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Privacy Policy

This Privacy Policy sets out how we, The Fone Stuff Ltd, collect, store and use information about you when you use or interact with our website, www.thefonestuff.com (our website) and where we otherwise obtain or collect information about you. This Privacy Policy is effective from 01/05/2018.

Contents

  • Summary

  • Our details

  • Information we collect when you visit our website

  • Information we collect when you contact us

  • Information we collect when you interact with our website

  • Information we collect when you place an order on www.thefonestuff.com

  • How we collect or obtain information about you from third parties

  • Disclosure and additional uses of your information

  • How long we retain your information

  • How we secure your information

  • Transfers of your information outside the European Economic Area

  • Your rights in relation to your information

  • Your right to object to the processing of your information for certain purposes

  • Sensitive Personal Information

  • Changes to our Privacy Policy

  • Children’s Privacy

  • California Do Not Track Disclosures

  • Copyright, credit and logo

Summary

This section summarises how we obtain, store and use information about you. It is intended to provide a very general overview only. It is not complete in and of itself and it must be read in conjunction with the corresponding full sections of this Privacy Policy.

  • Data controller: The Fone Stuff Ltd

  • How we collect or obtain information about you:

    • when you provide it to us by contacting us, placing an order on our website, signing up to our newsletter.

    • from your use of our website, using cookies and tracking beacons.

  • Information we collect: name, contact details, payment details including last 4 digits of card, IP address, information from cookies, information about your computer (device, browser type), information from cookies, information about how you use the website (which pages have been viewed), the time when you view them and what you clicked on, the geographical location from which you accessed our website (based on your IP address), the company name or business name (if applicable.

  • How we use your information: for administrative and business purposes (particularly to contact you and process orders on our website, to improve our business and website functionality and processes, to fulfil our contractual obligations, to advertise our goods and services, to analyse your use on our website and in connection with our legal rights and obligations.

  • Disclosure of your information to third parties: only to the extent necessary to run our business, to our service providers, to fulfil any contracts we enter into with you, where required by law or to enforce our legal rights.

  • Do we sell your information to third parties (other than in the course of a business sale or purchase or similar event): No.

  • How long we retain your information: for no longer than necessary, taking into account any legal obligations we have (e.g. to maintain records for tax purposes), any other legal basis we have for using your information (e.g. your consent, performance of a contract with you or our legitimate interests as a business). Information is retained for 5 years from the point of your order being received.

  • How we secure your information: using appropriate technical and organisational measures such as
    storing your information on secure servers, encrypting transfers of data to or from our servers using Secure Socket Layer (SSL) technology, encrypting payments you make on or via our website using Secure Socket Layer (SSL) technology, only granting access to your information where necessary.

  • Use of cookies: we use cookies and similar information gathering technologies on our website including essential, functional, analytical and targeting cookies. For more information, please visit our cookies policy https://www.thefonestuff.com/cookies.

  • Transfers of your information outside the European Economic Area: [we will only transfer your information outside the European Economic Area if we are required to do so by law] OR [in certain circumstances] we [transfer] your information outside of the European Economic Area[[, including to the following countries: [insert list of countries to which you transfer information]. Where we do so, we will ensure appropriate safeguards are in place[, including [insert safeguards used for data transfers outside the European Economic Area e.g. [the third parties we use who transfer your information outside the European Economic Area have self-certified themselves as compliant with] the EU-U.S. Privacy Shield]].3

  • Use of automated decision making and profiling: we use automated decision making with the use of web analytics, cookies and targeting cookies to display advertisements to people who visit our website on other websites and around the internet using Google Adsense network.

  • Your rights in relation to your information

    • to access your information and to receive information about its use

    • to have your information corrected and/or completed

    • to have your information deleted

    • to restrict the use of your information

    • to receive your information in a portable format

    • to object to the use of your information

    • to withdraw your consent to the use of your information

    • to have significant decisions made about you based soley on automated processing of your information

    • to complain to a supervisory authority

  • Sensitive personal information: we do not knowingly or intentionally collect what is commonly referred to as ‘sensitive personal information’. Please do not submit sensitive personal information about you to us.

Our details

The data controller in respect of our website is The Fone Stuff Ltd, Company Registration number 343343443 of 53 Renters Avenue, London, NW4 3RD. You can contact the data controller by writing to 53 Renters Avenue, London, NW4 3RD or sending an email to [email protected]

If you have any questions about this Privacy Policy, please contact the data controller.

Information we collect when you visit our website

Web server log information

We use a third party server to host our website called Online Fusion, the privacy policy of which is available here onlinefusion.co.uk/privacy.

