DATA PROTECTION POLICY – GENERAL
W V Howe Limited.
Company registration no. 507835.
The security of your data is our priority. We respect your privacy rights and pledge to handle your data fairly and legally at all times.
We are transparent about what data we collect about you and how we use it.
This policy gives you with information about:
how we use your data.
what personal data we collect.
how your privacy is maintained.
your legal rights relating to your personal data.
USING YOUR DATA
W V Howe (and our trusted partners) use your data:
to verify your identity
to provide goods to you.
to make available a tailored website.
to enable us to manage customer service interactions with you.
to manage your account(s).
for crime and fraud prevention, detection and related purposes.
to contact you, with your agreement, about promotional offers and products which we think may interest you.
for market research purposes.
where we have a legal right or duty to disclose your information (for example in relation to an investigation by a public authority
or in a legal dispute).
PROMOTIONS AND MARKETING
We use your personal data for marketing purposes (with your consent) and may update you with our latest offers.
You have the right to opt out of receiving promotional communications at any time by:
1. use the ‘unsubscribe’ link in emails or the “STOP” number for texts.
2. changing preferences via your account.
3. contact us as set out at the end of the policy.
If you visit our websites, you may receive personalised banner advertisements whilst browsing other websites.
Any banner advertisements you see will relate to products you have viewed whilst browsing our websites on your computer or
Data Share with third parties
Our service providers and suppliers
In order to make certain services available to you, we may need to share your personal data with some of our service partners.
These include IT, delivery and marketing service providers.
We will impose contractual obligations on service providers relating to data protection and security, which mean they can only use
your data to provide services to us and you, and for no other purposes.
Aside from our service providers, W V HOWE will not disclose your personal data to any third party, except as set out below.
We will never sell or rent our customer data to other organisations for marketing purposes.
We may share your data with:
credit reference agencies where necessary.
our carefully selected partners who provide W V HOWE products if we have your consent to do so.
government regulators, law enforcement agencies, courts/tribunals and insurers where we are required to do so:
to comply with legal obligations.
to exercise legal rights (for example in court cases).
for the prevention, detection, investigation of crime or prosecution of offenders. and
for the protection of our employees and customers.
We may sometimes share your data outside of the European Economic Area. This might occur when service providers are
located outside the EEA or if you are based outside the EEA. These transfers are subject to special rules under data protection laws.
In this event, we will ensure that the transfer will be compliant with the law and all personal data will be secure. We will use
standard data protection clauses which have been approved by the European Commission for such transfers.
Keeping your data
We will not retain your data for longer than necessary for the purposes set out in this Policy. Different retention periods apply for
different types of data, however the longest we will normally hold any personal data is 6 years.
COLLECTION OF PERSONAL DATA
We may collect the following information about you:
your contact details: postal address including billing and delivery addresses, telephone numbers (including mobile numbers)
and email address.
your name, age/date of birth and gender.
purchases and orders made by you.
your online browsing activities on our website.
your payment card details when you make a purchase.
your communication and marketing preferences.
your location at the time.
your communications with us.
other available personal data, including any which you have shared via a public platform (such as a Twitter feed or public Facebook
We do not knowingly collect data relating to children.
In some instances we may need to collect additional data for the purposes set out in this Policy. Some of the above personal data
is collected directly, for example when you set up an online account on our websites, or send an email to us. Other personal data
is collected indirectly, for example your browsing or shopping activity. We may also collect personal data from third parties who
have your consent to pass your details to us, or from publicly available sources.
We are committed to keeping your personal data secure.
regular cyber security assessments
encryption of data.
regular planning exercises to ensure we are ready to respond to cyber attacks and security incidents.
daily system testing.
internal policies setting out our data security approach and training for employees.
HOW TO HELP YOURSELF TO PROTECT YOUR DATA
If you are using a computing device in a public location, we recommend that you always log out and close the website browser
when you complete an online session.
We will never ask you to confirm any bank account or credit card details via email. If you receive an email claiming to be from
W V HOWE asking you to do so, please ignore it and do not respond.
Keep your account passwords private. Remember, anybody who knows your password may access your account.
When creating a password, use at least 8 characters. A combination of letters and numbers is best. Do not use dictionary words,
your name, email address, or other personal data that can be easily obtained. We also recommend that you frequently change
your password. You can do this accessing your online account.
