This privacy statement describes how Dunvegan Enterprises Limited (“we”, “our” or “us”) is committed to protecting the security and privacy of all personal information or data collected from you. We therefore conduct our business in compliance with applicable laws on data privacy protection and data security. This privacy statement tells you what to expect when we collect and process your personal information.
We try to meet the highest standards when processing your personal information. The data controller who is responsible for how we handle your personal information is Dunvegan Enterprises Limited trading registered under the Companies Acts (SC253780) and having its registered office at c/o McAllisters CA, Paxton House, 11 Woodside Crescent, Glasgow G3 7UL and its principal place of business at 1 Dunvegan Drive, Newton Mearns, Glasgow G77 5EB. Any queries you have in relation to the same should be directed to [email protected].
Information We May Collect from You
We may ask you to provide certain information about yourself when you use our website or are in contact with us about the products/services we provide (whether it is by telephone, email via the forms on our website, through applications or platforms we use, through our social media platforms or even face to face).
The personal information collected may include:
- Details in relation to your identity such as your name
- Contact details including your postal/e-mail addressand phone number
- Transaction details about services you specifically requestfrom us
- Financial details in relation to any services bought from us including addresses for invoices/billing and bank payment details (including credit card payment details)
- Profile details from documents you complete on-line such as your user name and preferences, interests and your transaction history
- Information from surveys and feedback forms in respect of any of our services you may have purchased or enquired about
- details of your visits to our website including but not limited to traffic data, location data, weblogs and other communication data and the resources that you access or use
The personal information we hold about you will be held solely for the following purposes:
- To maintain records of your use of our services and administering those services;
- To communicate with you regarding any transactions with you or enquiries you make or information you request;
- To make suggestions that may be of interest to you keeping you uptodate regarding our services and activities whether by newsletter, email, or otherwise;
- To facilitate payments in respect of any services requested by you;
- To comply with our regulatory and legal obligations;
- For credit and identity verification and fraud detection in respect of transactions with you;
- To establish, exercise or defend any complaints made by or against you or any claims or litigation process raised by either of us against the other including in respect of us resorting to debt recovery or enforcing our terms of business;
- To administer of our website and business (including webhosting and support) and to ensure that content from our website is relevant to you and is presented in the most effective manner for you including seeking your views on our products and service.
Our legal basis under GDPR for doing so is either performance of a contract with you, legal obligation or that such processing is in our legitimate interests in respect of running our organisation including developing our services, ensuring security and performance of our website and informing our overall marketing strategy.
We will generally not collect sensitive data from you. Sensitive data is personal information which includes your racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic or biometric data, or information concerning your health or mental wellbeing or sexual orientation. Given the nature of the services we provide it is extremely unlikely that we will require to collect any sensitive data about you. Where we do require to process such sensitive data to provide services to you we will notify you in advance and will request your express consent in writing to process such sensitive data.
If you do not wish us to collect any of the personal information stated above, you should discuss this with us. We can explain the reasons for collection and discuss the consequences of not providing the information or of providing partial or incomplete information and the effect, if any, this may have on our ability to provide our services or respond to enquiries.
How long we hold information for
We will only retain your personal information for as long as is necessary in line with the purposes for which it was originally requested or collected or where we are required to do so for some legal or reporting purpose.
In working out how long we retain personal data we look the type of personal data involved, the purpose of processing, how sensitive or confidential the data is and at legal and commercial considerations including any legal obligations we have. By way of example if you use our services by law we are required to keep accounting records for six years after end of the year in which the last transaction occurred. This means that we will be required to keep some basic service user details for that purpose even although our relationship with you may be at an end. However, it should be noted that the requirement is basic service user details and therefore it is not legitimate to also keep information such as your preferences for that period of time.
If you have any questions relating to either retention periods or more require more detail on the purposes of processing or the specific reason or legal grounds, we are relying on for that processing then please contact us for additional information.
Sharing Your Information
We will not sell the personal information that we collect from you and will only use it for the purposes set out in this privacy statement. We may share your personal information with the following parties: –
- Service providers who provide us with IT and administration services such as IT Support and back up, webhosting;
- Third party providers of services such as contractors delivering our services or payment services providers but only to the extent necessary for the provision of the services.;
- Regulatory authorities who require reporting of our activities by law such as the tax authorities;
- Professional advisers such as our lawyers, accountants, bankers and insurers but only to the extent that is necessary for the provision of their services to us;
- Debt collection agencies for the purposes of credit control or recovery of any sums due by you to us or where disclosure is necessary for the establishment, exercise or defence of legal claims; and
- Third parties to whom we sell, transfer or merge our business or any part of it.
All third parties with whom we share your data are required to protect your personal data, treat it confidentially and to process it in accordance with the law. Where we use third parties we will take all reasonable steps to ensure that they are GDPR compliant and in particular that:
- they have adequate technical and other measures in place to ensure the security of your personal information;
- that they only use it for specified purposes;
- That any employees or contractors who have access to the information are adequately trained and deal with it on a need to know basis only;
- and that they act only in accordance with our instructions.
