PRIVACY POLICY

Last updated May 2018

Dencon Accessories Ltd (Dencon Group) understand that your privacy is important and that you care about how your personal data is used and shared online. We respect the privacy of everyone who visits our website and uses our online services.

We are committed to respecting, securing and protecting your privacy and private data. We are also committed to being transparent about what we collect from you and how we use it.

This privacy notice, which covers your use of our website and online services provides you with information about what personal data we collect, how we use your data, how we ensure your privacy is maintained, and your legal rights relating to your personal data.

1. Who We Are

We are Dencon Accessories Ltd (Dencon Group), Lyden House, South Road, Templefields Industrial Estate, Harlow, Essex CM20 2BS

2. You can contact us by:

1. Telephone – 01279 433533
2. Email – [email protected]
3. Post – Data Protection Officer, Lyden House, South Road Templefields Industrial Estate, Harlow, Essex CM20 2BS

3. Your Rights

1. Under the General Data Protection Regulation (GDPR) you have a number of rights with regard to your personal data; which this policy and our use of your data have been designed to uphold:
   1. Right to be informed – you have the right to be informed about our collection & use of your personal data.
   2. Right of access – you have the right to request a copy of the information that we hold about you. You can do this by contacting us using the above details.
   3. Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
   4. Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
   5. Right to restriction of processing – where certain conditions apply, you have a right to restrict our processing.
   6. Right of portability – you have the right to have the data we hold about you transferred to another organisation.
   7. Right to object – you have the right to object to certain types of processing (such as direct marketing).
   8. Rights in relation to object to automated processing & profiling – you also have the right not to be subject to legal effects of automated decision making and profiling.
   9. Withdrawal of consent – where our processing is based on your consent you have the right to withdraw this at any time.
2. If you have cause for complaint about our use of your data, or you would like to exercise any of your rights, then please contact us using the details provided in Section 1 and we will do our best to solve the problem for you.
3. If we are unable to help, or you aren't satisfied with our response, you also have the right to lodge a complaint with the UKs supervisory authority – The Information Commissioner's Office (ICO). The ICO can be contacted:
   1. By post – The Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, SK9 5AF
   2. By telephone – 0303 123 1113
   3. Via their website – www.ico.org.uk

4. What Data Do We Collect from You?

1. Depending on how you use our site, we may collect some or all of the following personal data from you. Please also see section 7 on our use of Cookies and similar technologies.
2. Dencon account holders
   1. Your name
   2. Business / company name & job title
   3. Contact information such as email addresses, postal address & telephone numbers
   4. Demographic information such as postcode
   5. System information, such as IP address, browser type & version, operating system
   6. Information about your activity on our site
   7. Other publicly available information, including any which you have shared via a public platform such as Twitter or Facebook
3. Website visitors without a Dencon account
   1. System information, such as IP address, browser type & version, operating system
   2. Information about your activity on our site

5. How We Use Your Data

1. All personal data is processed and stored securely. We do not keep your personal data for any longer than it is necessary in light of the reason(s) for which it was first collected.
2. Dencon account holders
   1. We will keep your data for the duration of your Dencon account membership and when an account is closed, for 6 years from the date of your last purchase from us for legal reasons.
   2. If you have made enquiries or submitted your details in reference to business dealings with us, we will retain your contact information for a period of 12 months. If you have not registered for an account with us, we will delete your personally identifiable data.
3. Website visitors without a Dencon account
   1. We will keep data about your use of our website for 2 years for trend analysis and continuous improvement purposes.
   2. Where we have a legal obligation to keep it longer than that we will delete it as soon as our legal obligation is discharged.
   3. We may keep your data longer if we are involved in a legal claim or dispute. Where this is the case we will delete it as soon as such claim or dispute is resolved.
   4. Our server log files are stored to help us in the event of a malicious attack or website crash. The logs store user IP addresses. The files are deleted every 14 days and the back-up log files will not be kept for more than 3 years.
4. Our use of your data will always have a legal basis (as set out in Section 5), and we may use your data for the following purposes.
   1. Providing and managing your access to our website and services.
   2. Personalising and tailoring your experience on our website and services.
   3. Providing and managing your account on our website.
   4. Communicating with you (replying to your emails and enquiries).
   5. To provide you with goods and services as ordered.
   6. Market research.
   7. Analysing your use of our site and services, gathering feedback, to continually improve our site and your experience.
   8. If you consent, notifying you of products, services and specials offers that may be of use to you by email. You will always be able to unsubscribe or opt-out from this use at any time.
5. Legal Basis
6. We will only process your data where we have a legal basis under the General Data Protection Regulation (GDPR) to do so.
7. Our use of your personal data will always have a legal basis, either because:
   1. It is necessary for our performance of a contract with you; or
   2. You have consented to our use of your personal data; or
   3. We are complying with a legal obligation; or
   4. It is necessary in pursuit of our legitimate interests – detailed below.
8. Where our processing of your data is based on our legitimate interests, we will have ensured that such processing is necessary, and we will not do so where our interests are over-ridden by yours.
9. Our legitimate interests include:
   1. Selling & supplying our goods and services to customers and potential customers.
   2. Handling customer and potential customer contacts, queries, complaints or disputes.
   3. Understanding our customers (or potential customers) behaviour, activities & preferences.
   4. Improving our products and services, including developing new products and services.
   5. Promoting, marketing and advertising our goods and services.
   6. Complying with regulatory obligations.

