On 25 May 2018, the General Data Protection Regulation came into force across Europe together with the Data Protection Act 2018 in the United Kingdom. This legislation replaced the former data privacy law and regime, giving more rights to you as an individual and more obligations to organisations holding your personal data.
One of the rights is a right to be informed, which means we have to give you more information than before about the way in which we use, share and store your personal information.
As a result of this new law and the likelihood of changes in practice and precedent over the next few years, this Notice will remain a live document with regular updates to help you access this information, along with information about the increased rights you have in relation to the information we hold on you and the legal basis on which we are using it. Please note that date at the foot of this page which will inform you when this Notice was last amended.
WHO WE ARE
We are Gower Enterprises Limited, a company registered in England and Wales. We trade under the name Orderly Distribution. We sell electronic cigarettes, e-liquids and vaping accessories via our website to our wholesale customers.
We take your privacy seriously and safeguard your personal data to the best of our ability. Please see below for more detail on the personal data we collect, why we collect it and what we do with it.
HOW WE USE YOUR INFORMATION
This privacy notice tells you what to expect when Gower Enterprises trading as Orderly Distribution (Orderly) collects personal information. It applies to information we collect about:
- Customers who make purchases via our website
- People who call or email our customer services team
- People who subscribe to our newsletter
- Individuals in relation to a data protection enquiry or complaint
VISITORS TO OUR WEBSITE
When someone visits www.orderlydistro.co.uk we use a third party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website. If we do want to collect personally identifiable information through our website, we will be up front about this. We will make it clear when we collect personal information and will explain what we intend to do with it.
Our website search is powered by BigCommerce. Search queries and results are logged anonymously to help us improve our website and search functionality. No user-specific data is collected by either ECD or any third party.
CUSTOMERS WHO ENQUIRE ABOUT WHOLESALE PURCHASES
If you make an enquiry about purchasing products from us for the purpose of retailing to consumers (whether at a trade show, via email or via the telephone) but do not apply for an account agreement, we will usually retain your contact details for a period of two years unless you request that we delete them sooner. During this time, we will occasionally get in touch to see if you would like to progress with an account.
CUSTOMERS WHO PURCHASE FROM US VIA OUR WEBSITE
Before making a purchase, you will need to apply for a wholesale account with us. In order to enter into an agreement with you, we need certain information from you. This includes your company or business name and registered office and trading addresses (if different) and the name of any directors or authorised account contacts as well as contact telephone numbers and email addresses. We will send you an account agreement for signature with our usual terms of business appended although these are subject to change from time to time.
We will not pass your personal information on to any third parties for marketing purposes or for any reason not connected with the fulfilment of your contract with us. We will not use your telephone number or email address to market our products to you without your specific consent, and you can withdraw your consent at any time by unsubscribing from emails, emailing firstname.lastname@example.org or calling our Customer Services team.
PEOPLE WHO CALL OUR CUSTOMER SERVICES TEAM, CONTACT US VIA SOCIAL MEDIA OR EMAIL US
When you call our customer services team we may record information about your call including your name and telephone number and the reason for calling. If you place an order over the phone for the first time or if you are having difficulties ordering online, we may take information from you for the purpose of completing your order. Phone calls to our customer services team may be recorded for the purpose of training and improving our customer service standards and you will be advised of this prior to your call being connected. Once connected, you may ask the operator to stop recording the call. You may also request any recording of the call to be subsequently deleted and we will delete the recording within a reasonable time of your request, unless we have a legitimate interest in maintaining the recording or part of it. Call recordings are kept for a maximum of six months.
We use a third party provider, Hootsuite, to manage our social media interactions.
If you send us a private or direct message via social media the message will be stored by Hootsuite for three months. It will not be shared with any other organisations.
We use Transport Layer Security (TLS) to protect email traffic. If your email service does not support TLS, you should be aware that any emails we send or receive may not be protected in transit.
We will also monitor any emails sent to us, including file attachments, for viruses or malicious software. Please be aware that you have a responsibility to ensure that any email you send is within the bounds of the law.
We use a third party provider, Google Inc., to provide our email server. We have also entered into an agreement with Google who have undertaken to keep your personal information secure in line with European Union data protection standards and requirements.
PEOPLE WHO SUBSCRIBE TO OUR NEWSLETTERS
We will only send you emails if you have demonstrated your consent by opting in (by ticking a box or clicking a button in an email). You may unsubscribe at any time by clicking the unsubscribe link in any of our emails.
We use a third party provider, Mailchimp to deliver our monthly e-newsletters. We gather statistics around email opening and clicks using industry standard technologies including clear gifs to help us monitor and improve our e-newsletter. We have entered into a data processing agreement with Mailchimp where they have undertaken to comply with the GDPR and data protection legislation. For more information, please see Mailchimp’s privacy notice.
YOUR RIGHTS AS A DATA SUBJECT
At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:
- Right of access – you have the right to request a copy of the information that we hold about you.
- Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
- Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
- Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
- Right of portability – you have the right to have the data we hold about you transferred to another organisation.
- Right to object – you have the right to object to certain types of processing such as direct marketing.
- Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
- Right to judicial review: in the event that refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined in clause 3.6 below.
All of the above requests will be forwarded on should there be a third party involved in the processing of your personal data.
If you need any more information or guidance about your rights, you can find this here on the ICO’s website: https://ico.org.uk/for-the-public/is-my-information-being-handled-correctly/
ACCESS TO PERSONAL INFORMATION
We try to be as open as we can be in terms of giving people access to their personal information. Individuals can find out if we hold any personal information by making a ‘subject access request’ under the Data Protection Act 2018. If we do hold information about you we will:
- Give you a description of it;
- Tell you why we are holding it;
- Tell you who it could be disclosed to; and
- Let you have a copy of the information in an intelligible form.
To make a request for any personal information we may hold about you, you need to put the request in writing addressing it to our Data Protection Team, or writing to the address provided below. Before complying with your request, we will need to confirm your identity as far as reasonably possible. For example, we may ask you to confirm details so we can check it against the data we hold.
If you agree, we will try to deal with your request informally, for example by providing you with the specific information you need over the telephone.
If we do hold information about you, you can ask us to correct any mistakes by contacting the Data Protection Team.
COMPLAINTS OR QUERIES
We try to meet the highest standards when collecting and using personal information. For this reason, we take any complaints we receive about this very seriously. We encourage people to bring it to our attention if they think that our collection or use of information is unfair, misleading or inappropriate. We would also welcome any suggestions for improving our procedures.
This privacy notice was drafted with brevity and clarity in mind. It does not provide exhaustive detail of all aspects of ECD’s collection and use of personal information. However, we are happy to provide any additional information or explanation needed. Any requests for this should be sent to the address below.
If you want to make a complaint about the way we have processed your personal information or if we have not been able to assist with your queries, you can contact the Information Commissioner’s Office which is the statutory body which oversees data protection law – www.ico.org.uk/concerns.
LINKS TO OTHER WEBSITES
This privacy notice does not cover the links within this site linking to other websites. We encourage you to read the privacy statements on the other websites you visit.
CHANGES TO THIS PRIVACY NOTICE
We keep our privacy notice under regular review. This privacy notice was last updated on 3 February 2020.
HOW TO CONTACT US
Data Protection Team
Gower Enterprises Limited
Units 4-5 Bell Court