H.G. Stephenson Limited
“We” are H.G. Stephenson Limited (company number 00065741) and we’re based at Kennerley Works, 161 Buxton Road, Stockport, Cheshire SK2 6EQ. We are the data controller for the purposes of the Data Protection Act 2018, the EU General Data Protection Regulation (GDPR) and any other data protection legislation applicable in the UK from time to time.
Please note that links from our website may take you to external websites which are not covered by this policy. We recommend that you check their privacy policies before submitting any personal information to such sites. We will not be responsible for the content, function or information collection policies of these external websites.
What information do we collect about you and how do we collect it?
You are not required (by law or by any contract with us) to provide personal information to us via our website. We will only require you to provide personal information to us where it is necessary for us to provide you with a service at your request.
Information you provide to us
We may receive personal information about you whenever you contact us. For example, by doing the following:
- Enquiring about our products or services, including when you request a catalogue.
- Purchasing our products or services.
- Supplying us with your products or services.
- Using and browsing our website.
- Creating an account with us through our website.
- Signing up to our newsletter.
- Telephoning, texting, writing by post or emailing us.
- Enquiring about, or applying for, job vacancies.
This information may include the following:
- Normal identification information, such as your full name, date of birth, age, gender, marital status.
- Contact information, such as your postal address, email address and telephone number.
- Additional information relevant to your use of our website and services, such as your marketing preferences, survey responses and feedback.
- Information about your shipment, including the recipient.
- Your VAT status (for international shipments).
- Payment information (this is securely collected and processed by our payment provider).
- In respect of job applications, your CV including details of your education and employment history (and any other information which you may choose to provide to us with your CV).
Information we collect about you on our website
When you visit our website we may collect the following information:
- Which pages you view and which links you follow.
- Your IP address and general location.
- Details of the hardware and software that you are using to access the website.
- Any passwords that you use on our website.
- If you choose to log in using a third party, we will record your login provider.
- If you choose to link your account to a third party marketplace to import items for shipment, we will record the details necessary to facilitate that link.
- A device identifier (cookie or IP address) for fraud prevention.
- Details of your visits to our website and the resources that you access, including, but not limited to, traffic data, location data, weblogs and other communication data.
- Where orders originate from advertising sources, we record the source of each order. This is purely to allow us to assess the effectiveness of these adverts and is not used for customer profiling of any kind.
Our website is not intended for children and we do not knowingly collect data relating to children.
Information we collect about you from other sources
We may collect information about you from other sources. This may include the following:
- Publicly available information, from sources such as Companies House and the Electoral Roll.
- Information you have shared publicly, including on social media (particularly in respect of job applications).
- If you apply for a job, we may collect information about your criminal record by obtaining a DBS check through an approved agency (where required or permitted by law).
- Information from third party databases or lead suppliers, such as credit reference agencies, including details about your home.
This list is not exhaustive and, in specific instances, we may need to collect additional data for the purposes set out in this policy.
Information we receive about you from other sources
Sometimes you will have given your consent for other websites, services or third parties to provide information to us.
This could include information we receive about you if you use any of the other websites that we operate or the other services that we provide, in which case we will have informed you when we collected that data if we intend to share those data internally and combine it with data collected on this website. We will also have told you for what purpose we will share and combine your data.
It could also include information from third parties that we work with to provide our products and services, such as payment processors, credit check facilities, delivery companies, technical support companies and advertising companies. Whenever we receive information about you from these third parties, we will let you know what information we have received and how and why we intend to use it.
How and why do we use your personal information?
We take data protection law seriously, so below we have set out exactly how and why we use your information, and what our legal basis is to be able to use your information in each way.
Supplying our products and providing our services
It is necessary for us to use personal information about you to enter into and perform the contracts that we make with you, such as when you become a customer. To process your personal data in this way, we will rely on legal bases of performing our contract with you and pursuing our legitimate interests. Using your information in this context is necessary so that we can:
- Provide you with information about your contract with us.
- Provide you with information about our products and services, including sending our monthly newsletter if you sign up to receive it.
- Verify your identity.
- Make a decision to supply our products and services.
- Deal with any complaints you may have.
