1. About This Policy
1.1 We appreciate your interest in our products and services and your visit to this website. Your privacy is important to us and we want you to feel comfortable with how we use and share your personal information.
1.2 This policy sets out how Westbrook Cycles LTD handle your personal information, including when and why it is collected, used and disclosed and how it is kept secure.
1.3 You will find our contact details at the end of this policy which you can use if you have any questions, including how to update or access your personal information or to make a complaint.
1.4 This policy may change, so please check this page from time to time to ensure that you’re happy with any changes. Please see further Changes to this policy in Section 10.
1.5 This policy was last updated on 23 May 2022.
2. Who Are We?
2.1 Westbrook Cycles are a Limited Company in the UK. Whenever you deal with Westbrook Cycles, the ‘controller’ of your personal information will be Westbrook Cycles LTD. A ‘controller’ is a company that decides why and how your personal information is processed.
2.2 Where this policy refers to “we”, “our” or “us” below, unless it mentions otherwise, it’s referring to Westbrook Cycles LTD.
3. How And What Personal Information We Collect
3.1 We may collect and process the following personal information about you
Personal information you give to us: This is information about you that you give to us by entering information via our website or our social media pages or by corresponding with us by phone, email or otherwise and is provided entirely voluntarily. The information you give to us includes your name, contact details (such as phone number, email address and address), enquiry details and your opinion of our products.
Personal information we collect about you: We may automatically collect the following personal information: our web servers store as standard details of your browser and operating system, the website from which you visit our website, the pages that you visit on our website, the date of your visit, and, for security reasons, e.g. to identify attacks on our website, the Internet protocol (IP) address assigned to you by your internet service. We collect some of this information using cookies and similar technologies – please see Cookies in Section 8.2 for further information. We may also collect any personal information which you allow to be shared that is part of your public profile on a third party social network.
Personal information we may receive from other sources: We obtain certain personal information about you from sources outside our business which may include third party companies; the personal information received is as described in the two paragraphs above.
3.2 Please see further 'How we use your personal information' in Section 4 for details of the purposes for which we use the personal information we obtain from these sources and the legal basis on which we rely to process that information. The remaining provisions of this policy also apply to any personal information we obtain from these sources.
4. How We Use Your Personal Information
4.1 Where you have provided CONSENT
We may use and process your personal information where you have consented for us to do so for the following purposes:
- Where you have requested a call back;
- to supply material you have specifically requested from us;
- to contact you via email with marketing information about Westbrook Cycles and our products and services (see Marketing in section 9 below for further details);
- to share your personal information with any current or future third party partners of Westbrook Cycles. 4.2 You may withdraw your consent for us to use your information in any of these ways at any time. Please see Withdrawing your consent in Section 7.4 for further details.
4.3 Where required to perform a CONTRACT with you
We may use and process your personal information where it is necessary for the performance of a contract with you or in order to take steps at your request before entering into a contract with you including for the following purposes:
- To exchange information for warranty/aftersales;
4.4 Where it is in your VITAL INTEREST
We may use your personal information to contact you if there are any urgent safety or product recall notices to communicate to you or where we otherwise reasonably believe that the processing of your personal information will prevent or reduce any potential harm to you. It is in your vital interests for us to use your personal information in this way.
4.5 Where there is a LEGITIMATE INTEREST
We may use and process your personal information where it is necessary for us to pursue our legitimate interests as a business for the following purposes:
- for analysis, and profiling to inform our marketing strategy, and to enhance and personalise your customer or visitor experience;
- for market research in order to continually improve the products and services that we deliver to you;
- to administer our website and for internal operations, including troubleshooting, testing, statistical purposes;
- for marketing activities (other than where we rely on your consent) e.g. to tailor marketing communications or send targeted marketing messages via social media and other third party platforms;
- for the prevention of fraud and other criminal activities;
- to undertake credit checks for finance;
- to correspond and communicate with you;
- to create a better understanding of you as a customer or visitor;
- for network and information security in order for us to take steps to protect your information against loss or damage, theft or unauthorised access;
- to comply with a request from you in connection with the exercise of your rights (for example where you have asked us not to contact you for marketing purposes, we will keep a record of this on our suppression lists in order to be able to comply with your request);
- to enforce or protect our contractual or other legal rights or to bring or defend legal proceedings; and
- for general administration including managing your queries, complaints, or claims.
5. Others Who may Receive Or Have Access To Your Personal Information
5.1 Our suppliers and service providers
We may disclose your information to our third party service providers, agents, subcontractors and other organisations for the purposes of providing services to us or directly to you on our behalf. Such third parties may include cloud services providers (such as hosting and email management) or advertising agencies, administrative services or other third parties who provide services to us.
When we use third party service providers, we only disclose to them any personal information that is necessary for them to provide their service and we have a contract in place that requires them to keep your information secure and not to use it other than in accordance with our specific instructions.
5.2 Other ways we may share your personal information
We may transfer your personal information to a third party in order to comply with any legal obligation, to detect or report a crime, or to protect the rights, property or safety of our visitors and customers.
However, we will always take steps with the aim of ensuring that your privacy rights continue to be protected.
6. How Long We Keep Your Personal Information
6.1 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.
6.2 We do not retain personal information in an identifiable format for longer than is necessary.
6.3 We may need your personal information to establish, bring or defend legal claims, in which case we will retain your personal information for 7 years after the last occasion on which we have used your personal information in one of the ways specified in 'How we use your personal information' in Section 4.
