2. Purpose of this privacy notice
This privacy notice aims to give you information on how we collect and processes your personal data through your use of our site, including any data you may provide through our site when you sign up to our newsletter, make an order or register an account with us.
Our sites are not intended for children and we do not knowingly collect data relating to children.
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).
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.
3. Third-party links
Our sites 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 sites, we encourage you to read the privacy notice of every website you visit.
4. The data we collect about you
The data are provided by you, depending on the case, directly when you purchase the product either by visiting our website or by phone, register your product, visit our website, activate your account, request a Service or activate interactive functions (audio or video) on the products, when you participate in our campaigns.
We may collect, use, store and transfer different kinds of personal data that you give us through our sites or by using our applications, corresponding with us by phone, e-mail or otherwise about you which we have grouped together as follows:
- Identity Data includes first name, middle name, maiden name, last name, username or similar identifier.
- 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 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 our sites.
- Profile Data includes your username and password, purchases or orders made by you.
- Usage Data includes information about how you use our sites, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
5. How is your personal data collected ?
We use different methods to collect data from and about you including through:
- place an order for our products;
- return any products or request a refund;
- receive and/or rely on any warranty we or our suppliers provide to you;
- submit a comment on our sites;
- interact with us on our social media;
- submit an enquiry to us regarding our products;
- create an account on our sites;
- subscribe to our newsletters;
- request marketing to be sent to you;
- if you apply for a job with us; or
- give us some feedback.
- Automated technologies or interactions. As you interact with our sites, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see below for further details on cookies. We use the third parties set out to collect data about you; Emarsys, PCA Predict, Affiliate Window, Trustpilot, Google Tag Manager, Facebook, VWO, Fospha, Yotpo and Pingdom.
- Third parties or publicly available sources.
- Analytics providers such as Google based outside the EU;
- Advertising networks such as AdSense based inside and 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.
- Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.
6. Why do we collect your information?
The main purpose for which we use your information is to provide you with the products that you purchase from us and to send you offers and promotions that you might be interested in.
In particular, we use your information:
- to provide you with the products that you have purchased from us and any receipts of purchase, including to deliver your products, and to send you order status updates
- to take payments for the products that you have purchased and to give refunds or exchanges
- to provide customer service and support to you
- to develop and improve our products and services
- to develop and improve our websites and set default options for you (such as language and currency) and to ensure that content is presented in the most effective manner
- to provide you with information that you request from us or which we feel may interest you. We may send you marketing information by email, SMS or post. This can include information about new products and offers that you may find interesting
- to research our customers’ preferences and trending products
- to run surveys and competitions
- to notify you about changes to our products
- as part of our efforts to keep our stores safe and secure (for example through the use of CCTV in our stores)
- to prevent and detect fraud and crime (for example, through the use of CCTV in our stores).
7. Who do we share your information with?
We will never share your information except when we need to work with a third party (for example, a delivery service) or when we’re legally obliged to do so. We will never sell your information to advertisers or ad networks and we are committed to complying with the Data Protection Act 1998 and General Data Protection Regulation ((EU) 2016/679) (GDPR).
In certain circumstances, we may disclose your personal information to third parties for legitimate purposes subject to this Privacy Policy. Such circumstances may include:
- With vendors or other third parties who perform services on our behalf (e.g., IT management, payment processing, data analytics, customer support, cloud storage, fulfillment and shipping).
- With business and marketing partners, including PayPal, to provide services and advertise to you. Our business and marketing partners will use your information in accordance with their own privacy notices.
- When you direct, request us or otherwise consent to our disclosure of certain information to third parties, such as to ship you products or through your use of social media widgets or login integrations, with your consent.
- With our affiliates or otherwise within our corporate group, in our legitimate interests to run a successful business.
- In connection with a business transaction such as a merger or bankruptcy, to comply with any applicable legal obligations (including to respond to subpoenas, search warrants and similar requests), to enforce any applicable terms of service, and to protect or defend the Services, our rights, and the rights of our users or others.
8.Cookies
8.1 About Cookies
A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
Cookies can be used by web servers to identity and track users as they navigate different pages on a website and identify users returning to a website.
8.2 Our Cookies
We use both session and persistent cookies on our sites.
The names of the cookies that we use on our sites, and the purposes for which they are used, are set out below.
We use cookies on our sites to recognise a computer when a user visits on our sites/track users as they navigate on our sites / enable the use of a shopping cart on our sites / improve our site’s usability / analyse the use of our sites / administer our sites / prevent fraud and improve the security of our sites / personalise our sites for each user/target advertisements which may be of particular interest to specific users.
Analytics cookies:
We use Google Analytics to analyse the use of our sites.
Our analytics service provider generates statistical and other information about our site use by means of cookies.
The analytics cookies used by our sites have the following names: _utma, _utmb, _utmc and _utmz. The information generated relating to our sites is used to create reports about the use of our sites. Our analytics service provider’s privacy policy is available at: http://www.google.com/policies/privacy/.
Third-party cookies:
Our sites also use third party cookies.
