imposed upon us, such as a court order.
We will not process any special (or sensitive) categories of personal data or personal data relating to criminal convictions or offences except where we are able to do so under applicable legislation or with your explicit consent.

If the personal data we hold about you is inaccurate or incomplete, you are entitled to have it rectified. If we have shared your personal data with others, we’ll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we will also tell you who we’ve shared your personal data with so that you can contact them.

You can exercise your right  using the GDPR Compliance  or CCPA Compliance link.

You can ask us to delete or remove your personal data in some circumstances, such as where we no longer need it or where you withdraw your consent (where applicable). If we have shared your personal data with others, we will let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we will also tell you who we have shared your personal data with so that you can contact them directly.

You can exercise your right  using the GDPR Compliance  or CCPA Compliance link.

You can ask us to “block” or suppress the processing of your personal data in certain circumstances such as where you contest the accuracy of that personal data or you object to us processing it for a particular purpose. This may not mean that we will stop storing your personal data but, where we do keep it, we will tell you if we remove any restriction that we have placed on your personal data to stop us processing it further. If we’ve shared your personal data with others, we’ll let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal data with so that you can contact them directly.

You can exercise your right  using the GDPR Compliance  or CCPA Compliance link.

You have the right, in certain circumstances, to obtain personal data you have provided to us (in a structured, commonly used, machine-readable format) and to reuse it elsewhere or to ask us to transfer it to your chosen third party.

You can exercise your right  using the GDPR Compliance  or CCPA Compliance link.

You can ask us to stop processing your personal data, and we will do so, if we are: (i) relying on our own or someone else’s legitimate interest to process your personal data, except if we can demonstrate compelling legal grounds for the processing; or (ii) processing your personal data for direct marketing purposes.

You can exercise your right  using the GDPR Compliance  or CCPA Compliance link.

You have the right not to be subject to a decision when it is based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for the entering into, or the performance of, a contract between you and us.

You can exercise your right  using the GDPR Compliance  or CCPA Compliance link.

If we rely on your consent (or explicit consent) as our legal basis for processing your personal data, you have the right to withdraw that consent at any time. You can exercise your right of withdrawal by contacting us using our contact details in the “How to Contact Us ” section above or by using any other opt-out mechanism we may provide, such as an unsubscribe link in an email.

You can exercise your right  using the GDPR Compliance  or CCPA Compliance link.

If you have a concern about any aspect of our privacy practices, including the way we have handled your personal data, please contact us using the contact details provided in the “How to Contact Us” section above. You can also report any issues or concerns to a national supervisory authority in the Member State of your residence or the place of the alleged infringement. You can find a list of contact details for all EU supervisory authorities at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm. 

As we are incorporated in the UK, our regulatory authority is the Information Commissioner’s Office. Contact details can be found on its website at https://ico.org.uk.