6.4 The only exceptions to this are where:
- the law requires us to hold your personal information for a longer period, or delete it sooner; and
- 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 in this section 6, or because we are required under the law (see further Erasing your personal information or restricting its processing in Section 7.6)
7. Your Rights
7.1 Your ‘data subject’ rights:
You have a number of rights in relation to your personal information under data protection law. In relation to certain rights, we may ask you for information to confirm your identity and, where applicable, to help us to search for your personal information. Except in rare cases, we will respond to you within 30 days after we have received this information or, where no such information is required, after we have received your request.
7.2 Accessing your personal information
You have the right to ask for a copy of the information that we hold about you by emailing or writing to us at the address at the end of this policy. We may not provide you with a copy of your personal information if this concerns other individuals or we have another lawful reason to withhold that information.
7.3 Correcting and updating your personal information
Your personal information can be updated at any time by logging in to your account on the Westbrook Cycles website. If you wish to update personal information that we hold as a result of a transaction or communication not concerning the website, you can request a review by emailing or writing to us at the address as the end of this policy.
7.4 Withdrawing your consent
Where we rely on your consent as the legal basis for processing your personal information, as set out under 'How we use your personal information' in Section 4, you may withdraw your consent at any time by contacting us using the details at the end of this policy. If you would like to withdraw your consent to receiving any direct marketing to which you previously opted-in, you can also do so using our unsubscribe tool. If you withdraw your consent, our use of your personal information before you withdraw is still lawful.
7.5 Objecting to our use of your personal information and automated decisions made about you.
Where we rely on our legitimate business interests as the legal basis for processing your personal information for any purpose(s), as outlined under 'How we use your personal information' in Section 4, you may object to us using your personal information for these purposes by emailing or writing to us at the address at the end of this policy. Except for the purposes for which we are sure we can continue to process your personal information, we will temporarily stop processing your personal information in line with your objection until we have investigated the matter. If we agree that your objection is justified in accordance with your rights under data protection laws, we will permanently stop using your data for those purposes. Otherwise we will provide you with our justification as to why we need to continue using your data.
You may object to us using your personal information for direct marketing purposes and we will automatically comply with your request. If you would like to do so, please update your preferences in the Account section of the Westbrook Cycles website.
You may also contest a decision made about you based on automated processing by emailing or writing to us at the address at the end of this policy.
7.6 Erasing your personal information or restricting its processing
In certain circumstances, you may ask for your personal information to be removed from our systems by emailing or writing to us at the address at the end of this policy. Unless there is a reason that the law allows us to use your personal information for longer, we will make reasonable efforts to comply with your request.
You may also ask us to restrict processing your personal information in the following situations:
Where you believe it is unlawful for us to do so, you have objected to its use and our investigation is pending or you require us to keep it in connection with legal proceedings. In these situations, we may only process your personal information whilst its processing is restricted if we have your consent or are legally permitted to do so, for example for storage purposes, to protect the rights of another individual or company or in connection with legal proceedings.
7.7 Transferring your personal information in a structured data file
Where we rely on your consent as the legal basis for processing your personal as set out under Section 4 'How we use your personal information', you may ask us to provide you with a copy of that information in a structured data file. We are working on a way that allows us to provide this to you electronically in a structured, commonly used and machine readable form, such as a CSV file.
You can ask us to send your personal information directly to another service provider, and we will do so if this is technically possible. We may not provide you with a copy of your personal information if this concerns other individuals or we have another lawful reason to withhold that information.
7.8 Complaining to the UK data protection regulator
You have the right to complain to the Information Commissioners Office (ICO) if you are concerned about the way we have processed your personal information. Please visit the ICO’s website for further details.
8. Security/Cookies/Links/Social Plugins
8.1 Security measures we put in place to protect your personal information
Westbrook Cycles use technical and organisational security measures to protect the personal information supplied by you and managed by us against manipulation, loss, destruction, and access by third parties. Our security measures are continually improved in line with technological developments.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your information whilst in transit to our website and any transmission is at your own risk.
Where we have given (or where you have chosen) a password which enables you to access an account, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
8.2 Use of 'cookies'
'Cookies' are small pieces of information sent to your device and stored on its hard drive to allow our websites to recognise you when you visit.
8.3 Links to other websites
In addition, if you linked to our website from a third party website, we cannot be responsible for the privacy policies and practices of the owners and operators of that third party website and recommend that you check the policy of that third party website.
9.1 We may collect your preferences to send you marketing information directly from us by email (where applicable) if you register an account with us online. We will only do so if you have consented to receiving such marketing information directly from us.
9.2 We may contact you with targeted advertising delivered online through social media and platforms (operated by other companies) by using your personal information, or use your personal information to tailor marketing to improve its relevance to you, unless you object.
9.3 From time to time, we may ask you to refresh your marketing preferences by asking you to confirm that you consent to continue receiving marketing information from us.
9.4 You have the right to opt-out of our use of your personal information to provide marketing to you in any of the ways mentioned above. Please see 'Withdrawing your consent' in Section 7.4 and 'Objecting to our use of your personal information and automated decisions made about you' in Section 7.5 above for further details on how you can do this.
10. Changes To This Policy
We may review this policy from time to time and any changes will be notified to you by posting an updated version on our website and/or by contacting you by email. Any changes will take effect 7 days after the date of our email or the date on which we post the modified terms on our website, whichever is the earlier. We recommend you regularly check for changes and review this policy when you visit our website. If you do not agree with any aspect of the updated policy, you must promptly notify us and cease using our services.
11. Contact Us
If you have any questions, suggestions or complaints about the processing of your personal information or wish to contact us to amend/update your marketing please contact us using the details below.
Westbrook Cycles Data Protection Co-ordinator
9 Ellerbeck Way