We are committed to protecting and respecting your privacy.
Everyone has rights with regard to the way in which their personal information is handled. During the course of our activities we will collect, store and process personal information about our customers, suppliers and other third parties, and we recognise that the correct and lawful treatment of this data will maintain confidence in the organisation and will provide for successful business operations.
This policy sets out the basis on which any personal information 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 information and how we will treat it.
Data protection principles
When processing your information, we must comply with the six enforceable principles of good practice. These provide that your personal information must be:
- processed lawfully, fairly and in a transparent manner,
- processed for specified, explicit and legitimate purposes,
- adequate, relevant and limited to what is necessary,
- accurate and kept up-to-date,
- kept for no longer than is necessary, and
- processed in a manner than ensures appropriate security.
Information you give to us
We may collect, use, store and transfer different kinds of personal information about you, including:
- Identity Data, such as first name, maiden name, last name, marital status, title, date of birth and gender.
- Contact Data, such as your billing address, delivery address, email address and telephone numbers,
- Financial Data, such as bank account and payment card details,
- Transaction Data, including details about payments to and from you, and other details of products and services you purchase from us,
- Technical Data, including internet protocol (IP) address, 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 our website.
- Profile Data, such as purchases or orders made by you, your interests, boiler make/model, preferences, feedback and survey responses,
- Usage Data, including information about how you use our website, products and services, and
- Marketing Data, such as your preferences in receiving marketing from us and our third parties, and your communication preferences.
‘Special category’ data
Information relating to your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, criminal convictions, sex life or sexual orientation, or certain types of genetic or biometric data is known as ‘special category’ data.
During the course of dealing with you, we do not expect to collect any ‘special category’ data about you.
How we collect your personal information
We may obtain personal information by directly interacting with you, such as:
- placing orders for products on our website,
- subscribing to our services or publications, or otherwise requesting marketing material to be sent to you, or
- corresponding with us by phone, email, letters or otherwise.
We may obtain personal information via automated technology when you interact with our website by using cookies, server logs and other similar technologies.
We may also collect personal information about you from third parties or publicly-available sources, such as:
- analytics providers (such as Google),
- advertising networks,
- credit reference agencies such as those detailed at https://www.experian.co.uk/legal/crain/
- search information providers
- providers of technical, payment and delivery services,
- Companies House, LinkedIn, Facebook, Twitter, LinkedIn and the electoral register.
How we use your personal information
We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
- you have given us consent,
- we need to perform a contract we are about to enter into, or have entered into, with you,
- where it is necessary for our or a third party’s legitimate interests, and your interests and rights do not override those interests, or
- where we need to comply with a legal or regulatory obligation.
We will only use ‘special category’ information:
- provided we have your explicit consent to use it,
- where we believe that we need to use that data to protect your vital interests where you are not able to provide us with your explicit consent,
- where it is necessary for reasons of substantial public interest,
- where you have previously made that data public knowledge, or
- if we need to use that data to establish, exercise or defence legal claims.
Purposes for which we will use your personal information
We may use your personal information for a number of different purposes. For each purpose, we are required to confirm the ‘legal basis’ that allows us to use your information, as follows:
Purposes for which we will use the information you give to us
To register you as a new customer
It will be necessary for the performance of the contract between you and us
To process your order and, if accepted, to deliver the products to you (including managing payments, fees and charges)
It will be necessary for the performance of the contract between you and us
To complete a credit check to assess your creditworthiness, the suitability of products check your identity, manage your account, trace and recover debts and prevent criminal activity
It will be necessary for the performance of the contract between you and us and for out legitimate interests namely to recover debts due to us.
To collect and recover money owed to us
It will be necessary for our legitimate business interests, namely to ensure we receive payment for products that you have ordered from us
It will be necessary for the performance of the contract between you and us and for our legitimate business interests, namely to ensure you are aware of our current terms and conditions
To administer our website and for internal operations, including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting data, research, statistical and survey purposes, to allow you to participate in interactive features of our service, when you choose to do so, to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you and to make suggestions and recommendations to you and other users of our website about goods or services that may interest you or them
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
It will be necessary for our legitimate interests, namely to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy.
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
It will be necessary for our legitimate interests, namely to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy.
To provide you with information about special offers and other products we sell that are similar to those that you have already received from us
Where you have previously received marketing communications from us, then it will be necessary for our legitimate business interests, namely to ensure you continue to receive communications that you have previously agreed to receive and to develop our products/services and grow our business.
In all other cases, we will only do this if you give us your consent
We will only use your personal information for the purpose(s) 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.
What if you cannot or will not provide us with your personal information
It is a contractual requirement for you to provide us with certain information, namely your name, address, email address, contact number, boiler make and model and debit/credit card information. If you do not provide us with that information, we will be unable to accept and process your order and deliver the products to you.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Promotional offers from us
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 information from us or purchased goods or services from us and you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes. Should you be happy to hear about any future promotions or products, our promise is to never inundate you. We will never send more than 4 a year.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
We use the following cookies:
- Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
- Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
- Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
- Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
You can find more information about the individual cookies we use and the purposes for which we use them in the table below:
Tracking user behaviour and conversion data.
You can opt out of these cookies by disabling cookies or increasing privacy settings on social media or search engines.
Tracking user’s interaction with the website.
You can opt out of these cookies by rejecting cookies (please see below for more information).
Tracking interaction with emails such as opens and link clicks
You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.