IP Addresses and Cookies
When you visit our website we automatically collect certain information about the device you use to do so (“your device”), including information about your web browser, IP address, time zone and some of the cookies that are installed on your device. Additionally, as you browse the website we collect information about the individual webpages or products that you view, what websites or search terms referred you to the website and information about how you interact with the website. We refer to this automatically-collected information as Device Information.
We collect Device Information using the following technologies:
“Cookies” are data files that are placed on your device and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.
“Log files” track actions occurring on the website and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
“Web beacons”, “tags” and “pixels” are electronic files on the website used to record information about how you use the website.
We may provide you with information on products that we sell. In order to optimise your customer experience with you this may include postal mail, SMS and emails to you to update you on our latest offers and events. We may also show you content via social media platforms and other external applications such as Facebook and Instagram. This is regarded as marketing activity. We will only market to you where you have: –
- specifically requested marketing information from us; or
- Previously acquired similar services/goods from us; or
- Consented by way of ticking a box or opting in to receiving marketing from us.
If you have opted out of marketing, we will not send you any future marketing without your consent.
Each time we market to you we will always give you the right to opt out of any future marketing by using the simple “unsubscribe” link in emails or the “STOP” number for texts. We would point out that you have the right at any time to ask us not to market to you by emailing us at [email protected] rather than waiting on a specific opt out.
Security of Personal Data
We take information security very seriously. Your information and records will be stored securely to ensure privacy of your personal data. We take all reasonable steps to ensure that there are technical and organisational measures of security in place to protect your personal data from unauthorised access to or disclosure of it, and against loss or accidental damage or unauthorised alteration of it. Staff handling your personal data are also adequately trained in relation to the legal requirements for handling personal data. These include robust procedures for dealing with breaches including incident reporting and notifying the national supervisory or data protection authorities, and where appropriate you, of any breaches, the consequences of the same and the remedial action taken.
Where possible the information you provide us with will be held within the European Economic Area (“EEA”) or within the UK.
We would point out that countries outside of the EEA do not always have similar levels of protection for personal data as those inside the EEA. The law provides that transfers of personal data in respect of EU based individuals outside of the EEA is only permitted where that country has adequate safeguards in place for the protection of personal data. Some types of processing may use cloud solutions which can mean information may sometimes be held on servers which are located outside of the EEA or may use processors who are based overseas.
Where we use cloud-based services or third-party providers of such services and in either or both circumstances the data is processed outside of the EEA if you are an EU based individual that will be regarded as an overseas transfer. Before instigating an overseas transfer, we will ensure that the recipient country and/or processor has security standards at least equivalent to EU standards and in particular one of the following permitted safeguards applies: –
- The country in question is deemed to have adequate safeguards in place as determined by the European Commission; or
- There is a contract or code of conduct in place which has been approved by the European Commission which gives your personal information the same protection it would have had if it was retained within the EEA; or
- If the overseas transfer is to the United States, then the transferee is a signatory to the EU-US privacy Shield as all Privacy Shield signatories are obliged to give your personal information the same degree of protection it would have had if it was retained within the EEA.
If none of these safeguards exist, then we may seek your explicit consent for an overseas transfer. In line with your rights as an individual you are free to withdraw this consent at any time.
In certain instances, you have rights as an individual which you can exercise in relation to the information we hold about you. These rights are:
- the right to restrict processing of your personal data;
- the right to rectification or correction of your personal data;
- the right to object to processing of your personal data;
- the right of erasure of personal data (also referred to the right to be forgotten);
- the right not to be subject to a decision based solely on automated processing or profiling;
- the right to transfer your personal data (also referred to as the right of portability)
- the right to withdraw your consent to processing your personal data; and
- the right of access to your personal data.
Additional information about these rights can be found on the Information Commissioner’s website at www.ico.org.uk/for-organisation/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/
If you have provided consent and we are relying on that as the legal ground of processing your personal information and wish to exercise your right to withdraw that consent you can do so at any time by contacting us at [email protected].
Access to Personal Information
We try to be as open as we can in giving people access to their personal information. You can make a subject access request at any time about the personal information we process about you. Any request requires to be in writing and is not subject to any charges or fees. If we do hold any personal information about you, we will:
- give you a description of it;
- tell you why we are holding it;
- tell you who it has or will be disclosed to;
- the source of the information (if not you);
- where possible, the period for which it will be stored; and
- let you have a copy of the information in an intelligible form
We will respond to a subject access request within 30 days. On occasion we may need additional information from you to determine your identity or help us find the information more quickly. Where the information you have requested is complex we may take longer than this but shall keep you advised as to progress should this be the case.
If you believe that any information we hold about you is incorrect or incomplete you should email us at. Any information which is found to be incorrect will be corrected as soon as possible.
We would prefer to resolve any issues or concerns you may have direct with you. If you feel you are unable to resolve matters by contacting us direct or are you are unhappy or dissatisfied with how we collect or process your personal information you have the right to complain about it to your national data protection authority. For example, the Information Commissioner is the statutory body which oversees data protection law in the UK where we have our registered office. They can be contacted through www.ico.org.uk/concerns.
Questions, comments and requests regarding this privacy statement are welcomed and should be addressed to [email protected]
Changes to this Privacy Statement
We keep our privacy notice under regular review. This privacy statement was last updated on 14th June 2019.