At Sekura Global (“Sekura Global”) – a division of Clipper Retail Ltd – we are committed to complying with the General Data Protection Regulation (GDPR) and the Data Protection Act 2018, once enacted. Any personal information you share with us is of the utmost importance to us, and we want you to be confident that your personal data is kept safely and securely at all times. To help you understand how we use your information to provide the best possible service, we have compiled the following notice.
This notice is intended to help you understand:
- How and why Sekura Global collect information from you
- Who we share your information with, why, and on what basis
- What your rights are.
If we make changes to this notice we will notify you by updating it on our website.
This policy sets out the basis on which any personal information Sekura Global (‘we’ or ‘us’) collect from you via https://www.sekura-global.com/ (‘site’) or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal information and how we will treat it.
For the purpose of the Data Protection Act 1998 (the ‘Act’) the data controller is Sekura Global, Clipper Retail Ltd, Aspen House, Stephenson Road, Colchester, CO4 9QR, United Kingdom.
Sekura Global will be what is known as the ‘Data Controller’ of the personal data you provide to us, and we will sometimes refer to ourselves in this notice as “we” or “us”. By Data Controller, this means Sekura Global determines the purposes and way in which any personal data is, or will be, processed.
Should you need to contact us please write to:
Clipper Retail Ltd
Or email email@example.com quoting “Data and Privacy Enquiry” in the subject line.
This notice was last updated on the 24th of May 2018.
What information we collect when you register and why?
When you buy goods from us, you are entering into a contract with us. You will need to set up a Sekura Global Account before ordering from us; so we can set this up we may ask you to provide some information that might be considered personal, such as:
- Full name
- Contact numbers and email address
- VAT Number (if applicable)
- Company Registration Number (if applicable)
When you apply for a credit account, we get information about you from credit reference agencies. This is covered in more detail in the section “Who we share your information with and why”. Where we have sought references for a credit application (if applicable), these are not stored on our systems after the checks have been completed.
How do we use your information?
Data Protection says that we are allowed to use and share your personal data only where we have a proper reason to do so. The law says we must have one or more of these reasons and these are:
- Contract – your personal information is processed in order to fulfil a contractual arrangement (e.g. in order to send you your order)
- Consent – where you agree to us using your information in this way (e.g. storing your address to make re-ordering easier for you)
- Legitimate Interests – this means the interests of Sekura Global in managing our business to allow us to provide you with the best products and service in the most secure and appropriate way (e.g. to transfer your data to certain Third Party’s such as delivery partners)
- Legal Obligation – where there is statutory or other legal requirement to share the information (e.g. when we have to share your information for law enforcement purposes).
What do we use your personal information for?
This is a list of the ways that we may use your personal information, showing how the reasons described above permit us to do so. Where we list legitimate interests as a reason, we also describe what we believe these legitimate interests are.
Our reasons (legal basis) and our explanation of Sekura Global’s legitimate interests:
|What we use your personal information for||Our reasons (legal basis)||Our explanation of Sekura Global’s legitimate interests|
|Setting up your Sekura Global account||Legitimate interest||Process efficiency in dealing with such activity|
|Storing payment cards||Consent||We do not store your payment cards – this functionality may be available through our payment portal, but would be offered by Sage Pay or Worldpay only.|
|Processing your orders||Fulfilling a contract||N/A|
|Notifying you of your order status||Legitimate interests||Process efficiency in dealing with such activity, and to make improvements to our services|
|Managing your account/ providing customer services to you – this may include: transfers to Third Countries who undertake customer services/communications activities, call recording, data verification, customer complaints/queries||Legal obligation / Legitimate interests (depending on nature of services)||Keeping our records up to date, handling our customer contact efficiently and effectively, working out which of our products and services may interest you and telling you about them|
|To detect, investigate and report financial crime (e.g. Fraud)||Legal Obligation / legitimate interests||Developing and improving how we deal with financial crime – Complying with any legal obligation placed on us by regulators such as the FCA – Complying with any regulations that apply to us – Process efficiency in dealing with such activity, and to make service and process improvements|
|Undertake website personalisation and administration||Legitimate interests||Developing products, services, applications and designs that attract and retain customers – Improving customer interaction with our sites – Defining types of customers for new products or services|
|Marketing communications to inform you of special offers, promotions, new lines and Sales – provide you with online advertising||Legitimate interests / Consent||Developing products, services, applications and designs that attract and retain customers – Improving customer interaction with our sites|
|Notifying you about enhancements to our services, such as changes to the website and new services that may be of interest to you||Legitimate interests||Developing products, services, applications and designs that attract and retain customers – Improving customer interaction with our sites|
|Contact you to undertake customer satisfaction surveys, invite you to provide product reviews or for market research||Legitimate interests||Developing products, services, applications and designs that attract and retain customers. Improving customer interaction with our sites|
|Maintaining network and data security||Legitimate interests||To maintain the security of our network this in turns helps us to maintain the safety and confidentiality of your information|
|Logistics planning, demand forecasting, management information and research||Legitimate interests||We use information about shopping habits, products bought and volumes, to help us to respond to demand, ensure the right products get to the right areas and to help us plan our ranges|
How do we collect your information?
