A guide to how we look after your information
We understand that your privacy is important to you and that you care about how your information is used and shared online. We respect and value the privacy of everyone who visits our website and will only collect and use information in ways that are useful to you and in a manner consistent with your rights and our obligations under the law.
1 Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
“Account” means an account required to access and/or use certain areas and features of Our Website;
“Cookie” means a small text file placed on your computer or device by our website when you visit certain parts of our website and/or when you use certain features of our website. Details of the cookies used by our website are set out in section 12 below;
“Our Website” means this website, toffeln.com, toffeln.shop, toffelnsurgical.com and any associated websites, administration tools and/or applications to be provided by us to you;
“UK and EU Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended in 2004, 2011 and 2015; and
“We/Us/Our” means Toffeln Ltd Registered in England and Wales, 07564620, at Unit 2 Bridge Road, Kingswood, Bristol BS15 4FW. VAT Registered GB302628880.
2 Information about Us
2.1 Our websites, toffeln.com, toffeln.shop, toffelnsurgical.com, are owned and operated by us.
2.2 We are regulated by the Information Commissioners Office (ICO) and the terms of the Data Protection Act 1998.
2.3 Our ICO data protection number is ZA117074.
3 Scope – What Does This Policy Cover?
Information collected and stored automatically
Some data will be collected automatically by our websites; other data will only be collected if you voluntarily submit it, for example, when signing up for an Account.
The law on data protection sets out a number of different reasons for which a company may collect and process your personal data, including:
In specific situations, we can collect and process your data with your consent. For example, when you tick a box to receive email newsletters.
When collecting your personal data, we’ll always make clear to you which data is necessary in connection with a particular service.
In certain circumstances, we need your personal data to comply with our contractual obligations.
For example, if you order an item from us for home delivery, we’ll collect your address details to deliver your purchase, and pass them to our courier.
If the law requires us to, we may need to collect and process your data.
For example, we can pass on details of people involved in fraud or other criminal activity affecting the partnership to law enforcement.
In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests.
For example, as a customer we will use your purchase history to send you or make available personalised offers.
We also combine the shopping history of many customers to identify trends and ensure we can keep up with demand, or develop new products/services.
We may use your details to send you direct marketing information by email or post, telling you about products and services that we believe might interest you. Where you are a non-business customer, we will have obtained your specific approval to do this first.
4 Depending upon your use of our website, we may collect some or all of the following data:
4.2 business/company name;
4.3 job title;
4.5 contact information such as email addresses and telephone numbers;
4.6 demographic information such as post code, preferences and interests;
4.7 financial information such as credit / debit card numbers;
4.8 IP address (automatically collected);
4.9 web and mobile browser type and version (automatically collected);
4.10 operating system (automatically collected);
4.11 a list of URLs starting with a referring website, your activity on our website, and the website you exit to (automatically collected).
Please also be advised we do not store credit/debit card details within our Website nor do we share financial details with any third parties.
5 How Do We Use Your Data?
5.1 All personal data is stored securely in accordance with the principles of the Data Protection Act 1998. For more details on security see section 6, below.
5.2 We use your data to provide the best possible products and services to you. This includes:
5.2.1 Providing and managing your Account;
5.2.2 Providing and managing your access to Our Website;
5.2.3 Personalising and tailoring your experience on Our Website;
5.2.4 Supplying our products and services to you;
5.2.5 Personalising and tailoring our products and services for you;
5.2.6 Responding to communications from you;
5.2.7 Supplying you with email updates, newsletters and general communications that you have subscribed to (you may of course unsubscribe or opt-out at any time through links provided at the bottom of any marketing email or by requesting by emailing email@example.com);
5.2.8 Market research;
5.3 We will not send you any unsolicited marketing or spam and will take all reasonable steps to ensure that we fully protect your rights and comply with our obligations under the Data Protection Act 1998 and the Privacy and Electronic Communications (EC Directive) Regulations 2003, as amended in 2004, 2011 and 2015 as well as General Data Protection Regulation (GDPR) (EU) 2016/679.