We publish Google AdSense interest-based advertisements on our sites. These are tailored by Google to reflect your interests. To determine your interests, Google will track your behaviour on our sites and on other websites across the web using the DoubleClick cookie. We publish Google AdSense advertisements on our sites. To determine your interests, Google will track your behaviour on our sites and on other websites across the web using the DoubleClick cookie. This behaviour tracking allows Google to tailor the advertisements you see on other websites to reflect your interests (we do not publish interest-based advertisements on this website). You can view, delete or add interest categories associated with your browser by visiting: http://www.google.com/settings/ads/. You can also opt-out of the AdSense partner network cookie using those settings or using the NAI’s (Network Advertising Initiative’s) multi-cookie opt-out mechanism at: http://www.networkadvertising.org/choices/. However, these opt-out mechanisms themselves use cookies, and if you clear the cookies from your browser your opt-out will not be maintained. To ensure that an opt-out is maintained in respect of a particular browser, you may wish to consider using the Google browser plug-in available at: https://www.google.com/settings/ads/plugin.
9. How long we store your data ?
Your data will be stored for the period of time strictly required to achieve the purposes for which they were collected. In any event, the following storage terms will apply:
- for the Contractual and Legitimate Business Interest Purposes, the data will be stored for a period equal to the duration of the provision of the services you have requested and for the 10 years after that, without prejudice to cases in which storage for a subsequent period is required for any legal actions and, in the case of disputes, requests from the competent authorities or pursuant to applicable regulations;
- for the Marketing Purposes and for the Legitimate Marketing Interest Purpose, the data are stored for a period equal to the duration of the provision of the service requested and a period of 24 months subsequent to the last contact with you, to be understood, inter alia, as the use of a product or Service provided by ACE PUPS LLC or the opening of a newsletter (jointly defined as the “Last Contact”);
for the Marketing Purpose pursuant to letter l), the data are stored for a period of 24 months from the creation of your account or the use of a Service.
If the appliance allows the collection and the processing of audio to be converted into instructions for the machine, this, once correctly converted into commands, is immediately deleted. In the event that our appliance detects difficulties in recognizing the instructions given, the same data may be, for purposes of maintenance and troubleshooting, kept for a maximum period of 3 months and then immediately deleted.
Images acquired through the use of the App or the connection and use of the connected appliance, are processed in anonymous form. It is possible that, in certain cases, the App provide for the storage of image files on the memory of the mobile device used for their acquisition. In these cases, ACE PUPS LLC does not process such personal data: the images are in the exclusive availability of the user who can decide if and when to delete them.
10. What rights do you have?
You have a number of rights under the Data Protection Laws in relation to the way we process your personal data, which are set out below. You may contact us using the details at the beginning of this privacy policy to exercise any of these rights.
In some instances, we may be unable to carry out your request, in which case we will contact you to explain why.
| 1. You have the right to request access to your personal data | You have the right to request confirmation that your personal data is being processed, access to your personal data (through us providing a copy) and other information about how we process your personal data. |
| 2. You have the right to ask us to rectify your personal data | You have the right to request that we rectify your personal data if it is not accurate or not complete. |
| 3. You have the right to ask us to erase your personal data | You have the right to ask us to erase or delete your personal data where there is no reason for us to continue to process your personal data. This right would apply if we no longer need to use your personal data to provide products to you, where you withdraw your consent for us to send you marketing information, or where you object to the way we process your personal data (see right 6 below). |
| 4. You have the right to ask us to restrict or block the processing of your personal data | You have the right to ask us to restrict or to block the processing of your personal data that we hold about you. This right applies where you believe the personal data is not accurate, you would rather we block the processing of your personal data rather than erase your personal data, where we don’t need to use your personal data for the purpose we collected it for but you may require it to establish, exercise or defend legal claims. |
| 5. You have the right to port your personal data | You have the right to obtain and reuse your personal data from us to reuse for your own purposes across different services. This allows you to move personal data easily to another organisation, or to request us to do this for you. |
| 6. You have the right to object to our processing of your personal data | You have the right to object to our processing of your personal data on the basis of our legitimate business interests, unless we are able to demonstrate that, on balance, our legitimate interests override your rights or we need to continue processing your personal data for the establishment, exercise or defence of legal claims. |
| 7. You have the right not to be subject to automated decisions | You have the right to object to any automated decision making, including profiling, where the decision has a legal or significant impact on you. |
| 8. You have the right to withdraw your consent | You have the right to withdraw your consent where we are relying on it to use your personal data, for example where we are relying on your consent to send you marketing information. |
Marketing
We always give you the choice of whether or not you wish to receive marketing communications from us.
By contacting us at gdpr@elecgadgets.com you can tell us that you do not wish to receive marketing communications from us and we will update your records. You can also click on the unsubscribe link in any promotional emails.
11. Complaints
If you have any concerns regarding our processing of your personal data, or are not satisfied with our handing of any request made by you, or would otherwise like to make a complaint, please contact our customer contact centre in the first instance using the details at the start of this privacy policy, so that they can do their very best to sort out the problem.
You can also contact the Information Commissioner’s Office at Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF www.ico.org.uk.