Our servers is located in France.

Use of website server log information for IT security purposes

We and our third party hosting provider collect(s) and store(s) server logs to ensure network and IT security and so that the server and website remain uncompromised. This includes analysing log files to help identify and prevent unauthorised access to our network, the distribution of malicious code, denial of services attacks and other cyber attacks, by detecting unusual or suspicious activity.

Unless we are investigating suspicious or potential criminal activity, we do not make, nor do we allow our hosting provider to make any attempt to identify you from the information collected via server logs.

Legal basis for processing: compliance with a legal obligation to which we are subject (Article 6(1)(c) of the General Data Protection Regulation).
Legal obligation: we have a legal obligation to implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk of our processing of information about individuals. Recording access to our website using server log files is such a measure.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interests: we have a legitimate interest in using your information for the purposes of ensuring network and information security.

Cookies and similar technologies
Cookies are data file which are sent from a website to a browser to record information about users for various purposes.

We us cookies and similar technologies on our website, including essential, functional, analytical, targeting cookies and web beacons. For further information on how we use cookies, please see our cookies policy which is available here https://www.thefonestuff.com/cookies.

You can reject some or all of the cookies we use on or via our website by changing your browser settings or non essential cookies by using our cookie control tool, but doing so can impair your ability to use our website or some or all of its features. For further information about cookies, including how to change your browser settings, please visit www.allaboutcookies.org or see our cookies policy.

Information we collect when you contact us

We collect and use information from individuals who contact us in accordance with this section and the section entitled Disclosure and additional uses of your information.

Email

When you send an email to the email address displayed on our website we collect your email address and any other information you provide in that email (such as your name, telephone number and the information contained in any signature block in your email).

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).

Transfer and storage of your information

We use a third party email provider to store emails you send us. Our third party email provider is OVH, located in France.

Email you send us will be stored with the European Economic Area on our third party email providers servers in France.

Contact form

When you contact us using our contact form, we collect name, email address and telephone number, IP address, plus your comments. We also collect any other information you provide to us when you complete the contact form.

If you do not provide the mandatory information required by our contact form, you will not be able to submit the contact form and we will not receive your enquiry.

If you do nit supply the optional information required by our contact form we will not be able to respond to your enquiry by telephone.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).

Transfer and storage of your information

Message you send us via our contact form will be stored within the European Economic Area on our third party email and hosting providers servers in France. Our third party provider is OVH in France.

Phone

When you contact us by phone, we collect your phone number and any information provide to us during your conversation with us.

We do not record phone calls.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation)
Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).

Post

If you contact us by post, we will collect any information you provide to us in any postal communications you send us.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation)
Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).

Information we collect when you interact with our website

We collect and use information from individuals who interact with particular features of our website in accordance with this section and the section entitled Disclosure and additional uses of your information.

E-Newsletter

When you sign up for our e-newsletter on our website or opt to receive, news, offers and promotions from us by registering via our newsletter signup form or during the product purchase process. You will subscribe either by entering your email address within the newsletter sign up and clicking sign up. We will only collect your email address during this process.

Legal basis for processing: your consent (Article 6(1)(a) of the General Data Protection Regulation).
Consent: you give your consent to us sending you our e-newsletter by signing up to receive it using the steps described above.

Transfer and storage of your information

We use a third party service to send out our e-newsletters and administer our mailing list Mailchimp. Their privacy policy is available here: https://mailchimp.com/legal/privacy/

Information you submit to subscribe for our e-newsletter will be stored outside the European Economic Area on our third party mailing provider’s servers in the USA.

User of web beacons and similar technologies in emails.

We use technologies such as web beacons (small graphic files) in emails we send to allow us to access the level of engagement our emails receive measuring information such as the delivery rates, open rates and click through rates which our emails receive. We only use web beacons in our emails you have consented to doing so.

For more information on how we use web beacons in our marketing emails, see our cookies policy which is available here https://www.thefonestuff.com/cookies.

For more information about our third party mailing list provider and the use of web beacons, please see their privacy policy which is available here https://mailchimp.com/legal/privacy/

Registering on our website

When you register and create an account on our website, we collect the following information: first name, last name and email address. If you do not provide the mandatory information required by the registration form, you will not be able to register or create an account on our website.

Legal basis for processing: necessary to perform a contract or to take steps at your request prior to entering into a contract. Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: creating an account on our website is necessary to allow you to access the goods and services you have purchased from us.

Transfer and storage of your information

Information you submit to us via the registration form on our website will be stored within the European Economic Area on our third party hosting providers servers in France.

