1. Introduction

1.1 We take your privacy very seriously. Please read this privacy notice carefully as it contains important information on who we are and how and why we collect, store, use and share your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint.

1.2 We collect, use and are responsible for certain personal information about you. When we do so we are subject to the General Data Protection Regulation, which applies across the European Union (including in the United Kingdom) and we are responsible as ‘controller’ of that personal information for the purposes of those laws.

1.3 In this privacy notice the following words and phrases have the associated meanings:

we, us, our means Comics Salopia CIC, a community interest company limited by guarantee with company registration number 11625444.

you, your means a person who engages or deals with us and whose personal information we obtain.

personal information means any information relating to an identified or identifiable individual.

special category personal information means any personal information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership, genetic and biometric data, or data concerning health, sex life or sexual orientation.

2. Personal information we collect about you

2.1 We may collect and use the following personal information about you:
     2.1.1 your name and contact information, including residential or business address, email address, fax number, telephone number and company details;
     2.1.2 information to enable us to check and verify your identity including, for example, your date of birth;
     2.1.3 your gender information, if you choose to give this to us;
     2.1.4 location data, if you choose to give this to us;
     2.1.5 your billing information, transaction and payment card information;
     2.1.6 your personal or professional interests;
     2.1.7 your professional online presence including, for example, your LinkedIn profile;
     2.1.8 your contact history, purchase history and saved items;
     2.1.9 information from accounts you link to us including, for example, Twitter, Facebook and Instagram;
     2.1.10 information to enable us to undertake credit or other financial checks on you;
     2.1.11 information about how you use our website, apps, information technology, communication and other systems;
     2.1.12 your responses to surveys, competitions and promotions; and
     2.1.13 [other information].[1]

2.2 This personal information is required to provide our products and services to you. If you do not provide personal information we ask for, it may delay or prevent us from providing products services to you.

3. How your personal information is collected

3.1 We collect most of this personal information directly from you (whether in person, by telephone, text or email and/or via our website and apps). However, we may also collect information:
     3.1.1 from publicly accessible sources including, for example, Companies House;
     3.1.2 directly from a third party including, for example, sanctions screening providers, credit reference agencies, and other due diligence providers;
     3.1.3 from a third party with your consent including, for example, your bank, building society and credit card company;
     3.1.4 from cookies on our website and our apps. For more information on our use of cookies, please see our cookies policy; and
     3.1.5 via our other information technology systems.

4. How and why we use your personal information

4.1 Under data protection law, we can only use your personal information if we have a proper reason for doing so including, for example:
     4.1.1 to comply with our legal and regulatory obligations;
     4.1.2 for the performance of our contract with you or to take steps at your request before entering into a contract;
     4.1.3 for our legitimate interests or those of a third party; or
     4.1.4 where you have given consent.

4.2 A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

4.3 The table below explains what we use (process) your personal information for and our reasons for doing so:

 

What we use your personal information for Our reasons
To provide products and/or services to you. For the performance of our contract with you or to take steps at your request before entering into a contract.
To prevent and detect fraud against you or us. For our legitimate interests or those of a third party. In particular, to minimise fraud that could be damaging for us and for you.
Conducting checks to identify our customers and verify their identity.

Screening for financial and other sanctions or embargoes.

Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business.

To comply with our legal and regulatory obligations.
Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies. To comply with our legal and regulatory obligations.
Ensuring business policies are adhered to including, for example, policies covering security and internet use. For our legitimate interests or those of a third party. In particular, to make sure we are following our own internal procedures so we can deliver the best products and/or services to you.
Operational reasons, such as improving efficiency, training and quality control. For our legitimate interests or those of a third party. In particular, to be as efficient as we can so we can deliver the best products and/or services to you at the best price.
Ensuring the confidentiality of commercially sensitive information. For our legitimate interests or those of a third party. In particular, to protect trade secrets and other commercially valuable information.

To comply with our legal and regulatory obligations.

Statistical analysis to help us manage our business including, for example, in relation to our financial performance, customer base, product range or other efficiency measures. For our legitimate interests or those of a third party. In particular, to be as efficient as we can so we can deliver the best products and/or services to you at the best price.
Preventing unauthorised access and modifications to systems. For our legitimate interests or those of a third party. In particular, to prevent and detect criminal activity that could be damaging for us and for you.

To comply with our legal and regulatory obligations.

Updating and enhancing records. For the performance of our contract with you or to take steps at your request before entering into a contract.

To comply with our legal and regulatory obligations.

For our legitimate interests or those of a third party including, for example, making sure that we can keep in touch with our customers about existing orders and new products and/or services.

Statutory returns. To comply with our legal and regulatory obligations.
Ensuring safe working practices, staff administration and assessments. To comply with our legal and regulatory obligations.

For our legitimate interests or those of a third party including, for example, to make sure we are following our own internal procedures and working efficiently so we can deliver the best products and/or services to you.

