Freedom Stairlifts.

Freedom Stairlifts is a company registered in England & Wales (company number: 5438130) whose registered office is at 24 Cornwall Road, Dorchester, Dorset, DT1 1RX.

This website is operated and controlled by Freedom Stairlifts, who is the data controller and responsible for your personal data (referred to as ‘Freedom Stairlifts’, “we”, “us” or “our” in this privacy notice).

We have appointed a data protection contact 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 protection contact as follows:

Contact details: Data Protection Officer

Email address: privacy@freedomstairlifts.co.uk

Postal address: Freedom Stairlifts, 24 Cornwall Road, Dorchester, Dorset, DT1 1RX.

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 opportunity to help you rectify any of your concerns before you approach the ICO so please contact us in the first instance.

Business or personal data, or business or personal information, means any information about a business or an individual from which that business or 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 business or personal data about you which we have grouped together as follows:

• Identity Data including full business name or your full name, title.
• Contact Data including billing address, delivery address, email address and telephone numbers.
• Financial Data including bank account and payment card details.
• Transactional Data including details about payments made to and from the business or you and other details of products or services you have purchased from us.
• Technical Data including internet protocol (IP) address, your login data, browser type and version, time zone, setting and location, browser plug-in types and versions, operating system, platform and other technology devices you use to access this website.
• Profile Data including your username and password, purchases or orders made by the business or you, your preferences, feedback and survey responses.
• Usage Data will include information about how you use our website, products and services.
• Marketing and Communications Data including your preferences in receiving marketing from us and our third parties, and your communication preferences.

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. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. 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 (including 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.

If you fail to provide business or personal data

Where we need to collect business or personal data by law, or under the terms of a contract we have with you and you fail to provide that 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 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.

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity, Contact and (Financial Data, were applicable) by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes business or personal data you provide when you:

• Complete an online form for our products or services;
• create an account on our website,
• subscribe to our service or publications,
• request marketing to be sent to you,
• enter a competition, promotion or survey,
• or give us some feedback.

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, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our Cookie Policy for further details.

Third parties or publicly available sources. We may receive personal Technical Data about you from various third parties and public sources as set out below:

• analytics providers such as Google based outside the EU,
• advertising networks such as Google AdWords based inside the EU,
• and search information providers such as Google based inside or outside the EU.

We will only use your business or personal data when the law allows us to. Most commonly, we will use your business or 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 to contact you 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.

Consent must be given to us by you before an online form is submitted on our website/s that permits us to process your business or personal data including sending third party direct marketing communications to you via email, post phone or text message. Your details maybe shared with a third party if we believe that you might benefit from these third party products or services. You have the right to withdraw consent to marketing at any time by contacting us to update your communication preferences with us.

Marketing

Promotional offers from us

We may use your Identity, Contact, Technical, Usage 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, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if:

• You have requested information from us and consented to marketing communication by signing up for our newsletters,
• You have purchased goods or services from us and you have not opted out of receiving that marketing, or
• you have opted in to receive marketing email communication following an email from us, where you signed up as a customer but had not previously purchased goods or services.

Please note only the first and third options rely on your consent. Where the second option applies we will be marketing to you on the legal basis of our Legitimate Interests.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by visiting the appropriate website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you by us or by third parties or by contacting us.

Were you opt out of receiving these marketing messages, this will not apply to business or personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.

Cookies

You can set your 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 this website may become inaccessible or not function properly. For more information about the cookies we use, please click here

Change of purpose

We will only use your business or 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 business or 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 business or personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

We may have to share your business or personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

• Internal Third Parties as set out in the Glossary.
• External Third Parties as set out in the Glossary.
• 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.

Please note that in respect of any payments processors, the payment processor is a separate and independent controller of your data and you are advised to review their privacy notice.

Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries. More information
• Where we use certain service providers, within the European Commission: Model contracts for the transfer of personal data to third countries. More information
• Where we use providers based in the US, we may 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. For further details, see European Commission: EU-US Privacy Shield. More information

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

We have put in place appropriate security measures to prevent your business or personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your business or personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your business or 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 business or personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

How long will you use my business or personal data for?

We will only retain your business or 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 business or personal data, we consider the amount, nature, and sensitivity of the business or personal data, the potential risk of harm from unauthorised use or disclosure of your business or personal data, the purposes for which we process your business or 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 Contact, Identity, Financial and Transaction Data) for seven years after they cease being customers for tax and legal purposes. We audit our data on a regular basis to ascertain any data which has reached the retention period and delete such data insofar as technically possible.

In some circumstances you can ask us to delete your data: see Request erasure below for further information. However, 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.

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

• Request access to your personal data
• Request correction of your personal data
• Request erasure of your personal data
• Object to processing of your personal data
• Request restriction of processing your personal data
• Request transfer of your personal data
• Right to withdraw consent

If you wish to exercise any of the rights set out above, please email privacy@freedomstairlifts.co.uk

No fee usually required

There is no fee to pay in order to access your business or 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.

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 business or personal data (or to exercise any of your other rights). This is a security measure to ensure that business or 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 thirty one days. Occasionally it may take us longer than this period 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.

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/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your business or personal data for our legitimate interests. We do not use your business or 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).

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 business or personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

THIRD PARTIES

Internal Third Parties

Other companies in our extended group and based in the UK, Europe or North America provide us with alternative solutions, finance services and healthly lifestyle improvements acting as joint controllers or processors.

External Third Parties

• Service providers acting as processors based within the UK, Europe or North America who provide IT, logistics, payment providers, marketing, advertising and system administration services.
• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based within the UK, Europe or North America who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

YOUR LEGAL RIGHTS

You have the right to:

Request access to your business or personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the business or personal data we hold about you and to check that we are lawfully processing it.

Request correction of the business or 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 business or personal data. This enables you to ask us to delete or remove business or 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 business or 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 business or 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 business or 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 business or 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 business or personal data. This enables you to ask us to suspend the processing of your business or 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 business or personal data to you or to a third party. We will provide to you, or a third party you have chosen, your business or 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 business or 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.