Terms of Service

Pennine Market is a social and community e-commerce platform (website and app) that enables independent retailers to sell their products online to customers in the town in which they are located and to enable customers to click and collect or have delivered, the products they have purchased via the platform

These terms tell you the rules on which you can access and use the Pennine Market platform at www.penninemarket.uk and any services accessible through the Pennine Market platform.

The Pennine Market platform is a site operated by E RADAR Limited, a limited company registered at Companies House, UK. (Company no. 07095354) (“we”, “us”, “our”).

We do not sell or have possession of any of the products listed by vendors on the Pennine Market platform. The contract for the sale of those products is between you and the relevant vendor.

To contact us, please email hello@epenninemarket.uk

By using the Pennine Market platform you accept these terms

By using the Pennine Market platform you confirm that you are at least 18 years old, accept these terms of use and that you agree to comply with them. If you do not agree to these terms, you must not use the Pennine Market platform. We recommend that you print a copy of these terms for future reference.

There are other terms that may apply to you

These terms of use refer to the following additional terms, which also apply to your use of the Pennine Market platform:

Our Privacy Policy sets out the terms on which we process any information we collect from you, or that you provide to us. By using the Pennine Market, you consent to such processing and you warrant that all information provided by you is accurate.

Our Cookie Policy, which sets out information about the cookies on the Pennine Market platform.

We may make changes to these terms and the Pennine Market platform

We amend these terms from time to time. Every time you wish to use the Pennine Market platform, please check these terms to ensure you understand the terms that apply at that time.

We may update and change the Pennine Market platform from time to time to reflect changes to the services we offer, our users’ needs and our business priorities.

We may suspend or withdraw the website

We do not guarantee that the Pennine Market platform or any content on it, will always be available or be uninterrupted. We may suspend or withdraw or restrict the availability of all or any part of the Pennine Market platform for business and operational reasons.

You are also responsible for ensuring that all persons who access the Pennine Market platform through your internet connection are aware of these terms of use and other applicable terms and conditions, and that they comply with them.

The Pennine Market platform is only for users in the United Kingdom

The Pennine Market platform is directed to people residing in the United Kingdom. We do not represent that content available on or through the Pennine Market platform is appropriate for use or available in other locations.

You must keep your account details safe

If you choose, or you are provided with, a user identification code, password or any other piece of information as part of our security procedures, you must treat such information as confidential. You must not disclose it to any third party.

We have the right to disable any user identification code or password, whether chosen by you or allocated by us, at any time, if in our reasonable opinion you have failed to comply with any of the provisions of these terms of use.

If you know or suspect that anyone other than you knows your user identification code or password, you must promptly notify us at support@penninemarket.uk

Contracts with vendors for products

Contracts with vendors. We are not a vendor, a seller, or any kind of agent or intermediary for you or any of the vendors that make products available to you through the Pennine Market platform. We do not sell the products available through the Pennine Market platform and are not responsible for any part of the contract for the supply of products by any vendor. So we’re not responsible for their products or for any delivery, returns, refunds, guarantees, warranties or other after-sale care or for any related problems you may suffer. You will need to make your own independent judgement regarding your interaction with any vendor including the purchase and use of any products made available by them.

How vendors will accept your orderA vendor’s acceptance of your order for products will take place when we email you to notify you of their acceptance, at which point a contract will come into existence between you and the relevant vendor.

If a vendor cannot accept your order.If a vendor is unable to accept your order, the vendor will inform you of this and will not charge you for the relevant product or, where applicable, refund you the price paid for the product within a reasonable period of time. This might be because the product is out of stock, because of unexpected limits on a vendor’s resources which the vendor could not reasonably plan for, because the vendor has identified an error in the price or description of the product or because the vendor unable to meet a pick-up time you have specified.

Where to find the price for the product or services. The price of the vendor’s products (which includes VAT) will be the price indicated on the order pages when you placed your order. Vendors will take all reasonable care to ensure that the price of the product advised to you is correct.

