1. Important information
This privacy notice aims to give you information on how personal data is collected through your use of this website, including any data you may provide when you purchase a product or service. This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
2. Who we are
Internet Fusion Ltd (Co number 06012780 whose registered office is at 2 Stone Buildings, Lincoln's Inn, London, England, WC2A 3TH (“IFL”) operates the website and sells branded products as an authorised distributor of products produced by Brand Machine International Ltd (Company number 06873920) whose registered office is at Unit 1 Windsor Industrial Estate, 424 Ware Road, Hertford, Hertfordshire, SG13 7EW (“BMIL”),
• IFL will be a data controller in relation to the performance of any order you place through the website. • BMIL will be a data controller in relation to any subsequent marketing activities which may take place as a result of you placing an order through the website IFL and BMIL are not joint data controllers, operate independently from one another and will use your data for separate purposes. This policy refers to the actions of both IFL and BMIL to simplify the explanation.
IFL - Please contact our Data Privacy Manager: Email: [email protected] Postal address:Data Privacy Manager, Internet Fusion Ltd, 2 Stone Buildings, Lincoln's Inn, London, England, WC2A 3TH.
BMIL - Please contact our Data Privacy Manager: Email: [email protected] Postal address: Penfield Data Privacy Manager, Brand Machine International Limited Unit 1 Windsor Industrial Estate, 424 Ware Road, Hertford, Hertfordshire, SG13 7EW.
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 (ico.org.uk). Both IFL and BMIL would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
3. Third-party links
This Penfield website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. IFL does not control these third-party websites and is not responsible for their privacy statements. When you leave IFL’s website, we encourage you to read the privacy notice of every website you visit.
4. The data that is collected about you
Personal data, or personal information, means any information about an individual from which that person can be identified. The following categories of personal data may be collected about you which we have grouped together follows:
- Identity Data includes first name, last name, username or similar identifier and title.
- Contact Data includes billing address, delivery address, email address and telephone numbers.
- Financial Data may include payment card details.
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
- Technical Data may includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
- Profile Data may include your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data may include information about how you use our website, products and services.
- Marketing and Communications Data: your preferences in receiving marketing from BMIL and your communication preferences. Where IFL needs to collect personal data to fulfil your order and you fail to provide that data when requested, we will have to cancel your order. We will notify you if this is the case at the time.
5. How is your personal data collected?
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 by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
o apply for our products or services; o create an account on our website; o subscribe to our service or publications; o request marketing to be sent to you; or o give us some feedback.
• Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
o Technical Data from the following parties: o (a) analytics such as Google; o (b) advertising networks based inside or outside the EU; and o (c) search information providers based inside or outside the EU. o Contact, Financial and Transaction Data from providers of technical, payment and delivery services based inside the EU.
6. How we use your personal data; Lawful basis
IFL will only use your personal data: • to fulfil an order your place through the website, and where applicable for any follow-on issues (complaints, returns etc); or • to comply with a legal or regulatory obligation. BMIL will only use your express consent as a legal basis for processing your personal data to send direct marketing, promotional and advertising communications to you via email or text message. BMIL may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what it thinks you may want or need, or what may be of interest to you. BMIL may also have access to personal data relating to your order(s) in the event of any product warranty claims or recall situations.
You can ask BMIL or third parties to stop sending you marketing messages at any time by contacting BMIL at any time. Where you opt out of receiving marketing messages, this will not apply to personal data provided to IFL as a result of a product/service purchase, warranty registration, product/service experience or other.
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
|Purpose/Activity||Type of data||Who uses||Lawful basis for processing including basis of legitimate interest|
|To register you as a new customer||
|IFL||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
|IFL||(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
|To manage and process product or service warranty cover or product recall||(a) Identity
|BMIL||(a) Performance of a contract with you|
|(a) Performance of a contract with you
|To enable you to partake in a prize draw, competition or complete a survey||(a) Identity
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity
|IFL||(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 use data analytics to improve our website, products/services, marketing, customer relationships and experiences||(a) Technical
|Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business strategy)|
|To make suggestions and recommendations to you about goods or services that may be of interest to you||(a) Identity
We will only use your 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.
8. Who do we share personal data with?
IFL will not share your personal data with any third parties other than those third parties who provide part of our sales service. 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. We may also share your personal data with third parties to whom we may choose to 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.
9. International transfers
IFL will not transfer your personal data outside the UK or EEA. If we ever transfer your personal data out of the UK or EEA, we will ensure a similar degree of protection is afforded to it by ensuring at least one of the safeguards required by applicable privacy law is implemented including standard contractual clauses.
10. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your 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 personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
11. Data retention
IFL 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.
12. Your legal rights
Under UK privacy regulations you have certain rights in relation to your personal data to : Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the 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 personal data. This enables you to ask us to delete or remove 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 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 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 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 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 personal data. This enables you to ask us to suspend the processing of your 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 personal data to you or to a third party. We will provide to you, or a third party you have chosen, your 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 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.
Last updated April 2021