- Websites we operate from which you are accessing this Privacy Policy (the “Websites”);
- Software applications from which you are accessing this Privacy Policy (the “Apps”);
- Our social media pages and apps that link to this Privacy Policy (collectively, our “Social Media Pages”);
- Emails in HTML-format that we send to you with a link to this Privacy Policy or other relevant communications with you
- Your offline business interactions with us.
We refer to the Websites, Apps, Social Media Pages, emails, and offline business interactions as the “Services.”
PERSONAL INFORMATION
“Personal Information” is information that identifies you as an individual or relates to an identifiable individual. The Services collect Personal Information, including:
- Name
- Postal address (including billing and shipping addresses)
- Telephone number
- Email address
- IP address (we may also derive your approximate location from your IP address)
- Payment card details
- Profile picture
- ID for Social Media Accounts
- Personal Information contained in surveys or feedback that you provide to us or in competitions in which you participate
Collection of Personal Information
We and our service providers collect Personal Information in a variety of ways, including:
- We collect Personal Information through the Services, for example, when you sign up for a newsletter, register an account to access the Services, visit our stores, attend one of our events, place an order over the phone, contact customer service, or make a purchase.
- We receive your Personal Information from other sources, for example:
- publicly available databases;
- joint marketing partners, when they share the information with us.
- If you link your social media account to your Services account, you will share certain Personal Information from your social media account with us, for example, your name, email address, photo, list of social media contacts, and any other information that may be or you make accessible to us when you connect your social media account to your Services account.
Collecting Personal Information is necessary to provide the requested Services to you. If you do not provide the required information, we may not be able to provide the Services. If you disclose any Personal Information relating to other people to us or to our service providers in connection with the Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.
Use of Personal Information
We and our service providers may use Personal Information for the following purposes:
- To ensure the Services function and to fulfil your requests.
- To provide you with the Services, such as arranging access to your registered account, and providing you with related benefits, special promotions, or customer service.
- To respond to your questions and fulfill your requests, when you contact us via one of our online contact forms or otherwise, for example, when you send us questions, suggestions, compliments or complaints, or when you request a quote or other information about our Services.
- To complete your transactions, process returns and exchanges, verify your information, and provide you with related benefits, special promotions, or customer service.
- To send administrative information to you, such as changes to our terms, conditions, and policies.
- To allow you to send messages to another person through the Services if you choose to do so.
We do this to manage our contractual relationship with you and/or to comply with a legal obligation.
- To provide our newsletter and/or other marketing materials and facilitating social sharing.
- To send you marketing related emails, with information about our services, new products and other news about our company.
- To facilitate social sharing functionality that you choose to use.
We do this with your consent or where we have a legitimate interest.
- To analyse Personal Information for business reporting and providing personalized services.
- To analyse or predict our users’ preferences in order to prepare aggregated trend reports on use of our digital content so that we can improve our Services.
- To better understand your interests and preferences, so that we can personalize our interactions with you and provide you with information and/or offers tailored to your interests.
- To better understand your preferences so that we can deliver content via our Services that we believe will be relevant and interesting to you.
We provide personalized services based on our legitimate interests, and with your consent to the extent required by applicable law.
- To make it possible to participate in prize draws, competitions and other promotions.
- We may offer you the opportunity to enter prize draws, competitions or other promotions.
- Some of these promotions are subject to additional rules. These rules provide information about how we will use and disclose your Personal Information. Please read those additional rules before choosing to participate.
We use this information to manage our contractual relationship with you.
- Aggregating and/or anonymizing Personal Information.
- We may aggregate and/or anonymize Personal Information so that it will no longer be considered Personal Information. We do so to generate other data for our use, which we may use and disclose for any purpose, as it no longer identifies you or any other individual.
- To achieve our business goals
- For data analysis, e.g. to improve the efficiency of our Services.
- For audits, to verify that our internal processes function as intended and to meet legal, regulatory, or contractual requirements.
- For fraud prevention and fraud security monitoring purposes, e.g. to detect and prevent cyberattacks or attempted identity theft.
- For developing new products and services.
- For enhancing, improving, repairing, maintaining, or modifying our current products and services, as well as undertaking quality and safety assurance measures.
- For identifying usage trends, e.g. understanding which parts of our Services are of most interest to users.
- For determining the effectiveness of our promotional campaigns, so that we can tailor our campaigns to the needs and interests of our users.
- For operating and expanding our business activities, e.g. understanding which parts of our Services are of most interest to our users so we can focus our energies on meeting our users’ interests.
