Privacy Policy

Introduction

Welcome to John Davies Framing’s privacy notice.  John Davies Framing shall be referred to as “we”, “us”, “our” throughout this privacy notice.

This policy applies to all group companies (including John Davies Framing Limited and Davies & Davies Limited).

We respect your privacy and are committed to protecting your personal data. This privacy notice will inform you as to how we collect, use, handle and disclose your personal data, as well as telling you about your privacy rights and how the law protects you.   If you need any more information about our data protection practices, please contact us using the details below.

This privacy notice contains the following information:

  1. Important information and who we are
  2. Data protection principles
  3. The data we collect about you and how we collect and use your data
  4. Disclosures of your personal data
  5. International transfers
  6. Data security
  7. Data retention
  8. Your legal rights
  9. Glossary

 

  1. Important information and who we are

Purpose of this privacy notice

This privacy notice aims to give you information on how we collect and process your personal data, including any data you may provide when enquiring about our framing services or purchasing frames or our framing services from us. This also relates to any data you may provide through use of this website.  Please see the Glossary section for an explanation of the meaning of “personal data”.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Controller

John Davies Framing Limited is the controller and responsible for your personal data.

If you have any questions about this privacy notice, including any requests to exercise your legal rights (see section 8 below), please contact us using the following details:

Contact details

E-mail address:  john@johndaviesframing.com

Postal address:   8 Bury Street, St. James’s, London SW1Y 6AB

You have the right to make a complaint at any time to the Information Commissioner’s Office (“ICO”), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy notice and your duty to inform us of changes

This version was last updated on [25 May 2018].

The data protection law in the UK will change on 25 May 2018.

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.

Third-party links

Our 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 notice of every website you visit.

  1. Data protection principles

We adhere to the principles set out in data protection legislation when handling personal data.  These principles require personal data to be:

  • Processed lawfully, fairly and in a transparent manner.
  • Collected only for specified, explicit and legitimate purposes.
  • Adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed.
  • Accurate and where necessary kept up to date.
  • Not kept in a form which permits identification of data subjects for longer than is necessary for the purposes for which the data is processed.
  • Processed in a manner that ensures its security using appropriate technical and organisational measures to protect against unauthorised or unlawful processing and against accidental loss, destruction or damage.
  • Not transferred to another country without appropriate safeguards being in place.
  • Made available to data subjects and allow data subjects to exercise certain rights in relation to their personal data.

We are also responsible and accountable for ensuring that we can demonstrate compliance with the data protection principles listed above.

  1. The data we collect about you and how we collect and use your data

We may collect, use, store and transfer different kinds of personal data about you.  The personal data that we collect and process will broadly fall into the following categories:

  • personal data collected and processed in relation to customers who may enquire about our framing services or who acquire frames and our framing services from us; and
  • personal data collected and processed through the website (including when you use the “Contact” function on the website).

If you fail to provide personal data we may be unable to provide certain services and we will discuss this with you.

The below table provides a summary of how we collect and process your personal data:

 

Personal data collected and processed in relation to customers who may enquire about frames or framing services or purchase frames or services from us:

Types of data Collection How we process your data Lawful basis for processing
Contact details, including your name, address, e-mail address, telephone number, order details and financial payment information Personal data is collected through direct interaction with you, such as when you come in to our showroom and interact with our sales staff, if you contact us via email and telephone or when you purchase goods and services from us. For the purposes of selling our frames or framing services to our customers  

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests

 

 

Personal data collected through the website:

Types of data Collection How we process your data Lawful basis for processing
Contact details including name and e-mail address Personal data is collected through direct interaction with you on the website (for example, if you submit a request for us to contact you) For the purposes of communicating with you, managing our customer relationship and  administering and protecting our business and this website (including troubleshooting, data analysis, testing, system maintenance and network security)  

(a) Performance of a contract with you

(b) Necessary for our legitimate interests

Technical data, such as internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, session replay data and other technology on the devices you use to access this website Personal data is collected through automated technologies or interactions, from analytics providers or search information providers For the purposes of using data analytics to improve our website, marketing, client relationships and user experience, to administer and protect our business and this website (including troubleshooting, data analysis, testing and system maintenance and network security) and to allow you to participate in any interactive features on our website  

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security and to prevent fraud)

(b) Necessary to comply with a legal obligation

 

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.

See below for further details about the types of lawful basis that we will rely on to process your personal data.

Cookies

We use cookies to help collect the technical data (referred to above) and to help us understand how visitors interact with our site. We use this to help improve the layout, content and navigation of the site. Users can control the use of cookies at the individual browser level. If you reject cookies, you may still use our website, but your ability to use some features or areas of our website may be limited.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

  1. Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 3 above. We will not disclose your personal to a third party without consent or unless we are satisfied that we are legally entitled to share such data under data protection laws. Where we do disclose your personal data to a third party, we will have regard to the data protection principles under data protection laws.

We may however share customer personal data with the following organisations, and for the following purposes

Organisation Purpose
Cobweb Solutions Ltd Cobweb develop and host our website. The legal basis for sharing this data is our legitimate business interests, namely the proper performance of our website. Further details on Cobweb’s data protection compliance can be found at https://www.cobweb.com/gdpr
Service providers Other service providers who provide IT support and software and system administration services.
Dropbox Inc. We use Dropbox in order to store invoices and customer files and to securely share them between our showroom and our factory. The legal basis for sharing this data is our legitimate business interests, namely to enable us to deliver our services in an efficient and secure manner. As Dropbox has servers based within the EEA and in the US it complies with the EU-U.S. and Swiss-U.S. Privacy Shield Framework regarding the collection, use, and retention of personal information transferred from the European Union, the European Economic Area, and Switzerland to the United States. Further details on Dropbox’s data protection compliance can be found at  https://www.dropbox.com/en_GB/security/GDPR
Legal authorities HM Revenue & Customs and other authorities based in the United Kingdom may also require reporting of processing activities in certain circumstances
Professional advisers Professional advisers acting as processors or joint controllers including lawyers, bankers, experts, other accountants, insurers and other third parties based who provide legal, banking, consultancy, accounting, insurance and other related services

 

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 notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law.  We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

  1. International transfers

With the exception of Dropbox (see above) we do not transfer your personal data outside the European Economic Area (EEA).

  1. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

  1. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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 requirements.

Details of retention periods for different aspects of your personal data are available on request by contacting us using the details above.

  1. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

  • Request access to your personal data.
  • Request correction of your personal data.
  • Request erasure of your personal data.
  • Object to processing of your personal data.
  • Request restriction of processing your personal data.
  • Request transfer of your personal data.
  • Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

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 may refuse to comply with your request in these circumstances.

What we may need from you

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.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may 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.

  1. Glossary

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

Sensitive Personal Data means information revealing racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, physical or mental health conditions, sexual life, sexual orientation, biometric or genetic data, and personal relating to criminal offences and convictions.

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights 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).  You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us

Performance of contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

YOUR LEGAL RIGHTS

You have the right to:

Request access to your personal data (commonly known as a “data 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. 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) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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 (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

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.