6. Storing & Sharing Your Data

1. Data security is very important to us and we take appropriate security measures to safeguard and secure your data which is collected via our website and services.
2. We endeavour to keep all of your personal information in the European Economic Area (EEA). The EEA includes all EU Member States plus Norway, Iceland & Liechtenstein.
3. We will only move data to countries or organisations:
   1. Under a contract which enforces the EU Commission approved "standard data protection clauses" which can be viewed at: http://ec.europa.eu/justice/data-protection/international-transfers/transfer/index_en.htm
4. We will never sell or otherwise transfer or disclose your personal data to any third party except:
   1. We may sometimes contract with trusted service providers to provide goods and services on our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising, marketing and IT systems. This will sometimes necessitate the transfer of your personal data to those trusted service providers.
   2. We may share your name and address with selected print partners for mail merge purposes.
   3. Where we transfer your data to our trusted service providers we will have confirmed that they will apply data protection and security measures to the same standard we would. We will always impose contractual terms on all of our providers to ensure your data remains secure.
   4. In certain limited circumstances we may be legally required to share your personal data – for example where we are involved in legal proceedings, where we complying with a court order, regulatory requirement or government department with appropriate legal authority to compel us to do so.

7. Cookies

1. Like many other websites, ours uses Cookies. Cookies are small pieces of information sent by an organisation to your computer or device and stored on your computer or device to allow a website to recognise you when you visit. They help us collect statistical data about your browsing actions and patterns but should not contain personal data (other than the cookie itself, which is defined as personal data under GDPR).
2. All cookies used by and on our website are using in accordance with the current cookie law.
3. Before cookies are placed on your computer or device you will be shown a popup requesting your consent to set such cookies as detailed below. By giving us your consent, you are allowing us to provide the best possible experience of our website. You may refuse consent to cookies; however certain parts of our website may then not function correctly. You can alter your browser settings to refuse all cookies.
4. There are four types of cookies:
   1. Strictly Necessary Cookies – These are essential to make a website work and provide features you've asked for. Generally, these are used to provide shopping baskets and similar. Without these cookies the website may not work as intended.
   2. Performance Cookies – These collect anonymous information about users for the purposes of tracking the performance of a website. Common uses include well known analytics tools such as Google Analytics.
   3. Targeting / Advertising Cookies – Similar to performance cookies, however these are used to track users' behaviour and that information is then used on a "per user" basis to advertise products / services on the basis of the behavioural information collected.
   4. Functionality Cookies – These are used to automatically remember choices that users have made in order improve their experience on the website; for example selecting desired layout or language.
5. The cookies we use on our website are:

   Cookie Name	Purpose
   Strictly Necessary Cookies
   CFID	These cookies allow the website to maintain your login status and your site preferences for the duration of your session.
   CFTOKEN	This cookie stores whether you have seen the pop up message on the site to notify you of our cookie use.
   COOKIEMSG	This cookie stores your response to the notification.
   Performance Cookies
   Google Analytics	We collect anonymous data on how our website visitors use the site. This helps us to continually refine and improve the website. More information is available here https://support.google.com/analytics/answer/6004245
   JSESSIONID	We use this tool to monitor the technical performance of the site. More information is available here https://docs.newrelic.com/docs/browser/new-relic-browser/page-load-timing-resources/new-relic-cookies-used-browser
   Hotjar	We use a third-party tool, Hotjar, to analyse how website visitors use the site. This helps us to continually refine and improve the website. More information is available here https://www.hotjar.com/legal/policies/cookie-information

8. Changes To Our Privacy Notice

1. We may change this Privacy Notice from time to time (for example, if the law changes). Any changes will be immediately posted on our site. We recommend you check the privacy notice regularly to remain up to date.
2. This privacy notice was last updated in May 2018.