Safeguarding the Personal Information (defined below) of our customers, visitors, and users ("Users", "you", or "your") is important to us and we recognise the responsibility you entrust us with when providing your Personal Information.
Extra does not sell, trade, or rent users personal identification information to others. We may share generic aggregated demographic information not linked to any personal identification information regarding visitors to our Website(s) and users with our business partners or trusted affiliates.
Generally speaking, Extra receives information because:
- We require it for our Legitimate Interests in order to provide Services and/or Goods to you;
- You have provided it to us;
- We collect it from you; and/or
- Third parties we engage (such as data analytics providers) collect it from you on our behalf. So where we describe below (Information You Provide to Us) the ways in which we collect information from you, you acknowledge that such collection may also be carried out by third parties. These third parties may have their own privacy policies that they also adhere to.
When purchasing goods, using our Services or entering into contract or agreement with Extra, you consent to the terms of our Data Policy.
If you have any questions or comments regarding privacy issues in regard to our Website(s) and/or Services, please contact us by e-mail at email@example.com.
TYPES OF INFORMATION WE MAY COLLECT
We collect both Personal Information and non-personal information, such as Anonymous Information, about our Customers and Users. "Personal Information" is information that can be used to contact or identify you, such as your full name, email address and/or phone number as well as information that is linked to such Personal Information. "Anonymous Information" is information that is not linked to your Personal Information, cannot be used to contact or identify you and is not linked to information that can be used to do so. Anonymous Information includes passively collected information about your activities on our Website(s) or on the Services or using our Software, such as usage data.
We process the data you provide to us on the basis of the General Data Protection Regulation (GDPR) as a rule under article 6 (Lawfulness of processing), 6-1a (Consent), 6-1b (Contractual Relationships), 6-1c (Legal Requirements) and 6-1f (Legitimate Interest).
"Legitimate Interests" provides a lawful basis for processing where: "processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child." As Extra requires name, address, and/or payment information, to perform our Legitimate Interests, we are not required to obtain consent to process this information.
INFORMATION YOU PROVIDE TO US
In order to use certain Services, you may be required to create an account ("Company Account"), which will require you to provide Personal Information, such as your name and email address.
Extra also receives information from Customers containing personal information. In this circumstance the Customer is required to obtain consent for the information provided to Extra. Please note that this Personal Information is useable under Article 6-1f "Legitimate Interests" section of GDPR.
We may also offer the option of creating a Company Account through connecting via a third party account (for example, with a social media site - a "Third Party Account"), in which case you will be required to approve the connection as well as the types of information (which may include Personal Information) that is made available to us and the types of activities that we may perform in connection with that Third Party Account. Even if you later disconnect your Company Account from the Third Party Account, we still keep a copy of the Personal Information that we received from the connection of the two accounts.
In either case, we may send you an email or other electronic message confirming your Company Account creation (or otherwise instructing you how to confirm it).
By contacting Extra using any form of communication such as but not limited to Telephone, Email, Text, Online Communication, Fax, Post, you voluntarily give your consent to Extra to store, transfer, and process any information that you provide.
If you make a purchase either via our online Services or directly with us, you will be required to provide certain billing data to process and fulfil the purchase. We may use the products and services of trusted third party service providers to process and fulfil such purchases, in which case you will be providing the information to such third party services providers as well.
Our Websites may contain blog forums displaying information about us and some of our products and services. The Site may also offer you the opportunity to subscribe to newsletters and participate in surveys and other promotional activities. Your interaction (such as responding on any blog forum, subscribing to a newsletter, or participating in a survey) may require you to provide certain Personal Information such as your name and email address, together with any additional Personal Information you choose to enter on the blog forum. You should read the separate terms and conditions that govern these activities, if any.
When you participate in one or more activities through our Website(s) and Services or directed at our official handles on various social media platforms, we may collect additional information provided by you for such participation. You should read the separate terms and conditions that govern those social media platforms.
INFORMATION WE COLLECT FROM YOU
We collect information through server log files, but also by deploying tracking technologies within our Website(s) and Services and we may also associate this information with your Company Account. We do this to analyse trends, track user movement around the Website(s) and Services, gather demographic information, and to generally collect information that we may find insightful or allow us to improve the services we offer.
The type of information collected may include (but is not limited to) internet protocol (IP) addresses, MAC address, mobile network information including phone number, device type and hardware model, browser type, operating system type, type of browser, Internet Service Provider (ISP), date/time stamp of Site or Service use, referring/exit pages, and clicked pages.
For example, the Website(s) may use Google Analytics, more information on which you can find here: https://www.google.com/intl/en/policies/privacy/partners/
The legal grounds for processing the cookie information consists of the execution of the agreement as well as of our rightful interest towards the safe and user-friendly presentation of our Website(s).
Extra will store your information for as long as it is necessary to provide our services, deal with your queries, and as required to conform to the minimum data retention requirements as dictated by law or regulatory bodies, or for as long as you might legally bring claims against us. We adopt appropriate data collection, storage, processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of your personal information, username, password, transaction information and data stored on secure servers provided by our trusted affiliates.
We take what we consider to be appropriate measures to protect Personal Information. Data is stored on secure servers with appropriate security measures taken to aid in the protection of the data. All data files are treated as confidential and employees who may see any data are bound and subject to confidentiality agreements. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we try to use reasonably acceptable means to protect your Personal Information, we cannot guarantee its absolute security or confidentiality. If you have any questions about security you can contact us at firstname.lastname@example.org
TRANSFER TO AFFILIATES
Extra uses trusted third-parties and affiliates to render some services, including but not limited to mailing and fulfilment, email marketing and cloud storage. We provide name and address information to delivery service providers to deliver goods as well as trusted accredited payment processing providers for the processing of electronic payments.
We may also release your information when we believe release is appropriate to comply with the law or to protect our rights, property or safety. It is our policy to notify customers of requests for their data from law enforcement unless we are prohibited from doing so by statute or court order. Law enforcement officials who believe that notification would jeopardise an investigation should obtain an appropriate court order or other process that specifically prevents Customer notification.
YOUR RIGHT TO ACCESS DATA
We would like to maintain accurate Personal Information, and we endeavour to comply with all rights you might have under data protection laws. If you would like to delete, access or correct any of your Personal Information that we may be storing, there may be tools that we make available via our Website(s) or Services. Otherwise, please contact us at email@example.com to make your request. A formal request for the data must be submitted in writing using our "Data Access Request" form and furnished to our Data Controller. We will comply with the request in accordance with the law and endeavour to furnish the information within one month. Should we decide than an extension is required you will be informed. No charge will be made for complying with a request unless the request is manifestly unfounded, excessive or repetitive, or unless a request is made for duplicate copies to be provided to parties other than the person making the request. In these circumstances, a reasonable charge will be applied.
You may choose not to receive future promotional, advertising or other Services-related emails from us by selecting an unsubscribe link at the bottom of each email that we send or by modifying your selections on our Website(s) using the tools we may provide. Please note that even if you opt out of receiving the foregoing emails, we may still respond to communications initiated by you, as well as send administrative emails that are necessary to facilitate your use of our Website(s) and/or Services (for example, emails confirming updates to our policies).
Extra (UK) Ltd
Park Farm Industrial Estate
Tel: 01933 672170
This document was last updated on June 13, 2018