Marketing our products and/or services to existing and former customers, third parties who have previously expressed an interest in our services, and third parties with whom we have had no previous dealings.

 

For our legitimate interests or those of a third party. In particular, to promote our business to existing and former customers.

4.4 The above table does not apply to special category personal information, which we will only process with your explicit consent.

5. Promotional communications

5.1 We may use your personal information to send you updates (by email, text message, telephone, post and our apps) about our products and/or services, including exclusive offers, promotions or new products and/or services.

5.2 We have a legitimate interest in processing your personal information for promotional purposes (see above ‘How and why we use your personal information’). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.

5.3 We will always treat your personal information with the utmost respect and never sell or share it with other organisations for marketing purposes.[2]

5.4 You have the right to opt out of receiving promotional communications at any time by:
     5.4.1 contacting us (see below ‘How to contact us’); or
     5.4.2 using the ‘unsubscribe’ link in emails.

5.5 We may ask you to confirm or update your marketing preferences if you instruct us to provide further products and/or services in the future, or if there are changes in the law, regulation, or the structure of our business.

6. Who we share your personal information with

6.1 We routinely share personal information with:
     6.1.1 third parties we use to help deliver our products and/or services to you, including, for example, payment service providers, warehouses and delivery companies;
     6.1.2 other third parties we use to help us run our business, including, for example, marketing agencies or website hosts;
     6.1.3 third parties approved by you including, for example, social media sites you choose to link your account to or third party payment providers;
     6.1.4 our bank; and
     6.1.5 [others].[3]

6.2 We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you.

6.3 We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

7. Where your personal information is held

7.1 Information may be held at our offices and those of our, third party agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal information with’).

7.2 Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below: ‘Transferring your personal information out of the EEA’.

8. How long your personal information will be kept

8.1 We will keep your personal information while you have an account with us or we are providing products and/or services to you. Thereafter, we will keep your personal information for as long as is necessary:
     8.1.1 to respond to any questions, complaints or claims made by you or on your behalf;
     8.1.2 to show that we treated you fairly; and
     8.1.3 to keep records required by law.

8.2 We will not retain your personal information for longer than necessary for the purposes set out in this privacy notice.

9. Transferring your personal information out of the EEA

9.1 To deliver our products and/or services to you, it is sometimes necessary for us to share your personal information outside the European Economic Area (EEA) including, for example:
     9.1.1 with your and our service providers located outside the EEA; and
     9.1.2 if you are based outside the EEA.

9.2 These transfers are subject to special rules under European and UK data protection law.

9.3 These non-EEA countries do not have the same data protection laws as the United Kingdom and EEA. We will, however, ensure the transfer complies with data protection law and all personal information will be secure. Our standard practice is to use standard data protection contract clauses that have been approved by the European Commission.

9.4 If you would like further information please contact us (see ‘How to contact us’ below).

10. Your rights

10.1 You have the following rights, which you can exercise free of charge:
     10.1.1 Access. The right to be provided with a copy of your personal information (the right of access);
     10.1.2 Rectification. The right to require us to correct any mistakes in your personal information;
     10.1.3 To be forgotten. The right to require us to delete your personal information in certain situations;
     10.1.4 Restriction of processing. The right to require us to restrict processing of your personal information in certain circumstances, including, for example, if you contest the accuracy of the data;
     10.1.5 Data portability. The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party in certain situations;
     10.1.6 To object. The right to object:
          (a) at any time to your personal information being processed for direct marketing (including profiling); or
          (b) in certain other situations to our continued processing of your personal information, including, for example, processing carried out for the purpose of our legitimate interests; and
     10.1.7 Not to be subject to automated individual decision-making. The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you.

10.2 For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.

10.3 If you would like to exercise any of those rights, please:
     10.3.1 email, call or write to us (see below ‘How to contact us’);
     10.3.2 let us have enough information to identify you (including, for example, your full name, address and customer or matter reference number;
     10.3.3 let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
     10.3.4 let us know what right you want to exercise and the information to which your request relates.

11. Keeping your personal information secure

11.1 We have appropriate security measures to prevent personal information from being accidentally lost, or used or accessed unlawfully. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

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

12. How to complain

12.1 We hope that we can resolve any query or concern you may raise about our use of your information.

12.2 The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns or telephone: 0303 123 1113.

13. Changes to this privacy notice

13.1 This privacy notice was published on [date] and last updated on [date].

13.2 We may change this privacy notice from time to time when we do we will inform you via email, our app or otherwise on our website.

14. How to contact us

14.1 Please contact us by post, email or telephone if you have any questions about this privacy notice or the information we hold about you.

14.2 Our contact details are as follows:
     14.2.1 address: Comics Salopia CIC, Chapter House North, Abbey Lawn, Abbey Foregate, Shrewsbury, Shropshire, SY2 5DE.
     14.2.2 telephone number: 07843 443 340.
     14.2.3 email address: info@comicssalopia.com.

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