We receive information in one of two ways; either we (a) collect information from you when you register on the site, place an order, respond to a survey or communication such as e-mail, or participate in another site feature or (b) from a third party such as credit reference agencies (for example to assess your credit rating).
When ordering or registering, we may ask you for your name, e-mail address, mailing address, phone number or other information. You may, however, visit our site anonymously.
We also collect information about gift recipients so that we can fulfil the gift purchase. The information we collect about gift recipients is not used for marketing purposes.
Like many websites, we use “cookies” to enhance your experience and gather information about visitors and visits to our websites. Please refer to the “Do we use ‘cookies’?” section below for information about cookies and how we use them.
Use of Credit Reference Agency Information
In the interests of responsible lending and for security purposes we carry out searches with credit reference agencies when you register with us and further searches may be carried out before deciding whether to accept orders and/or grant further credit. The agencies record these searches. We also share information about you and the conduct of your account with credit reference agencies, other lenders and relevant third parties.
Information about you will be used to verify your identity and for the credit assessment of you. We may also use your information for payment recovery or fraud and debt tracing. We will pass on details of defaulting accounts to debt collection agencies. We do not store the results of Credit Reference Checks.
As part of the processing of your personal data, decisions may be made by automated means. We may automatically decide that you pose a fraud or money laundering risk if our processing reveals your behaviour to be consistent with money laundering or known fraudulent conduct, or is inconsistent with your previous submissions, or you appear to have deliberately hidden your true identity. You have rights in relation to automated decision-making: if you want to know more please contact us at firstname.lastname@example.org or call 01206 390 800.
Whenever fraud prevention agencies transfer your personal data outside of the European Economic Area, they impose contractual obligations on the recipients of that data to protect your personal data to the standard required in the European Economic Area. They may also require the recipient to subscribe to ‘international frameworks’ intended to enable secure data sharing.
Consequences of Processing
If we, or a fraud prevention agency, determine that you pose a fraud or money laundering risk, we may refuse to provide the services or financing you have requested, or to employ you, or we may stop providing existing services to you.
A record of any fraud or money laundering risk will be retained by the fraud prevention agencies, and may result in others refusing to provide services, financing or employment to you. If you have any questions about this, please contact us at email@example.com or call 01206 390 800.
Your personal data is protected by legal rights, which include your rights to object to our processing of your personal data; request that your personal data is erased or corrected; request access to your personal data.
For more information or to exercise your data protection rights, please contact us using the contact details above. You also have a right to complain to the Information Commissioner’s Office, which regulates the processing of personal data.
How do we protect visitor information?
We implement a variety of security measures to maintain the safety of your personal information. Your personal information you provide to us is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential. Where we have given you a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
When you place orders or access your personal information, we offer the use of a secure server. All sensitive/credit information you supply is transmitted via Secure Socket Layer (SSL) technology and then encrypted into our databases to be only accessed as stated above.
All payment transactions are handled by Sage Pay or Worldpay. We do not store your credit or debit card details. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised transactions.
Keeping in touch with you
We want to keep you up to date with information about new ranges, special offers and improvements to our website. When you set your account up, we will ask you if you want to receive this type of marketing information.
Sekura Global will not share your information with companies outside of Sekura Global for their marketing purposes. Clipper Retail Ltd includes Clipper Retail and Sekura Global.
If you decide you do not want to receive this marketing information you can request that we stop by writing to the Data Protection Officer at the address provided above, emailing firstname.lastname@example.org, by calling us on 01206 390 800, or by using the unsubscribe link within the email you have received. You will also have the opportunity to “unsubscribe” using the link present in every Marketing email sent by us or on our behalf.
