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Clintons respects your privacy and is committed to protecting your personal data.
This privacy notice sets out to how we look after your personal data whenever that information is provided to us. [This includes when you request information from us, Contact us (or we contact you), buy products [or services] from us, use our websites (including clintoncards.co.uk, clintonsretail.co.uk, and any other websites we may operate from time to time) ("Websites") or apps, [connect with us via social media], link to or from our website(s)/apps, or visit our shops]. It also tells you about your privacy rights and how the law protects you. It has been updated to reflect the new and additional requirements of the General Data Protection Regulation ("GDPR").
This privacy notice is provided in a layered format so you can click through to the specific areas set out below, to find the information you want. Alternatively you can download a pdf version of the policy here [LINK].
This privacy notice provides information on how Clintons collects and processes your personal data in our dealings with you, including in providing goods and services to you, and including any data you may provide through the Websites.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
AG Retail Cards Limited, trading as Clintons, ("Clintons", "we", "us") is the controller of your personal data and responsible for our Websites.
This privacy notice was last updated on 21st May 2018. We will update this privacy notice from time to time, and will notify you of any significant changes.
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.
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. When you leave our website, we encourage you to read the privacy notice of every website you visit.
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:
[We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.]
In the normal course, we will not collect or process special categories of personal data about you, for example health, or racial or ethnic origin. If we ever do, we will make sure that we have your consent or another lawful basis to process it.
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a contract you have with us, but we will notify you if this is the case at the time.
We collect data from and about you in different ways, including through:
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:
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.
You have the right to withdraw consent at any time by Contacting us.
We have set out below, in a table format, a description of the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.
Necessary to take steps at your request prior to entering into a contract with you.
Necessary for our legitimate interests in protecting our business from fraud.
Necessary for means of substantial public interest (preventing fraud).]
Performance of a contract with you
Necessary for our legitimate interests (to operate our business and obtain payment).
To manage our relationship with you which will include:
(b) Asking you for feedback, by leaving a review or taking part in a survey
Necessary to comply with a legal obligation
Necessary for our legitimate interests (to keep our records updated and to understand how customers use our services, what they think of our products, and how we can improve them)
Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security and to prevent fraud
Necessary for our legitimate interests.
Necessary to establish, exercise or defend legal claims
When we refer to legitimate interests we mean the interest of our business in conducting and managing our business to enable us to give you the best service/product. 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).
We do not undertake automated decision making using your personal data.
Where you have agreed to receive marketing communications, we may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which goods, services and offers may be relevant for you.
We will only share your personal data for marketing purposes in accordance with your preferences/consent.
You can ask us to stop sending you marketing messages at any time [by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or] by Contacting us at any time].
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please Contact us.
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.]
We may have to share your personal data with the categories of parties set out below for the purposes set out in the table in paragraph 4 above.
Where these third parties are our processors, we require them to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party processors 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. Some of the third parties mentioned above, for example many professional advisers and HM Revenue and Customs, are controllers who, like us, are subject to specific obligations under data protection law, and who will have their own privacy notices setting out how they deal with personal data.
Though we do not seek actively to transfer personal data outside the European Economic Area ("EEA"), some of the external third parties we deal with are based outside the EEA or process personal data outside the EEA, so their processing of your personal data will involve a transfer of data outside the EEA.
[Whenever we transfer your personal data out of the EEA, we look to ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
[Please Contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.]
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. Processors we appoint will only process your personal data on our instructions and they are subject to a duty of confidentiality.
[You should be aware, however, that transmission of information via the internet is not completely secure.]
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.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
[Details of retention periods for different types of your personal data are [available in our retention policy which you can request from us by Contacting us].
In some circumstances you can ask us to delete your data: see [Request erasure] below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
You have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
If you wish to exercise any of the rights set out above, please email us at email@example.com
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to enable us to deal with your request or to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or we have received a number of requests. In this case, we will notify you and keep you updated.
You have the right to:
We may monitor and/or record:
(a) telephone calls;
(b) transactions [and activities at all points of contact];
(c) web, traffic and activities
These are to ensure that we carry out your instructions accurately, for training purposes and to improve our services, and to ensure security and prevent fraud. For the greater security of our customers and staff, and to prevent and detect crime, we use CCTV in and around our stores and other premises. [To obtain information about our use of CCTV [Contact us]].
Customers need to be over 16 to register with our Websites or to sign up for our newsletter, and must be over 18 to take part in competitions, prize draws or other promotions. We will not knowingly collect data about under 16s, and if you are under 16, please do not provide us with your personal information. We would ask parents please to ensure that their children under 16 do not provide us with personal information without your permission. If you believe that a child who is under 16 has provided personal data to us, please contact us, using the details below, and we will seek to delete that data from our systems.
By email at firstname.lastname@example.org
By post to: