WEBSITE PRIVACY NOTICE

At Webmartz, we believe that privacy is as vital as a well-tailored suit: essential for navigating the digital landscape. We value your privacy and are dedicated to safeguarding your data.

This privacy policy outlines how we gather and manage your data in the following scenarios:

·         Your interaction with our website (www.webmartz.co.uk), including any details provided via our live chat feature.

·         Transactions made at our online retail store.

·         Account creation or subscription to our newsletters or email updates.

·         Product purchases on our website.

·         Participation in competitions or surveys.

·         Communication with our call center.

·         Order fulfillment processes.

1.       IMPORTANT INFORMATION AND WHO WE ARE

Webmartz, operating as the online retail business of Commerce Sphere Limited (“we”, “us” and “our”), is a registered company in England and Wales with company number 15306185. We serve as the controller of your data. Whether referred to as Commerce Sphere or Webmartz, we are the same entity. Should you have any inquiries regarding this privacy policy, our privacy practices, or your data, please don't hesitate to reach out to us:

·         Email address: datacontroller@webmartz.co.uk

·         Postal and registered office address: The Data Protection Officer, Commerce Sphere Limited, 9, Keswick Close, Tilehurst, Reading RG30 4SD.

2.       THE DATA WE COLLECT ABOUT YOU

We prioritize the protection and confidentiality of your personal information. We define personal data as any information that can identify an individual. We're committed to transparency about the types of personal data we collect, use, store, and transfer, which we categorize as follows:

·         Identity Data: This includes your first name, last name, username or similar identifier, marital status, title, date of birth, and gender.

·         Contact Data: We collect your billing address, delivery address, email address, and telephone numbers to ensure smooth communication and delivery of our services.

·         Financial Data: Your bank account and payment card details are securely stored for efficient payment processing.

·         Transaction Data: We gather details about payments made by you and other transactional information related to products purchased from us.

·         Technical Data: Information such as your IP address, browser type and version, time zone setting, location, and device technology helps us improve your browsing experience.

·         Profile Data: Your username, password, purchase history, preferences, feedback, and survey responses enable us to tailor our services to your needs.

·         Usage Data: We analyze how you interact with our website, products, and services to enhance user experience and optimize our offerings.

·         Marketing and Communications Data: Your preferences regarding marketing communications, as well as your engagement metrics like open and click-through rates, assist us in delivering relevant content.

In addition, we collect, use, and share Aggregated Data for various purposes. This data, derived from personal information but devoid of any identifying markers, helps us analyze trends and improve our services without compromising individual privacy. For instance, we may use aggregated usage data to assess the popularity of specific website features.

Rest assured, we do not gather any Special Categories of Personal Data, including information related to race or ethnicity, religious beliefs, sexual orientation, political opinions, or health status. Our commitment to privacy extends to refraining from collecting data about criminal convictions and offenses. Furthermore, we confirm that our website is not directed at children, and we do not knowingly collect data from individuals under the age of consent.

3.       HOW YOUR DATA IS COLLECTED

We employ various methods to collect data from and about you, ensuring transparency and security in our practices. These methods include:

·         Direct Interactions: You can provide us with your Identity, Contact, and Financial Data through direct interactions. This may occur when you engage with our online platform, contact our customer service team, or visit our retail stores. Whether you're:

o   making a purchase.

o   creating an account.

o   subscribing to marketing materials.

o   participating in promotions or surveys, or

o   simply reaching out with feedback or inquiries,

we gather the necessary personal data to facilitate these interactions and enhance your experience.

·         Automated Technologies or Interactions: As you navigate through our website, we automatically gather Technical Data related to your device, browsing behaviors, and preferences. This is achieved using cookies, server logs, and similar technologies. Additionally, we may receive Technical Data to refine your experience further if you visit other websites utilizing our cookies. For comprehensive details, please refer to our cookie policy.

·         Third Parties or Publicly Available Sources: We may receive personal data about you from various third-party sources and public databases, ensuring accuracy and relevance. These sources include:

o   Technical Data from reputable parties such as:

§ Analytics providers like Google, located within the EU.

§  advertising networks like Epsilon and the Abacus Alliance, situated in the UK.

§ Search information providers such as Google based inside the EU.

o   Contact, Financial, and Transaction Data from trusted providers of technical, payment, and delivery services, including Adyen and Amazon Shipping, operating within the EU.

o Identify and Contact Data from data brokers, aggregators, or esteemed data pooling retail partners such as Epsilon and Experian, based in the UK. These partners manage prospect pools on behalf of retailers in the UK.

o   Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register, operating within the EU.

4.       HOW WE USE YOUR DATA

We are committed to using your data responsibly and under applicable laws and regulations. We ensure that your privacy is protected and respected. Here's how we handle your data:

o   Contractual Obligations: We will use your data when it is necessary to fulfill the contract we have entered or are about to enter with you as part of our online retail business.

o   Legitimate Interests: We may process your data when it is necessary for our legitimate interests or those of a third party, provided your interests and fundamental rights do not override those interests. This includes activities essential for the operation of our online retail business under the trading name of Webmartz.

o   Legal Compliance: We will use your data to comply with any legal obligations imposed on us.

Generally, we do not rely on consent as a legal basis for processing your data although we will get your consent before sending third-party direct marketing communications to you via email or text message. You have the right to withdraw your consent for marketing activities at any time by reaching out to us.

Below, we outline the specific purposes for which we plan to use your data, the legal bases for such processing, and where applicable, our legitimate interests:

5.       MARKETING AND OPTING OUT

We strive to tailor our offerings to suit your preferences. We may analyze your Identity, Contact, Technical, Usage, and Profile Data to better understand your interests and provide you with relevant products, services, and offers.

You'll receive marketing communications from us if you've sought information from us or made purchases without opting out of such communications.

Occasionally, we may share your data with trusted third parties, such as Epsilon and the Abacus Alliance. We do so in pursuit of our mutual interests, including the promotion of our products and theirs.

You have the power to control your marketing preferences. If you wish to stop receiving marketing messages, simply utilize the opt-out links in any marketing correspondence or reach out to us using the contact details provided above.

It's important to note that opting out of marketing messages won't affect the personal data we've collected from you because of product purchases, experiences, or other transactions.

6.       CHANGE OF PURPOSE

We are committed to using your data solely for the purposes for which it was collected. However, there may be instances where we find it necessary to utilize your information for another compatible reason. Should this situation arise, we will ensure that the new purpose aligns with the original intent of the collection.

If you require clarification regarding how the processing for the new purpose aligns with the initial objective, please do not hesitate to reach out to us.

If we need to employ your data for an unrelated purpose, we will inform you accordingly and explain the legal basis permitting such action.

Please be aware that there may be circumstances where we process your data following the above guidelines, even without explicit knowledge or consent, if mandated or allowed by law.

7.       DISCLOSURES OF YOUR DATA

We may share your data with the parties set out below for the purposes set out in the table above:

·         Any member of our corporate group (if any), as defined by section 1159 of the Companies Act 2006, or one of our connected companies.

·         Service providers acting as processors based in the EU/UK or outside of the European Economic Area (EEA) who provide IT and system administration services, customer support, and delivery services.

·         HM Revenue & Customs, regulators, and other authorities acting as processors or joint controllers based in the UK who require reporting of processing activities in certain circumstances.

·         Our professional advisors.

·         Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your data in the same way as set out in this privacy policy.

·         Third parties to which we may be under a duty to disclose or share your data to comply with any legal obligation, enforce a legal obligation, or protect the rights, property, or safety of Webmartz, our customers, or others.

·         Our trusted third-party retail partners for data pooling or any other third party with your prior consent.

We require all third parties to respect the security of your data and to treat it by the law. We do not allow our third-party service providers to use your data for their purposes and only permit them to process your data for specified purposes and under our instructions.

8.       INTERNATIONAL TRANSFERS

Safeguarding your data is paramount, even when it's transferred outside of the UK and the European Economic Area (EEA). Given that many of our external partners operate beyond the EEA, the processing of your data may necessitate its transfer outside this region.

Rest assured; we uphold stringent measures to ensure that your data receives an equivalent level of protection. This includes implementing one of the following safeguards:

·         Transfer to Adequate Jurisdictions: Your data will only be transferred to countries that the European Commission has deemed to offer an adequate level of protection for personal data.

·         Utilization of Approved Contracts: In instances where we engage specific service providers, we adhere to contracts pre-approved by the European Commission. These contracts ensure that your data receives the same level of protection as it would in Europe.

For further details on the mechanisms employed by Webmartz for the transfer of your data outside the EEA, please don't hesitate to contact us.

9.       DATA SECURITY

Safeguarding your data is our utmost priority. We employ robust security measures to prevent any inadvertent loss, unauthorized access, misuse, alteration, or disclosure of your information. Rest assured, we restrict access to your data to authorized personnel, including employees, agents, contractors, and relevant third parties, who require access for legitimate business purposes only. These authorized parties will process your data solely based on our instructions and are bound by strict confidentiality obligations.

Moreover, we have implemented comprehensive procedures to address any suspected personal data breaches promptly. In the event of such an occurrence, we will notify you and any relevant regulatory authorities, as required by applicable laws and regulations.

10.   YOUR DUTY TO INFORM US OF CHANGES

The personal data we hold about you must be accurate and current. Please keep us informed if your data changes during your relationship with us.

11.   THIRD-PARTY LINKS

Our website or any of our publications 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 policy of every website you visit.

12.   DATA RETENTION

We will only retain your data for as long as reasonably necessary to fulfill the purposes we collected it for, including to satisfy any legal, regulatory, tax, accounting, or reporting requirements. We may retain your data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation concerning our relationship with you.

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 unauthorized use or disclosure of your data, the purposes for which we process your data, and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Details of retention periods for different aspects of your data are available in our retention policy which you can request from us by contacting us.

13.   YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws concerning your data.

·         Request access to your data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

·         Request correction of your data. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

·         Request the erasure of your data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully, or where we are required to erase your data to comply with local law. However, we may not always be able to comply with your request for erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

·         Object to processing of your data. This applies where we are relying on a legitimate interest (or those of a third party) and there is something about your situation that makes you want to object to processing on this ground as you feel it impacts your fundamental rights and freedoms. You also have the right to object where we are processing your data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

·         Request restriction of processing your data. This enables you to ask us to suspend the processing of your data in the following scenarios:

·         If you want us to establish the data's accuracy.

·         Where our use of the data is unlawful, but you do not want us to erase it.

·         Where you need us to hold the data even if we no longer require it as you need it to establish, exercise, or defend legal claims.

·         You have objected to our use of your data, but we need to verify whether we have to override legitimate grounds to use it.

·         Request transfer of your data. We will provide to you, or a third party you have chosen, your data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information that you initially provided consent for us to use or where we used the information to perform a contract with you.

·         Right to withdraw consent. Where we are relying on consent to process your data, you can withdraw consent at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us.

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.

14.   NO FEE USUALLY REQUIRED

You will not have to pay a fee to access your 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 could refuse to comply with your request in these circumstances.

15.   WHAT WE MAY NEED FROM YOU

We may need to request specific information from you to help us confirm your identity and ensure your right to access your 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 about your request to speed up our response.

16.   TIME LIMIT TO RESPOND

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.