Privacy Policy

1.  INTRODUCTION  

This privacy notice provides you withdetails of how we collect and process your personal data through your use ofour site /including any information you may provide through our site when you purchase aproduct or service, sign up to our newsletter or take part in a prize draw orcompetition.

By providing us with your data, youwarrant to us that you are over 13 years of age.

XEN-TAN is the data controller and we are responsible for your personal data (referredto as “we”, “us” or “our” in this privacy notice).

If you are not happy with any aspect ofhow we collect and use your data, you have the right to complain to the InformationCommissioner’s Office (ICO), the UK supervisory authority for data protectionissues (www.ico.org.uk). We should begrateful if you would contact us first if you do have a complaint so that wecan try to resolve it for you.

It is very important that theinformation we hold about you is accurate and up to date. Please let us know ifat any time your personal information changes by emailing us at customercare@xen-tan.co.uk.

2.  WHAT DATA DO WE COLLECT ABOUT YOU

 Personal data means anyinformation capable of identifying an individual. It does not includeanonymised data.

 We may process certain types ofpersonal data about you as follows:

•                    Identity Data may include your first name, maidenname, last name, username, marital status, title, date of birth and gender.

•                    Contact Data may include your billing address,delivery address, email address and telephone numbers.

•                    Financial Data may include your bank account andpayment card details.

•                    Transaction Data may include details about paymentsbetween us and other details of purchases made by you.

•                    Technical Data may include your login data, internetprotocol addresses, browser type and version, browser plug-in types andversions, time zone setting and location, operating system and platform andother technology on the devices you use to access this site.

•                    Profile Data may include yourusername and password, purchases or orders, your interests, preferences,feedback and survey responses.

•                    Usage Data may includeinformation about how you use our website, products and services.

•                    Marketing and Communications Data may include your preferences in receiving marketing communicationsfrom us and our third parties and your communication preferences.

We may alsoprocess Aggregated Data from your personal data but this data does not revealyour identity and as such in itself is not personal data. An example of this iswhere we review your Usage Data to work out the percentage of website usersusing a specific feature of our site. If we link the Aggregated Data with yourpersonal data so that you can be identified from it, then it is treated aspersonal data.

Sensitive Data

We do not collect any Sensitive Data about you. Sensitivedata refers to data that includes details about your race or ethnicity,religious or philosophical beliefs, sex life, sexual orientation, politicalopinions, trade union membership, information about your health and genetic andbiometric data. We do not collect any information about criminal convictionsand offences.

3.  HOW WE COLLECT YOUR PERSONAL DATA

 We collect data about you througha variety of different methods including:

•                    Direct interactions: You may provide data by filling informs on our site (or otherwise) or by communicating with us by post, phone,email or otherwise, including when you:

•                    order our products or services;

•                    create an account on our site;

•                    subscribe to our service or publications;

•                    request resources or marketing be sent to you;

•                    enter a competition, prize draw, promotion or survey; or

•                    give us feedback.

•                    Automated technologies or interactions: As you use oursite, we may automatically collect Technical Data about your equipment,browsing actions and usage patterns. We collect this data by using cookies,server logs and similar technologies. We may also receive Technical Data aboutyou if you visit other websites that use our cookies. Please see our cookiepolicy at /contact-us/cookies/ for furtherdetails.

4.  HOW WE USE YOUR PERSONAL DATA  

 We will only use your personaldata when legally permitted. The most common uses of your personal data are:

•                    Where we need to perform the contract between us.

•                    Where it is necessary for our legitimate interests (or thoseof a third party) and your interests and fundamental rights do not overridethose interests.

•                    Where we need to comply with a legal or regulatoryobligation.

 

Under the Law, we must have a validlegal basis to process your data. In most instances, we will process your databecause we have a contract with you e.g. to deliver your purchases or toprovide you with other services you have requested. We will also use yourpersonal data to send you sales and marketing communications that we believemay be of interest to you if we have your consent for this activity, or if youare an existing customer where we have a legitimate interest in communicatingwith you, whether that be via email, text message or telephone. You have theright to withdraw consent to marketing at any time by emailing us at customercare@xen-tan.co.uk.

