This is the privacy and fair processing notice of St Helens ONE. In this document, “we”, “our”, or “us” refer to St Helens ONE. References to “our Website” or “the Website” are to www.sthelens.one and other sub domains of the aforementioned website.
Our registered office is at:
St Helens ONE
We are a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.
We may update this notice from time to time.
It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.
This notice will also bind any successor to our business which processes your personal data in the future.
Payment information for online purchases is never taken by us or transferred to us either through our website or otherwise. Our employees and contractors never have access to it. At the point of payment, you will be transferred to a secure page on the website of Shopify or some other reputable payment service provider. That page may be branded to look like a page on our website, but it is not controlled by us.
Data Protection Principles
We will comply with data protection law. This says that the personal information we hold about you must be:
- Used lawfully, fairly and in a transparent way.
- Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
- Relevant to the purposes we have told you about and limited only to those purposes.
- Accurate and kept up to date.
- Kept only as long as necessary for the purposes we have told you about.
- Kept securely.
Information We Hold
There are “special categories” of more sensitive personal data which require a higher level of protection, but we do not envisage that that we will process any such data in relation to you.
We may collect, store, and use the following categories of personal information about you:
- Identity data such as your name, title, and gender [(and in cases where we need to verify your identity documents such as such as your driving licence, passport, utility bill and/or bank statements).]
- Personal contact data such as postal and email address(es), landline and/or mobile telephone numbers, social or business media accounts.
- Regulatory Information about you in relation to your holding of any firearms or firearms related licences or governmental consents.
- Information about your employment or role, occupation, business interests, intentions and business relationships (Business Information)
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website(s).
- Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our website, products and services.
- If we are providing you with products or services personally (rather than to a company which is your employer) financial information about your dealings involving us which may include your bank account details and any details of any transfers of funds to us. (Transaction Data)
- If you request us to provide you with products or services personally (or you are a director of a company and ask us to provide that company with products or services), we may perform credit reference checks on you via credit references or similar agencies. Their results will contain personal information on you that we may use to determine whether to act for you or for an entity in which you have an interest and whether to request payments on account. (Credit Reference Information)
- Marketing and Communications data including your preferences for receiving newsletters, and event invitations from us and your communication preferences (how you will be contacted).
- 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.
Collection of Data
We may collect additional personal information by any of the above methods in the course of providing the requested services throughout the period of our relationship.
In relation to Marketing and Communications data we may also collect this data where you have made enquiries of us or expressed an interest in any of our products, services, events or marketing materials (whether in person or via telephone, email, website or social media).
How We Use Data
We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
- Where we need to perform the contract, we have entered into with you;
- Where we need to comply with a legal obligation;
- 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; or
- With your express consent.
We may also use your personal information in the following situations, which are likely to be rare:
- Where we need to protect someone’s life.
- Where it is needed in the public interest.
When We Use Data
Where you have ordered products or services from us, we will need certain of the categories of information listed above (see the paragraph above titled ‘The kind of information we hold about you’) to allow us to perform our contract with you to the appropriate standard.
In some cases (for example in relation to use of Marketing and Communications data) we may use your personal information to pursue legitimate interests of our own provided your interests and fundamental rights do not override those interests or we may rely on your specific consent to process. You can stop us from using your personal information for marketing purpose by requesting this at any time.
We may also need to process your personal information if we have a legal obligation to do so or are ordered to hand over data by a court or other relevant authority.
The situations in which we will process your personal information are listed below. We have indicated the purpose or purposes for which we are processing or will process your personal information, as well as indicating which categories of data are involved and whether any third parties may receive the same.
|Purpose||Data Category||Grounds for
|Identity data Personal
Contact data Regulatory
|To ID verification agencies.|
|Identity data Personal
Contact data Regulatory
Info Technical Profile
and Usage data
|To other contractors or
persons involved in
delivery of the products
or services as required
to properly deliver the
same to you.
|Credit reference checks||Identity data Personal
Contact data Credit
|Identity data and personal
contact data to credit
and seminar invites
data Marketing and
|To any external
provider used by us.
Possibly to other
businesses in the case of
jointly held seminars or
court order or to
|Any||Legal Obligation||To ID verification agencies.|
|To our auditors/accountants,
insurers, legal advisors or to
such other thrid parties as
is resonably required to ensure
our compliance with legal
obligations, codes of practice,
accounting or quality standards
or to assess, defend, avoid or
mitigate a claim or potential
claim against us.
|To protect life or
other vital interest
|Any||Vital Interest||Possibly – as required.|
|Health and Safety||Any||Legal Obligation
Our Legitimate Interests
|Possibly to HSE authorities.|
|Prevention of fraud
or crime etc.
Our Legitimate Interests
As noted above some of the above grounds for processing may overlap and there may be several grounds which justify our use of your personal information.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes. You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.