- Contact you about any changes that we make to our products or services.
- Administer our website, including troubleshooting problems, analysing statistics, conducting research and tests and keeping the website secure.
- Administer your order and take payments.
If you enquire about, or apply for, a job vacancy, it is necessary for us to use your personal information as part of the recruitment process, in order to assess your suitability for a particular role.
Telling you about other products or services that we think may be of interest to you
We may use your information to identify and tell you about our products or services that we think may be of interest to you, and we will rely on the lawful basis of legitimate interests in doing so. We will only do this where you have informed us that you would like to receive marketing communications and you may update your preferences at any time by Contacting Us.
We may also use your information to invite you to participate in market research. If we do contact you about market research, you do not have to participate. If you tell us that you do not want to receive market research communications, we will respect this.
Whether you choose to receive marketing communications, or market research communications is entirely up to you. You can choose to receive both, none, or just one or the other. Your choice will not affect any products or services that you have purchased from us, nor will it affect any quotes for products or services you buy in future.
Telling you about products or services that are similar to ones that you have already bought
If you have already bought a product or service from us, or you have already obtained a quote from us, we may contact you with some information about products and services that are similar. We will rely on the lawful basis of legitimate interests in doing so.
We will only contact you by email or telephone and you can choose not to receive these messages at any time. Simply follow the instructions in the message, or Contact Us.
Making our business better
We always want to offer the best products, services and experience that we can. Sometimes this means we may use your information to find ways that we can improve what we do, or how we do it. For example, we may carry out email and postal campaigns and we may ask you for product and service reviews through our reviews platform.
In this context, we will rely on the lawful basis of legitimate interests and will only use your information where it is necessary so that we can:
- Review and improve our existing products and services and develop new ones.
- Review and improve the performance of our systems, processes and staff (including training).
- Improve our website to ensure that content is presented in the most effective manner for you and for your computer.
- Measure and understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you.
We want to stay in touch with you. Sometimes we may need to use the information that we have about you in order to respond to your questions or let you know about important changes. We will rely on the lawful basis of performing our contract with you and pursing our legitimate interests when we contact you.
We will only use your information in this respect where it is necessary so that we can:
- Interact and respond to any communications you send us, including where you use the Contact Us section, and any social media posts that you tag us in.
- Let you know about any important changes to our business or policies.
Verifying your identity
We may use your information where it is necessary for us to do so in order to meet our legal obligations or to detect and prevent fraud, money-laundering and other crimes.
Protecting you and others from harm
We may use your information where it is necessary to protect your interests, or the interests of others, in accordance with our legal obligations and the pursuit of legitimate interests. This may include in the event of criminality such as identity theft, piracy or fraud.
We need all the categories of information listed above to allow us:
- to enter into and perform our contract with you;
- to enable us to comply with legal obligations; and
- to pursue legitimate interests of our own or those of third parties (provided your interests and fundamental rights do not override those interests).
Change of purpose
We will only use your personal information 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 we need to use your personal information 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 personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Who do we share your personal information with?
Sharing your information within our company and group
We share the information that you provide to us with our staff so that we can provide our products and services to you.
We may share the information that you provide to us with other companies within our group and other websites that we and our group companies operate.
Sharing your information with third parties
We may share your data with selected third parties. For example, we may share your information with:
- Internet hosting providers to host the website, related infrastructure, services and applications.
- Contact management systems to send emails, instant messages, social media messages and SMS messages.
- Mailing distributor to send out catalogues or special offers.
- Customer review platforms.
- Payment gateway platforms.
There are certain exceptional circumstances in which we may disclose your information to third parties. This would be where we believe that the disclosure is:
- Required by the law, or in order to comply with judicial proceedings, court orders or legal or regulatory proceedings.
- Necessary to protect the safety of our employees, our property or the public.
- Necessary for the prevention or detection of crime, including exchanging information with other companies or organisations for the purposes of fraud protection and credit risk reduction.
- Proportionate as part of a merger, business or asset sale, in the event that this happens we will share your information with the prospective seller or buyer involved.
How long do we keep your personal information?
We will only store your personal information for as long as we need it for the purposes for which it was collected. Where we provide you with any service, we will retain any information you provide to us at least for as long as we continue to provide that service to you.
