Privacy Policy

PLEASE SEE BELOW THE PRIVACY NOTICES FOR RECKITT BENCKISER AND TROJAN ELECTRONICS 2018 LTD

 

RECKITT BENCKISER - GLOBAL PRIVACY NOTICE

Welcome to Reckitt Benckiser's Global Privacy Notice ("Privacy Notice").

We are committed to protecting your privacy. This Privacy Notice applies to all of our brands globally and explains how we collect, use, disclose and protect your Personal Information and respect any rights you benefit from under your local law.

In this Privacy Notice "we", "us" and "our" refers to all the companies of the Reckitt Benckiser group. As this Privacy Notice applies globally, there may be differences in how we collect, use or disclose your Personal Information from country to country, in which case we will inform you about any specific processing activities that take place in your country.

Your Personal Information is controlled by Reckitt Benckiser Group plc (having a registered office at 103-105 Bath Road, Slough, Berkshire, SL1 3UH, United Kingdom) or our Reckitt Benckiser company located in your country. As regards this website, RB UK Commercial Limited (having its registered office at 103-105 Bath Road, Slough, Berkshire, SL1 3UH, United Kingdom) is the data controller.

For more information about us, our local companies, our brands and our presence in your jurisdiction, please visit www.rb.com.

 

Definitions

By "Personal Information" (in some countries referred to as "personal data" or "personally identifiable information") we mean any information relating to an identified or identifiable individual. This is broader than just information of a personal or private nature, and also includes information such as your name, date of birth, and e-mail address. Please see Section 3 below for what Personal Information is obtained from you.

By “Sensitive Personal Information” (in some countries referred to as “sensitive personal information” or “special categories of data”) we mean any Personal Information relating to an individual’s racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data or biometric data processed for the purpose of uniquely identifying that individual, data concerning health, or data concerning an individual’s sex life or sexual orientation. It also includes information about an individual’s criminal offences or convictions, as well as any other information deemed sensitive under applicable data protection laws.

 

Quick Reference:

1. Scope of our Privacy Notice

2. Fair and lawful processing

3. How do we obtain your Personal Information

4. For which purposes may we use your Personal Information

5. To whom we may disclose your Personal Information

6. How we protect your Personal Information

7. Your choices regarding direct marketing

8. Your rights

9. Complaints

10. How long we retain your Personal Information

11. Children

12. Transfers to other countries

13. How to contact us

14. Changes to this Privacy Notice

 

1. Scope of our Privacy Notice

Our Privacy Notice applies to all Personal Information we collect, use, share or otherwise process through our business activities, both online and offline, which display, link or refer to this Privacy Notice, including:

  • our websites;
  • our official social media pages;
  • our e-mails;
  • our apps;
  • our online and offline campaigns; and
  • your conversations or correspondence with our representatives.

Throughout this document, we will refer to our online activities as "Sites" and to our offline activities as "Services".

You should be aware of the fact that our Sites may contain hyperlinks to third party websites, apps, etc. which are not controlled by us and which are not covered by this Privacy Notice. We have no responsibility or liability for the content and activities of these third party websites, apps, etc. As these third parties may collect your Personal Information, we suggest that you consult the privacy policies of these third parties to learn more about their use of your Personal Information.

Our websites make use of cookies. For more information on this subject, please also consult our Cookies Policy.

Further, when using our Sites or Services, please always also read our Terms of Use.

 

2. Fair and lawful processing

We process your Personal Information for the below listed purposes on the basis of your consent, unless stated otherwise. In some cases, where required by local law, we may ask for your explicit consent for processing your Personal Information for a specific purpose.

We only collect, use, disclose or otherwise process your Personal Information where it is fair and lawful to do so.

In many cases providing your Personal Information to us is necessary for the performance of your contract with us; if you do not wish to provide your Personal Information to us, we may not be able to provide you with the products and services you have requested from us.