 

Purposesfor processing your personal data  

Setout below is a description of the ways we intend to use your personal data andthe legal grounds on which we will process such data. We have also explainedwhat our legitimate interests are where relevant.

We may process your personal data formore than one lawful ground, depending on the specific purpose for which we areusing your data. Please email us at customercare@xen-tan.co.uk ifyou need details about the specific legal ground we are relying on to processyour personal data where more than one ground has been set out in the table below.

 

Purpose/Activity

 

Type of data

 

Lawful basis for processing

 

To register you as a new customer

 

(a) Identity

(b) Contact

 

Performance of a contract with you

 

To process and deliver your order including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

 

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Marketing and Communications

 

(a) Performance of a contract with you

(b) Necessary for our legitimate interests to recover debts owed to us

 

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

 

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

 

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests to keep our records updated and to study how customers use our products/services

 

To enable you to partake in a prize draw, competition or complete a survey

 

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

 

(a) Performance of a contract with you

(b) Necessary for our legitimate interests to study how customers use our products/services, to develop them and grow our business

 

To administer and protect our business and our site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

 

(a) Identity

(b) Contact

(c) Technical

 

(a) Necessary for our legitimate interests for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise

(b) Necessary to comply with a legal obligation

 

To deliver relevant content and advertisements to you and measure and understand the effectiveness of our advertising

 

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

 

Necessary for our legitimate interests to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy

 

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

 

(a) Technical

(b) Usage

 

Necessary for our legitimate interests to define types of customers for our products and services, to keep our site updated and relevant, to develop our business and to inform our marketing strategy

 

To make suggestions and recommendations to you about goods or services that may be of interest to you

 

(a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

 

Necessary for our legitimate interests to develop our products/services and grow our business

 

 

Marketingcommunications 

You will receive marketingcommunications from us if you have:

(i)                  requested information from us or purchased goods or servicesfrom us; or

(ii)                if you provided us with your details and ticked the box atthe point of entry of your details for us to send you marketing communications;and

(iii)               in each case, you have not opted out of receiving thatmarketing. 

 

We will get your express opt-in consentbefore we share your personal data with any third party for marketing purposes.

You can ask us or third parties to stopsending you marketing messages at any time [by logging into the website andchecking or unchecking relevant boxes to adjust your marketing preferences] OR[by following the opt-out links on any marketing message sent to you or] OR byemailing us at customercare@xen-tan.co.uk atany time.

Where you opt out of receiving ourmarketing communications, this will not apply to personal data provided to usas a result of a product/service purchase, warranty registration,product/service experience or other transactions.

 

Change of purpose  

We will only use your personal data forthe purposes for which we collected it, unless we reasonably consider that weneed to use it for another reason and that reason is compatible with theoriginal purpose. If you wish to find out more about how the processing for thenew purpose is compatible with the original purpose, please email us at customercare@xen-tan.co.uk.  

If we need to use your personal datafor a purpose unrelated to the purpose for which we collected the data, we willnotify you and we will explain the legal ground of processing.

We may process your personal datawithout your knowledge or consent where this is required or permitted bylaw. 

5.  DISCLOSURES OF YOUR PERSONAL DATA  

We may have to share your personal datawith the parties set out below for the purposes set out in the table inparagraph 4 above: 

•                    Service providers who provide IT and system administrationservices.

•                    Professional advisers including lawyers, bankers, auditorsand insurers who provide consultancy, banking, legal, insurance and accountingservices.

•                    HM Revenue & Customs, regulators and other authoritiesbased in the United Kingdom and other relevant jurisdictions who requirereporting of processing activities in certain circumstances.

•                    Third parties to whom we sell, transfer, or merge parts ofour business or our assets.

We require all third parties to whom wetransfer your data to respect the security of your personal data and to treatit in accordance with the law. We only allow such third parties to process yourpersonal data for specified purposes and in accordance with our instructions.

6.  INTERNATIONALTRANSFERS  

We do not transfer your personal dataoutside the European Economic Area (EEA).