If your application for employment is unsuccessful, the organisation will hold your data on file for 12 months after the end of the relevant recruitment process for consideration for future employment opportunities. At the end of that period, or once you withdraw your consent, your data will be deleted or destroyed.
We will only retain your 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 personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. 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.
How do we protect your personal information?
We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this policy.
We try to ensure that all information you provide to us is transferred securely via the website. 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 data transmitted to our website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
All information you provide to us is stored on third party secure servers in the UK. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
What rights do you have in respect of your personal information?
If you require any further information about your rights as explained below, or if you would like to exercise any of your rights, please Contact Us.
You have the right to be informed
We have a legal obligation to provide you with concise, transparent, intelligible and easily accessible information about your personal information and our use of it. We have written this policy to comply with this right.
You have the right to access your personal data
You have the right to ask us to confirm whether or not we hold any of your personal information. If we do, you have the right to have a copy of your information and to be informed of the following:
- Why we have been using your information.
- What categories of information we were using.
- Who we have shared the information with.
- How long we envisage holding your information.
In order to maintain the security of your information, we will have to verify your identity before we provide you with a copy of the information we hold. The first copy of your information that you request from us will be provided free of charge, if you require further copies we may charge an administrative fee to cover our costs.
You have the right to correct any inaccurate or incomplete personal data
Where you have requested a copy of the information we hold about you, you may notice that there are inaccuracies in the records, or that certain parts are incomplete. If this is the case you can Contact Us so that we can correct our records.
You have the right to be forgotten
There may be times where it is no longer necessary for us to hold personal information about you. This could be if:
- The information is no longer needed for the original purpose that we collected it for.
- You withdraw your consent for us to use the information (and we have no other legal reason to keep using it).
- You object to us using your information and we have no overriding reason to keep using it.
- We have used your information unlawfully.
- We are subject to a legal requirement to delete your information.
In those situations you have the right to have your personal data deleted. If you believe one of these situations applies to you, please Contact Us.
You have the right to have your data transferred to you or a third party in a common format
Also known as data portability, you have the right to obtain a copy of your personal data for your own purposes. This right allows you to move, copy or transfer your personal data more easily from one IT system to another, in a safe and secure way.
If you would like us to transfer a copy of your data to you or another organisation in a structured, commonly use and machine-readable format, please Contact Us. There is no charge for you exercising this right.
You have the right to object to direct marketing
You can tell us at any time that you would prefer that we do not use your information for direct marketing purposes. If you would not like to receive any direct marketing from us, please Contact Us or use the links provided in any of our marketing communications.
You have the right to object to us using your information for our own legitimate interests
Sometimes, we use your personal information to achieve goals that will help us as well as you. This includes when we tell you about products or services that are similar to ones you have already bought; when we use your information to help us make our business better; and when we contact you to interact, communicate or to let you know about changes we are making.
We aim to always ensure that your rights and information are properly protected. If you believe that the way we are using your data is not justified due to its impact on you or your rights, you have the right to object. Unless we have a compelling reason to continue, we must stop using your personal data for these purposes.
You have the right to restrict how we use your personal data
You have the right to ask us to stop using your personal data in any way other than simply keeping a copy of it. This right is available where:
- You have informed us that the information we hold about you is inaccurate, and we have not yet been able to verify this.
- You have objected to us using your information for our own legitimate interests and we are in the process of considering your objection.
- We have used your information in an unlawful way, but you do not want us to delete your data.
- We no longer need to use the information, but you need it for a legal claim.
This version was last updated on [INSERT DATE OF UPLOAD] and historic versions can be obtained by contacting us.
If you wish to make a complaint about our collection or use of your personal data, please Contact Us in the first instance so that we may seek to resolve your complaint.
You have the right to lodge a complaint with the Information Commissioner’s Office (ICO), the statutory body which oversees data protection law in the UK. Please visit the ICO website if you wish to lodge a complaint with the ICO.
Our contact details are as follows:
H.G Stephenson Limited, 161 Buxton Road, Stockport, Cheshire, SK2 6EQ
Telephone: 0161 483 6256