Red Paddle Co Limited (“Red Paddle”, “we”, “us” or “our”) is a company incorporated in England and Wales with company number 01371094. Our registered office is Unit 12 Halwell Business Park, Halwell, Totnes, Devon, TQ9 7LQ.
This policy sets out the basis on which any personal data we collect from you, that you provide to us or that we obtain from other sources, will be processed by us when you:
- use our website at www.redpaddleco.com;
- purchase products from us;
- register your purchase with us; and
- sign up to our newsletter.
For the purpose of data protection laws, the data controller is Red Paddle Co Limited of Unit 12 Halwell Business Park, Halwell, Totnes, Devon, TQ9 7LQ. We are registered as a data controller with the Information Commissioner’s Office under number ZA210070.
1 BASIS FOR PROCESSING PERSONAL DATA
1.1 Paragraphs 1.2 – 1.6 below explain how and why we process your personal data, as well as the legal basis on which we carry out this processing.
1.2 To provide products to you:
Where you order our products online (for example our SUP boards, paddles, clothing and accessories), we will process your personal data to provide these products to you (for example, by delivering products to you). Where you register for enhanced warranties, we will store your details and the information related to your product in connection with the enhanced warranty. Our use of your personal data in this way includes sharing your personal data with our employees and other personnel as well as certain of our suppliers such as our payment gateway provider and our courier service.
We need to process your personal data in this way to be able to enter into and fulfil our contract with you for the sale of products and/or any enhanced warranty.
1.3 To make our website better:
We may also process personal data in order to provide you with a more tailored experience, including using personal data to make sure our website is displayed in the most effective way for the device you are using. This processing means that our services will be more tailored to you.
We also use various third party cookies to help us improve our website (more details are set out in section 3), but we will not share your personal data with the third party analytics and search engine providers that assist us in the improvement and optimisation of our website.
We will also process personal data for the purposes of making our website more secure, and to administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
The legal basis on which we process personal data in these circumstances is our legitimate interest to provide you with a better user experience, and to ensure that our website is kept secure.
The use of any non-essential cookies is subject to your consent. You can also prevent us from using your personal data in this way by using the ‘do not track’ functionality in the internet browser. If you enable such do not track functionality, our website may be less tailored to your needs and preferences.
1.4 For marketing purposes:
1.4.1 Where you have opted in to receive marketing communications from us, we will process your personal data to provide you with marketing communications in line with the preferences you have provided. We may use external marketing agents to help us with such marketing communications.
1.4.2 The legal basis on which we process personal data for marketing purposes is your consent. You are not under any obligation to provide us with your personal data for marketing purposes, and you can withdraw your consent to personal data being processed in this way at any time by contacting us at [0044 (0) 1803 896 847] or [firstname.lastname@example.org] or, where relevant, by following the unsubscribe link in any marketing communication you receive from us. If you do choose to withdraw consent, this will not mean that our processing of personal data before you withdrew your consent was unlawful.
1.5 If our business is sold: We will transfer your personal data to a third party:
1.5.1 in the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets (at all times in accordance with all applicable data protection laws); or
1.5.2 if Red Paddle or substantially all of its assets are acquired by a third party, in which case personal data held by Red Paddle about its customers will be one of the assets transferred to the purchaser,
in each case, the legal basis on which we process data in these circumstances is our legitimate interest to ensure our business can be continued by a purchaser. If you object to our use of personal data in this way, the relevant seller or buyer of our business may not be able to provide products to you.
1.6 In certain circumstances we may also need to share your personal data if we are under a duty to disclose or share personal data in order to comply with any legal obligation.
2 CATEGORIES OF INFORMATION WE COLLECT FROM YOU
We will collect and process the following personal data:
2.1 Information you give us: This is information about you that you give us by filling in your details at the online checkout process or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you sign up for our newsletter, register your purchase with us, participate in social media functions on our website, enter a promotion or event, complete a survey and/or when you report a problem with our website. The information you give us may include names, addresses, email addresses and phone numbers.
2.2 Information we collect: With regard to visits to our website we will automatically collect the following information:
2.2.1 technical information, including the Internet protocol (IP) address used to connect computers to the internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, screen resolution, operating system and platform; and
2.2.2 information about visits, including the full Uniform Resource Locators (URL), clickstream to, through and from our website (including date and time), page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs) and methods used to browse away from the page.
2.3 Information we receive from other sources: We are also working closely with third parties (including, for example, business partners, sub-contractors, advertising networks, analytics providers, event coordinators, hosting providers and search information providers) from whom we may also receive information about you.
2.4 We do not process any special categories of personal data, meaning personal data revealing:
2.4.1 racial or ethnic origin;
2.4.2 political opinions; religious or philosophical beliefs;
2.4.3 trade union membership;
2.4.4 genetic or biometric data that uniquely identifies individuals; or
2.4.5 data concerning an individual’s health, sex life or sexual orientation.