Products may vary slightly from their pictures. The images of vendor’s products on Pennine Market platform are for illustrative purposes only and in the case of fresh foods are taken from a general image library. Although vendors have made every effort to display the colours accurately, vendors cannot guarantee that a device’s display of the colours accurately reflects the colour of the products. Your product may vary slightly from those images.

Your rights to make changes. If you wish to make a change to the product you have ordered please contact the relevant vendor. They will let you know if the change is possible. If it is possible they will let you know about any changes to the price of the product, the timing of supply or anything else which would be necessary as a result of your requested change and ask you to confirm whether you wish to go ahead with the change.

Click and Collect and costs. The relevant vendor that supplies you with the products will ensure they are ready for you to collect as agreed if you chose the click and collect option. If you have any questions about or issues with your click and collect point, please contact the relevant vendor supplying the product(s) to you. There is no charge for collecting products ordered at a single point or for collecting products from the vendor directly. Collection points are provided by third parties and are not the responsibility of Pennine Market or E RADAR

Delivery and delivery costs. The relevant vendor that supplies you with the products will ensure they are delivered as agreed if you chose the delivery option. If you have any questions about or issues with your delivery partner, please contact the relevant vendor supplying the product(s) to you. Delivery costs, if applicable, will be shown and charged at the time you place your order. Delivery is provided by third parties and are not the responsibility of Pennine Market or E RADAR.

When vendors will provide the products.During the order process we will let you choose a time when you can pick up the products or when you can expect them to be delivered.

If you do not pick up your products or accept delivery at the specified time, then you should contact the delivery partner, vendor or collection point directly, as applicable.You will still be liable for payment of products if you fail to collect, or accept delivery of, the items.

If you are entitled to a refund.If you are entitled to a refund in relation to the products supplied by a vendor, the vendor will make the relevant refund to you. Each vendor’s refund policy is available on its page on the Pennine Market platform. If you are unable to contact the vendor, please contact Pennine Market on support@penninemarket.uk and we will endeavor to raise any concerns.

How you may use material on the Pennine Market platform

We are the owner or the licensee of all intellectual property rights in the Pennine Market platform, and in the material published on it. Those works are protected by copyright laws and treaties around the world. All such rights are reserved. You must not use any part of the content on the Pennine Market platform for commercial purposes without obtaining a licence to do so from us or our licensors.

We are not responsible for websites we link to

Where the Pennine Market platform contains links to other sites and resources provided by third parties, these links are provided for your information only. Such links should not be interpreted as approval by us of those linked websites or information you may obtain from them. We have no control over the contents of those sites or resources.

User-generated content not approved by us

The Pennine Market platform may include information and materials uploaded by vendors and other users of the website, including to bulletin boards. This information and these materials have not been verified or approved by us. The views expressed by vendors and other users on the website do not represent our views or values.

If you wish to complain about information and materials uploaded by other users please contact us by email support@penninemarket.uk

Our responsibility for loss or damage suffered by you

We do not exclude or limit in any way our liability to you where it would be unlawful to do so. This includes liability for death or personal injury caused by our negligence or the negligence of our employees, agents or subcontractors and for fraud or fraudulent misrepresentation.

Please note that we only provide the Pennine Market platform for domestic and private use by you. You agree not to use the Pennine Market platform for any commercial or business purposes, and we have no liability to you for any loss of profit, loss of business, business interruption, or loss of business opportunity. Separate terms of use are applicable to any vendor that uses the Pennine Market platform.

Acceptable use of the Pennine Market platform

Whenever you use the Pennine Market platform or make use of a feature that allows you to upload content to the Pennine Market platform, or to make contact with vendors or other users of the website, you must comply with the content standards set out below.

You may use the Pennine Market platform only for lawful purposes. You may not use the website: in any way that breaches any applicable local, national or international law or regulation; in any way that is unlawful or fraudulent, or has any unlawful or fraudulent purpose or effect; to transmit, or procure the sending of, any unsolicited or unauthorised advertising or promotional material or any other form of similar solicitation (spam); or to knowingly transmit any data, send or upload any material that contains viruses, Trojan horses, worms, time-bombs, keystroke loggers, spyware, adware or any other harmful programs or similar computer code designed to adversely affect the operation of any computer software or hardware.