What happens if you send us personal information?
6 How and Where Do We Store Your Data?
6.1 We only keep your data for as long as we need to in order to use it as described above in section 5, and/or for as long as we have your permission to keep it.
6.2 Your data will only be stored within the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland and Liechtenstein).
6.3 Data security is of great importance to us, and to protect your data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through our Website.
6.4 Steps we take to secure and protect your data including password protection, secure encryption, physical and people processes.
6.5 Notwithstanding the security measures that we take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to us data via the internet.
7 Do We Share Your Data?
7.1 We may share your data with other companies only within our group. Where applicable, this includes our subsidiaries AND/OR our holding company and its subsidiaries.
7.2 We may sometimes contract with third parties to supply products and services to you on our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising and marketing. In some cases, the third parties may require access to some of your data. Where any of your data is required for such a purpose, we will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under the law.
7.3 We may compile statistics about the use of Our Website including data on traffic, usage patterns, user numbers, sales and other information. All such data will be anonymised and will not include any personally identifying information. We may from time to time share such data with third parties such as prospective investors, affiliates, partners and advertisers. Data will only be shared and used within the bounds of the law.
7.4 In certain circumstances we may be legally required to share certain data held by us, which may include your personal information, for example, where we are involved in legal proceedings, where we are complying with the requirements of legislation, a court order, or a governmental authority. We do not require any further consent from you in order to share your data in such circumstances and will comply as required with any legally binding request that is made of us.
8 How Can You Control Your Data?
8.1 When you submit information via Our Website, you may be given options to restrict our use of your data. In particular, we aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details AND/OR by managing your Account).
9 Your Right to Withhold Information
9.1 You may access certain areas of our website without providing any data at all. However, to use all features and functions available on our website you may be required to submit or allow for the collection of certain data.
10 How Can You Access Your Data?
You have the right to request:
Access to the personal data we hold about you, free of charge in most cases.
The correction of your personal data when incorrect, out of date or incomplete.
That we stop using your personal data for direct marketing (either through specific channels, or all channels).
That we stop any consent-based processing of your personal data after you withdraw that consent.
Review by a Partner of any decision made based solely on automatic processing of your data (i.e. where no human has yet reviewed the outcome and criteria for the decision).
You can contact us to request to exercise these rights at any time as follows:
To ask for your information please contact Toffeln Ltd by email firstname.lastname@example.org. To ask for your information to be amended please use the same email address or contact our Customer Services team on 0345 500 4433.
If we choose not to action your request, we will explain to you the reasons for our refusal.
Your right to withdraw consent
Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent.
Where we rely on our legitimate interest
In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation.
We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.
You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We must always comply with your request.
Checking your identity
To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Notice.
If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.
12 What Cookies Do We Use and What For?
12.2 By using Our Website you may also receive certain third party Cookies on your computer or device. Third party Cookies are those placed by websites, services, and/or parties other than us. We use third party Cookies on Our Website for advertising services and conversion tracking. For more details, please refer to section 5, above, and to section 12.6 below. These Cookies are not integral to the functioning of Our Website.
12.3 All Cookies used by and on Our Website are used in accordance with current UK and EU Cookie Law.
12.4 Before Cookies are placed on your computer or device, subject to section 12.5, you will be shown a message bar requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Website may not function fully or as intended.
12.5 You can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
12.6 You can choose to delete Cookies at any time however you may lose any information that enables you to access our website more quickly and efficiently including, but not limited to, login and personalisation settings.
12.7 It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
13 Contacting Us
About the company
Unit 2 Bridge Road, Kingswood, Bristol BS15 4FW UK
Should you at any time wish to know what information is held by ourselves please feel free to contact us whereupon we shall endeavour to provide you with that information as soon as possible. At this point, you will have the opportunity of amending any inaccuracies.
Use and acceptance of these terms