 

3. How do we obtain your Personal Information?

Personal Information obtained from you directly

Firstly, we may obtain your Personal Information from you directly, e.g. when you sign up for our newsletters, register on our Sites, buy a product from us, fill out a survey, make a comment or enquiry, post something on our social media pages, subscribe to direct marketing etc.

Personal Information collected this way may include:

  • name;
  • address;
  • e-mail address;
  • username;
  • telephone number (and recordings when you call our consumer line);
  • credit card or other payment information;
  • age;
  • date of birth;
  • gender;
  • product purchase and usage information;
  • household information;
  • information, feedback or content you provide regarding your marketing preferences;
  • user-generated content, posts and other content you submit to our Sites;
  • in limited circumstances, information about your family or other individuals that you have provided to us. In such cases, we assume that you have the authority to share any personal information your provide to us about them;
  • in limited circumstances based on your explicit consent or for carrying out our legal obligations or if necessary for reasons of substantial public interest, Sensitive Personal Information such as information relating to your image, health (including information related to product usage and medical history), sexual life (and related behavior) and biometrics collected during volunteer consumer research studies (such as facial expression recognition, heart rate and skin condition);
  • demographic information; or
  • any other Personal Information you voluntarily provide us with directly.

Personal Information collected automatically

Secondly, some Personal Information may be collected automatically when you visit or use our Sites (and those of our third party service providers acting on our behalf), such as information collected by cookies and other technologies (such as web analytic tools and pixel tags) on our websites. Please also consult our Cookies Policy for more information on how we make use of cookies and other automated means of data collection.

Personal Information collected this way may include:

  • information about your (mobile) device or your type of browser;
  • information about the way you use our websites, such as details of the web pages you have viewed, the banners and the hyperlinks you have clicked, etc.;
  • whether you have opened e-mails sent by us to you;
  • the websites you have visited before arriving at one of our websites;
  • your IP address;
  • the hyperlinks you have clicked;
  • your username, profile picture, gender, networks and any other information you choose to share when using third party sites (such as when you use the “Like” functionality on Facebook or the +1 functionality on Google+);
  • your MAC address;
  • information you choose to share by using social media tools incorporated in our websites or using your social media log-in details to access certain RB product sites or applications; and
  • information you share with us about your location. Where we are required to do so by local law, we will only use that information where you have agreed that we can.

Personal Information obtained from other sources

Lastly, we may also collect Personal Information about you from other sources. These other sources may include:

  • our trusted business partners;
  • social media sites;
  • consumer research organisations;
  • credit reference agencies;
  • intermediaries that facilitate data portability; and
  • other members of our group.

Personal Information collected this way may include your interests such as hobbies and pets, consumer and market research data, purchase behavior, publicly observed data or activities such as blogs, videos, internet postings and user generated content.

 

4. For which purposes, may we use your Personal Information

We use your Personal Information for our following business purposes:

  • based on your contract with us, handling and managing your purchase, for instance to communicate to you with respect to your purchase, to process your payments, to deliver the purchased products and services, and to offer you the necessary customer service;
  • allowing you to participate in promotions, contests, surveys and polls;
  • allowing you to share information and ideas on our social media pages, forums, blogs and other communication channels, to participate in social sharing and to send messages to a friend through our Sites or the websites of our trusted business partners;
  • better understanding your needs in order to provide you with more relevant information, analyzing and evaluating our corporate activities, testing, developing and evaluating new products and improving our existing products and services, conducting market research and audits, identifying user trends and examining the degree of effectiveness of our marketing campaigns and degree of satisfaction of our customers;
  • telling you about our products and services, and sending you promotional materials (such as announcements relating to new products, promotions, savings programs, joint promotions and other programs) relating to our brands and those of our carefully selected trusted business partners, subject to your consent to such marketing where required by local law;
  • managing our Sites, and tune the experience and content of our Sites to your previous activities on our Sites, in view of personalizing your experience when visiting our Sites;
  • responding to your requests or enquiries;
  • dealing with any product adverse events you report to us;
  • administering general record keeping; and
  • meeting legal and regulatory requirements.

