www.couchrolls.com respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website and your privacy rights. This privacy notice aims to give you information on how we collect and processes your personal data through your use of this website or by phone. www.couchrolls.com is the controller and responsible for your personal data (collectively referred to as "we, "us" or "our" in this notice).
If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us at our registered office:www.couchrolls.com,
Pinnacle House Business Centre
Email address: email@example.com
Telephone number: 02039 575 579
- 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 (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
- It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
- Third-party links: 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.
- 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, use, store and transfer different kinds of personal data about you which we have grouped together follows :
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Contact Data includes your email address and telephone numbers.
- 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 this website.
- Usage Data includes information about how you use our website.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
- 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 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.
- 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 services). In this case, we may have to cancel a service you have with us. We will notify you if this is the case at the time.
- Data collection: We use different methods to collect data from and about you including through direct interactions. You may give us your identity and contact data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you contact us for our services or request marketing to be sent to you.
- As you interact with our website, we may automatically collect technical data about your equipment. We may also receive technical data about you if you visit other websites employing cookies.
- We may receive personal data about you from various third parties: analytics providers; advertising networks; search information providers; Identity and Contact Data from data brokers or aggregators; Identity and Contact Data from publicly availably sources (for example Yellow Pages).
- How we use your data: We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances: Where we need to perform the contract we are about to enter into or have entered into with you; Where it is necessary for our legitimate interests and fundamental rights do not override those interests. (see also later text on legitimate interests); Where we need to comply with a legal or regulatory obligation.
- You have the right to withdraw consent to marketing at any time by contacting us.
- We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your consent and if you have not opted out of receiving that marketing.
- Opting out: You can ask us to stop sending you marketing messages at any time 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 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.
- 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 or we have a legitimate interest.
- Disclosure of your personal data: We may have to share your personal data with the parties as described in the GDPR legislation.
- 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.
- Date 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 a duty of confidentiality. We will notify you and any applicable regulator of a breach where we are legally required to do so.
- 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 and for our legitimate interests.
- 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.
- By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
- In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
- Your Legal Rights: Under certain circumstances, you have rights under data protection laws in relation to your personal data :
- Request access to your personal data; Request correction of your personal data; Request erasure of your personal data; Object to processing of your personal data; Request restriction of processing your personal data; Request transfer of your personal data; Right to withdraw consent.
- 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 unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
- 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.
- 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.
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).
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 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.
Third Parties (External): Service providers acting as processors based within or outside the EEA who provide services that support our services supplied to you. Professional advisers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services. HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
This document notes the legitimate interests defence when processing personal data for phoning and emailing couchrolls.com [hereafter referred to as The Company] valued customers and prospects. The Company is fully committed to retain a fair balance between the rights of the company and the rights of the data subject, ensuring the rights of the Company legitimately prevail. The Company accepts that this judgement is unavoidably subjective and it is always open to consider an alternative view if a data subject elects to challenge it. (Contact details previously noted).
- The Rights of the Company: The processing of personal data for direct marketing purposes is regarded as being carried out for legitimate interests. Reference: Article 16 of the European Charter of Fundamental Rights: The Company retains the right to run its business, including the right to make use of direct marketing strategies. The benefit that The Company is seeking to achieve by using personal data is summarised as:
- 1. Communicating with the outside world, key to the Company’s survival.
- 2. Generating profit.
- 3. Creating and protecting employment.
- 4. Providing information and offers for our high-quality goods and services.
- 5. Distributing product information and alerts.
This statement will be re-assessed if the nature of the business activities change.
- The Balancing Equation
- The Rights of the data subject: The Company has considered the reasonable expectations of the data subjects, as well as any direct impacts from the use of personal data. The Company has also made reference to Ofcom’s guidance on persistent misuse of an electronic communications network, to ensure as far as possible there is no potential harm from its activities. It has taken positive steps to minimise any harm. (See Additional Safeguards, A to L below)
- The Company will train its staff to make every effort to ensure calls are conducted professionally, and are made aware of GDPR requirements in working practice.
- The Company sees the data subject’s minor potential inconvenience at receiving a marketing phone call as being out-balanced by The Company’s needs to provide information to all its existing and prospective customers (noted by the bullet points 1 to 5 above).
- The Company notes that for GDPR, a desire to inform potential customers about its products and services needs to be controlled and balanced against the data subject’s desire not to take marketing phone calls. To assist, the following Additional Safeguards also apply.
- a. Outbound calls made only within generally accepted business hours (08:30 to 05:00)
- b. Phone calls will be made to numbers listed in Yellow Pages or Yell.com business pages.
- c. All phone calls and emails will be made to recognisable business contacts.
- d. Those called will have the ability to easily opt-out of further use of their data or contact. (Telesales procedures and continuous record keeping in place using SAP)
- e. There will be strict limitations on how much data is collected and how long it is kept.
- f. The Company will conduct periodic Data Protection Assessments.
- g. Staff training will include GDPR requirements and include how to respond to legitimate requests for information from individuals about themselves.
- h. The Company will limit the number of calls placed to individuals within a given timeframe. (There is a separate Telesales report mechanism to support this, using SAP.)
- i. The Company will carry out a further review on any occasion its use of personal data changes.
- j. The Company will ensure all individuals are able to exercise their right to object to the use of their data and The Company will stop using that data immediately.
- k. Any individual will have the ability to request a copy of all the data that The Company holds regarding them and their business within one calendar month of the request.
- l. The Company will ensure any individual has the right to erasure e.g.“the right to be forgotten”, where that does not conflict with Company Law, HMRC retention requirements or other statutory duty to retain adequate business records.