We may from time to time provide interactive services on the Pennine Market platform, including, without limitation bulletin boards.

Where we do provide any interactive service, we will provide clear information to you about the kind of service offered, if it is moderated and what form of moderation is used (including whether it is human or technical).

We will do our best to assess any possible risks for users (and in particular, for children) from third parties when they use any interactive service provided on Pennine Market platform, and we will decide in each case whether it is appropriate to use moderation of the relevant service (including what kind of moderation to use) in the light of those risks. However, we are under no obligation to oversee, monitor or moderate any interactive service we provide on Pennine Market platform and we expressly exclude our liability for any loss or damage arising from the use of any interactive service by a user in contravention of our content standards, whether the service is moderated or not.

The following content standards apply to any and all material which you contribute to Pennine Market platform, and to any interactive services associated with it. You must comply with the spirit and the letter of the following standards. The standards apply to each part of any contribution as well as to its whole.

Contributions must: be accurate (where they state facts); be genuinely held (where they state opinions); and comply with applicable law in the UK.

Contributions must not: contain any material which is defamatory of any person; contain any material which is obscene, offensive, hateful or inflammatory; promote sexually explicit material; promote violence; promote discrimination based on race, sex, religion, nationality, disability, sexual orientation or age; infringe any copyright, database right or trade mark of any other person; be likely to deceive any person; be made in breach of any legal duty owed to a third party, such as a contractual duty or a duty of confidence; promote any illegal activity; be threatening, abuse or invade another’s privacy, or cause annoyance, inconvenience or needless anxiety; be likely to harass, upset, embarrass, alarm or annoy any other person; be used to impersonate any person, or to misrepresent your identity or affiliation with any person; give the impression that they emanate from us, if this is not the case; or advocate, promote or assist any unlawful act such as (by way of example only) copyright infringement or computer misuse.

We will determine, in our discretion, whether there has been a breach of these acceptable use standards through your use of Pennine Market platform. When a breach of these standards has occurred, we may take such action as we deem appropriate.

We also have the right to disclose your identity to any third party who is claiming that any content posted or uploaded by you to the Pennine Market platform constitutes a violation of their intellectual property rights, or of their right to privacy.

We have the right to remove any posting you make on the Pennine Market platform if, in our opinion, your post does not comply with the standards set out above.

We are not responsible for viruses and you must not introduce them

We do not guarantee that the Pennine Market platform will be secure or free from bugs or viruses. You are responsible for configuring your information technology, computer programmes and platform to access the Pennine Market platform. You should use your own virus protection software.

You must not misuse the Pennine Market platform by knowingly introducing viruses, trojans, worms, logic bombs or other material that is malicious or technologically harmful. You must not attempt to gain unauthorised access to the Pennine Market platform, the server on which the website is stored or any server, computer or database connected to the website. You must not attack the Pennine Market platform via a denial-of-service attack or a distributed denial-of-service attack. By breaching this provision, you would commit a criminal offence under the Computer Misuse Act 1990. We will report any such breach to the relevant law enforcement authorities and we will co-operate with those authorities by disclosing your identity to them. In the event of such a breach, your right to use the Pennine Market platform will cease immediately.

Other important terms

We may transfer our rights and obligations under these terms to another organisation.

Each of the paragraphs of these terms operates separately. If any court or relevant authority decides that any of them are unlawful, the remaining paragraphs will remain in full force and effect.

Headings in these terms are for ease of reference only and do not limit the scope of the relevant section.

If we do not insist immediately that you do anything you are required to do under these terms, or if we delay in taking steps against you in respect of your breaking these terms, that will not mean that you do not have to do those things and it will not prevent us taking steps against you at a later date.

These terms are governed by English law.

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Privacy

Introduction

Welcome to the E RADAR Limited Privacy Notice.

