Privacy Policy

Important information and who we are

Purpose of this privacy notice

Hot Tub and Spa Hub is operated by Hygiene Supplies Direct Limited

This privacy notice aims to give you information on how Hygiene Supplies Direct Limited collects and processes your personal data, however you provide it to us.

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.

Controller

Hygiene Supplies Direct Limited is the controller and is responsible for your personal data (collectively referred to as "we", "us" or "our" in this privacy notice).

We have appointed a data 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 data privacy manager using the details set out below.

Contact details

Email address: GDPR@hsdonline.co.uk

Postal address: Tayson House, Methley Road, Castleford, West Yorkshire WF10 1PA

We also operate the website at www.hsdonline.co.uk.

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

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.

We reserve the right to make changes to this privacy notice at any time.

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, last name and title.
• Contact Data includes home address, delivery address, email address and telephone numbers.
• Transaction Data includes details of products you have purchased or otherwise received from us.
• Technical Data includes internet protocol (IP) address, your login data for our website, 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 our website.
• Marketing and Profile Data includes your preferences in receiving marketing from us and your communication preferences, your interests, feedback and survey responses.

We may collect, use and store Financial Data (which includes bank account and payment card details) in respect of our suppliers. However, we do not do so in respect of our customers. Customer payments are processed by a third party payment provider and we do not have access to those details. Where a customer buys a product from us over the telephone, we will insert their payment details directly into the web portal of our third party payment provider, and will not retain any of that information.

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. 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.

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.

Please also note that we do not knowingly collect data relating to children.

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 or to provide you with products you have requested, and you fail to provide that data when requested, we may not be able to perform the contract we have or to provide you with the products you have requested from us. In this case, we may have to cancel the contract in question that you have with us but we will notify you if this is the case at the time.

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 data by corresponding with us by post, phone, email or otherwise. This includes for example personal data you provide when you create an account on our website, request a quote or purchase a product from us.
• Third parties or publicly available sources. We may receive personal data about you from various third parties such as through our shopping channels on Ebay & Amazon, or through our third party Live Chat provider.
• Contact, Financial and Transaction Data from providers of technical, payment and other services.
• Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies.

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 or regulatory obligation.

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.

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.

Marketing

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

We will not share your personal data with any third party for marketing purposes.

Promotional offers from us

We may use your Identity, Contact, Technical, and Marketing 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 and offers may be relevant for you.

You will receive marketing communications from us if you have purchased products from us and you have not (or have not subsequently) opted out of receiving that marketing.

Opting out

You can ask us 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 that we process and use on a different lawful basis, or in respect of which you continue to consent to us processing.

Social Media

If you post personal data on any of our social media feeds, we may re-publish that data on those social media feeds ourselves. We do so on the basis of our legitimate interests (to develop and market our business), and on the basis that we are merely re-publishing to our social media feed the information you yourself have already made known to those who can view that feed.

Our Website – Cookies

Cookies are small text files that are placed on to your computer by websites that you visit. We use cookies on our website, which may collect personal data.

Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

You can set your web 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 our website may become inaccessible or not function properly. To find out more about managing cookies visit http://www.aboutcookies.org.

We use cookies to:

• provide a shopping service such as logging in to your account, remembering the contents of your basket and remembering your details whilst going through checkout. This is a session cookie.
• remember if you wish to see prices with or without VAT. This is a persistent cookie.

Third parties may set cookies on your browser to enable our live chat functionality (but we do not collect personal data from this cookie).

We also use information from third party analytical cookies, but this information does not reveal any personal data to us.

Our Website - 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.

Trade References

If you are a business and we open a trade account for you, you will be asked to provide a number of trade references, which may include third party personal data. We will only use this data to contact the trade references in question about you. We will retain this third party personal data for one year in relation to successful applications and for 1 month in relation to unsuccessful applications.

Suppliers

If you are a supplier to us, you will be asked to supply certain personal data to us and we will process that personal data for the purposes of the contract that you and we enter into for the supply of your products.

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.

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.

• Service providers (acting as processors) who provide services to us, including; (i) IT service providers (including Mailchimp for electronic marketing; Rackspace and Microsoft One-Cloud to host data, Sage for accounts data); and (ii) Suppliers and transport companies (we may pass your Identity and Contact Data to them so they can deliver your order to you)
• Professional advisers (acting as processors or joint controllers) including bankers, lawyers, auditors, accountants and insurers who provide banking, consultancy, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities (acting as processors or joint controllers) who may require reporting of processing activities in certain circumstances.
• 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.

International transfers

Some of the third parties to whom we may pass your personal data are based outside the European Economic Area (EEA). Their processing of your personal data will involve a transfer of data outside the EEA. Whenever such third parties who process personal data on our behalf have access to your personal data, or we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring that safeguards are implemented. For example, where we use Mailchimp (who are based in the US) to send out marketing emails, or Rackspace to host our data or Microsoft One-Cloud to host certain accounting data, we transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.

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

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.

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 certain Contact, Identity, and Transaction Data) for seven years after they cease being customers, for tax purposes (although data relating to customer remittances is only kept for one year).

We keep personal data on our customer marketing list for 5 years after the last sale of a product to that customer (unless they have asked for it to be removed from that list earlier).

If a customer has asked us for a quote (but has not accepted that quote and bought a product from us), we will generally keep the personal data provided to us (if any) for no more than 3 months.

We keep personal data relating to our suppliers for longer, as it is in both our interests and theirs that they remain on our system and potentially available for work from us.

In some circumstances you can ask us to delete your data: see 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.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see the further information towards the bottom of this privacy policy.

If you wish to exercise any of the rights set out above, please contact our data privacy manager.

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.

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. 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.

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.