We do this to manage our contractual relationship with you, to comply with a legal obligation, and/or based on our legitimate interest.
Disclosure of Personal Information
We share Personal Information as follows:
- Bristan is the party responsible for the management of the shared Personal Information. To our third party service providers, to facilitate services they provide to us.
- These can include providers of services such as website hosting, data analysis, payment processing, order fulfillment, return authorization, fraud prevention, information technology and related infrastructure provision, customer service or related benefits (including special promotions), email delivery, auditing, and other services.
- To third party dealers. For example:
- You can use the dealer locator on our Services to send a contact request to the dealer of your choice. We do not check the information submitted by you, but we pass on your enquiry directly to the dealer, who then obtains the information submitted by you, including your Personal Information.
- We share personal information with third parties who sponsor prize draws, competitions, and similar promotions.
- By using the Services, you may choose to disclose Personal Information.
- On message boards, chat, profile pages, blogs, and other services to which you are able to post information and content (including, without limitation, our Social Media Pages). Please note that any information you post or disclose through these services will become public and may be available to other users and the general public.
- Through your social sharing activity. When you connect your Services account to your social media account, you will share information with your friends linked to your social media account, with other users, and with your social media account provider. By doing so, you are allowing us to share this information, and you understand that the use of shared information will be governed by the social media provider’s privacy policy.
Other Uses and Disclosures
We also use and disclose your Personal Information as necessary or appropriate, in particular when we have a legal obligation or legitimate interest to do so:
- To comply with applicable law and regulations.
- This may include laws outside your country of residence.
- To cooperate with public and government authorities.
- To respond to a request or to provide information we believe is necessary or appropriate.
- These can include authorities outside your country of residence.
- To cooperate with law enforcement.
- For example, when we respond to law enforcement requests and orders or provide information we believe is important.
- To enforce our terms and conditions
- To protect our rights, privacy, safety or property, and/or that of our third parties, you or others.
- In connection with a sale or business transaction.
- We have a legitimate interest in disclosing or sharing your Personal Information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings) affecting our business, assets or stock or any part thereof.
OTHER INFORMATION
“Other Information” is any information that cannot be used to identify you as an individual or does not directly relate to you as an identifiable individual. For more information is our Cookies & Similar Technologies Notice.
Uses and Disclosures of Other Information
We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as Personal Information under applicable law, we may use and disclose it for the purposes for which we use and disclose Personal Information as detailed in this Policy. In some instances, we may combine Other Information with Personal Information. In such case, we will treat the combined information as Personal Information for as long as it is combined.
SECURITY
We strive to use appropriate organizational, technical and administrative measures to protect Personal Information in our Business. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us using the details in the “Contacting Us” section below.
CHOICES AND ACCESS
Your choices regarding our use and disclosure of your Personal Information
We give you choices regarding our use and disclosure of your Personal Information for marketing purposes. You may opt out from:
- Receiving marketing-related emails from us. If you no longer wish to receive marketing related emails from us in the future, you may opt out by unsubscribing directly in the email.
- Sharing of your Personal Information with affiliated companies for their direct marketing purposes. If you would like us to stop sharing your Personal Information with our affiliates for their direct marketing purposes, you can let us know by emailing us at gdpr@bristan.com
- Sharing of your Personal Information with unaffiliated third parties for their direct marketing purposes. If you would like us to stop sharing your Personal Information with unaffiliated third parties for their direct marketing purposes, you can let us know by emailing us at gdpr@bristan.com
We will endeavour to comply with your request(s) as soon as possible. Please note that if you opt out of receiving marketing emails from us, we may still send you important administrative communications, from which you cannot opt out of.
Accessing, changing, or deleting (erasing) your Personal Information
If you would like to request to access, correct, update, suppress, restrict, or delete (erase) Personal Information; or if you want to object to or opt out of the processing of Personal Information; or if you would like to request a copy of your Personal Information for transfer to another company (to the extent you are entitled to such rights under applicable law), you may contact us using the details in the “Contacting Us” section below. We will process your request in accordance with applicable law. If you are a California resident, please refer to the “Additional Information Regarding California” section at the end of this Policy for more information about the requests you may make under the CCPA.
Please state clearly in your request which Personal Information you would like to have changed or whether you would like to have your Personal Information deleted (erased) from our database. For your protection, we may only implement requests with respect to the Personal Information linked with the email address that you use to send us your request, and we may need to verify your identity before processing your request. We will endeavour to comply with your request as soon as reasonably practicable.
Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion (e.g., when you make a purchase or enter a promotion, you may not be able to change or delete the Personal Information provided until after the completion of such purchase or promotion). You can also lodge a complaint with a data protection authority for your country or region where you have your habitual residence or place of work or where an alleged infringement of applicable data protection law is taking place. A list of data protection authorities for the EU/EEA is available at https://edpb.europa.eu/about-edpb/about-edpb/members_en and the data protection authority for the UK is the Information Commissioner’s Office.
RETENTION PERIOD
We retain Personal Information for as long as necessary or permitted in regard to the purpose(s) for which it was collected and in accordance with applicable law.
The criteria used to determine our retention periods include:
- The period during which there is an ongoing relationship with you and we are providing the Services to you (e.g. for as long as you have an account with us or keep using the Services);
- Whether we are under a legal obligation (e.g. certain laws require us to keep records of your transactions for a certain period of time before we can delete them)
- Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).
THIRD PARTY SERVICES
This Privacy Policy does not cover, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating any website or service linked to in the Services. The link in the Services does not imply endorsement of the linked site or service by us or by our affiliates.
We are also not responsible for the information collection, use, disclosure, or security policies or practices of other organizations, such as Facebook, Apple, Google, Microsoft, RIM, or any other app developer, app providers, social media platform providers, operating system providers, wireless service providers, or device manufacturers, including with respect to any Personal Information you disclose to other organizations through or in connection with the Apps or our Social Media Pages.
THIRD PARTY ADVERTISING
We use third-party advertising companies to serve advertisements regarding goods and services that may be of interest to you when you access and use the Services and other websites or online services.
- You may receive advertisements based on information relating to your access to and use of the Services and other websites or online services on one of your devices, as well as information received from third parties. These companies place or recognize a unique cookie on your browser (including through the use of pixel tags). They may also use these technologies, along with information they collect about your browsing behaviour, to recognize you across the devices you use, such as your mobile phone and laptop. If you would like more information about this practice, and to learn how to opt out of it on computer and mobile browsers on the device you are using to access this Privacy Policy, please visit http://optout.aboutads.info/#/ and http://optout.networkadvertising.org/#/. You can download the AppChoices app to control interest-based advertising at: www.aboutads.info/appchoices.
USE OF SERVICES BY MINORS
The Services are not directed to individuals under the age of sixteen (16), and we do not knowingly collect Personal Information from individuals under the age of 16.
Your Right To Request Removal of Content
If you are a resident of California, under 18, and a registered user of the Services, you may request that we remove content or information that you have posted to the Services by emailing us at gdpr@bristan.com, pursuant to California Business & Professions Code section 22581. Please note that your request does not ensure complete or comprehensive removal of the content or information, because e.g. some of your content may have been reposted by another user.
JURISDICTION AND CROSS-BORDER TRANSFER
Your Personal Information may be stored and processed in any country where we are located or where we employ service providers. By using the Services you understand that your information will be transferred to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Information.
ADDITIONAL INFORMATION REGARDING THE EEA/UK: Some non-EEA/UK countries are recognized by the European Commission and UK government as providing an adequate level of data protection according to EEA/UK standards (the full list of these countries is available here for the EEA and here for the UK). For transfers from the EEA/UK to countries not considered adequate by the European Commission or the UK government, we have put in place adequate measures, such as standard contractual clauses adopted by the European Commission and the UK government and binding corporate rules to protect your Personal Information. You may obtain a copy of these measures by contacting us in accordance with the “Contact Us” section below.
SENSITIVE INFORMATION
Unless we request it, we ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., National Insurance numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background, or trade union membership on or through the Services or in any other way.
THIRD PARTY PAYMENT SERVICE
The Services may provide functionality allowing you to make payments to the Company using third-party payment services with which you have created your own account. When you use such a service to make a payment to us, your Personal Information will be collected by such third party and not by us, and will be subject to the third party’s privacy policy, rather than this Privacy Policy. We have no control over, and are not responsible for, this third party’s collection, use, and disclosure of your Personal Information.
UPDATES TO THIS PRIVACY POLICY
The “LAST UPDATED” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised. Any changes will become effective when we post the revised Privacy Policy on the Services.
CONTACTING US
Bristan Group Limited, is the company responsible for collection, use, and disclosure of your Personal Information under this Privacy Policy. If you have any questions about this Privacy Policy, please contact us at
gdpr@bristan.com
or
Birch Coppice Business Park
Pooley Hall Drive
Dordon
Tamworth
B78 1SG
You may also contact our Group Data Protection Officer at gdpr@bristan.com. Because email communications are not always secure, please do not include credit card or other sensitive information in your emails to us.
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