Our Privacy Policy

This document explains how we use your personal data.

Welcome to The Willcox Group Limited’s privacy policy. This Privacy Notice explains how The Willcox Group Limited together with other companies within the Willcox group (which means our subsidiaries, our ultimate holding company and its subsidiaries from time to time) (“Willcox”, “We”, “Us”, “Our”) collects and processes your personal data when dealing with us or purchasing a product or services from us either in person, over the telephone or through our website

Willcox is the data controller in respect of all personal data collected from you and we are committed to safeguarding the privacy of our customers, business clients and other visitors. This policy explains how we handle your personal data.

1. How we use your personal data
1. This section provides you with details about:

1. what personal data we may process;
2. in the case of personal data that we did not obtain directly from you, where we obtained that data from, and what types of data we have collected;
3. the purposes for which we may process your personal data; and
4. the legal grounds on which we process your data.

2. Customer data. We may process information that you provide to us ("customer data"). This customer data may include your name, address, telephone number, email address, company name and in some instances credit card and bank details. We may use this data to provide you with a quote, samples and for providing our products and services to you.

The legal basis for this processing is for the purposes of performing our contract with you, or in taking steps at your request prior to entering into a contract and our legitimate interests, namely our interest in the proper administration of our business.

Where you are a consumer and have provided your consent for us to do so, we may contact you regarding the latest promotions and offers regarding our products and services and send you newsletters. 

3. Service data. If you are employed by one of our corporate customers (i.e. one of our distributors or retailers), which has a contractual arrangement with Willcox for the provision of goods or services (the “customer”), we may use your contact data where you have been appointed by the customer as our point of contact. We will process this personal data for the purposes of providing the goods and services to the customer, under the contract that we have with them. For these purposes, this data will be the “service data”. 

We will treat the customer as the controller of any service data that we are provided with. We may receive personal data in respect of such points of contact direct from the customer. We will process any such personal data referred to in this paragraph strictly in accordance with the instructions of the customer, not the individual point of contact, including sharing all such data with the customer.

The legal basis for this processing is our legitimate interests in supplying products or services to the customer, in managing and administering our relationship and contract with the customer, and in marketing our products and services to the customer.

Where you are an individual, sole trader, or working in a partnership and have provided your consent for us to do so, we may contact you regarding the latest promotions and offers regarding our products and services, and those of our partner organisations, and to send you newsletters. 

If you work for any other type of organisation such as a limited company, we may also contact you regarding the latest promotions and offers regarding our products and services, and those of our partner organisations, and to send you newsletters. This will be based on our legitimate interests in marketing our products and services and furthering our relationship with you.

4. Enquiry data. We may process information contained in any enquiry you submit to us regarding our products and services ("enquiry data"). The Enquiry data may include your name email address, phone number and information relating to your enquiry such as details of your desired design or inscription. The enquiry data may be processed for the purposes of offering, marketing and selling relevant bespoke products and/or services to you. 

The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.

5. Usage data. We may process data about your use of our website and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. 

The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.

6. Transaction data. We may process information relating to any payments made by you to us ("transaction data"). The transaction data may include your contact details, your bank account details, your credit card details and the transaction details. The transaction data may be processed for the purposes of processing these payments and keeping proper records of those transactions. 

The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely our interest in the proper administration of our website and business.

7. Delivery and Returns data. We may process information relating to any deliveries of our products or any products bought through a third-party distributor, and any information relating to the return of any such delivery (“delivery and returns data”). The delivery and returns data may include your name, address, postcode, telephone number, email address, reason for returning. The delivery and returns data may be processed for the purposes of delivering products to you, keeping proper records of those deliveries and for the processing of any returns. 

The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely our interest in the proper administration of our website and business.

8. Notification data. We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters and marketing materials relating to products and services that we provide ("notification data"). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters and marketing materials. 

Where you are a consumer the legal basis for this processing is consent. 

9. Correspondence data. We may process information contained in or relating to any communication that you send to us ("correspondence data"). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. 

The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.

10. Other processing activities. In addition to the specific purposes for which we may process your personal data set out above, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or to protect your vital interests or the vital interests of another natural person.

