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Introduction

3WM respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website at officesuppliesplease.co.uk (“our website”) (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you. This privacy policy also applies to any personal data collected or received through means other than our website – for example via email, telephone or face-to-face contact.

 

1.  Important information and who we are

Controller

This privacy policy is issued on behalf of 3WM Limited (which is the data controller and responsible for our website), so when we mention “3WM Office Supplies Please”,"we", "us" or "our" in this privacy policy or elsewhere on our website, we are referring to 3WM Limited.

We have appointed a Privacy Manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights (as set out in paragraph 8 of this privacy policy), please contact the Privacy Manager using the details set out below.

Contact details

Our full details are:

Full name of legal entity: 3WM Limited

Email address:   dpo@3wm.co.uk

Postal address:  Melford House, 65 Millgate, Newark, NG24 4TU.

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 policy and your duty to inform us of changes

This version was last updated on [DATE] 2021 and historic versions can be obtained by contacting us.

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.

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 as follows:

· Identity & Contact Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, gender, job title and employer, address, email address and telephone number.

· Transaction Data includes bank account and payment card details, details about your financial position and credit-worthiness, 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 our website.

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

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 personal 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 policy.

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.

3.  How is your 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 Transaction Data by filling in forms or by corresponding with us by post, phone, email or otherwise, including face-to-face contact.

·  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.

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 fulfil our contractual obligations to you as a customer and to allow us to provide you with the best possible experience in dealing with us.

·  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 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.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of the main ways we plan (or may in the future 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. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you as a new customer or account holder, and to process your orders and collect/recover payments

(a) Identity & Contact

(b) Transaction

(c) Marketing & Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (including to recover debts due to us)
To manage our relationship with you including notifying you of updated policies/terms and obtaining your feedback.

(a) Identity & Contact

(b) 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, and to administer and grow our business)
To administer, operate and protect our business and our website (including troubleshooting, data analysis/analytics, testing, system maintenance, support, reporting, hosting of data, provision of advertising (not comprising direct electronic marketing)) 

(a) Identity & Contact

(b) Technical

(c) Transaction

(d) Marketing and Communications

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud, in the context of a business reorganisation or group restructuring exercise, to grow our business and inform our strategy)

(b) Necessary to comply with a legal obligation

 

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. It is entirely your choice whether you consent to us providing you with direct electronic marketing – we will only do so where you have given us your consent to do so. For further information please visit our Email Marketing policy at [insert link].

Opting out

You can ask us to stop sending you marketing messages by contacting us at any time.

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 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.

·  Our suppliers - Products that you order from us are sometimes shipped to you directly from the warehouses and fulfilment centres of our suppliers. In these instances, it is necessary for us to pass enough information (for instance: delivery name, delivery address and products ordered) for our suppliers to deliver the products to you on our behalf. For most transactions it is also necessary to pass the delivery name, delivery address details and any special delivery instructions to couriers.

·  Service providers who provide payment, delivery, IT and system administration services.

·  Credit reference agencies – where we extend credit to you for the products we may pass your personal information to credit reference agencies and they may keep a record of any search that they do.

·  Professional advisers including lawyers, bankers, auditors and insurers.

·  Regulators, industry bodies and other authorities.

·  Manufacturers of products which we sell – we may pass your personal information to the manufacturer of the products that you purchase, particularly where it is new, amongst other things to register the purchase and activate the manufacturer’s warranty. We will also pass your personal information to our subcontractors where it is required to enable them to perform the ancillary services forming part of the products.

·  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 policy.

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.  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.

7.  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:

·  Providing the services you have requested from us;

·  Facilitating a high standard of after sales customer support;

·  Satisfying requirements mandated by law, contract or similar obligations applicable to our business operations including the requirement to maintain adequate and accurate business and financial records;

·  Preserving, resolving, defending or enforcing our legal/contractual rights.

We make a clear distinction between live data, normally accessible through our operational interfaces, and archived data which is not accessed easily and held only for specific legal or contractual compliance reasons. It is our policy to keep both classifications of personal data held to the minimum.

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.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. If you wish to exercise any of those rights, please contact us at dpo@3wm.co.uk.

No fee usually required

You will not usually 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 verify your identity and ensure your right to access your personal data (or to exercise any of your other rights).

Time limit to respond

We try to respond to all legitimate requests within 28 days. Occasionally it may take us longer than 28 days 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.

8.  Your legal rights

Please contact us for further information about, or to exercise, these rights. You have the right to:

Request access to your personal data (commonly known as a "data subject access request").

Request correction of the personal data that we hold about you.

Request erasure of your personal data. 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 in certain circumstances. 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. 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.

Request the transfer of your personal data to you or to a third party. 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.

9.  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 necessary for the performance of a contract with you 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.

 

 

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