Your local law may require us to set out in this Privacy Notice the legal grounds on which we rely in order to process your Personal Information. In such cases, our use of your Personal Information is permitted by law because:

  • it is necessary for our legitimate interests in the effective delivery of information, services and products to you and in the effective and lawful operation of our business (in each case provided such interests are not overridden by your rights);
  • it is necessary for taking steps to enter into a contract with you for the products you purchase, or for carrying out our obligations under such a contract;
  • it is required to satisfy any legal or regulatory obligations that we are subject to; and
  • in limited circumstances and if required by local law, you have agreed to us processing your Personal Information, such as when you opt in to marketing, or processing with your explicit consent in the case of Sensitive Personal Information, such as health information.

We may create anonymous data records from Personal Information by excluding information (such as your name) that make the data personally identifiable to you. We use this anonymous data to analyse our products and services. We reserve the right to use such anonymous data for any purpose and disclose anonymous data to third parties, including but not limited to our research partners, in our sole discretion.

 

5. To whom we may disclose your Personal Information

Intra-group sharing

Your Personal Information may be shared between the different companies and brands of our group, for the purposes set out in this Privacy Notice. As we have stated above, this Privacy Notice applies to all these companies’ and brands’ use of your Personal Information. For more information about us, our companies, our brands and our presence in your jurisdiction, please visit www.rb.com.

Third party service providers

We may share your Personal Information with trusted third party service providers who work on our behalf, such as marketing agencies, market research companies, e-commerce fulfilment partners, software, data hosting and other IT service providers, merchants selling RB products, call centres, payment processors, etc. These third party service providers are required not to use your Personal Information other than to provide the services requested by us or otherwise in accordance with our instructions.

Other trusted third parties

We may also share your Personal Information with other trusted third parties, such as our business partners, advertisers (where we are permitted to do so) and data exchanges, so that we can offer you tailored content, including more relevant advertising for products and services which may be of interest to you. These third parties may set and access their own cookies, web beacons and similar tracking technologies on your device in order to deliver customized content and advertising to you when you visit RB websites.

Our websites and/or applications may also allow you to log in using a social network or other third-party account. An example of a third-party login is “Log in with Facebook”. Logging into one of our sites with your social network or other third-party account may allow us to gather information that you give us permission to access from that social network or third party. The login feature may also transfer information to the social network or third party, such as your username and password, to authenticate you. The social network or third party may also automatically collect information such as your IP address, information about your browser and device, and the address of the web page you are visiting on our site. The login feature may also place and read cookies from that third party that may contain a unique identifier the social network or other third party assigns to you. The functionality of, and your use of, the login is governed by the privacy policy and terms of the party that provided the login functionality, rather than this Privacy Notice.

Acquisitions

If another company acquires (part of) our company, business, or our assets, that company may acquire all or part of the Personal Information collected by us and will assume the rights and obligations regarding your Personal Information as described in this Privacy Notice. In the unlikely event of an insolvency, bankruptcy or receivership, your Personal Information may also be transferred as a business asset, subject of applicable law.

Disclosures

We may disclose your Personal Information if we believe in good faith that such disclosure is necessary for our legitimate interest or prudent in light of our obligations under applicable law:

  • in connection with any legal investigation;
  • to comply with relevant laws or to respond to court our authority orders, subpoenas or warrants served on us;
  • to protect or defend our rights in legal procedures; or
  • to investigate or assist in preventing any violation or potential violation of the law, this Privacy Notice, or any applicable Terms of Use.

 

6. How we protect your Personal Information

We value the trust you place in us.

We have implemented appropriate technical and organisational measures to protect your Personal Information against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access and against all other unlawful forms of processing.

When collecting or transferring Sensitive Personal Information we use a variety of additional security technologies and procedures to help protect your information.