Please do not supply any other person's personal data to us unless we prompt you to do so.

2. Providing your personal data to others
1. To our partner services providers and distributors. We may disclose your personal data to our partner organisations who assist us in providing services to you, such as our couriers or delivery companies, or our distributors and retailers.
2. To our group companies. We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes set out in this policy.
3. Our insurers/professional advisers. We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining and maintaining insurance coverage, managing risks, obtaining professional advice and managing legal disputes.
4. Where we provide your personal data to any third party. Where we share your personal data with any third party, we will ensure this processing is protected by appropriate safeguards including a suitable data processing agreement with that third party. 
5. To comply with legal obligations. In addition to the specific disclosures of personal data detailed above, we may also disclose your personal data where such disclosure is necessary for compliance with a legal obligation we must comply with, or to protect your vital interests or the vital interests of another individual.
6. Should our company or its business or undertaking be sold or otherwise disposed of, your data will be passed to the purchasing or acquiring company to allow continued service.

 

3. Where your personal information is held

 

1. Information may be held at our offices and those of our group companies, third party agencies, service providers, representatives and agents as described above.

 

4. How long your personal information will be kept

 

1. We will keep your personal information while you have an account with us or we are providing products and services to you. Thereafter, we will keep your personal information for as long as is necessary:

• to respond to any questions, complaints or claims made by you or on your behalf;
• to show that we treated you fairly;
• to keep records required by law.

 

2. We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information.

5. Transfers of your personal data outside the European Economic Area 

If your personal data is transferred outside the EEA, we will ensure that either (a) The European Commission has made an "adequacy decision" with respect to the data protection laws of the country to which it is transferred, (b) we have entered into a suitable data processing agreement with the third party situated in that country to ensure the adequate protection of your data, or (c) where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. Transfers outside the EEA will be protected by appropriate safeguards.

6. Retaining and deleting personal data
1. Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes. 
2. Unless we contact you and obtain your consent for us to retain your personal data for a longer period, we will retain and delete your personal data as follows:

1. Contact data will be retained for 6 years following the date of our last contact or dealing with you, at the end of which period it will be deleted from our systems.
2. Service data will be retained for 6 years following the date of our last contact or dealing with you, at the end of which period it will be deleted from our systems.
3. Enquiry data will be retained for 6 years following the date of our last contact or dealing with you, at the end of which period it will be deleted from our systems.
4. Usage data will be retained for 6 years following the date of our last contact or dealing with you, at the end of which period it will be deleted from our systems.
5. Transaction data will be retained for 6 years following the date of our last contact or dealing with you, at the end of which period it will be deleted from our systems.
6. Financial data (which includes bank account and payment card details will be retained for 6 years following the date of our last contact or dealing with you, at the end of which period it will be deleted from our systems.
7. Delivery and returns data will be retained for 6 years following the date of our last contact or dealing with you, at the end of which period it will be deleted from our systems.
8. Notification data will be retained for 6 years following the date of our last contact or dealing with you, at the end of which period it will be deleted from our systems.
9. Correspondence data will be retained for 6 years following the date of our last contact or dealing with you, at the end of which period it will be deleted from our systems.

3. We may retain your personal data where such retention is necessary for compliance with a legal obligation or for tax purposes to which we are subject, or to protect your vital interests or the vital interests of another natural person.

7. Amendments
1. We may update this policy from time to time by publishing a new version on all of our websites.
2. You should check these pages occasionally to ensure you are happy with any changes to this policy.
3. We may notify you of changes to this policy by email.
8. Your rights
1. You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to: 

1. your request not being found to be unfounded or excessive, in which case a charge may apply; and
2. the supply of appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address).

2. We may withhold personal information that you request to the extent permitted by law.
3. The rights you have under data protection law are:

1. the right to access;
2. the right to rectification;
3. the right to erasure;
4. the right to restrict processing;
5. the right to object to processing;
6. the right to data portability;
7. the right to complain to a supervisory authority; and
8. the right to withdraw consent.