You may continue to receive mailings for a short period while your request is dealt with.
How long we keep your information
If we collect your personal information, the length of time we retain it is determined by a number of factors including the purpose for which we use that information and our obligations under other laws.
We may need your personal information to establish, bring or defend legal claims. For this purpose, we will always retain your personal information for 7 years after the date it is no longer needed by us, for any of the purposes listed under “How we use your information” above. The only exceptions to this are where:
- The law requires us to hold your personal information for a longer period, or delete it sooner
- You exercise your right to have the information erased (where it applies) and we do not need to hold it in connection with any of the reasons permitted or required under the law
- We bring or defend a legal claim or other proceedings during the period we retain your personal information, in which case we will retain your personal information until those proceedings have concluded and no further appeals are possible
- In limited cases, existing or future law or a court or regulator requires us to keep your personal information for a longer or shorter period.
Do we disclose the information we collect to outside parties?
We do not sell, trade, or otherwise transfer to outside parties your personally identifiable information unless we provide you with advance notice, except as described below. The term “outside parties” does not include Clipper Retail (our parent company) or Sekura Global. It also does not include website hosting partners and other parties including credit reference agencies as stated above, who assist us in operating our site, conducting our business, or servicing you, so long as those parties agree to keep this information confidential. We will disclose your personal information to couriers in order for them to deliver your order. We may also release your information when we believe release is appropriate to comply with the law, enforce our site policies, or protect ours or others’ rights, property, or safety.
However, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.
Transfers to third countries
Some of the information you provide to us may be transferred outside the European Economic Area to countries such as India and the US. This is a transfer to a “third country”. For example Sekura Global has a business relationship with APPSeCONNECT in India, who provide us with IT support and website integration services. Although the data is held in UK data centres, colleagues in India may access it to undertake the activities described above.
If you place an order with us and you are outside of the UK, we will transfer the data that we hold on you to Clipper Retail Ltd in the UK.
Sekura Global also works with suppliers and partners who may make use of cloud and/or hosted technologies. We undertake data security due diligence on our partners and ensure that that these partners conform to appropriate accreditations.
Wherever transfers of data to third countries occurs, Sekura Global will put in place appropriate contractual provisions to ensure that there are strict rules regarding both the confidentiality and security of your information. To find out more please contact us at email@example.com or call 01206 390 800.
How can you opt-out, remove or modify information you have provided to us?
To modify your e-mail subscriptions, please let us know by modifying your preferences in the “My Account” section. Please note that due to email production schedules you may still receive emails that are already in production.
To delete all of your online account information from our database, sign into the “My Account” section of our site and remove your shipping addresses, billing addresses & payment information. Please note that we may maintain information about an individual sales transaction in order to service that transaction and for record keeping.
Each Marketing email we send will also have an “unsubscribe” link at the foot of the text – allowing you the chance to opt out quickly and easily from receiving future Marketing communications from us.
Third party links
In an attempt to provide you with increased value, we may include third party links on our site. These linked sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these linked sites (including if a specific link does not work).
Access to information
The Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act. Any access request may be subject to a fee of £10 to meet our costs in providing you with details of the information we hold about you.
Changes to our policy
What are your rights?
You are entitled to request the following from Sekura Global. These are your Data Subject Rights and more information about them is available on the Information Commissioners website (www.ico.org.uk):
- Right of access – to request access to your personal information and information about how we process it
- Right to rectification – to have your personal information corrected if it is inaccurate and to have incomplete personal information completed
- Right to erasure (also known as the Right to be Forgotten) – to have your personal information erased – email firstname.lastname@example.org or phone 01206 390 800
- Right to restriction of processing – to restrict processing of your personal information
- Right to data portability – to electronically move, copy or transfer your personal information in a standard form
- Right to object – to object to processing of your personal information
- Rights with regards to automated individual decision making, including profiling –rights relating to automated decision making, including profiling.
If you have any general questions about your rights or want to exercise your rights please email email@example.com or call on 01206 390 800.
You have the right to lodge a complaint with a data protection regulator in Europe, in particular in a country you work or live or where your legal rights have been infringed. The contact details for the Information Commissioner’s Office (ICO) – the data protection regulator in the UK – are available on the ICO website www.ico.org.uk. If you suspect your personal information has or is being used in a way that you believe does not comply with data protection laws, we encourage you to contact us before making any complaint and we will seek to resolve any issues or concerns you may have.