Countries outside of the EuropeanEconomic Area (EEA) do not always offer the same levels of protection toyour personal data, so European law has prohibited transfers of personal dataoutside of the EEA unless the transfer meets certain criteria.

Many of our third parties serviceproviders are based outside the European Economic Area (EEA) so theirprocessing of your personal data will involve a transfer of data outside theEEA.

Whenever we transfer your personal dataout of the EEA, we do our best to ensure a similar degree of security of databy ensuring at least one of the following safeguards is implemented:

•                    We will only transfer your personal data to countries thathave been deemed to provide an adequate level of protection for personal databy the European Commission; or

•                    Where we use certain service providers, we may use specificcontracts or codes of conduct or certification mechanisms approved by theEuropean Commission which give personal data the same protection it has inEurope; or

•        Where we use providers based in the United States, we maytransfer data to them if they are part of the EU-US Privacy Shield whichrequires them to provide similar protection to personal data shared between theEurope and the US.

If none of theabove safeguards is available, we may request your explicit consent to thespecific transfer. You will have the right to withdraw this consent at anytime.

Please email usat customercare@xen-tan.co.uk if you want further information on thespecific mechanism used by us when transferring your personal data out of theEEA.

7.  DATA SECURITY  

We have put in place appropriatesecurity measures to prevent your personal data from being accidentally lost,used or accessed in an unauthorised way, altered or disclosed. In addition, welimit access to your personal data to those employees, agents, contractors andother third parties who have a business need to know such data. They will onlyprocess your personal data on our instructions and they are subject to a dutyof confidentiality.

We have put in place procedures to dealwith any suspected personal data breach and will notify you and any applicableregulator of a breach where we are legally required to do so.

8.  DATA RETENTION  

We will only retain your personal datafor as long as necessary to fulfil the purposes we collected it for, includingfor the purposes of satisfying any legal, accounting, or reportingrequirements.

To determine the appropriate retentionperiod for personal data, we consider the amount, nature, and sensitivity ofthe personal data, the potential risk of harm from unauthorised use ordisclosure of your personal data, the purposes for which we process yourpersonal data and whether we can achieve those purposes through other means,and the applicable legal requirements.

By law we have to keep basicinformation about our customers (including Contact, Identity, Financial andTransaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us todelete your data: see below for further information.

In some circumstances we may anonymiseyour personal data (so that it can no longer be associated with you) forresearch or statistical purposes in which case we may use this informationindefinitely without further notice to you.

9.  YOUR LEGAL RIGHTS  

Under certain circumstances, you haverights under data protection laws in relation to your personal data. Theseinclude the right to:

•                    Requestaccess to your personal data.

•                    Requestcorrection of your personal data.

•                    Requesterasure of your personal data.

•                    Object to processing of yourpersonal data.

•                    Request restriction of processingyour personal data.

•                    Request transfer of your personaldata.

•                    Right to withdraw consent.

 

You can seemore about these rights at:

https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

If you wish toexercise any of the rights set out above, please email us at customercare@xen-tan.co.uk.

You will not have to pay a fee toaccess your personal data (or to exercise any of the other rights). However, wemay charge a reasonable fee if your request is clearly unfounded, repetitive orexcessive. Alternatively, we may refuse to comply with your request in thesecircumstances.  

We may need to request specific informationfrom you to help us confirm your identity and ensure your right to access yourpersonal data (or to exercise any of your other rights). This is a securitymeasure to ensure that personal data is not disclosed to any person who has noright to receive it. We may also contact you to ask you for further informationin relation to your request to speed up our response.

We try to respond to all legitimaterequests within one month. Occasionally it may take us longer than a month ifyour request is particularly complex or you have made a number of requests. Inthis case, we will notify you and keep you updated.

10.THIRD-PARTY LINKS  

This website may include links tothird-party websites, plug-ins and applications. Clicking on those links orenabling those connections may allow third parties to collect or share dataabout you. We do not control these third-party websites and are not responsiblefor their privacy statements. When you leave our website, we encourage you toread the privacy notice of every website you visit.

11. COOKIES  

You can set your browser to refuse allor 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 websitemay become inaccessible or not function properly. For more information aboutthe cookies we use, please see: /contact-us/cookies/.

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