Information we collect when you place an order on our website

We collect and use information from individuals who place an order on our website in accordance with this section and the section entitled Disclosure and additional uses of your information.

Information collected when you place an order

Mandatory information

When you place an order for goods or services on our website, we collect your full name, email address, contact number, full billing address, full shipping address.

If you do not provide this information, you will not be able to purchase goods or services from us on our website or enter into a contract with us.

Legal basis for processing: necessary to perform a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: we need the mandatory information collected by our checkout form to establish who the contract is with and to contact you to fulfil our obligations under the contract, including sending you receipts and order confirmations.

Legal basis for processing: compliance with a legal obligation (Article 6(1)(c) of the General Data Protection Regulation).

Legal obligation: we have a legal obligation to issue you with an invoice for the goods and services you purchase from is where you are VAT registered we require the mandatory information collected by our checkout form for this purpose. We also have a legal obligation to keep accounting records, including records of transactions.

Optional information

We also collect optional information from you, such as company name, We also ask if you would like to receive marketing communications from us. For further information see ‘Marketing Communications’ in the section below.

If you do not provide the optional information requested at checkout, we will not be able to contact you via these forms of communication.

Legal basis for processing: your consent (Article 6(1)(a) of the General Data Protection Regulation).

Legitimate interests: you consent to us processing any optional information you provide by submitting that information to us.

Processing your payment

After you place an order on our website you will need to make payment for the goods or services you have ordered. In order to process your payment we use a third party processor Payzone and Paypal. Your payment will be processed by Payzone or Paypal via a payment gateway.

Payzone and Paypal collects, uses and processes your information, including payment information, in accordance with their privacy polices. You can access their privacy policies via the following link(s) https://www.payzone.co.uk/privacy-policy/ and https://www.paypal.com/en/webapps/mpp/ua/privacy-full

Transfer and storage of your information

Payzone located in the UK and Paypal located in Ireland. Information relating to the processing of your payment is stored with the European Economic Area on our third party payment processors servers located in the UK and Ireland.

Legal basis for processing: necessary to perform a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: to fulfil your contractual obligation to pay for the goods or services you have ordered from us.

Marketing communications

At checkout you will have the option of receiving marketing communications from us.

Our similar goods and services

You can opt-out from receiving marketing communications in relation to our goods and which are similar to those which you purchase from us, by ticking a box to opt-out.

We will send you marketing communications in relation to similar goods and services if you do not opt out from receiving them.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interests: direct marketing and advertising products and services.

Transfer and storage of your information

We use a third party service to administer our mailing list, Mailchimp.

Information you submit to subscribe for our e-newsletter will be stored within the European Economic Area on our third party mailing list providers servers in the USA.

Use of web beacons and similar technologies in emails.

We use technologies such as web beacons (small graphic files) in the emails we send out to allow us to assess the level of engagement our emails receive by measuring information such as the delivery rates, open rates and click through rates which our emails achieve. We will only use web beacons in our emails if you have consented to us doing so.

For more information on how we use web beacons in our emails, see our cookies policy which is available here https://www.thefonestuff.com/cookies.

For more information about our third party mailing list provider and the use of web beacons, please see their privacy policy which is available here https://mailchimp.com/legal/privacy/

Our goods and services

You can opt in to receiving marketing communications from us in relation to our goods and services by email and phone by ticking the appropriate boxes you would like to receive communications.

We will send you marketing communications in relation to our goods and services only if you opt-in to receive them.

Legal basis for processing: consent (Article 6(1)(a) of the General Data Protection Regulation).
Consent: you give your consent to us sending you information about our goods and services by signing up to receive such information in accordance with the steps described above.

Transfer and storage of your information

We use a third party service to administer our mailing list, Mailchimp.

Information you submit to subscribe for our e-newsletter will be stored within the European Economic Area on our third party mailing list providers servers in the USA.

Use of web beacons and similar technologies in emails

We use technologies such as web beacons (small graphic files) in the emails we send to all us to assess the level of engagement our emails receive by measuring information such as the delivery rates, open rates and click through rates which our emails achieve. We only use web beacons in our emails if you consented to us doing so.

For more information on how we use web beacons in our emails, see our cookies policy at https://www.thefonestuff.com/cookies.

For more information about our third party mailing list provider and the use of web beacons, please see their privacy policy which is available here https://mailchimp.com/legal/privacy/

Third party goods and services

In addition to receiving information about our products and services you can opt in to receiving marketing communications from us in relation to third party goods and services by email and phone by ticking a box indicating that you would like to receive such communications.