E RADAR Limited respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

1.  Important information and who we are

PURPOSE OF THIS PRIVACY NOTICE

This privacy notice (together with our terms of service and any other documents referred to on it) aims to give you information on how we collect and process your personal data through your use of this website, including any data you may provide through this website, when you sign up to our newsletter, purchase a product or service or take part in a competition.

This website is not intended for children and we do not knowingly collect data relating to children.

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

E RADAR Limited is the controller and responsible for your personal data (collectively referred to as “we”, “us” or “our” in this privacy notice).

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, please contact the DPO using the details set out below.

CONTACT DETAILS

Name of DPO: Will Roebuck

Email address: will.roebuck@eradar.uk

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 is the current version of our Website Privacy Notice.

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

This 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.

2.  The data we collect about you

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).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.

Contact Data includes billing address, delivery address, email address and telephone numbers.

Financial Data includes bank account and payment card details.

Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.

Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.

Profile Data includesany username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.

Usage Data includes information about how you use our website, products and services.

Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preference..

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

3.  How is personal data collected

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

• apply for our products or services;
• create an account on our website;
• subscribe to our service or publications;
• request marketing to be sent to you;
• enter a competition, promotion or survey; or
• give us some feedback.

Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.

Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:

Technical Data from the following parties:

• analytics providers such as Google based outside the EU;
• advertising networks based inside or outside the EU; and
• search information providers based inside or outside the EU.
• Contact, Financial and Transaction Data from providers of technical, payment and delivery services based inside or outside the EU
• Identity and Contact Data from data brokers or aggregators based inside or outside the EU
• Identity and Contact Data from publicly-available sources such as Companies House and the Electoral Register based inside the EU.

4.  How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us on

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

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.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new customer or client	(a) Identity(b) Contact	Performance of a contract with you
To process and deliver your order or service including:(a) Manage payments, fees and charges(b) Collect and recover money owed to us	(a) Identity(b) Contact(c) Financial(d) Transaction(e) Marketing and Communications	(a) Performance of a contract with you(b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include:(a) Notifying you about changes to our terms or privacy policy(b) Asking you to leave a review or take a survey	(a) Identity(b) Contact(c) Profile(d) Marketing and Communications	(a) Performance of a contract with you(b) Necessary to comply with a legal obligation(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to partake in a prize draw, competition or complete a survey	(a) Identity(b) Contact(c) Profile(d) Usage(e) Marketing and Communications	(a) Performance of a contract with you(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity(b) Contact(c) Technical	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)(b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity(b) Contact(c) Profile(d) Usage(e) Marketing and Communications(f) Technical	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	(a) Technical(b) Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you	(a) Identity(b) Contact(c) Technical(d) Usage(e) Profile	Necessary for our legitimate interests (to develop our products/services and grow our business)

MARKETING

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. If you wish to opt out of any marketing communications, please contact us on hello@eradar.eu

PROMOTIONAL OFFERS FROM US

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

THIRD-PARTY MARKETING

We will get your express opt-in consent before we share your personal data with any third party group of companies for marketing purposes.

OPTING OUT

You can ask us or third parties to stop sending you marketing messages at any time by contacting us on hello@eradar.eu at any time

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transaction.

COOKIES

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.

The cookies we use are “analytical” cookies. They allow us to recognise and count the number of visitors and to see how visitors move around the site when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

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 on hello@eradar.eu.

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.

5.  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 4 above.

Internal Third Parties as set out in the Glossary.

External Third Parties as set out in the Glossary.

Specific third parties listed in the table in paragraph 4 above.

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.

6.  International Transfers

We do not transfer your personal data outside the European Economic Area (EEA).

7.  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.

8.  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.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see Request erasure below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9.  Your Legal Rights

Under certain circumstances, you have the following rights under data protection laws in relation to your personal data.

• 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 the DPO.

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.

10.  Glossary

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/product 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).

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.

THIRD PARTIES

INTERNAL THIRD PARTIES

Other companies in the Group acting as joint controllers or processors and who provide IT and system administration services and undertake leadership reporting..

EXTERNAL THIRD PARTIES

Service providers acting as processors who provide IT and system administration services.

Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.

HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

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.

Updated April 2021

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