Avoid using the same password for multiple online accounts.
You have the following rights:
the right in reasonable circumstances to request that we delete personal data held on you. where we no longer have any
legal reason to retain it (the right of erasure or to be forgotten).
the right to ask for a copy of personal data that we hold about you (the right of access).
the right to ask us to update and correct any outofdate or incorrect personal data that we hold about you (the right of rectification).
the right to opt out of any marketing communications that we may send you and to object to us using / holding your personal data
if we have no legitimate reasons to do so (the right to object).
the right in reasonable circumstances to ask us to restrict processing of data. This means that we would need to secure and
retain the data for your benefit but not otherwise use it (the right to restrict processing).
the right (in certain circumstances) to ask us to supply you with some of the personal data we hold about you in a structured
machine readable format and/or to provide a copy of the data in such a format to another organisation (the right to data portability).
We collect your personal data because is it necessary for:
the purposes of complying with our duties and exercising our rights under a contract for the sale of goods to a customer.
the pursuit of our legitimate interests as below.
complying with our legal obligations.
In general, we only rely on consent as a legal basis for processing personal data in relation to sending direct marketing
communications to customers via email or text message.
Customers have the right to withdraw consent at any time. Where consent is the only legal basis for processing,
we will cease to process data after consent is withdrawn.
The legal basis for processing customer data, is that it is necessary for our legitimate interests as follows:
promoting, marketing and advertising our products and services.
selling and supplying goods and services to our customers.
sending promotional communications which are relevant and tailored to individual customers.
understanding our customers’ behaviour, activities, preferences, and needs.
improving existing products and services and developing new products and services.
complying with our legal and regulatory obligations. protecting customers, employees and other individuals and maintaining
their safety, health and welfare.
other devices (such as smart ‘phones or ‘tablets’) as you browse this website. They are used to ‘remember’ when your computer
or device accesses our websites. Cookies are essential for the effective operation of our websites and to help you purchase online.
They are also used to tailor the products and services offered and advertised to you generally.
Collection of information
Some cookies collect information about browsing and purchasing behaviour when you access this website via the same computer
or device. This includes information about pages viewed, products purchased and your journey around a website.
The cookies stored on your computer or other device when you access our websites are designed by:
W V Howe, and on our behalf, and are necessary to enable you to a make purchases on our website.
Our partners who participate with us in marketing programmes.
Third parties who broadcast web banner advertisements on our behalf.
The main purposes for which cookies are used are:
1. For technical purposes essential to effective operation of our websites, particularly in relation to online transactions and
2. For us to market to you, particularly web banner advertisements and targeted updates.
3. To enable us to collect information about your browsing and shopping patterns, including to monitor the success of campaigns,
To do this you need to change your website browser settings to reject cookies. Further details on how to disable cookies for
the most popular browsers are set out below:
1. Choose Settings> Advanced
2. Under "Privacy and security," click “Content settings”.
3. Click “Cookies”
Microsoft Internet Explorer:
1. Choose the menu “tools” then “Internet Options”
2. Click on the “privacy” tab
3. Select the setting the appropriate setting
1. Choose Preferences > Privacy
2. Click on “Remove all Website Data”
1. Choose the menu “tools” then “Options”
2. Click on the icon “privacy”
3. Find the menu “cookie” and select the relevant options
Opera 6.0 and further:
1. Choose the menu Files”> “Preferences”
Depending on which cookies you disable, in general the website may not operate properly if cookies are switched off.
If you only disable third party cookies, you will not be prevented from making purchases on our sites. If you disable all cookies,
you will be unable to complete a purchase on our sites.
DATA PROTECTION OFFICER
We have appointed a Data Protection Officer to ensure we protect the personal data of our customers (and others) and comply
with data protection legislation.
If you wish to know more about how we use your personal data, or if you want to exercise your rights regarding your personal data,
please contact our Data Protection Officer by
telephone: 0121 433 3651.
email: [email protected]
write to: Data Protection Officer, W V Howe Limited, 65 Melchett Road, Kings Norton Business Centre, Birmingham, B30 3HP
A complaint can also be lodged with the Information Commissioner’s Office. Further information, including contact details,
is available at https://ico.org.uk.