This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
For the purpose of the data protection laws, Dormole Limited is the data controller and responsible for your personal data.
Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
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 chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
3. Information we collect about you and how we collect it
Personal data or information means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous 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 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 send you marketing emails and to enter you into our competitions).
The types of personal data we collect depend upon how we interact with you. We will collect more personal data from you if you are entering a competition than if you are signing up to receive our email newsletters.
We will collect and process the following data about you:
· Information you give us. This is information about you that you give us by filling in forms on www.realdealsforyou.com (our site), by entering competitions, promotions or surveys or by corresponding with us by phone, e-mail or otherwise. It includes the following types of information:
(a) Identity Data: includes name(s), username or similar identifier (which will usually be your email address), title, gender;
(b) Contact Data: includes address(es), email address(es) and telephone number(s);
(c) Profile Data: includes any feedback you have given us;
(d) Marketing Data: includes your preferences to receive marketing from us.
· Information we collect about you. With regard to each of your visits to our site we will automatically collect the following information:
(a) Technical Data: includes the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, location, browser plug-in types and versions, operating system and platform;
(b) Usage Data: includes the full Uniform Resource Locators (URL); clickstream to, through and from our site (including date and time); products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs) and any phone number used to call our customer service number.
· We may also receive information from other sources. This is information we receive about you if you use any of the other websites we operate or the other services we provide. We are working closely with third parties (for example, including business partners, sub-contractors in technical services, analytics providers (such as Google) and search information providers). We may receive some of the information detailed above about you from them.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Special Categories of personal data. Under data protection laws there are certain categories of more sensitive personal data (these include details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). We do not collect these types of data about you, nor do we collect information relating to criminal convictions.
Aggregated data. We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will 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.
4. How we use your information
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
(a) Where we need to perform the contract we are about to enter into or have entered into with you (Contract Reason);
(b) Where it is necessary for our legitimate interests (or those of a third party), and your interests and fundamental rights do not override those interests (Legitimate Interests Reason). Legitimate Interest means the interest of our organisation in conducting and managing our business to enable us to give you the best product and the 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 personal data for our legitimate interests. We do not use your 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);
(c) Where we need to comply with a legal obligation (Legal Obligations Reason); or
(d) Where we have your explicit consent (Consent Reason).
We have set out below a description of the ways we plan to use your personal data and which of the above legal bases we rely on to do so. We have also explained what our legitimate interests are where appropriate.
|Purpose||Legal basis for processing|
|To register you as wishing to receive our newsletters by email||• Consent|
|To respond to enquiries and to send information to you which you request||• Contract Reason
• Legitimate Interests Reason (to respond to potential customers and grow our business)
• Legitimate Interests Reason (to keep our records updated and to understand and review how customers use our products)
|To enable you to participate in prize draws and competitions||• Contract Reason
• Legitimate Interests Reason (to understand and review how customers use our products and website, to develop our products and to grow our business)
|To respond to, defend or otherwise deal with any claims made against us, including in respect of litigation.||• Legal Obligations Reason
• Contract Reason
• Legitimate Interests Reason (to defend our business)
|To administer and protect our business and our site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||• Legitimate Interests Reason (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)
• Legal Obligations Reason
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of our site and the advertising we serve to you||• Legitimate Interests Reason (to study how customers use our products/services, to improve our site, to develop them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve our site, products/services, marketing, customer relationships and experiences||• Legitimate Interests Reason (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 products or services that may be of interest to you||• Consent Reason|
Where in the above table we have identified more than one legal basis on which we are relying on to process your personal data, this is because it will depend on the specific circumstances. You can contact us on the details set out above to find out which particular basis we are relying on where more than one basis has been set out.
We strive to provide you with choices regarding marketing and advertising.
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 to receive them from us.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out or unsubscribe links on any marketing message sent to you or by contacting us at any time on the contact details set out above. You can also unsubscribe by clicking here and completing your email address.
7. Disclosure of your information
We may share your personal information with:
Internal third parties: this means any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries who are based in the United Kingdom and Ireland and who provide IT and administration services and undertake leadership reporting.
External third parties including:
- Service Providers such as business partners, suppliers and sub-contractors who are based in the United Kingdom and Ireland who provide delivery, IT, website hosting, storage and administration services;
- Email marketing platforms such as Mailchimp who are based outside of Europe who provide email marketing solutions;
- Professional advisers including lawyers, bankers, auditors and insurers based in the United Kingdom and Ireland who provide consultancy, banking, legal, insurance and accounting services;
- HM Revenue & Customs, regulators and other authorities based in the United Kingdom and Ireland who require reporting of processing activities in certain circumstances;
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.
8. Where your personal data is stored
All information you provide to us is stored on secure servers hosted by third party suppliers who have warranted to us that they are compliant with all applicable data protection laws.
Our servers are based in the European Economic Area (EEA). However, some of our external third parties are based outside the 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 safeguards are implemented. These safeguards may mean 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;
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe; or
- 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 Europe and the US.
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 site; any transmission is at your own risk.
However, once we have received your information, we have put in place security measures, strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed, altered or disclosed in an unauthorised way.
10. Data Retention
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
In some circumstances, we will 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.
11. Your rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Your rights include:
(a) 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.
(b) 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.
(c) 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.
(d) Object to the 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.
(e) 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 (i) if you want us to establish the data’s accuracy; (ii) where our use of the data is unlawful but you do not want us to erase it; (iii) 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 (iv) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
(f) 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. 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.
(g) 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.
You will not have to pay a fee to access your 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. Alternatively, we could refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that 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.
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month 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.