The Personal Information you provide us with is stored on computer systems located in controlled facilities which can only be accessed by a limited number of persons who have a need to know in order to carry out their tasks and any services requested by you.

When we process highly confidential information (such as credit card numbers) over the Internet, we protect it through the use of encryption.

 

7. Your choices regarding direct marketing

We may periodically send you free newsletters, surveys, offers, and other promotional materials related to our products and services which we believe are useful for you, if you have consented (opted-in) to receive such messages via e-mail or any other electronic channel (where such opt-in is required under your local law).

If you do not wish to receive such communications any more, you will always have the opportunity to "opt out" by following the unsubscribe instructions provided in each of our direct marketing e-mails or by contacting us directly (please see our contact information at “how to contact us” below).

Where permitted under applicable law, we may send you service messages identifying any updates to our Privacy Notice (even where you have opted out of receiving marketing messages from us).

 

8. Your rights

Depending on your location, you may have various rights in relation to your Personal Information. In particular, you may have the right to:

  • request a copy of Personal Information we hold about you;
  • ask that we restrict the way in which we use your Personal Information;
  • ask that we update the Personal Information we hold about you, or correct any Personal Information that you think is incorrect or incomplete;
  • ask that we delete personal data that we hold about you (the “right to be forgotten”);
  • withdraw consent at any time for the future to our processing of your Personal Information (to the extent such processing is based on consent);
  • object to our processing of your Personal Information (including for direct marketing purposes); or
  • request your personal data be transferred to you or another data controller (the “data portability” right).

In addition, in certain circumstances we may process your personal data through automated decision-making, including profiling. This may include segmenting and tailoring the data to enable us to match our communication and products to your perceived needs. In the case we process your Personal Information through automated decision-making, we will inform you about the logic involved, as well as the significance and the envisaged consequences of such processing for you. Depending on your location, you may be able to request not to be subject to automated decision-making, including profiling.

If you would like to exercise these rights or understand if they apply to you, please click here to complete and submit an online request form. Alternatively, you can get in touch using the details set out at “how to contact us” below.

 

9. Complaints

If you are unhappy with the way we have handled your Personal Information or any privacy query or request that you have raised with us, you have a right to complain to your local data protection regulator.

 

10. How long we retain your Personal Information

We will only retain your Personal Information as long as reasonably required for the purposes as set out in this Privacy Notice or otherwise to comply with legal or regulatory requirements applicable to us.

When your Personal Information is processed:

§ for the performance of your contract with us, we retain your Personal Information for a period of 7 years following completion of a contractual order;

§ for meeting, legal and regulatory requirements, we retain your Personal Information as it is set out by the applicable law; and

§ In all other cases, we process your Personal Information, depending on the type, for up to 2 years from the date of our last interaction with you.

 

11. Children

Most of our Sites are not directed towards children and we request that children below the age of 16 do not provide Personal Information through our Sites.

If you are the parent or legal guardian of a child under 16 who has registered on one of our Sites, or who you believe has otherwise provided Personal Information to us, please contact us using the details set out at “how to contact us” below to have the information deleted. Information voluntarily provided by children via e-mails, message boards, chat sessions etc. may be used by other parties to generate unsolicited e-mails. We encourage parents and legal guardians to inform children about how to use the Internet in a safe and responsible manner.

Depending on your location and where permitted by local law, we may collect information on your children in order to provide you with relevant information about our products and services.

 

12. Transfers to other countries

Your Personal Information may be transferred to and processed in other countries where laws governing the processing of Personal Information may be less stringent than the laws in your country (including jurisdictions outside the European Economic Area).

In such cases, where required by local law we will ensure that there are adequate safeguards in place to protect your Personal Information. Depending on the location of the RB entity exporting the relevant Personal Information, this adequate safeguard might be a data transfer agreement with the recipient based on standard contractual clauses approved by the European Commission. Where we are legally required to do so, further details of these transfers and copies of these agreements are available from us on request.