Legal basis for processing: consent (Article 6(1)(a) of the General Data Protection Regulation).
Consent: you give your consent to us sending you information about third party goods and services by signing up to receive such information in accordance with the steps described above.

Transfer and storage of your information

We use a third party service to send out our e-newsletters and administer our mailing list Mailchimp. Their privacy policy is available here: https://mailchimp.com/legal/privacy/

Information you submit to subscribe for our e-newsletter will be stored outside the European Economic Area on our third party mailing provider’s servers in the USA.

Use of web beacons and similar technologies in emails

We use technologies such as web beacons (small graphic files) in the emails we send to all us to assess the level of engagement our emails receive by measuring information such as the delivery rates, open rates and click through rates which our emails achieve. We only use web beacons in our emails if you consented to us doing so.

For more information on how we use web beacons in our emails, see our cookies policy at https://www.thefonestuff.com/cookies

We use a third party service to send out our e-newsletters and administer our mailing list Mailchimp. Their privacy policy is available here: https://mailchimp.com/legal/privacy/

Information collected or obtained from third parties

This section sets out how we obtain or collect information about you from third parties.

Information received from third parties

Generally, we do not receive information about you from third parties. The third parties from which we receive information about you will generally include affiliates or business partners.

It is also possible that third parties with whom we have had no prior contact may provide us with information about you.

Information we obtain from third parties will generally be your name and contact details, but will include any additional information about you which they provide to us.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: where a third party has passed on information about you to us (such as your name and email address) in order for us to provide services to you, we will process your information in order to take steps at your request to enter into a contract with you and perform a contract with you (as the case may be).

Legal basis for processing: consent (Article 6(1)(a) of the General Data Protection Regulation).
Consent: where you have asked that a third party to share information about you with us and the purpose of sharing that information is not related to the performance of a contract or services by us to you, we will process your information on the basis of your consent, which you give by asking the third party in question to pass on your information to us.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interests: where a third party has shared information about you with us and you have not consented to the sharing of that information, we will have a legitimate interest in processing that information in certain circumstances.

For example, we would have a legitimate interest in processing your information to perform our obligations under a sub-contract with the third party, where the third party has the main contract with you. Our legitimate interest is the performance of our obligations under our sub-contract.

Similarly, third parties may pass on information about you to us if you have infringed or potentially infringed any of our legal rights. In this case, we will have a legitimate interest in processing that information to investigate and pursue any such potential infringement.

Where we receive information about you in error

If we receive information about you from a third party in error and/or we do not have a legal basis for processing that information, we will delete your information.

Information obtained by us from third parties

In certain circumstances (for example, to verify the information we hold about you or obtain missing information we require to provide you with a service) we will obtain information about you from certain publicly accessible sources, both EU and non-EU, such as the electoral register, companies house, online customer databases, business directories, social medial and websites, including your own if you have one.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: where you have entered into a contract or requested that we enter into a contract with you, in certain circumstances, we will obtain information about you from public sources in order to enable us to understand your business and provide services to you or services to a sufficient standard.

For example, we would obtain and/or verify your email address from your website or from a directory where you ask us to send you information by email but we do not possess the information or we need to confirm that we have recorded your email address correctly.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interests: in certain circumstances, we will have a legitimate interest in obtaining information about you from public and private sources. For example, if you have infringed or we suspect that you have infringed any of our legal rights, we will have a legitimate interest in obtaining and processing information about you from such sources in order to investigate and pursue any suspected or potential infringement.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation.

Our use of automated decision-making and profiling

We use automated decision making and profiling on our website. We do not consider that this has any legal effect on you or similarly significantly affects you.

You have the right to object to our use of automated decision making and profiling described in this section. You can do that by opting-out of cookies and similar technologies in accordance with the method described in the relevant section below. If you do not want us to process your actual IP address (usually the IP address assigned to you by your Internet Service Provider) when you visit our website, you can use a Virtual Private Network (VPN) or a free service such as Tor.

You can find out more about our use of cookies and similar technologies (including the legal basis on which we use them) and how to opt out from them in our cookies policy, which is available here: https://www.thefonestuff.com/cookies.

Automated decision making

Automated decision making is decision making by technological means (i.e. by a machine) without human involvement.

Use of automated decision making for (display) advertising.

We automate the display advertisements containing our products and services on other websites you visit, you based on the fact that you have visited our website using cookies. For further information on the cookies we use, please see our cookie policy which is available here: https://www.thefonestuff.com/cookies

Logic Involved: automatically displaying advertisements to individuals who have visited our website results in increased efficiencies and cost savings for us than manually displaying advertisements or displaying advertisements by different means.


