1. Introduction

1.1  We are committed to safeguarding the privacy of our website visitors and customers; in this policy we explain how we will handle your personal data.

1.2  This policy applies where we are acting as a data controller with respect to your personal data; in other words, where we determine the purposes and means of the processing of that personal data.

2. The personal data that we collect

2.1  In this Section 2 we have set out the general categories of personal data that we process and, in the case of personal data that we did not obtain directly from you, information about the source and specific categories of that data.

2.2  We may process data enabling us to get in touch with you (“contact data“). The contact data may include your name, email address, telephone number, postal address and/or social media account identifiers. The source of the contact data is you. If you log into our website using a social media account, we will obtain elements of the contact data from the relevant social media account provider.

2.3  We may process your website user account data (“account data“). The account data may include your account identifier, name, email address, account creation and modification dates, website settings and marketing preferences. The primary source of the account data is you, although some elements of the account data may be generated by our website. If you log into our website using a social media account, we will obtain elements of the account data from the relevant social media account provider.

2.4  We may process information relating to our customer relationships (“customer relationship data“). The customer relationship data may include your name, your contact details, your classification / categorisation within our customer relationship management system and information contained in or relating to communications between us and you. The source of the customer relationship data is you.

2.5  We may process information relating to transactions, including purchases of goods, that you enter into with us or through our website (“transaction data“). The transaction data may include your name, your contact details, your payment card details (or other payment details) and the transaction details. The source of the transaction data is you and our payment services provider.

2.6  We may process information contained in or relating to any communication that you send to us or that we send to you (“communication data“). The communication data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms.

2.7  We may process data about your use of our website and services (“usage data“). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system Google Analytics.

3. Purposes of processing and legal bases

3.1  In this Section 3, we have set out the purposes for which we may process personal data and the legal bases of the processing.

3.2  Operations – We may process your personal data for the purposes of operating our website, the processing and fulfilment of orders, providing our services, supplying our goods, generating invoices, bills and other payment-related documentation, and credit control. The legal basis for this processing is our legitimate interests, namely the proper administration of our website, services and business and the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

3.3  Publications – We may process profile data and/or service data for the purposes of publishing such data on our website and elsewhere through our services in accordance with your express instructions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

3.4  Relationships and communications – We may process contact data, account data, customer relationship data, transaction data and/or communication data for the purposes of managing our relationships, communicating with you (excluding communicating for the purposes of direct marketing) by email, SMS, post, fax and/or telephone, providing support services and complaint handling. The legal basis for this processing is our legitimate interests, namely communications with our website visitors, service users, individual customers and customer personnel, the maintenance of our relationships, enabling the use of our services, and the proper administration of our website, services and business.

3.5  Personalisation – We may process account data and/or usage data for the purposes of personalising the content and advertisements that you see on our website and through our services to ensure that you only see material that is relevant to you. The legal basis for this processing is consent.

3.6  Direct marketing – We consider “marketing” to mean context-specific information and communications that we might send to you in a format such as a newsletter or other emails for which we use our own in-house marketing platform operated by us, to send you such information on our behalf. We may process your contact data, account data and/or transaction data for the purposes of creating and sending direct “marketing” communications by email for “marketing”-related purposes. The legal basis for this processing is our legitimate interests, namely promoting us and communicating “marketing” messages to our website visitors and service users.

3.7  Research and analysis – We may process usage data and/or transaction data for the purposes of researching and analysing the use of our website and services, as well as researching and analysing other interactions with our business. The legal basis for this processing is our legitimate interests, namely monitoring, supporting, improving and securing our website, services and business generally.

3.8  Record keeping – We may process your personal data for the purposes of creating and maintaining our databases, back-up copies of our databases and our business records generally. The legal basis for this processing is our legitimate interests, namely ensuring that we have access to all the information we need to properly and efficiently run our business in accordance with this policy.