To the extent required and valid under your local law, you consent to your Personal Information being transferred and processed this way.

 

13. How to contact us

We welcome your feedback. If you have any comments, questions or complaints regarding this Privacy Notice or our processing of your Personal Information, or would like to exercise any of the rights set out at “your rights” above that are applicable in your location, you can contact us by sending an e-mail to PrivacyOffice@rb.com.

You may also write to us at:

RB Global Privacy Office
Turner House
103-105 Bath Road
Slough,
United Kingdom
SL1 3UH

 

14. Changes to this Privacy Notice

This Privacy Notice was updated on 21 May 2018. This document is a notice to you and not a contract between us. We may occasionally modify or amend it from time to time. When we make changes to this Privacy Notice, we will update the revision date at the top of this Privacy Notice. Where those changes are material, we will take steps to let you know. The new modified or amended Privacy Notice will apply from that revision date. Please always verify whether you have consulted the latest version of the Privacy Notice.

 

Trojan Electronics 2018 Ltd Privacy Statement

1. GENERAL

    Trojan Electronics 2018 Ltd, trading as Trojan Electronics 2018 Ltd, whose registered office is Trident Business Park, Leeds Road, Huddersfield, HD2 1UA, or other trading name (“we” “us” “our”) are committed to protecting and respecting your privacy. For the purposes of data protection legislation, we are the data controller and we will process your personal data in accordance with the General Data Protection Regulation (EU) 2016/679 and national laws which relate to the processing of personal data. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

     

    2. VISITORS TO OUR WEBSITE

    2.1 We may collect and process personal data about you in the following circumstances:
    2.1.1 when you complete forms on our website (“Site”). This includes your name contact details, credit/debit card details, which is provided at the time of registering to use our Site, where you ask us to contact you about our goods or services, subscribe to our mailing list, or subscribe/request or goods or services;
    2.1.2 whenever you provide information to us when reporting a problem with our Site, making a complaint, making an enquiry or contacting us for any other reason. If you contact us, we may keep a record of that correspondence;
    2.1.3 details of your visits to our Site including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise, and the resources that you access (see section 2.2.2 on Cookies below); and
    2.1.4 whenever you disclose your information to us, or we collect information from you in any other way, through our Site.

    2.2 We may also collect data in the following ways:
    IP Address
    2.2.1 We may collect information about your device, including where available your Internet Protocol address, for reasons of fraud protection. We may also collect information about your device’s operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users' browsing actions and patterns, and does not identify any individual.
    Cookies
    2.2.2 Our Site uses cookies to distinguish you from other users of our Site. This helps us to provide you with a good experience when you browse our Site and also allows us to improve our Site. For detailed information on the cookies we use and the purposes for which we use them see our Cookie Policy.

    2.3 We may use your personal data for our legitimate interests in order to:
    2.3.1 provide you with information, or services that you requested from us;
    2.3.2 allow you to participate in interactive features of our Site, when you choose to do so;
    2.3.3 ensure that content from our Site is presented in the most effective manner for you and for your device;
    2.3.4 improve our Site and services;
    2.3.5 process and deal with any complaints or enquiries made by you; and
    2.3.6 contact you for marketing purposes where you have signed up for these (see section 6 for further details).

    Website Links

    Our Site may, from time to time, contain links to and from the websites of third parties. Please note that if you follow a link to any of these websites, such websites will apply different terms to the collection and privacy of your personal data and we do not accept any responsibility or liability for these policies. When you leave our Site, we encourage you to read the privacy notice/policy of every website you visit.