Significance and envisaged consequences: cookies will be used to recognise the fact that you have visitd our website in order to display advertisements to you (unless you have blocked such cookies) and will collect information about your online behaviour.

How to object: you can block these cookies by using the cookie control management tool on your site. For further information, please see our cookies policy: https://www.thefonestuff.com/cookies

Automated decision making

We use automated decision making for display advertising.

Logic Involved: automatically displaying advertisements to individuals.

Significance and envisaged consequences: cookies will be used to recognise the fact that you have visitd our website in order to display advertisements to you (unless you have blocked such cookies) and will collect information about your online behaviour.

How to object: you can block these cookies by using the cookie control management tool on your site. For further information, please see our cookies policy: https://www.thefonestuff.com/cookies

Profiling

Profiling is any form of automated processing of your information to evaluate personal aspects about you, in particular to analyse or predict things like your performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.

Use of profiling for web analytics

Our web analytics service, Google Analytics, uses collects information such as your location (based on your IP address) and your behaviour (based on cookies) when you access our website (such as the pages you visit and what you click on). We will only process information from cookies if you have consented to us setting cookies on your computer in accordance with our cookie policy: https://www.thefonestuff.com/cookies Information collected about you, once collected is anonymised and stored on an aggregate basis.

Logic involved: by automatically analysing and categorising information such as the location (based on IP address) as well as the behaviour and devices of visitors to our website (using cookies), we are able to gain a better understanding of what our website visitors wants (in terms of the content of our website and our products), how to improve our website and how to advertise and market our services to them.

Significance and envisaged consequences: cookies will be used to track and store information about your behaviour and device on our website (unless you have opted out from receiving such cookies by using tool. Your location will be analysed based upon your IP address. We may target advertisements based on the level of interest we receive from certain visitors and their behaviour on our website.

Legal basis for processing: by automatically analysing and categorising information such as the location (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest: analysing the level of engagement and effectiveness of our marketing and content.

Use of profiling in marketing emails

We use web beacons in our marketing emails to analyse who opens our emails and what actions they take (for example what they click on). We will only process information from web beacons if you have consented to their use in accordance with our cookies policy: https://www.thefonestuff.com/cookies

Logic involved: by analysing how our email recipients respond to our emails, we are able to improve the content and effectiveness of our emails and gauge who is most interested.

Significance and envisaged consequences: your behaviour when you open our emails will be tracked using web beacons, and include open rates and click through rates.

How to object: You can object to the use of web beacons by contacting us.

Legal basis for processing: legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest: analysing the level of engagement and effectiveness of our marketing emails and content.

Disclosure and additional uses of your information

This section sets out the circumstances in which will disclose information about you to third parties and any additional purposes for which we use your information.

Disclosure of your information to service providers

We use a number of third parties to provide us with services which are necessary to run our business or to assist us with running our business and who process your information for us on our behalf. These include the following:

  • Email provider(s), OVH. Their privacy policy is available here: https://ovhcloud.com/legal/privacy-policy

  • Web developer(s), Broadland Digital. Their privacy policy is available here: http://broadlanddigital.co.uk/privacy

  • Hosting provider(s), Online Fusion. Their privacy policy is available here: http://onlinefusion.co.uk/privacy

Our third party service providers are located in the UK and France.

Your information will be shared with these service providers where necessary to provide you with the service you have requested, whether that is accessing our website or ordering goods and services from us.

We do not display the identities of all our service providers publically by name for security and competitive reasons. If you would like further information about the identities of our service providers, however, please contact us directly via our contact form or email and we will provide you with such information where you have a legitimate reason for requesting it.

Legal basis for processing: legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest relied on: where we share your information with these third parties in a context other than where is necessary to perform a contract (or take steps at your request to do so), we will share your information with such third parties in order to allow us to run and manage our business efficiently.

Legal basis for processing: necessary to perform a contract and/or to take steps at your request prior to entering into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: we may need to share information with our service providers to enable us to perform our obligations under that contract or to take the steps you have requested before we enter into a contract with you.

Disclosure of your information to other third parties

We disclose your information to other third parties in specific circumstances, as set out below.

Providing information to third parties such as Google.

Google collects information through our use of Google Analytics on our website. Google uses this information, including IP addresses and information from cookies, for a number of purposes, such as improving its Google Analytics service. Information is shared with Google on an aggregated and anonymised basis. To find out more about what information Google collects, how it uses this information and how to control the information sent to Google, please see the following page: https://www.google.com/policies/privacy/partners/

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s): meeting our contractual obligations to Google under our Google Analytics Terms of Service (https://www.google.com/analytics/terms/us.html)

You can opt out of Google Analytics by installing the browser plugin here: https://tools.google.com/dlpage/gaoptout

Transfer and storage of your information

Information collected by Google Analytics is stored outside the European Economic Area on Google’s servers in the United States of America.

