Sustainable Footprints Limited respects your privacy and is committed to protecting your personal data. Personal data, or personal information, means any information about an individual from which that person can be uniquely identified. It does not include data where the identity has been removed (anonymous data).
Our site is not intended for children and we do not knowingly collect data relating to children.
This 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.
Typical examples of these third-party websites include Facebook, Linkedin, Twitter and Instagram.
It is important that you read this GDPR Policy & 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 Policy & Privacy Notice supplements any other notices given and is not intended to override them.
The objective of this GDPR Policy & Privacy Notice is to:
1.0 What, How, Why
1.1 What Data We Collect
We may collect, use, store and transfer different kinds of personal data that you give us through our site or by using our applications, corresponding with us by phone, e-mail or otherwise about you which we have grouped together as follows:
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 page, newsletter or other 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 nor do we collect any information about criminal convictions and offences.
1.2 How We Collect Your Data
We collect data mainly by direct interactions with you when you:
1.2 Why We Collect Your Data
We will only use your personal data when the law allows us to and, most commonly, we will use your personal data in the following circumstances:
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party or 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.
The table below sets out 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 (please see paragraph 10 (Glossary) for a definition of legitimate interest).
|Purpose/Activity||Type of data||Lawful basis for processing/basis of legitimate interest|
|To register you as a new customer.||
|Performance of a contract with you (please see paragraph 10 (Glossary) for a definition of performance of a contract).|
|To process and deliver your order including:
> Manage payments, fees and charges.
> Collect and recover money owed to us.
|> Performance of a contract with you.
> Necessary for our legitimate interests (to recover debts due to us).
|To manage our relationship with you which will include:
> Asking you to leave a review, feedback or take a survey.
|> Performance of a contract with you.
> Necessary to comply with a legal obligation.
> Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services).
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).||
|> 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).
> Necessary to comply with a legal obligation (please see paragraph 10 (Glossary) for a definition of comply with a legal or regulatory obligation).
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.||
|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||
|Necessary for our legitimate interests (to develop our products/services and grow our business).|
1.2.1. Marketing Purposes
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. 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 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 or purchased goods from us and, in each case, you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any company outside of Sustainable Footprints Limited for marketing purposes.
You can ask us, or third parties, to stop sending you marketing messages by contacting us at any time.
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 purchase, warranty registration, product experience or other transactions.
Most browsers allow you to refuse to accept cookies for example:
Blocking all cookies will have a negative impact upon the usability of many websites. If you block cookies, you will not be able to use all the features on our website, additionally deleting cookies will have a negative impact on the usability of many websites.
You can delete cookies already stored on your computer; in the following ways:
Internet Explorer (version 10): you must manually delete cookie files (instructions for doing so at http://support.microsoft.com/kb/278835 );
Firefox (version 24): you can delete cookies by clicking "Tools", "Options" and "Privacy", then selecting "Use custom settings for history", clicking "Show Cookies", and then clicking "Remove All Cookies";
Chrome (version 29): you can delete all cookies by accessing the "Customise and control" menu, and clicking "Settings", "Show advanced settings" and "Clear browsing data", and then selecting "Delete cookies and other site and plug-in data" before clicking "Clear browsing data".
1.2.3. 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 but only where this is required or permitted by law.
1.2.4. International Transfers
In the course of our operations we may need to transfer your data outside the European Economic Area (EEA) for the purposes of backups or due to web hosting arrangements.
Countries to which we may transfer your personal data outside of the EEA do not have an adequate level of protection for personal data by the European Commission. However, where we use certain service providers, we will use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
1.3 Personal Data Disclosures
We may have to share your personal data with the parties set out below for the purposes set out in the table above:
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.
1.4. Decision Not 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 decide not to provide that data when requested, then 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). In this case, we may be unable to process an order for a product or we may have to cancel a product you have ordered with us but we will notify you if this is the case at the time.
2.0 Data Retention & Security
2.1 Data Security
We 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 non-disclosure agreement and a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
2.2 Data retention
We 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.
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 requirements.
Your personal data will be stored for no longer than nine months following you ceasing to be registered with us as a customer of the site.
If you have registered to receive communications from us as part of our mailing list, then we will keep your personal data for two years at which time we will seek to obtain consent from you to continue storing your data and contacting you. If this is not received, we will automatically delete your personal data at that time.
3.0 Your Rights
3.1 Data Control Officer
Sustainable Footprints Limited is the data controller and fully responsible for your personal data. To this end we have in place a Data Control Officer (DCO) who is responsible for overseeing and responding to any related questions you may have, including any requests to exercise your legal rights.