Except for essential cookies, all cookies will expire after 2 years.
Disclosure of your information
We may share your personal information with the parties set out below:
- other companies within our group, including EFS Portfolio and Hassle Free Boilers,
- providers of IT and system administration services to our business, including Dropbox, One Drive, Google Drive, One Drive, Interbacs, Joblogic, Sharepoint and other online cloud providers,
- our professional advisers (including solicitors, bankers, auditors and insurers),
- HM Revenue & Customs, the Information Commissioner’s Office, Financial Conduct Authority, regulators and other authorities who require reporting of processing activities in certain circumstances,
- Credit reference agencies such as Experian and other credit reference agencies such as those detailed at https://www.experian.co.uk/legal/crain/,
- Debt collection agencies such as Credit Style Ltd,
- HM Land Registry,
- Signable (digital contract provider),
- BACS (automated payment provider),
- analytics and search engine providers that assist us in the improvement and optimisation of our website,
- our chosen subcontractors (a list of our relevant subcontractors is available on request), and
- third parties to whom we may choose to sell, 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 information in the same way as set out in this policy.
We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.
Where we store your personal information
All information you provide to us is stored on our secure servers in the United Kingdom.
We will take all steps reasonably necessary to ensure that your data is treated securely, including taking the following safeguards:
- PCI DSS standards. We comply with the Payment Card Industry Data Security Standards in relation to debit/credit card payments made on our website.
- Building entry controls. We have security such as door locks and a building alarm at our premises.
- Secure lockable desks and cupboards. Desks and cupboards are kept locked when not in use if they hold confidential information of any kind.
- Methods of disposal. Paper documents are disposed of by shredding in a manner that ensures confidentiality.
- Data safeguards. Including use of Joblogic to safeguard information.
- Overseas transfers. Whenever we transfer your personal information outside the United Kingdom, we ensure a similar degree of protection is afforded to it by ensuring that we apply appropriate safeguards. We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data. Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
If you are concerned about the levels of data security in any of those countries, please let us know and we will endeavour to advise what steps will be taken to protect your data when stored overseas.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, 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.
How long we will store your personal information
The length of time that we will store your data will depend on the ‘legal basis’ for why we are using that data, as follows:
Length of time
Where we use/store your data because it is necessary for the performance of the contract between you and us
We will use/store your data for as long as it is necessary for the performance of the contract between you and us
Where we use/store your data because it is necessary for us to comply with a legal obligation to which we are subject
We will use/store your data for as long as it is necessary for us to comply with our legal obligations
Where we use/store your data because it is necessary for our legitimate business interests
We will use/store your data until you ask us to stop. However, if we can demonstrate the reason why we are using/storing your data overrides your interests, rights and freedoms, then we will continue to use and store your data for as long as it is necessary for the performance of the contract between you and us (or, if earlier, we no longer have a legitimate interest in using/storing your data)
Where we use/store your data because you have given us your specific, informed and unambiguous consent
We will use/store your data until you ask us to stop
To determine the appropriate retention period for personal information, we consider the amount, nature and sensitive of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
You have various legal rights in relation to the information you give us, or which we collect about you, as follows:
- You have a right to access the information we hold about you free-of-charge, together with various information about why and how we are using your information, to whom we may have disclosed that information, from where we originally obtained the information and for how long we will use your information.
- You have the right to ask us to rectify any information we hold about you that is inaccurate or incomplete.
- You have the right to ask us to erase the information we hold about you (the ‘right to be forgotten’). Please note that this right can only be exercised in certain circumstances and, if you ask us to erase your information and we are unable to do so, we will explain why not.
- You have the right to ask us to stop using your information where: (i) the information we hold about you is inaccurate; (ii) we are unlawfully using your information; (iii) we no longer need to use the information; or (iv) we do not have a legitimate reason to use the information. Please note that we may continue to store your information, or use your information for the purpose of legal proceedings or for protecting the rights of any other person.
- You have the right to ask us to transmit the information we hold about you to another person or company in a structured, commonly-used and machine-readable format. Please note that this right can only be exercised in certain circumstances and, if you ask us to transmit your information and we are unable to do so, we will explain why not.
- Where we use/store your information because it is necessary for our legitimate business interests, you have the right to object to us using/storing your information. We will stop using/storing your information unless we can demonstrate why we believe we have a legitimate business interest which overrides your interests, rights and freedoms.
- Where we use/store your data because you have given us your specific, informed and unambiguous consent, you have the right to withdraw your consent at any time.
- You have the right to object to us using/storing your information for direct marketing purposes.
If you wish to exercise any of your legal rights, please contact our customer services team by writing to the address at the top of this policy, or by emailing us at email@example.com.
You also have the right, at any time, to lodge a complaint with the Information Commissioner’s Office if you believe we are not complying with the laws and regulations relating to the use/storage of the information you give us, or that we collect about you.
No fee usually required
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.
What we may need from you
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.
Time limit to respond
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.
Opting out of receiving marketing communications
You can ask us to stop sending you marketing communications at any time by contacting our customer services team by writing to the address at the top of this policy, or by emailing us at firstname.lastname@example.org.
We do not use automated decision-making processes.
Third party links
Our 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. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
Changes to our policy
Questions, comments and requests regarding this policy are welcomed and should be addressed to our customer services team by writing to:
- Data Queries, Hassle Free Boilers, Kemble Airfield Enterprise Park, Cirencester, GL7 6BQ,
or calling us on: 03456 474747.