For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.

Sharing your information with third parties, which are either related to or associated with the running of our business, where it is necessary for us to do so. These third parties include our accountants, independent contractors and insurers.

Further information on each of these third parties is set out below.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: running and managing our business efficiently.

Accountants

We share information with our accountants for tax purposes. For example, we share invoices we issue and receive with our accountants for the purpose of completing tax returns and our end of year accounts.

Our accountants are Gohil’s Accountancy Services Limited and are located in the UK.

Independent Contractors

We use independent contractors in our business. Your information will be shared with independent contractors only where it is necessary for them to perform the function we have hired them to perform in relation to our business.

Our independent Contractors are King Crescent and are based in India.

Sharing your information with a prospective or actual purchaser or seller in the context of a business or asset sale or acquisition by us, a merger or similar business combination event, whether actual or potential.

Legal basis for processing: legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s)
: sharing your information with a prospective purchaser, seller or similar person in order to allow such a transaction to take place.

Disclosure and use of your information for legal reasons

Indicating possible criminal acts or threats to public security to a competent authority

If we suspect that criminal or potential criminal conduct has been occurred, we will in certain circumstances need to contact an appropriate authority, such as the police. This could be the case, for instance, if we suspect that we fraud or a cyber crime has been committed or if we receive threats or malicious communications towards us or third parties.

We will generally only need to process your information for this purpose if you were involved or affected by such an incident in some way.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interests: preventing crime or suspected criminal activity (such as fraud).

In connection with the enforcement or potential enforcement our legal rights

We will use your information in connection with the enforcement or potential enforcement of our legal rights, including, for example, sharing information with debt collection agencies if you do not pay amounts owed to us when you are contractually obliged to do so. Our legal rights may be contractual (where we have entered into a contract with you) or non-contractual (such as legal rights that we have under copyright law or tort law).

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: enforcing our legal rights and taking steps to enforce our legal rights.

In connection with a legal or potential legal dispute or proceedings

We may need to use your information if we are involved in a dispute with you or a third party for example, either to resolve the dispute or as part of any mediation, arbitration or court resolution or similar process.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s): resolving disputes and potential disputes.

For ongoing compliance with laws, regulations and other legal requirements

We will use and process your information in order to comply with legal obligations to which we are subject. For example, we may need to disclose your information pursuant to a court order or subpoena if we receive one.

Legal basis for processing: compliance with a legal obligation (Article 6(1)(c) of the General Data Protection Regulation).
Legal obligation(s)
: legal obligations to disclose information which are part of the laws of England and Wales or if they have been integrated into the United Kingdom’s legal framework (for example in the form of an international agreement which the United Kingdom has signed).

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: where the legal obligations are part of the laws of another country and have not been integrated into the United Kingdom’s legal framework, we have a legitimate interest in complying with these obligations.

How long we retain your information

This section sets out how long we retain your information. We have set out specific retention periods where possible. Where that has not been possible, we have set out the criteria we use to determine the retention period.

Retention periods

Server log information: we retain information on our server logs for a period of 6 months.

Order Information: When you place an order for goods and services, we retain that information for six years following the end of the financial year in which you placed your order, in accordance with our legal obligations to keep records for tax purposes.

Correspondence and enquiries: when you make an enquiry or correspond with us for any reason, whether by email or via our contact form or phone, we will retain your information for as long as it takes to respond to and resolve your enquiry, and for a further 3 months after which point we will delete your information.

E-newsletter: we retain the information you used to sign for our e-newsletter for as long as you remain subscribed (I.e. you do not unsubscribe) or if we decide to cancel our e-newsletter service, whichever comes earlier.

Criteria for determining retention periods

In any other circumstances, we will retain your information for no longer than necessary, taking into account the following:

  • [the purpose(s) and use of your information both now and in the future (such as whether it is necessary to continue to store that information in order to continue to perform our obligations under a contract with you or to contact you in the future);

  • whether we have any legal obligation to continue to process your information (such as any record-keeping obligations imposed by relevant law or regulation);

  • whether we have any legal basis to continue to process your information (such as your consent);

  • how valuable your information is (both now and in the future);

  • any relevant agreed industry practices on how long information should be retained;

  • the levels of risk, cost and liability involved with us continuing to hold the information;

  • how hard it is to ensure that the information can be kept up to date and accurate; and

  • any relevant surrounding circumstances (such as the nature and status of our relationship with you).]4

How we secure your information

We take appropriate technical and organisational measures to secure your information and to protect it against unauthorised or unlawful use and accidental loss or destruction, including:

  • only sharing and providing access to your information to the minimum extent necessary, subject to confidentiality restrictions where appropriate, and on an anonymised basis wherever possible;

  • using secure servers to store your information.

