Ralawise group is made up of different legal entities. Details of these entities can be found in Schedule 3. When we say ‘we’ or ‘us’ or ‘our’ in this privacy notice, we may be referring to the whole of the Ralawise group, or the separate and distinct legal entities that make up the Ralawise group (which will depend on the context). It also includes any other businesses we add to this group in the future. When you are working with one of our group companies, it will be clear from the information you receive from our group companies which company you are working with and this company will be the controller of your data unless specified otherwise.
Any Ralawise group company may be the controller or a joint controller of the personal data you provide us.

If you want more information about any of the subjects covered in this Policy or if you would like to discuss any related issues or concerns with us, please contact data.security@ralawise.com or in writing to Ralawise Ltd, Unit 112, Tenth Avenue, Zone 3, Deeside Industrial Park, Deeside, Flintshire, CH5 2UA.

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 the following types of information:

• your name, address, email address, telephone number(s) and other identity and contact details;
• your financial data, such as bank account and payment card details;
• Profile Data, such as your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses;
• marketing and communications data, such as your preferences in receiving marketing from us and our third parties and your communication preferences;
• information required to provide you with a service, the details of the service that you have used and other information about how you use our website, products and services;
• technical information collected through your use of the Ralawise website (see Cookie Policy for further information);
• marketing and communications data includes your preferences in receiving marketing from us and our third parties and your communication preferences;
• details of any enquiry;
• information about items delivered to; or
• signatory information when signing for receipt of a delivery.

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.

Your duty to inform us of changes

If any of the personal information given to us changes, such as your contact details or those of a relevant colleague within your business, please inform us without delay by contacting us.

If you fail to provide personal data

Where 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 (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

Ralawise collects your personal information:

• in order to provide you with our products and service(s) under the contract we are about to enter into or have entered into with you;
• where we have obtained your consent;
• where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; and
• where we need to comply with a legal obligation.

Where we rely on consent as a legal basis for processing your personal data, we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

In the operational use and maintenance of our services, Ralawise may collect personal information when:

• you use our website;
• you use our services;
• request marketing to be sent to you;
• you contact us; or
• you are a recipient of our products or services.

This may include information which is recorded on items being delivered to you or if you have:
• completed an online form,
• set up an account or entered information on the Ralawise website,
• provided information as part of a webform contact request / enquiry, or
• contacted Ralawise in writing or by phone.

Automated technologies or interactions.

As you interact with our website or services, we will automatically collect certain technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies on, such as pixels and web beacons, to analyse trends, administer the website, track users’ movements around the website, serve targeted advertisements, and gather demographic information about our user base as a whole. Please see our Cookie Policy for further details.

Third parties or publicly available sources.

We will receive personal data about you from various third parties as set out below:

• certain technical data from analytics providers, advertising networks and search information providers.
• data from other Ralawise group companies inside the UK and in the European Economic Area (the EEA).
• from our retail partners, who provide Ralawise with information about the end customer, so that we may fulfil our delivery services.
• when products or services are provided together with a business partner and the information is collected by the business partner in order for Ralawise to provide you with our products or services.

The information we learn from our customers helps us to personalise and continually improve your experience and our services. We use the information to handle orders, deliver products and services, process payments/ invoices, communicate with you about orders, products, services and promotional offers, update our records and generally maintain your accounts with us, and recommend products and services that might be of interest to you. We may use your information to prevent or detect fraud or because it is required by law or for the purposes of legal proceedings. And to enable third parties to carry out logistical or other functions on our behalf.

We may transfer your data to other third parties (including the police, law enforcement agencies, credit reference and fraud prevention agencies and other bodies) to protect our or another person's rights, property, or safety, in connection with the prevention and detection of crime.

We have set out in Schedule 1, in a table format, a description of 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 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.

Marketing

We may use your personal information 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, registered on our website, provided your consent to receive that marketing, or if we can demonstrate that we have a legitimate interest in sending marketing material to you (and you have not opted-out).

If you have provided your personal data to one Ralawise group company, we will get your express opt-in consent before we share your personal data with another Ralawise group company, unless we are legally otherwise able to share this information. This is in order that we can provide a high quality service across our group and can provide you with advice about our services that are relevant to your interests.

We will get your express opt-in consent before we share your personal data with any third party outside of the Ralawise group for marketing purposes.

You can ask us or third parties to stop sending you marketing messages at any time by either logging into our website and checking or unchecking relevant boxes to adjust your marketing preferences (for example, within the ‘My account’ section of Ralawise.com website) or by following the opt-out links on any marketing message sent to you.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

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.