     

    3. CUSTOMERS

    3.1 We will collect details such as name, address, contact details, delivery address, bank/credit/debit card details when you order goods or services from us either via our Site, over the telephone or in store. We will use this information to process your order and comply with our contractual obligations.
    3.2 In order to perform our contract with you, we may also need to share personal data with third parties such as, credit reference agencies, payment providers and postal service/logistics organisations to assist in the delivery of goods or services you have ordered.
    3.2a If you are applying for credit we may use credit reference agencies to assess your credit worthiness before offering you any credit options. The two credit agencies we may use are Transunion and Experian. You can view Transunion's Privacy Policy here and you can view Experian's Privacy Policy here. You can view TransUnion's Credit Reference Agency Information Notice here.
    3.3 We may also advertise your feedback on our website and marketing materials (subject to obtaining your prior consent where necessary);
    3.4 We will retain your information as long as we require this to provide you with the goods or services ordered from us and for a period of 15 years afterwards. Where you have subscribed to receive marketing correspondence from us we will keep your personal data for the period of time described in section 6 below.

     

    4. SUPPLIERS

    We will collect details such as your name, contact details and bank details in order to contact you about goods or services ordered with you, to place further orders, and to pay you for the goods and/or services supplied. We will keep the personal data for 7 years further to being provided with the goods/services.

     

    5. 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 the 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 our 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.

     

    6. MARKETING

    6.1 In addition to the uses described in sections 2-4 above, where you indicate you would like to receive marketing correspondence from us, subscribe to our mailing lists or newsletters, enter into any of our competitions or provide us with your details at networking events we may use your personal data for our legitimate interests in order to provide you with details about our goods, services, business updates and events which we think may be of interest.

    6.2 You have the right to opt-out of receiving the information detailed in section 6.1 at any time. To opt-out of receiving such information you can:
    6.2.1 tick the relevant box situated in the form on which we collect your information;
    6.2.2 click the unsubscribe button contained in any such communication received; or
    6.2.3 email us at dpo@trojanemail.co.uk

    6.3 Where you have subscribed to receive marketing correspondence from us we will keep personal data 5 years from when you are provided with the opportunity to opt-out of receiving marketing correspondence from us or you last placed an order, whichever is later.

     

    7. MONITORING AND RECORDING

    We may monitor and record communications with you (such as telephone communications and emails) for the purpose of quality assurance, training, fraud prevention and compliance. We also have CCTV cameras installed in our premises for the purpose of crime prevention and for health and safety reasons. We retain CCTV images for up to 60 days and telephone recordings for up to 7 years.

     

    8. AUTOMATED PROCESSING

    8.1 Some of our decisions are made automatically by inputting your personal information into a system or computer and the decision is calculated using certain automatic processes rather than our employees making those decisions. We make automated decisions to check for orders which may be fraudulent.

    8.2 We may carry out a credit check on our customers:
    8.2.1 so that we can make credit decisions about you; and
    8.2.2 to prevent fraud and money laundering.

    8.3 Our search may be recorded on the files of the credit reference agency.

    If further to undertaking a credit check you receive a low credit score, we reserve the right not to supply you with goods or services on credit and/or require upfront payment for the goods or services you wish to purchase.

    If you provide false or inaccurate information and we suspect fraud, we will record this.

     

    9. LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA

    9.1 We will only use your personal data where the law allows us to. Most commonly, we will use your personal data in the following circumstances:
    9.1.1 for performance of a contract we enter into with you;
    9.1.2 where necessary for compliance with a legal or regulatory obligation we are subject to; and
    9.1.3 for our legitimate interests (as described within this policy) where your interests and fundamental rights do not override these interests.

     

    10. DISCLOSURE OF PERSONAL DATA to third parties

    10.1 In addition to the third parties mentioned above, we may disclose your information to third parties for our legitimate interests as follows:
    10.1.1 to staff members in order to facilitate the provision of goods or services to you;
    10.1.2 to our affiliated entities to support internal administration;
    10.1.3 IT software providers that host our website and store data on our behalf;
    10.1.4 professional advisers including consultants, lawyers, bankers and insurers who provide us with consultancy, banking, legal, insurance and accounting services;
    10.1.5 HM Revenue and Customs, regulators and other authorities who require reporting of processing activities in certain circumstances; and
    10.1.6 third parties who we may choose to sell, transfer or merge parts of our business or assets. Alternatively, we may seek to acquire other business 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.
    10.1.7 review aggregators, acting on our behalf, to invite you to review your product and/or purchase.