2.5 We do not process data relating to criminal convictions unless legally obliged to do so.
3.2 A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer. We only use (and store) non-essential cookies on your computer’s browser or hard drive if you provide your consent.
Third Party Cookies:
Some of the cookies described above are stored on your machine by third parties when you use our website. We have no control over these cookies of how the third party uses them. They are used to allow that third party to provide a service to us, for example website analytics. For more information on these cookies and how to disable them, please see:
- Internet Advertising Bureau website at www.youronlinechoices.com where you will be able to opt-out of receiving Internet Based Advertising cookies from some of the third parties listed below. And/or
3.4 You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.
3.5 Except for essential cookies, all cookies will expire as outlined under the expiration column in the table included in paragraph 3.2.
4 USES MADE OF THE INFORMATION
We will combine the information you provide to us with information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).
5 WHERE WE STORE PERSONAL DATA
5.1 The data that we collect from you will be stored in (and will not be transferred out of) the European Economic Area.
5.2 All information you provide to us is stored on secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website, you are responsible for keeping this password confidential. You must not share your password with anyone.
6 PERIOD OF STORAGE
6.1 Where you purchase products from us, we will retain your data for a period of [six (6)] years after the goods were delivered, to ensure that we are able to assist with any questions or feedback in relation to our goods or to enforce, or protect, or defend our legal rights.
6.2 Where we have processed your personal data to provide marketing communications with your consent, we may contact you at least every [twelve (12) months] to ensure you are happy to continue receiving such communications. If you tell us that you no longer wish to receive such communications, your personal data will be removed from our mailing lists.
7 RIGHTS UNDER DATA PROTECTION LAWS
Right to object
7.1 You have the right to object to us processing your personal data where we are processing your personal data:
7.1.1 based on our legitimate interests (as set out at sections 1.2, 1.3, 1.3 and 1.5 above). If you ask us to stop processing your personal data on this basis, we will stop processing your personal data unless we can demonstrate compelling grounds as to why the processing should continue in accordance with data protection laws; and
7.1.2 for direct marking purposes. If you ask us to stop processing your personal data on this basis, we will stop.
Right of access
7.2 You have the right to receive confirmation as to whether your personal data is being processed by us, as well as various other information relating to our use of your personal data. You also have the right to access your personal data which we are processing. [We may charge you for exercising this right if we are allowed to do so by applicable law.]
Right to rectification
7.3 You have the right to require us to rectify any inaccurate personal data we hold about you. You also have the right to have incomplete personal data we hold about you completed, by providing a supplementary statement to us.
Right to restriction
7.4 You have the right to restrict our processing of your personal data where:
7.4.1 the accuracy of the personal data is being contested by you;
7.4.2 the processing by us of your personal data is unlawful, but you do not want the relevant personal data erased;
7.4.3 we no longer need to process your personal data for the agreed purposes, but you want to preserve your personal data for the establishment, exercise or defence of legal claims; or
7.4.4 we are processing your data on the basis of our legitimate interest (as set out at sections 1.2, 1.3, 1.3 and 1.5 above) and you:
18.104.22.168 object to our processing on the basis of our legitimate interest under section 7.1.1 above; and
22.214.171.124 want processing of the relevant personal data to be restricted until it can be determined whether our legitimate interest overrides your legitimate interest.
7.5 Where any exercise by you of your right to restriction determines that our processing of particular personal data are to be restricted, we will then only process the relevant personal data in accordance with your consent and, in addition, for storage purposes and for the purpose of legal claims.
Right to data portability
7.6 You have the right to receive your personal data in structured, standard machine readable format and the right to transmit such personal data to another controller.
Right to erasure
7.7 You have the right to require we erase your personal data which we are processing where one of the following grounds applies:
7.7.1 the processing is no longer necessary in relation to the purposes for which your personal data was collected or otherwise processed;
7.7.2 our processing of your personal data is based on your consent, you have subsequently withdrawn your consent and there is no other legal ground we can use to process your personal data;
7.7.3 you object to the processing in as set out in section 7.1.1 of this policy and we have no overriding legitimate interest for our processing;
7.7.4 the personal data have been unlawfully processed; and
7.7.5 the erasure is required for compliance with a law to which we are subject.
7.8 You have the right to lodge a complaint with the Information Commissioner’s Office, the supervisory authority for data protection issues in England and Wales.
7.9 You can exercise such rights by contacting us on [01803 896 847] or by writing to us at [email@example.com]
8 LINKS ON OUR WEBSITE
Our website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that you have left our website and these websites have their own privacy policies. We do not accept any responsibility or liability for these policies or websites. Please check these policies before submitting any personal data to these websites.
 If the policy is going to be used immediately. consider including this sentence as up until 25 May 2018, businesses are entitled to charge £10 for any request for information by an individual about the personal data held about them (‘subject access requests’). Note, after this time, such information must be provided free of charge.