Privacy Policy of Lyons Outdoor and Media Ltd trading as Criterion Sleeping Bags

0. Data Processing – Overview

What personal data we retain is kept as securely as is reasonably possible given its non-critical, non-sensitive nature. Without exception, data is kept only for legal, contractual or legitimate interest purposes. [E&OE].

1. The obtaining of personal data

We obtain personal data as a result of enquiries and/or orders received from customers, potential customers, persons requesting technical assistance, and suppliers of goods and services. We DO NOT purchase data bases. Whilst most of the data received relates to company data, some personal data is also received either directly or through 3rd parties. The latter is usually a request by our customer to despatch a product directly to its customer and in this case, the processing of personal data is done for legitimate interest purposes. Such personal data includes names, telephone numbers, email addresses, postal addresses and other data as provided by potential customers / customers. In exceptional circumstances we may also receive personal bank account information, though this is a very rare occurrence. We do not have access to credit or debit card data as we have no means of processing it. Payment information relating to purchases that are made through our eBay sales shop is handled remotely by eBay. Payment information relating to purchases made through our website is handled remotely by PayPal.

2. Storage of personal data

Personal data is stored in computer files as well as in paper records. These are kept in our offices at 3 Craven Court, Altrincham, WA14 5DY, and at other premises. Security is provided firewalls and physical security.

3. Use and retention of personal data

We use and retain personal data for the following lawful purposes: to comply with legal requirements relating to the company’s business, including the retention of sales, purchase and insurance documentation for statutory periods. for contractual purposes, including the provision of pre-sales information and after-sales service. when requested, to respond to enquiries that might lead to business in the future. When in doubt we seek consent from the enquirer to process his/her data in order to be ably to comply with their request. We DO NOT ‘cold call’ or send unsolicited e-mails to private individuals and restrict any such communications to existing customer companies when some new product/information becomes available.

4. Retention periods for personal data

In general the information that we hold has long term relevance, even extending many years. In cases where we despatch goods directly to private individuals, we retain their data either… … to the end of any statutory ‘returns’ period, or … to whatever statutory period is required in the case of sales documentation by HMRC. Note – we give a lifetime guarantee for the Criterion sleeping bags, so any personal data relating to that business is kept indefinitely to enable us to verify the veracity of any claimant.

5. Provision of personal data to 3rd parties, including overseas

This is not done generally. However, occasions arise when we receive an enquiry from a person who is resident in an overseas country where we have a distributor. In such cases we may pass the enquiry onto our distributor with a request for it to respond directly to the enquirer. We usually copy the enquirer into such a request. Another instance is if we are involved in triangular business whereby we sell another company’s goods to our customer and put the two sides in contact with each other for technical reasons. This only involves companies, but contact details that we may pass across may also include private telephone/email information. We may also pass personal data such as name, address, phone number and e-mail address to delivery companies and freight forwarders for the purpose of delivering goods ordered from us. In the above instances the processing of personal data is done for contractual and legitimate interest purposes, as a means of facilitating business.

6. Agreement

By submitting your personal information to us you agree to the storing, processing and transfer of your data as detailed in the sections above.

7. Right to request removal and right to object

Any person whose data we hold has the right to request … a copy of the data that we hold and/or that it be modified and/or that it be removed from our records. Such requests should be made in writing by letter to our office address, 39 Leinster Road, Swintonn, M27 5YQ. We will comply with such requests as soon as practically possible, and no later than within 30 days of receiving the request. We will not respond to requests sent by electronic means as we have no way of verifying the sender. If said person is dissatisfied with any aspect of our actions he/she has th right to raise a complaint with ICO, whose contact details are: Wycliffe House, Water Lane, Wilmslow, SK9 5AF Tel: 0303 123 1113 Further information can be obtained from their website www.ico.org.uk

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