Privacy Policy

Introduction

Welcome to the Arcadia Corporate Merchandise's privacy notice.

We respect your privacy and are committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you interact with us and tell you about your privacy rights and how the law protects you.

Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.

Important information and who we are
The data we collect about you
How is your personal data collected
How we use your personal data
Disclosures of your personal data
International transfers
Data security
Data retention
Your legal rights
Glossary

1. Important Information and who we are.

Purpose of this privacy notice.

This privacy notice aims to give you information on how Arcadia Corporate Merchandise collects and processes your personal data when you interact with us, including any data you may provide to us.

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

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This may include privacy notices on our micro sites. We also have a separate privacy notice in relation to the data we collect as an employer. This privacy notice supplements the other notices and is not intended to override them.

Controller.

Arcadia Corporate Merchandise is the controller and responsible for your personal data (collectively referred to as "Arcadia", "we", "us" or "our" in this privacy notice).

We have an appointed a privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the privacy manager using the details set out below.

Contact Details.

Our full details are:

Full name of legal entity: Arcadia Corporate Merchandise Ltd

Name or title of person to contact: David Dobson

Email address: dpo@arcadiaonline.co.uk

Postal address: Grove Place, Wellington Road, High Wycombe, Bucks HP12 3PR.

Telephone number: 0845 130 2620

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy notice and your duty to inform us of changes.

This version was last updated on 29/05/2018. 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.

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. When you leave our website, we encourage you to read the privacy notice of every website you visit.

2. The data we collect about you.

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

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

Identity Data - includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender. In some cases, we may also collect passport and driving licence numbers, national identity cards and date of birth information.
Contact Data - includes home address, billing address (which may be a business address), delivery address, email address and telephone numbers.
Financial Data - includes bank account and payment card details.
Health Data - includes information about allergies, health requirements and allergies, this could include details of specific medical or health conditions.
HR Data - includes information we collect in the capacity as an employer. In addition to Identity Data, Contact Data, Financial Data and Technical Data, it will include Special Category Data, details of your information you provide in a recruitment process and information about your education, training and work background, your employment history and other personnel information. (We have a separate Employee Privacy Policy for employee and workers).
Transaction Data - includes details about payments to and from you and other details of products and services you have purchased from us.
Technical Data - includes internet protocol (IP) address, your login data, browser type and version, device type, 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.
Profile Data - includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
Usage Data - includes information about how you use our website, products and services.
Marketing and Communications Data - includes your preferences in receiving marketing from us and our third parties and your communication 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 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.

As highlighted above, we do collect some Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data.

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

3. How is 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 Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes:

As a customer when you:

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

As a supplier:

When you market to us or transact business with us; and
When you tender for business;
When you supply us or a customer directly

As an employee or worker (we have a separate Employee privacy policy):

When you apply for employment or work with us; and
During your employment or work for us.

In relation to references we are asked to provide for you:

Automated technologies or interactions. As you interact with our website and micro websites, 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. Please see our cookie policy.
Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
Technical Data from the following parties: A. analytics providers such as Google based outside the EU B. our marketing platform, Lead Liaison based in the EU
Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
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.

4. How we use your personal data.

We collect and use your personal data as a customer for the purpose of dealing with your order and requests, tailoring our services to your requirements, providing you information about products and services we offer and to improve our service to you.

Where you are a supplier or potential supplier we use the data for the purposes of managing the supply and performance of the supply or for evaluating the use the suppliers, including for evaluating tenders.

For employees and workers, we use the data for the purposes of recruitment and employing you. Further details are set out in our Employee Privacy Policy.

In all cases, we also use personal data for the purposes of satisfying any legal, accounting, or reporting requirements.