  • verifying the identity of any individual who requests access to information prior to granting them access to information;

  • using Secure Socket Layer (SSL) software to encrypt any information you submit to us via any forms on our website and any payment transactions you make on or via our website.

  • Only transferring you information via closed system or encrypted data transfers.

Transmission of information to us by email

Transmission of information over the internet is not entirely secure, and if you submit any information to us over the internet (whether by email, via our website or any other means), you do so entirely at your own risk.

We cannot be responsible for any costs, expenses, loss of profits, harm to reputation, damages, liabilities or any other form of loss or damage suffered by you as a result of your decision to transmit information to us by such means.6

Transfers of your information outside the European Economic Area

All of your information is stored in the following European Economic Area (EEA) countries, UK and France.

Other than to comply with legal obligations to which we are subject (compliance with a court order, for example), we do not intend to transfer your information outside the EEA or to an international organisation. In the unlikely event that we are required to transfer your information outside the EEA (or to an international organisation) for such a purpose, we will ensure appropriate safeguards and protections are in place.

Your rights in relation to your information

Subject to certain limitations on certain rights, you have the following rights in relation to your information, which you can exercise by writing to 53 Renters Avenue, London, NW4 or sending an email to [email protected]

  • to request access to your information and information related to our use and processing of your information;

  • to request the correction or deletion of your information;

  • to request that we restrict our use of your information;

  • to receive information which you have provided to us in a structured, commonly used and machine-readable format (e.g. a CSV file) and the right to have that information transferred to another data controller (including a third party data controller);

  • to object to the processing of your information for certain purposes (for further information, see the section below entitled Your right to object to the processing of your information for certain purposes); and

  • to withdraw your consent to our use of your information at any time where we rely on your consent to use or process that information. Please note that if you withdraw your consent, this will not affect the lawfulness of our use and processing of your information on the basis of your consent before the point in time when you withdraw your consent.

  • The right not to be subject to a decision based on automated processing, including profiling which produces legal affects concerning you or similarly significantly affects you.

In accordance with Article 77 of the General Data Protection Regulation, you also have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or of an alleged infringement of the General Data Protection Regulation.

For the purposes of the UK, the supervisory authority is the Information Commissioner’s Office (ICO), the contact details of which are available here: https://ico.org.uk/global/contact-us/

Further information on your rights in relation to your personal data as an individual

The above rights are provided in summary form only and certain limitations apply to many of these rights. For further information about your rights in relation to your information, including any limitations which apply, please visit the following pages on the ICO’s website:

You can also find out further information about your rights, as well as information on any limitations which apply to those rights, by reading the underlying legislation contained in Articles 12 to 22 and 34 of the General Data Protection Regulation, which is available here: http://ec.europa.eu/justice/data-protection/reform/files/regulation_oj_en.pdf

Verifying your identity where you request access to your information

Where you request access to your information, we are required by law to use all reasonable measures to verify your identity before doing so.

These measures are designed to protect your information and to reduce the risk of identity fraud, identity theft or general unauthorised access to your information.

How we verify your identity

Where we possess appropriate information about you on file, we will attempt to verify your identity using that information.

If it is not possible to identity you from such information, or if we have insufficient information about you, we may require original or certified copies of certain documentation in order to be able to verify your identity before we are able to provide you with access to your information.

We will be able to confirm the precise information we require to verify your identity in your specific circumstances if and when you make such a request.

Your right to object to the processing of your information for certain purposes

You have the following rights in relation to your information, which you may exercise in the same way as you may exercise by writing to 53 Renters Avenue, London, NW4 3RD or sending an email to [email protected]

  • to object to us using or processing your information where we use or process it in order to carry out a task in the public interest or for our legitimate interests, including ‘profiling’ (i.e. analysing or predicting your behaviour based on your information) based on any of these purposes; and

  • to object to us using or processing your information for direct marketing purposes (including any profiling we engage in that is related to such direct marketing).

You may also exercise your right to object to us using or processing your information for direct marketing purposes by:

  • clicking the unsubscribe link contained at the bottom of any marketing email we send to you and following the instructions which appear in your browser following your clicking on that link;

  • sending an email to [email protected], asking that we stop sending you marketing communications or by including the words “OPT OUT”.