Full name of legal entity: Sustainable Footprints Limited
Name or title of DCO: Geri Findlay
Email address: email@example.com
Telephone number: +44 (0) 1444 350021
You have the right to access information held about you and any access request will usually be free of charge. We will endeavour to provide information in a format requested but we may charge you a reasonable fee for additional copies. A Data Subject Access Request form may be requested by you from our DCO via email.
If you would like to speak to us in relation to any concerns you have, please contact the DCO named above.
3.2. Changes to the privacy notice and your duty to inform us of changes
This version was last updated on 27 March 2020 and can be obtained via the contact details in paragraph 3.1.
It is important that the personal data we hold about you is accurate and current. So please keep us informed if your personal data changes during your relationship with us.
3.3. Information Commissioner's Office
Should you have any concerns, we would appreciate the chance to deal with them in the first instance, and would encourage you to contact our DCO.
However, you have the right to make a complaint at any time to the Information Commissioner's Office (ICO), who is the UK supervisory authority for data protection issues (www.ico.org.uk).
3.4. Your Legal Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
We will inform you (before collecting your data) if we intend to use your data for marketing purposes. We will only use your data for this if you have agreed in advance.
3.6. Correction of information
If you notify us that the personal data we hold is complete or inaccurate, we will correct or complete the information as soon as possible.
3.7. Deletion of information
You have the right to request that your personal data be deleted including if we no longer need it for the purpose we collected it or you withdraw your consent.
Following such a request, we will erase your personal data without undue delay unless continued retention is necessary and permitted by law. If we made the personal data public, we will take reasonable steps to inform other data controllers processing about your erasure request.
3.8. Object to processing
You have the right to object to us processing 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.
3.9. Restriction on processing
You have the right to request that we suspend processing your personal data and hold it for you in the event the personal data we hold is inaccurate, the processing is unlawful or we no longer need the personal data. Once the processing is restricted, we will only continue to process your personal data if you consent or we have another legal basis for doing so.
3.10. Data Portability
You have the right to receive a copy of your personal data which you gave to us. The copy will be provided in a commonly used and machine-readable format. You can also have it transmitted directly from us to another data controller where technically possible.
If you wish to exercise any of the rights set out above, please contact us.
You 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.
3.12. Consent Withdrawal
You may withdraw your 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.
3.13. What We May Need From You
We 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.
3.14. Response Times
We 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.
4.0 Lawful Basis Processing Terms
4.1. Legitimate Interest
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.
4.2. 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.
4.3. Legal or Regulatory Obligations
Means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Contact us at firstname.lastname@example.org if you have any queries or questions about this GDPR Policy & Privacy Notice.
LAST UPDATED: June 2020 © Sustainable Footprints Ltd.
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In no event shall Sustainable Footprints Ltd. or its affiliates, contractors or respective employees, be liable for any damages, including, without limitation, special, indirect or consequential damages, or any damages whatsoever resulting from loss of use, data or profits, whether in an action of contract, negligence or other action at law, arising out of or in connection with the use or performance of this website.
This website may include material with technical inaccuracies or typographical errors which may be corrected as they are discovered at Sustainable Footprints Ltd's sole discretion. Changes are made periodically to the information contained herein. Corrections and changes may be incorporated into this website at a later date. Sustainable Footprints Ltd. may at any time make modifications, improvements and/or changes to the information, names, images, pictures, logos and icons contained in this publication or the products and services referred to within, with or without notice. Since the Internet is maintained independently at thousands of sites around the world, the information, names, images, pictures, logos and icons that may be accessed may originate outside any particular national boundary. Sustainable Footprints Ltd., therefore, excludes any obligation or responsibility regarding any content derived, obtained, accessed within, through or outside the original website.
The names, images, logos and pictures identifying particular products and services are in many countries proprietary marks: nothing contained herein shall be construed as conferring by implication or otherwise any license or right under any patent or trademark of Sustainable Footprints Ltd. or any third party. Except as expressly provided in writing, nothing contained herein shall be construed as conferring any license or right under Sustainable Footprints Ltd. copyright or other intellectual property rights.
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Sustainable Footprints Ltd. has a policy of continuous product improvement and therefore reserves the right to make changes to specifications without notice. Products delivered may thus differ in detail from those described. While Sustainable Footprints Ltd. believes that information contained within this website is true and accurate, Sustainable Footprints Ltd. cannot be held responsible for any errors or omissions contained herein. No commitment to supply equipment is entered into by documents contained in this site. Due to the nature of the application of the instruments described, it is the responsibility of the customer to determine the suitability of the products and services for the purpose intended.
LAST UPDATED: June 2020 © Sustainable Footprints Ltd.
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