Your personal data – what is it?
“Personal data” is any information about a living individual which allows them to be identified from that data (for example a name, photographs, videos, email address, or address). Identification can be by the information alone or in conjunction with any other information. The processing of personal data is governed by [the Data Protection Bill/Act 2017 the General Data Protection Regulation 2016/679 (the “GDPR” and other legislation relating to personal data and rights such as the Human Rights Act 1998].
Who are we?
This Privacy Notice is provided to you by The Extraordinary Group Ltd. which is the data controller for your data.
We also share personal data with the trusted third parties such as courier companies used for the delivery of online orders.
These organisations are joint data controllers. This means we are all responsible to you for how we process your data.
Each of the data controllers have their own tasks and a description of what data is processed and for what purpose is set out in this Privacy Notice. This Privacy Notice is sent to you by The Extraordinary Group Ltd. on our own behalf and on behalf of each of these data controllers. In the rest of this Privacy Notice, we use the word “we” to refer to each data controller, as appropriate.
What data do the data controllers we work with process? They will process some or all of the following where necessary to perform their tasks:
Names, titles, and aliases, photographs;
Contact details such as telephone numbers, addresses, and email addresses;
Where relevant, or where you provide them to us, we may process demographic information such as gender, age, date of birth, marital status, nationality, education/work histories, academic/professional qualifications, hobbies, family composition, and dependants;
Where you pay for goods or services, financial identifiers such as bank account numbers, payment card numbers, payment/transaction identifiers, policy numbers, and claim numbers;
Where you provide this information, we may also process special categories of data or sensitive personal data. Processing this type of data will be rare but, for example, you may tell us details about a disability if it is relevant to a home delivery.
How do we process your personal data?
We will comply with all legal obligations to keep personal data up to date; to store and destroy it securely; to not collect or retain excessive amounts of data; to keep personal data secure, and to protect personal data from loss, misuse, unauthorised access and disclosure and to ensure that appropriate technical measures are in place to protect personal data.
We use your personal data for some or all of the following purposes:
To enable us to meet all legal and statutory obligations;
To serve you better as a customer;
To maintain our own accounts and records;
To process your payments and any refunds;
To seek your views or comments;
To notify you of changes to our services and events;
To send you communications which you have requested and that may be of interest to you. These may include information about sales, special offers, competitions, etc.
Our processing also includes the use of CCTV systems for the prevention and prosecution of crime.
What is the legal basis for processing your personal data?
Most of our data is processed because it is necessary for our legitimate interests, or the legitimate interests of a third party (such as another data controller). We will always take into account your interests, rights and freedoms.
Some of our processing is necessary for compliance with a legal obligation. For example, we are required maintain certain records by law such as VAT records.
We may also process data if it is necessary for the performance of a contract with you, or to take steps to enter into a contract. An example of this would be processing your data in connection with a purchase you have made.
Where your information is used other than in accordance with one of these legal bases, we will first obtain your consent to that use.
Sharing your personal data
Your personal data will be treated as strictly confidential. It will only be shared with third parties where it is necessary for the performance of our tasks or where you first give us your prior consent. It is likely that we will need to share your data with some or all of the following (but only where necessary):
Our agents, servants and contractors. For example, we may ask a commercial provider to send out newsletters on our behalf, or to maintain our database software;
How long do we keep your personal data?
We will keep some records permanently if we are legally required to do so. We may keep some other records for an extended period of time. For example, it is current best practice to keep financial records for a minimum period of 7 years to support HMRC audits or 6 years for VAT records. In general, we will endeavour to keep data only for as long as we need it. This means that we may delete it when it is no longer needed.
Your rights and your personal data
You have the following rights with respect to your personal data:
When exercising any of the rights listed below, in order to process your request, we may need to verify your identity for your security. In such cases we will need you to respond with proof of your identity before you can exercise these rights.
The right to access information we hold on you
At any point you can contact us to request the information we hold on you as well as why we have that information, who has access to the information and where we obtained the information from. Once we have received your request we will respond within one month.
There are no fees or charges for the first request but additional requests for the same data may be subject to an administrative fee.
The right to correct and update the information we hold on you
If the data we hold on you is out of date, incomplete or incorrect, you can inform us and your data will be updated.
The right to have your information erased
If you feel that we should no longer be using your data or that we are illegally using your data, you can request that we erase the data we hold.
When we receive your request we will confirm whether the data has been deleted or the reason why it cannot be deleted (for example because we need it for our legitimate interests or regulatory purpose(s)).
The right to object to processing of your data
You have the right to request that we stop processing your data. Upon receiving the request we will contact you and let you know if we are able to comply or if we have legitimate grounds to continue to process your data. Even after you exercise your right to object, we may continue to hold your data to comply with your other rights or to bring or defend legal claims.
The right to data portability
You have the right to request that we transfer some of your data to another controller. We will comply with your request, where it is feasible to do so, within one month of receiving your request.
The right to withdraw your consent to the processing at any time for any processing of data to which consent was sought.
You can withdraw your consent easily by telephone, email, or by post (see Contact Details below).
The right to object to the processing of personal data where applicable.
The right to lodge a complaint with the Information Commissioner’s Office.
Transfer of Data Abroad
Any electronic personal data transferred to countries or territories outside the EU will only be placed on systems complying with measures giving equivalent protection of personal rights either through international agreements or contracts approved by the European Union. Our website is also accessible from overseas so on occasion some personal data (for example in a newsletter) may be accessed from overseas.
If we wish to use your personal data for a new purpose, not covered by this Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions. Where and whenever necessary, we will seek your prior consent to the new processing.
Please contact us if you have any questions about this Privacy Notice or the information we hold about you or to exercise all relevant rights, queries or complaints at:
The Data Controller, The Extraordinary Group Ltd.
How to make a complaint
If you are unhappy with the way in which your personal data has been processed, you may in the first instance contact the Data Protection Officer using the contact details firstname.lastname@example.org
If you remain dissatisfied, then you have the right to apply directly to the Information Commissioner for a decision. The Information Commissioner can be contacted at:
The Information Commissioner, Wycliffe House, Water Lane, Wilmslow Cheshire SK9 5AF
Telephone: 01625 545 700
Data Protection Help Line: 01625 545 745
Notification Line: 01625 545 740