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

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. 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.	A. Identity. B. Contact.	A. Performance of a contract with you. B. Necessary for our legitimate interests (to recover debts due to us).
To register you as a new Supplier.	A. Identity. B. Contact.	A. Performance of a contract with you. B. Necessary for our legitimate interests.
To process and deliver your order including: A. Arrange and deliver the products and services to your business. B. Manage payments, fees and charges. C. Collect and recover money owed to us.	A. Identity. B. Contact. C. Financial. D. Transaction. E. Marketing and Communications.	A. Performance of a contract with you. B. Necessary for our legitimate interests.
To manage our relationship with you which will include: A. Account management & customer services. B. Notifying you about changes to our terms or privacy policy. C. Asking you to leave a review or take a survey.	A. Identity. B. Contact. C. Profile. D. Marketing and Communications.	A. Performance of a contract with you. B. Necessary to comply with a legal obligation. C. Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services).
To manage our relationship with you in our HR capacity, including but not limited to recruitment and references.	A. Identity. B. Contact. C. Profile. D. Usage. E. Health. F. Special category data.	A. Performance of a contract with you. B. Necessary for our legitimate interests. C. Vital interests.
To enable you to partake in a prize draw, competition or complete a survey.	A. Identity. B. Contact. C. Profile. D. Usage. E. Marketing and Communications.	A. Performance of a contract with you. B. Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business).
To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).	A. Identity. B. Contact. C. Technical.	A. Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise). B. Necessary to comply with a legal obligation.
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.	A. Identity. B. Contact. C. Profile. D. Usage. E. Marketing and Communications. F. Technical.	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy).
To use data analytics to improve our website, products/services, marketing, customer relationships and experience.	A. Technical. B. Usage.	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy).
To make suggestions and recommendations to you about goods or services that may be of interest to you.	A. Identity. B. Contact. C. Technical. D. Usage. E. Profile.	Necessary for our legitimate interests (to develop our products/services and grow our business).

Marketing.

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

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

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

Third-party marketing
We will not sell your personal information to third parties without first obtaining your consent and will only disclose information to our selected business partners and service providers for the purpose of performing our contract with you or if we are obliged by UK governing law to disclose information to law enforcement agencies as required.

Opting out
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

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

Cookies
Our website uses ‘cookie’ technology. A cookie encrypts strings of text that a website stores on a user’s hard drive (but it does not access your hard drive). In order to improve our website, services and build profile information about visits to our website, we may from time to time send you cookies.

Whilst you do not need to allow your browser to accept cookies in order to browse much of our website or access our services, we strongly recommend that your cookies are enabled if you wish to proceed with using our web services.

The type of cookies that we use are referred to as ‘session’ cookies and ‘persistent’ cookies. Session cookies are temporary and are automatically deleted once you leave the website. Persistent cookies remain on your computer hard drive until you delete them. Usage of the cookie is in no way linked to any personally identifiable information apart from what you voluntarily provide us in your dealings with us.

Most browsers allow you to turn off the cookie function. If you want to know how to do this please look at the help menu on your browser. As previously mentioned, this will restrict your ability to perform transactions, use certain functions and access certain content on our website.

For more information about the cookies we use, please see our cookies page.

Change of purpose.

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

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.

External Third Parties as set out in the Glossary (section 9).
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International transfers.

We do from time to time use suppliers from outside the European Economic Area (EEA) in order to perform our contract with you. This may involve transferring business contact data and delivery addresses where necessary for performing the contract.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
We do source some supplies from China and so may forward business contact information for our employees and customers to Chinese suppliers. Where we do so, we add data security terms.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7. Data security.

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Whilst we take all reasonable steps to protect your personal information, data transmission over the Internet cannot be entirely secure. We therefore cannot guarantee the security of the information you disclose online and the use of our facilities (e.g. email) is at your own risk.

We will not be liable for any damages or losses suffered directly or indirectly arising out of or in connection with unauthorised access, loss or corruption of personal data which you provide to us on this website unless we have been found to be negligent.

8. Data retention.

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

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

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

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

Under certain circumstances, 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:

Request access to your personal data.
Request correction of your personal data.
Request erasure of your personal data.
Object to processing of your personal data.
Request restriction of processing your personal data.
Request transfer of your personal data.
Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

9. Your legal rights.

You have the right to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

10. Glossary.

LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

THIRD PARTIES

External Third Parties

Service providers acting as processors based in the EU who provide IT, HR and system administration services.
Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the EU who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
Prospective employers when we provide references;
Suppliers and customers, when we provide contact or delivery information.