As a customer of NuCONNECT, we respect your right to privacy at all times and have outlined this Privacy Statement as a means to clarify how we deal with any data you provide us while visiting and/or purchasing with us on this site, ‘www.nuconnect.co.uk’. By using this site you are agreeing with this privacy statement, if you are unhappy with any content listed here please do not use this site. Any external links to other websites are clearly identified and we do not accept responsibility for any content or terms and conditions on these other websites.
1.1 Purpose of this Privacy Notice
- This Privacy Notice aims to give you information on how we collect and process your personal data through your use of this website, including any data you may provide through this website when you use our online ordering facility, sign up to our newsletter, submit a query or use other online services;
- This website is not intended for children and we do not knowingly collect data relating to children.
- It is important that you read this Privacy Notice together with any other Privacy Notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Notice supplements the other notices and is not intended to override them.
- This Privacy Notice is issued on behalf of NuCONNECT Ltd in the United Kingdom, who is the controller and responsible for this website.
- If you have any questions about this Privacy Notice, including any requests to exercise your legal rights, please contact email@example.com.
- You have the right to make a complaint at any time to the Office of the Data Protection Commission ("ODPC"), the Irish supervisory authority for data protection issues at firstname.lastname@example.org. We would, however, appreciate the chance to deal with your concerns before you approach the ODPC so please contact us in the first instance.
1.3 Changes to the Privacy Notice and your duty to inform us of changesThe data protection law in the UK and Ireland will change on 25 May 2018. Although this Privacy Notice sets out most of your rights under the new laws, we may not yet be able to respond to some of your requests (for example, a request for the transfer of your personal data) until May 2018 as we are still working towards getting our systems ready for some of these changes. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
1.4 Third-party linksThis 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.
2.1 Types of Data
- Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
- We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier, and title.
- Contact Data includes billing and/or shipping address, email address and telephone numbers.
- Financial Data includes bank account (where applicable and provided) and payment card details.
- Transaction Data includes details about payments to and from you or other offers you have purchased from us.
- Technical Data includes internet protocol (IP) address, your login data, 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 this website.
- Profile Data includes your username and password, purchases or orders made by you, (and when provided) your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our website.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
- We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Notice.
- We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
2.2 If you fail to provide personal dataWhere we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel a booking you have with us but we will notify you if this is the case at the time.
3.1 Direct interactions.You may give us your Identity, Contact and Financial Data filling in forms or by corresponding with us by post, phone, email, or otherwise. This includes personal data you provide when you:
- make a purchase online
- create an account on our website
- subscribe to our newsletter
- request marketing to be sent to you
- enter a competition, promotion or survey
- Apply for a job in our "Careers" section
- give us some feedback
- submit a query through the Contact Us form
3.2 Automated technologies or interactions.As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
3.3 Automated technologies or interactions.We may receive personal data about you from various third parties as set out below:
- Technical Data from the following parties:
- analytics providers such as Google
- advertising networks such as Google and Facebook
- search information providers such as Google and Bing
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Ingenico.
4.1 Lawful basis
- We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances where:
- we need to perform the contract we are about to enter into or have entered into with you
- it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests
- where we need to comply with a legal or regulatory obligation.
- Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email. You have the right to withdraw consent to marketing at any time by contacting us at email@example.com
4.2 Purposes for which we will use your personal data
- We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
- Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us at firstname.lastname@example.org if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
4.3 General marketingWe strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms set out in paragraphs 4.4 – 4.8.
4.4 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, received a product or service from us, or if you provided us with your details have not opted out of receiving that marketing.
4.5 Third-party marketingWe will get your express opt-in consent before we share your personal data with any company outside NuCONNECT for marketing purposes.
4.5 Opting out
- You can ask us or third parties to stop sending you marketing messages at any time by contacting us at email@example.com at any time. This will not apply to order confirmation or invoice emails for items you have purchased.
- Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a purchase of a product or service.
4.7 Change of purpose
- We will only use your personal data for the purposes 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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at firstname.lastname@example.org.
- If we need to use your personal data 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 data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5.1We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above:
- Internal Third Parties as set out in the Glossary
- External Third Parties as set out in the Glossary
- 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 or newly acquired businesses may use your personal data in the same way as set out in this Privacy Notice.
5.2We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
7.1We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
7.2We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable supervisory authority or other regulator of a breach where we are legally required to do so.
8.1We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
8.2To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
8.3By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax and other legal purposes.
8.4In some circumstances you can ask us to delete your data: see below for further information.
8.5In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
9.1Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
9.2If you wish to exercise any of the rights set out above, please contact us at email@example.com.
9.3You 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 may refuse to comply with your request in these circumstances.
9.4We 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.
9.5We try to respond to all legitimate requests within one month. Occasionally it may 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.
10.1 Lawful Basis
- Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best offering and the best and most secure experience; we make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests; we do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law); you can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us at firstname.lastname@example.org.
- Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
- Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
10.2 Third Parties
- Internal Third Parties: Other companies in the Biconic Group (to which NuCONNECT belongs) based in the EEA that provide IT and system administration services and marketing services to the Biconic Group.
- External Third Parties
- service providers based in Ireland, UK and in Netherlands who provide IT and system administration services, goods deliveries
- professional advisers acting as processors or controllers including lawyers, bankers, auditors and insurers based in the EEA who provide consultancy, banking, legal, insurance and accounting services
- the Revenue Commissioners, regulators and other authorities acting as processors or joint controllers based in the UK and Ireland who require reporting of processing activities in certain circumstances.