Introduction
Welcome to Click Spares’ privacy policy.
Click
Spares respects your privacy and is committed to protecting your personal data.
This privacy policy will inform you as to how we look after your personal data
when you visit our website (regardless of where you visit it from) and tell you
about your privacy rights and how the law protects you.
This privacy policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.
- 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 policy
privacy policy aims to give you information on how Click Spares collects and
processes your personal data through your use of this website, including any
data you may provide through this website when you order a spare part.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy policy together with any other privacy
policy or fair processing policy 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 policy supplements
other notices and privacy policies and is not intended to override them.
Controller
Click Spares Ltd. (company number 06219602) is the controller and responsible for
your personal data (collectively referred to as Click Spares, "we",
"us" or "our" in this privacy policy). We often work
directly with the Retailer that sold you the product which requires spare parts
(the “Retailer”), so we may also
receive your personal data directly from the Retailer or a member of its group.
Further information on this can be found in the sections of this policy named How is your personal data collected and External Third Parties.
We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy.
Contact details
If you have any questions about this privacy policy or our privacy practices, including
any requests to exercise your legal rights, please contact our DPO in the following ways:
Post:
Click Spares Ltd, unit 9, Manor Farm, Collum Lane, Kewstoke, BS22 9JL
Email: Bruce.Hartley@ClickSpares.co.uk
Telephone: 01934 524180
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however,
appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review. This version was last updated in November 2022.
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
This 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 policy 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 as follows:
- Identity Data includes first name, last name and title.
- Contact Data includes delivery address, email address and telephone numbers.
- Transaction Data includes details of spare parts that you have ordered from us, or orders for spare parts which we have received on your behalf from the Retailer.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
- Usage Data includes information about how you use our website.
We also collect, use
and share Aggregated Data such as statistical or
demographic data for any purpose. Aggregated Data could be derived from your
personal data but is not considered personal data in law as this data will 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 policy.
We do not collect any Special Categories of Personal Data about you (this
includes details about your race or ethnicity, religious or philosophical
beliefs, sex life, sexual orientation, political opinions, trade union
membership, information about your health, and genetic and biometric data). Nor
do we collect any information about criminal convictions and offences.
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 by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- submit an order for spare parts; or
- give us feedback or contact us.
- Automated technologies or interactions. As you interact with our website, we will 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 Please see our cookie policy click here for further details.
- Third parties or publicly available sources. We will receive personal data about you from various third parties as set out below:
- Identity, Contact Data and Transaction Data from Retailers (based inside the UK) in circumstances where a Retailer has submitted an order for spare parts to us on your behalf, or have provided your details for us to contact you;
- Contact and Transaction Data from providers of technical, payment and delivery services such as Stripe based inside the UK.
4 .How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal obligation.
Click here to find out more about the types of lawful basis that we will rely on to process your personal data.
Generally, we do not rely on consent as a legal basis for processing your personal data
although we will get your consent before sending third party direct marketing
communications to you via email or text message. You have the right to withdraw
consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of 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
|
Performance of a contract with you
|
To confirm to the Retailer that we have received an order
for spare parts from you
|
(a) Identity
(b) Contact
(c) Transaction
|
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to confirm to
the Argos Group the details of the orders that we have received from their
customers for spare parts)
|
To process and deliver your order including:
(a) Manage payments, fees and
charges
(b) Collect and recover money owed to us
(c) sending the spare parts to you via a courier service
(d) receive payment for your order from the Argos Group
|
(a) Identity
(b) Contact
(c) Transaction
|
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to receive amounts
due to us)
|
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy
policy
(b) Asking you to leave a review or take a survey
|
(a) Identity
(b) Contact
|
(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 enable you to partake in a prize draw, competition or
complete a survey
|
(a) Identity
(b) Contact
(c) Usage
|
(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 this 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) Usage
(d) 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 experiences
|
(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
|
Necessary for our legitimate interests (to develop our products/services
and grow our business)
|
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when
websites set or access cookies. If you disable or refuse cookies, please note
that some parts of this website may become inaccessible or not function
properly. For more information about the cookies we use, please see here
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 share your personal data with the parties set out below for the purposes set
out in the table Purposes for which we
will use your personal data above.
- Internal Third Parties as set out in the Glossary
- External Third Parties as set out in the Glossary
- Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers
to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. International transfers
We do not transfer your personal data outside of the UK, unless weare doing so to fulfil your international order.
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.
8. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil
the purposes we collected it for, including for the purposes of satisfying any
legal, regulatory, tax, accounting or reporting requirements. We may retain
your personal data for a longer period in the event of a complaint or if we reasonably
believe there is a prospect of litigation in respect to our relationship with
you.
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, regulatory, tax, accounting or other requirements.
Details of retention periods for different aspects of your personal data are available in
our retention policy which you can request from us by contacting us.
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation
to your personal data. Please see the section named “YOUR LEGAL RIGHTS” below to find out more
about these rights. 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 could 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 could 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.
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 intosuch a contract
Comply with a legal obligation means processing your
personal data where it is necessary for compliance with a legal obligation that
we are subject to.
THIRD PARTIES
External Third Parties
- Service providers acting as processors based in the UK who provide IT and system administration services or payment processing services.
- Delivery providers that we use, such as Royal Mail, GFS, ParcelHub, Evri, DPD, DHL, Tuffnells, DX based in the UK.
- The Retailer, acting as controller or processor or either on a joint basis depending on whether we have received your personal data from them or we have received it directly from you.
- Professional advisers acting as processors including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities acting as processors based in the United Kingdom who require reporting of processing activities in certain circumstances
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:
- If you want us to establish the data's accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- 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.
- 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.