For more information on how to object to our use of information collected from cookies and similar technologies, please see the section entitled How to accept or reject cookies in our cookies policy, which is available here: https://www.thefonestuff.com/cookies

Sensitive Personal Information

Sensitive personal information’ is information about an individual that reveals their racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic information, biometric information for the purpose of uniquely identifying an individual, information concerning health or information concerning a natural person’s sex life or sexual orientation.

W do not knowingly or intentionally collect sensitive personal information from individuals, and you must not submit sensitive personal information to us.

If, however, you inadvertently or intentionally transmit sensitive personal information to us, you will be considered to have explicitly consented to us processing that sensitive personal information under Article 9(2)(a) of the General Data Protection Regulations. We will use and process your sensitive personal information for the purposes of deleting it.

Changes to our Privacy Policy

We update and amend our Privacy Policy from time to time.

Minor changes to our Privacy Policy

Where we make minor changes to our Privacy Policy, we will update our Privacy Policy with a new effective date stated at the beginning of it. Our processing of your information will be governed by the practices set out in that new version of the Privacy Policy from its effective date onwards.

Major changes to our Privacy Policy or the purposes for which we process your information

Where we make major changes to our Privacy Policy or intend to use your information for a new purpose or a different purpose than the purposes for which we originally collected it, we will notify you by email (where possible) or by posting a notice on our website.

We will provide you with the information about the change in question and the purpose and any other relevant information before we use your information for that new purpose.

Wherever required, we will obtain your prior consent before using your information for a purpose that is different from the purposes for which we originally collected it.

California Do Not Track Disclosures

Do Not Track” is a privacy preference that users can set in their web browsers. When a user turns on a Do Not Track signal in their browser, the browser sends a message to websites requesting that they do not track the user. For information about Do Not Track, please visit www.allaboutdnt.org

At this time, we do not respond to Do Not Track browser settings or signals. In addition, we use other technology that is standard to the internet, such as pixel tags, web beacons to track visitors to the website. Those tools may be used by us and third parties to collect information about you and your internet activity, even if you have turned on No Not Track signal. For information on how to opt out from tracking technologies used on our website, see our cookies policy which is available here: https://www.thefonestuff.com/cookies

Copyright, credit and logo

This Privacy Policy is based on a General Data Protection Regulation (Regulation (EU) 2016/769) (GDPR) compliant template provided by GDPR Privacy Policy. For further information, please visit https://gdprprivacypolicy.org

The copyright in this Privacy Policy is either owned by, or licensed to, us and is protected by copyright laws around the world and copyright protection software. All intellectual property rights in this document are reserved.

Where we display the GDPR Privacy Policy logo on our website, this is used to indicate that we have adopted a privacy policy template provided by GDPR Privacy Policy as the basis for this Privacy Policy.

1 When you upload this privacy policy to your website, at a minimum, you should ensure that the titles in this “Contents” section link to the relevant headings in the main body of the privacy policy. For instance, the “Our details” title in this “Contents” section should link to the “Our details” heading in the main body of the privacy policy. An alternative and highly recommended way of ensuring your privacy policy meets the clear and accessible requirements of the General Data Protection Regulation is to use drop down boxes for each section of the privacy policy which expand and show the information in that section when clicked on. This allows a user to easily access the information they are interested in quickly and effectively.

2 This summary section is designed to meet the GDPR’s requirement for a privacy policy to be in a concise, transparent, intelligible and easily-accessible form and uses the ICO’s suggestion of adopting a layered approach in order to achieve this. The individual can then look at the corresponding section in the main body of the privacy policy if they require more information on any particular aspect of your privacy policy. If you use an individual’s personal data in a way they would not reasonably expect, you must ensure that you bring it to their attention in this summary section. The summary section can be contained in or separated from the rest of the privacy policy and inserted above it (with the rest of the full privacy policy below) to draw the summary section more clearly to the user’s attention.

3 Where you transfer personal information outside the European Economic Area (EEA), you must ensure appropriate safeguards are in place before you make such a transfer. For further information on such safeguards please see the full section entitled ‘Transfers of your information outside the European Economic Area’.

4 These are general factors which the Information Commissioner’s Office recommends that you consider when determining the retention period for personal information. You should delete any factors that do not apply to your determination of how long you retain information and add any additional factors that you take into account (if any).

5 This section includes some mandatory security measures you are required to take as well as some suggested further actions methods of securing personal information which you may or may not use in practice. You should add to this list any additional methods which you use to secure personal information which are not covered in this list.

6 Although transmission of information over the internet is inherently insecure, you need to ensure that personal information collected via your website is stored on secure servers.