Here at Bottle Bling (we, us), we are committed to protecting the data that we hold and use about you and to respecting your privacy. We are confident that you will find the information that you need set out in this policy, but if you need to know more about the data that we hold or the way that we use it, you can contact us by emailing firstname.lastname@example.org or by post at "Privacy Team, Unit 9 The Pavillions, Blackpool FY4 2DP'
- About this policy
- The way that we use your personal data
- What personal data do we collect?
- How do we collect personal data?
- How do we use personal data?
- How do we share your personal data?
- Security and retention of your personal data
- Your rights and how to contact us
1. About this policy
The "data controller" of your personal data (in other words, the organisation that determines how your data is used) is B & T Promotions Limited
2. The way that we use your personal data
A. What personal data do we collect?
This policy gives you information about the way that we use your "personal data". Personal data is any information that could be used to identify you in some way. The personal data that we collect from or about you may include the following:
- e-mail address;
- phone number;
- any location or category preferences you have subscribed to in relation to the products and services we offer;
- location information from the device that you use to visit the site or whilst using our App;
- financial, credit and debit card information when you make a purchase or call our customer service line;
- information about the products and services you purchase from us;
- information about your visit to our websites, including information about how and when you came to visit our websites, how you interacted with the websites (products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information such as scrolling, clicks, and mouse-overs), and where you went next (including full URLs and methods used to browse away from the site);
- technical information about the way that you use web or mobile services, including the internet protocol (IP) address used to connect your computer to the internet, your login information if you register on our website or via our app, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, device information;
- information collected from our websites and elsewhere across the internet through cookies, web beacons, pixel tags, device identifiers and other technologies including information about your shopping habits and preferences; and
- demographic information and other information provided by you.
Similarly, we do not intend to collect (and we ask you not to disclose) any particularly sensitive data such as data relating to your health, religion or ethnic background.
B. How do we collect personal data?
We may collect personal data in a variety of ways including:
- Directly from you: Information such as name, address, telephone number, email address, as well as other information, such as your website registration details and preferred means of communication, may be collected when you voluntarily provide this information to us (for example when you register on the site as a customer or make an enquiry, purchase any of our products or services, participate in our message boards, blogs or any other user generated content facilities, or send emails to us);
- From other sources:
- We work closely with third parties providing services to us (including, for example, business partners, sub-contractors providing technical, payment and delivery services related to the goods or services we provide to you, advertising networks, social networking platforms, analytics providers, search information providers) and we may also receive information about you from them;
- In some circumstances related to a particular transaction, we may obtain data from public databases and
- We may combine information that we collect about you from other sources with the information that you give to us directly. We may use this combined information as described in this policy;
C. How do we use personal data, and what is our justification for doing so?
We use your personal data for a variety of purposes related to the products and services that we provide. From a legal perspective, there are various reasons for doing so and we have set out an explanation of this below.
For purposes related to the provision of the products and services that we offer to you:
For advertising and marketing purposes, including to measure how effective our marketing is:
We rely on your consent to contact you directly about the products and services on offer on our site (. In other scenarios (for example, measuring the effectiveness of our marketing), we will rely on our legitimate interests as a business, always ensuring that your rights are protected.
For administrative and internal business purposes:
It is in our legitimate interests as a business to use your data in this way. For example, we have a clear interest in ensuring that our site works properly and that our products and services are high quality and efficient. We will always ensure that your rights are protected.
For security and legal and compliance purposes:
In some cases, we will need to use your personal data to fulfil a legal obligation (for example, if we receive a legitimate request from law enforcement agencies), and in other cases (such as the detection of fraud or ensuring the security of the site) we will rely on our legitimate interests as a business to use your data in this way.
International transfer of your data:
Whenever we send (or permit a third party to send) your personal data outside of Europe, we will make sure that we take steps necessary to protect your data as required by applicable laws. For example, we may implement specific contract terms or we may rely on service providers who adhere to certain compliance programmes overseas, or we may select service providers based in countries with strong local laws to protect your personal data.
D. How do we share your personal data?
We will never sell your personal data or give it to anyone else for them to use for their own purposes without making that clear to you. There are, however, various ways in which we will share your data, as set out below:
- Sharing data within our group:
We engage various third parties to provide services to us for specific functions, and this will often mean that we need to share your personal data with them (it is in our legitimate interests to do so, since we may not have the capabilities to provide these services ourselves). In each case, we will ensure that these third parties are only allowed to use your personal data in order to provide the relevant services to us. We will always make sure that we use organisations that we trust to look after your personal data appropriately and as required by applicable laws.
Some examples of these third parties will include: credit card processing services, order fulfilment, analytics, website management, information technology and related infrastructure provision, customer service, auditing, and other similar services.
- Sharing data with online advertising related service providers:
We may from time to time work with online advertisers, social media platforms and advertising networks to deliver, tailor and measure advertising to you and others both on the site and elsewhere on the internet (including on social media platforms such as Facebook and Twitter). We also use various tools and products which involve the sharing of data with Google (https://policies.google.com/privacy?hl=en-GB), Acxiom (https://www.acxiom.co.uk/about-acxiom/privacy/uk-privacy-policy/)
The personal data that we allow to be shared with these third parties includes online identifiers such as IP address, data from cookies or similar technologies, or other device related information.
Similarly, we may share certain online identifiers with analytics and search engine providers that assist us in the improvement and optimisation of our site.
You can choose not to allow your data to be used to deliver targeted advertising by changing your settings within social media platforms, or as described in the third party privacy policies set out above
There may be scenarios where we are subject to a legal obligation to disclose or share your personal data, such as with law enforcement agencies or public authorities in order to prevent or detect crime.
3. Security and retention of your personal data
- Security of your personal data:
We take the security of your data very seriously and have put physical, technical and administrative strategies, controls and measures in place to help protect your personal data from unauthorised access, use of disclosure as required by law and in accordance with accepted good industry practice.
To help us keep your data safe please choose a strong, secure password and keep your password confidential and avoid sharing it with anyone.
- Retention of your personal data:
4. Your rights and how to contact us
The law gives you a number of rights in relation to your personal data and our use of it. You have the right:
- to ask us not to use your personal data for direct marketing purposes;
- to ask to see what personal data we hold about you and to find out about the way that we process the data (and in some circumstances, you can ask us to provide a copy to a third party);
- to ask us to correct or update any personal data which is inaccurate;
- to ask for personal data to be deleted in some (but not all) circumstances where there is no good reason for us to continue to process it;
- to ask us to temporarily stop using your data if you don't believe that we have a right to use it, or to stop us from using your personal data where there is no good reason for us to continue to use it; and
- not to be subject to decisions made solely on the basis of 'automated processing' (i.e. the right not to be subject to decisions made solely by algorithms or computers without input from a human) in certain circumstances.
You also have the right to complain about our use of your personal data. You can contact the Information Commissioner's Office via their website: https://ico.org.uk/concerns/ or by calling 0303 123 1113.
© v1.1 2018
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