    10.2 We may disclose personal data to the police, regulatory bodies, legal advisors or similar third parties where we are under a legal duty to disclose or share personal data in order to comply with any legal obligation, or in order to enforce or apply our website terms and conditions and other agreements; or to protect our rights, property, or safety of our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

    10.3 We will not sell or distribute personal data to other organisations without your approval.

     

    11. CROSS-BORDER DATA TRANSFERS

    11.1 Where permitted by applicable law, we may transfer your personal data to the United States and other jurisdictions outside the European Economic Area (‘EEA’) for the purposes set out in this privacy policy. We have implemented binding corporate rules/standard contractual clauses approved by the European Commission/the EU-US Privacy Shield/Swiss-US Privacy Shield/consent to secure the transfer of your personal data to jurisdictions outside the EEA.

     

    12. DATA SECURITY

    12.1 Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

    12.2 Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your information transmitted to our Site; any transmission is at your own risk.

    12.3 Information you provide to us is shared on our secure servers. We have implemented appropriate physical, technical and organisational measures designed to secure your information against accidental loss and unauthorised access, use, alteration or disclosure. In addition, we limit access to personal data to those employees, agents, contractors and other third parties that have a legitimate business need for such access.

     

    13. ACCESS TO, UPDATING, DELETING AND RESTRICTING USE OF PERSONAL DATA

    13.1 It is important that the personal data we hold about you is accurate and current. Please keep us informed if the personal data we hold about you changes.

    13.2 Data protection legislation gives you the right to object to the processing of your personal data in certain circumstances or withdraw your consent to the processing of your personal data where this has been provided. You also have the right to access information held about you and for this to be provided in an intelligible form. If you would like a copy of some or all of your personal information, please send an email to dpo@trojanemail.co.uk. In certain circumstances we reserve the right to charge a reasonable fee to comply with your request.

    13.3 You can also ask us to undertake the following:
    13.3.1 update or amend your personal data if you feel this is inaccurate;
    13.3.2 remove your personal data from our database entirely;
    13.3.3 send you copies of your personal data in a commonly used format and transfer your information to another entity; or
    13.3.4 restrict the use of your personal data.

    13.4 We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the personal data that we hold about you or make your requested changes. Data protection legislation may allow or require us to refuse to provide you with access to some or all the personal data that we hold about you or to comply with any requests made in accordance with your rights referred to above. If we cannot provide you with access to your personal data, or process any other request we receive, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

    13.5 Please send any requests relating to the above to our Data Lead at dpo@trojanemail.co.uk specifying your name and the action you would like us to undertake.

     

    14. RIGHT TO WITHDRAW CONSENT

    Where you have provided your consent to the collection, processing and transfer of your personal data, you have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, please contact us at dpo@trojanemail.co.uk .

     

    15. CHANGES TO OUR PRIVACY POLICY

    We reserve the right to update this privacy policy at any time, and any changes we make to our privacy policy will be posted on this page. Please check periodically for any updates. If we would like to use your previously collected personal data for different purposes than those we notified you about at the time of collection, we will provide you with notice and, where required by law, seek your consent, before using your personal data for a new or unrelated purpose. We may process your personal data without your knowledge or consent where required by applicable law or regulation.

     

    16. CONTACT US

    We have appointed a Data Lead to oversee compliance with this privacy policy. If you have any questions, comments or requests regarding this policy or how we use your personal data please contact our Data Lead at dpo@trojanemail.co.uk . This is in addition to your right to contact the Information Commissioners Office if you are unsatisfied with our response to any issues you raise at https://ico.org.uk/global/contact-us/