4. Your right to access your data. You have the right to ask us to confirm whether or not we process your personal data and, to have access to the personal data, and any additional information. That additional information includes the purposes for which we process your data, the categories of personal data we hold and the recipients of that personal data. You may request a copy of your personal data. The first copy will be provided free of charge, but we may charge a reasonable fee for additional copies.
5. Your right to rectification. If we hold any inaccurate personal data about you, you have the right to have these inaccuracies rectified. Where necessary for the purposes of the processing, you also have the right to have any incomplete personal data about you completed.
6. Your right to erasure. In certain circumstances you have the right to have personal data that we hold about you erased. This will be done without undue delay. These circumstances include the following: it is no longer necessary for us to hold those personal data in relation to the purposes for which they were originally collected or otherwise processed; you withdraw your consent to any processing which requires consent; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are certain general exclusions of the right to erasure, including where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for establishing, exercising or defending legal claims.
7. Your right to restrict processing. In certain circumstances you have the right for the processing of your personal data to be restricted. This is the case where: you do not think that the personal data we hold about you is accurate; your data is being processed unlawfully, but you do not want your data to be erased; it is no longer necessary for us to hold your personal data for the purposes of our processing, but you still require that personal data in relation to a legal claim; and you have objected to processing, and are waiting for that objection to be verified. Where processing has been restricted for one of these reasons, we may continue to store your personal data. However, we will only process it for other reasons: with your consent; in relation to a legal claim; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
8. Your right to object to processing. You can object to us processing your personal data where our legal basis for the processing is that it is necessary for: the performance of a task carried out in the public interest, or in the exercise of any official authority vested in us; or the purposes of our legitimate interests or those of a third party. If you make an objection, we will stop processing your personal information unless we are able to: demonstrate compelling legitimate grounds for the processing, and that these legitimate grounds override your interests, rights and freedoms; or the processing is in relation to a legal claim.
9. Your right to object to direct marketing. You may instruct us at any time not to process your personal information for marketing purposes.

In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.

You can object to us processing your personal data for direct marketing purposes. If you make an objection, we will stop processing your personal data for this purpose.

10. Your right to data portability. Where you have given us consent to process your personal data, or where we are processing your personal data for the performance of a contract, you have a legal right to receive a copy of the personal data we hold about you in a structured, commonly used and computer readable format. When a data request is made of us we will make available all applicable personal data to you in a computer readable format and will transmit your personal data to the appropriate third party pursuant to your instruction. We will not process your data in this way if we believe that it may pose a threat to the security of the data.
11. Your right to object for statistical purposes. You can object to us processing your personal data for statistical purposes on grounds relating to your particular situation, unless the processing is necessary for performing a task carried out for reasons of public interest.
12. Automated data processing. To the extent that the legal basis we are relying on for processing your personal data is consent, and where the processing is automated, you are entitled to receive your personal data from us in a structured, commonly used and machine-readable format. However, you may not have this right if it would adversely affect the rights and freedoms of others.
13. Complaining to a supervisory authority. If you think that our processing of your personal data infringes data protection laws, you can lodge a complaint with a supervisory authority responsible for data protection. You may do this in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
14. Right to withdraw consent. To the extent that the legal basis we are relying on for processing your personal data is consent, you are entitled to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
15. Exercising your rights. You may exercise any of your rights in relation to your personal data by written notice to us in addition to the other methods specified above.
8. Cookie Policy

For information about how we use Cookies please see our Cookie Policy at: [Insert link to cookie policy on website] 

10. Our details
1. This website and all other group websites are owned and operated by The Willcox Group Limited.
2. We are registered in England and Wales under registration number 11083356, and our registered office is at Unit 27 Weston Industrial Estate, Honeybourne, Evesham, Worcestershire, England, WR11 7QU.
3. Our principal place of business is at Unit 27 Weston Industrial Estate, Honeybourne, Evesham, Worcestershire, England, WR11 7QU. 
4. You can contact us:

1. by post, using the postal address given above;
2. using our website contact form;
3. by telephone, on the contact number published on our website from time to time; or
4. by email, using the email address published on our website from time to time.

11. Data protection Contact 

Our data protection contact can be reached via email: a.drew@willcoxgranite.co.uk or telephone: 01386 840855.

12. How to complain
13. We hope that we can resolve any query or concern you may raise about our use of your information.
14. The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns  or telephone: 0303 123 1113.