Customer Privacy Notice

BACKGROUND

Hotfoot Design Limited understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of our customers and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.

1. Information About Us

Regalo Gifts Limited (“Regalo”)

Limited company, registered in England under company number 11885127

Registered address: The Storey, Meeting House Lane, Lancaster, LA1 1TH

VAT number: GB319326992

Data Protection Officer: Aidan Watt

Email address: dpo@hotfootdesign.co.uk

Telephone number: 01524 388813

Postal Address: The Storey, Meeting House Lane, Lancaster, LA1 1TH

We are regulated by the ICO.

Data Protection Registration Reference: ZA561293

2. What Does This Notice Cover?

This Privacy Information explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.

3. What is Personal Data?

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

The personal data that we use is set out in Part 5, below.

4. What Are My Rights?

Under the GDPR, you have the following rights, which we will always work to uphold:

The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 11.

The right to access the personal data we hold about you. Part 10 will tell you how to do this.

The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 11 to find out more.

The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Part 11 to find out more.

The right to restrict (i.e. prevent) the processing of your personal data.

The right to object to us using your personal data for a particular purpose or purposes.

The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.

Rights relating to automated decision-making and profiling. We do not use your personal data in this way.

For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 11.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.

5. What Personal Data Do You Collect?

We may collect some or all of the following personal data (this may vary according to your relationship with us:

• Name

• Date of birth

• Address

• Email address

• Telephone number

• Business name

• Job title

• Profession

• Payment information

6. How Do You Use My Personal Data?

Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data will be used for the following purposes:

Providing and managing your account, including invoicing and billing.

Supplying our products and services to you. Your personal details are required in order for us to enter into a contract with you.

Communicating with you. This may include responding to emails or calls from you.

Supplying you with information by email and post that you have opted-in to (you may unsubscribe or opt-out at any time by clicking an unsubscribe link or contacting us).

With your permission and where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email, telephone or post with information and news on our products and services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt out.

7. How Long Will You Keep My Personal Data?

We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. We need to keep personal data to allow us to communicate with you in our day-to-day operations to service your requests as a Customer, so we will always hold personal information about you as long as there is a relationship. We also need to hold personal data for our records after a relationship is finished for no longer than 6 years.

8. How and Where Do You Store or Transfer My Personal Data?

We store or transfer data within the UK and Ireland, this data will be fully protected under the GDPR or to equivalent standards by law. We also store or transfer some or all of your personal data in countries that are not part of the European Economic Area (the “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein). These are known as “third countries” and may not have data protection laws that are as strong as those in the UK and/or the EEA. This means that we will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR as follows.

We use specific contracts with external third parties that are approved by the European Commission for the transfer of personal data to third countries. These contracts ensure the same levels of personal data protection that would apply under the GDPR. More information is available from the European Commission.

Where we transfer your data to a third party based in the US, this may be protected if they are part of the EU-US Privacy Shield. This requires a third party to provide data protection to standards similar levels of data protection to those in Europe. More information is available from the European Commission.

To find a list of processors we use and where they are based please click here.

The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:

• necessary safety routines for avoiding virus attacks or other threats that could be harmful to the IT environment

• an encryption system and/or other security measures with the purpose of avoiding tapping or revealing signals

• necessary security routines for IT equipment

• a control system based on user authorization, which enables identification of user identity (through the usage of passwords or such) and prevents unauthorized use of or access to the processed Personal Data

• automatic backup routines, including storage of backup copies, as well as destruction or other means of eradication of all media that has contained Personal Data that no longer is used

9. Do You Share My Personal Data?

We may share your personal data with other companies in our group for administrative purposes. This includes Regalo.

In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

10. How Can I Access My Personal Data?

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 11.

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We will respond to your subject access request within one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

11. How Do I Contact You?

To contact us about anything to do with your personal data and data protection, including making a subject access request, please use the following details (for the attention of Aidan Watt Data Protection Officer):

• Email address: dpo@hotfootdesign.co.uk

• Telephone number: 01524 388813

• Postal Address: Regalo Gifts Limited, The Storey, Meeting House Lane, Lancaster, LA1 1TH

12. Changes to this Privacy Notice

We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

Any changes will be made available here.