3.9  Security – We may process your personal data for the purposes of security and the prevention of fraud and other criminal activity. The legal basis of this processing is our legitimate interests, namely the protection of our website, services and business, and the protection of others.

3.10  Legal compliance and vital interests – We may also process your personal data where such processing is necessary for compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person.

4. Providing your personal data to others

4.1  Your personal data is held in our website database.

4.2  Financial transactions relating to our website and services may be handled by our payment services providers, such as for the purposes of transacting orders. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds.

4.3  In addition to the specific disclosures of personal data set out in this Section 5, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

5. International transfers of your personal data

5.1  In this Section 5, we provide information about the circumstances in which your personal data may be transferred to countries outside the United Kingdom and the European Economic Area (EEA).

5.2  The hosting facilities for our website are situated in the United Kingdom

5.3  You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

6. Retaining and deleting personal data

6.1  This Section 6 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

6.2  Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

6.3  We will retain your personal data as follows:

(a)  contact data will be retained for as long as you remain subscribed to receive our “marketing” communications and any other subscription services that we may provide;

(b)  account data will be retained for as long as you remain subscribed to an account through which we may provide services to you;

(c)  transaction data will be retained for as long as we are required to for taxation, audit, and legal reporting purposes;

(d)  communication data will normally be via email, including as sent using our Contact Us form on our website, and will be retained for a minimum period of 1 month following the date of the communication in question, and for a maximum period following that date of 3 years, unless the nature of the communication is exceptional and thus will be retained for a period that reflects the nature of the communication;

(f)  usage data will be retained for 2 years following the date of collection; and

6.4  Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

7. Security of personal data

7.1  We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.

7.2  We will store your personal data on secure servers, personal computers and mobile devices, and in secure manual record-keeping systems.

7.3  The following personal data will be stored by us in encrypted form: your name, contact information, password(s) and cardholder data.

7.4  Data relating to your enquiries and financial transactions that is sent from your web browser to our web server, or from our web server to your web browser, will be protected using encryption technology.

7.5  You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.

7.6  You should ensure that your password is not susceptible to being guessed, whether by a person or a computer program. You are responsible for keeping the password you use for accessing our website confidential and we will not ask you for your password (except when you log in to our website).

8. Your rights

8.1  In this Section 8, we have listed the rights that you have under data protection law.

8.2  Your principal rights under data protection law are:

(a)  the right to access – you can ask for copies of your personal data;

(b)  the right to rectification – you can ask us to rectify inaccurate personal data and to complete incomplete personal data;

(c)  the right to erasure – you can ask us to erase your personal data;

(d)  the right to restrict processing – you can ask us to restrict the processing of your personal data;

(e)  the right to object to processing – you can object to the processing of your personal data;

(f)  the right to data portability – you can ask that we transfer your personal data to another organisation or to you;

(g)  the right to complain to a supervisory authority – you can complain about our processing of your personal data; and

(h)  the right to withdraw consent – to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.

8.3  These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by visiting [https://edpb.europa.eu/our-work-tools/general-guidance/gdpr-guidelines-recommendations-best-practices_en and https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/].

8.4  You may exercise any of your rights in relation to your personal data [by written notice to us, using the contact details set out below.

9. Personal data of children

9.1  Our website and services are targeted at persons over the age of 18.

9.2  If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.

10. Updating information

10.1  Please let us know if the personal information that we hold about you needs to be corrected or updated.

11. Amendments

11.1  We may update this policy from time to time by publishing a new version on our website.

11.2  You should check this page occasionally to ensure you are happy with any changes to this policy.

11.3  We may notify you of significant changes to this policy.

12. Our details

12.1  This website is owned and operated by G Davison and Sons.

12.2  Our principal place of business is at 57 Broadway West, Leigh-on-Sea, Essex, SS9 2BX

12.3  You can contact us:

(a)  by post, to the postal address given above;

(b)  using our website contact form;

(c)  by telephone, on 01702 472227; or

(d)  by email, using contact@davisonjewellers.com