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.

Sometimes we may share your personal data with other parties.

Inside the Ralawise group

We may need to share your personal data with other companies in the Ralawise group for our general business, reporting to management, authorisations/approvals from relevant decision makers, and where systems and services are used or provided on a shared basis, such as IT services, tracking orders and reviewing credit offerings. Ralawise group companies which may share your personal data in accordance with this section can be found here.

Access rights between members of the Ralawise group are limited and granted only on a need to know basis, depending on job functions and roles.

Where any Ralawise group company processes your personal data on behalf of another Ralawise group company (either as its processor or joint controller), we will make sure that the processing company has appropriate security standards in place to protect your personal data.

Outside the Ralawise group

From time to time we ask third parties to carry out certain services for us. These third parties may process your personal data on our behalf (either as our processor or joint controller). We will disclose your personal data to these parties so that they can perform those functions. Before disclosing personal data to third party data processors, we will enter into a written contract with them requiring them to have in place appropriate security standards to ensure that they protect your personal data.

We may share your personal data with 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 may use your personal data in the same way as set out in this privacy policy.

We 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.

We may need to disclose your personal data in order to comply with a legal obligation, to enforce a contract or to protect the rights, property or safety of our employees, customers, suppliers or others.

We have set out below a list of the categories of recipients with whom we may share your personal data:
• consultants and professional advisors including legal advisors and auditors;
• courts, court-appointed persons/entities, receivers and liquidators;
• business partners and joint ventures;
• credit reference agencies;
• insurance companies;
• software and IT systems and/or service providers, such as (without limitation) the provision of IT platforms (such as Dotdigital) and the provision of carrier services (such as DPD); and
• government departments, statutory and regulatory bodies including the relevant data protection Supervisory Authority, the police and relevant tax and customs authorities.

Ralawise group companies are located in the UK and the EEA. Sharing your personal data within Ralawise group companies may involve transferring your data outside of the UK or outside of the EEA (depending on which Ralawise group company holds your personal data).

In operating our services, it may become necessary to transfer the data that we collect from you to third parties and business partners who are located outside of the UK or the EEA, in which case their processing of your personal data may involve a transfer of data outside of the UK or the EEA.

Any such transfer of information will only be in connection with the services that Ralawise provides. If we need to transfer your data outside of the UK or the EEA, we have procedures in place to ensure your data in accordance with the applicable data protection law and receives the same protection as if it were being processed inside the UK or the EEA (as applicable). For example, we may enter in a specific contract with a third party recipient of data which stipulates the standard they must follow when processing your data.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK or the EEA.

We have put in place appropriate security measures (as required by applicable data protection laws) to protect your personal data from unlawful or unauthorised processing and accidental loss, destruction or damage.

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To 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, regulatory, tax, accounting or other requirements.

Details of retention periods for different aspects of your personal data are available in our Data Retention Schedule which you can request from us by contacting us.

Individuals have certain legal rights, which are briefly summarised at Schedule 2, in relation to any of their personal data which we hold.

If you wish to exercise any of your rights please contact us in the first instance.

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk), or equivalent if you are based in a jurisdiction other than the UK, to which data protection laws apply. We would, however, appreciate the chance to deal with your concerns before you approach the ICO or another regulator so please contact us in the first instance.

Purpose/Activity	Lawful basis for processing including basis of legitimate interest
To register you as a new customer	Performance of a contract with you
To process and deliver your order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include (without limitation): (a) Notifying you about changes to our terms, privacy policy, goods or services (b) Asking you to leave a review or take a survey (c) communicating with our customers about their account and provide customer support	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to partake in a prize draw, competition or complete a survey	(a) Consent (b) Performance of a contract with you (c) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Consent (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you	(a)    Consent (b)    Necessary for our legitimate interests (to develop our products/services and grow our business)
To enforce compliance with our terms and conditions and applicable law To meet legal requirements, including complying with court orders and other appropriate legal mechanisms To provide information to representatives and advisors, including attorneys and accountants, to help us comply with legal, accounting, or security requirements To prosecute and defend a court, arbitration, or similar legal proceeding To respond to lawful requests by public authorities, including to meet national security or law enforcement requirements	(a) Necessary to comply with a legal obligation (b) Necessary for our legitimate interests (including for running our business)

 

Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product 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.

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 obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

YOUR LEGAL RIGHTS

You have the right to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
• If you want us to establish the data's accuracy.
• Where our use of the data is unlawful but you do not want us to erase it.
• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

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