Legitimate Interest means our interest in conducting and managing our operations to enable us to regulate you as our member and/or 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.
Contractual Performance 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 or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
We may have to share your data with third parties, including third-party service providers.
We require third parties to respect the security of your data and to treat it in accordance with the law.
WHY MIGHT YOU SHARE MY PERSONAL INFORMATION WITH THIRD PARTIES?
We will share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so.
WHICH THIRD-PARTY SERVICE PROVIDERS PROCESS MY PERSONAL INFORMATION?
“Third parties” includes third-party service providers (including contractors and designated agents) and other entities which provide goods or services to us. The following activities may be carried out by third-party service providers: credit reference checks, provision of online communications and cloud-based database solutions.
HOW SECURE IS MY INFORMATION WITH THIRD-PARTY SERVICE PROVIDERS AND OTHER ENTITIES?
All our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions. Third parties processing your personal information on our instructions will have to agree to treat the information confidentially and to keep it secure.
WHAT ABOUT OTHER THIRD PARTIES?
We may also share your personal information with other third parties, for example in the context of our possible merger, sale or restructuring or with a regulator or to otherwise comply with the law.
Cookies are small text files that are placed on your computer’s hard drive by your web browser when you visit any website. They allow information gathered on one web page to be stored until it is needed for use on another, allowing a website to provide you with a personalised experience and the website owner with statistics about how you use the website so that it can be improved.
Some cookies may last for a defined period, such as one day or until you close your browser. Others last indefinitely.
Your web browser should allow you to delete any you choose. It also should allow you to prevent or limit their use.
- to track how you use our website
- to record whether you have seen specific messages we display on our website
- to keep you signed in our site
- to record your answers to surveys and questionnaires on our site while you complete them
- to record the conversation thread during a live chat with our support team.
- Personal identifiers from your browsing activity.
- to show you personalised advertising
Requests by your web browser to our servers for web pages and other content on our website are recorded.
We record information such as your geographical location, your Internet service provider and your IP address. We also record information about the software you are using to browse our website, such as the type of computer or device and the screen resolution.
We use this information in aggregate to assess the popularity of the webpages on our website and how we perform in providing content to you.
If combined with other information we know about you from previous visits, the data possibly could be used to identify you personally, even if you are not signed into our website.
These third party service providers, such as Google and Facebook, will utilise these cookies to display such adverts.
We will only transfer your personal information outside the EU with your informed consent, at your specific request or where such transfer is reasonably required for our legitimate business purposes and where the transmittee either resides in a territory with an EU adequacy declaration or has contractually agreed to comply with data protection provisions affording your personal data protections equivalent to the protections given under EU law.
At present the only international transfers of your data anticipated are to MailChimp which is a global provider of email communications solutions and cloud-based contact databases and which has entered into contractual data protection provisions with us complying with the EU standard clauses in this area.
We have put in place measures to protect the security of your information. Details of these measures are available upon request.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
HOW LONG WILL YOU USE MY INFORMATION FOR?
We will only retain your personal information 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.
In respect of data recording sales of firearms and ammunition we are currently obliged by law to keep such information indefinitely.
In respect of other data where we have acted for you or your employer this will usually be kept for 7 years after the end of our contractual relationship with you or your employer.
Unless you have requested its earlier destruction, we will retain your Marketing and Communications data for marketing and communications purposes for no longer than 3 years after its acquisition save where you have during that period updated the same, or confirmed that you wish to remain on our Marketing and Communications database or we have provided products or services to you or your employer (in which case the 3 year Marketing and Communications data period runs from the date of the last such update, confirmation or service/product provision).
You can insist on our cessation of marketing to you and removal of your personal information from our Marketing and Communications database at any time by contacting our Compliance and Data Security Advisor via email at firstname.lastname@example.org
In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.
YOUR DUTY TO INFORM US OF CHANGES
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.
Your Rights with Personal Data
Under certain circumstances, by law you have the right to:
- Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below), unless we have a legal obligation to retain this data.
- Object to processing of your personal information 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. You also have the right to object where we are processing your personal information for direct marketing purposes.
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal information to another party. If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact our Compliance and Data Security Advisor via email at email@example.com
Further details about your rights can be found here:
NO FEE USUALLY REQUIRED
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
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 the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
RIGHT TO WITHDRAW CONSENT
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact our Compliance and Data Security Advisor via email at firstname.lastname@example.org Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
COMPLIANCE AND DATA SECURITY ADVISOR
We have appointed a Compliance and Data Security Advisor to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact our Compliance and Data Security Advisor via email at email@example.com
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.
CHANGES TO THIS PRIVACY NOTICE
We reserve the right to update this privacy notice at any time, and we will advise you when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.