Pranda UK Limited T/A Gemondo ("Gemondo", "we" and "us") is committed to our customers' privacy and the following notes outline our information practices. If you feel we are not abiding with our obligations under data protection law, or if you have any questions please contact firstname.lastname@example.org.
We are keen to strike a fair balance between your personal privacy and ensuring you obtain full value from the internet and other products and services we may be able to market to you.
We are fully registered under the Data Protection Act 1998 and the EU General Data Protection Regulation and ensure we comply with all protection the Act affords to you. Further information on the Act is available at www.informationcommissioner.gov.uk. We use the data protection padlock symbol below to show when we gather personal data from you. Look out for it on the site.
Reproduced courtesy of the Information Commissioner's Office and the National Consumer Council.
1. Personal Information
For the purposes of this Privacy Notice, "Personal Information" consists of any information that relates to you and/or information from which you can be identified, directly or indirectly. For example, information which identifies you may consist of your name, address, telephone number, photographs, location data, an online identifier (e.g. cookies identifiers and your IP address) or to one or more factors specific to your physical, physiological, genetic, mental, economic, cultural or social identity. We may collect, use, store and transfer different kinds of Personal Information about you when you visit our site, contact us by the telephone, email or post, or purchase any of our products.
- In some areas of our site we ask you to provide information directly. This includes: identity and contact Personal Information (Name, email address, address, etc.) which you provide as part of our registration process when setting up your Gemondo account, when you purchase any of our products, voluntarily complete a Contact Form on our website or otherwise interact with us by telephone, email or post.
- We also collect technical and usage Personal Information about users' equipment, browsing actions and patterns other activities on our site. This includes internet protocol (IP) addresses, the type of browser used while visiting our site, the number of users visiting our site and usage session dates and duration.
- From time to time we may also ask for additional personal information as part of a promotion/competition.
2. Use of Personal Information
1. Your personal data will be used to:
- provide the information, goods and services offered through our website to you,
- for billing and order fulfilment,
- to provide customer support services,
- for business monitoring and internal record keeping,
- in the event there is a complaint which arises concerning your use of this website, where such use does not comply with our terms and conditions,
- To communicate with you, including communicating with you about your transactions with us, giving you important information about your products, sending you notices about any material changes to our Privacy Notice, and, where permitted by you and applicable laws, marketing, sending you offers and promotions for our products.
The law allows us to use your Personal Information for these purposes on the basis that the processing is necessary for the performance of a contract with you, or we are acting in our "legitimate interests" in the promotion and efficient running of our business, and your interests are not overridden. We may also access and disclose your Personal Information to comply with applicable laws and lawful government requests. We use your Personal Information in this way on the basis that it is necessary for compliance with a legal obligation to which we are subject.
2. The information you provide will be kept confidential and will be used only to support your customer relationship with us. We do not disclose or sell your information outside our corporate group except if we sell the whole or part of our business.
3. When you register with Gemondo you may give us your explicit consent to receive our newsletter and other marketing communications. We may pass your Personal Information to our third party service provider, FetchCommerce, to assist us in sending you our marketing communications. We will only market to you the same kind of goods and services you purchased from us or made an enquiry to us about.3. We may also use transactional data to update your profile so that we can offer you similar products that may be of interest to you based on this data, with your explicit consent. If you would rather not receive future marketing emails from us please inform us by email at email@example.com, or by updating your marketing preferences on your Account page of our site. Such use is strictly in accordance with applicable data protection laws. Every email from us comes with an easy to use unsubscribe instruction and you can be removed from our lists at any time, although this can take up to 30 days to effect.
4. From time to time we will perform analysis on our member and transaction databases. The results of this analysis may be released to third parties, but only in aggregate form and will contain no Personal Information at all.
3. Who do we disclose your Personal Information to?
We will only use your Personal Information for our internal business purposes, some of which are mentioned above. We do not sell any of your Personal Information to third parties. We may disclose your Personal Information to:
We may need to transfer your Personal Information to other Gemondo affiliates to provide the products you require or any other services/assistance you request. All Gemondo affiliates are required to follow the privacy practices set forth in this Privacy Notice, or such other privacy notice that they may notify to you.
We use third party service providers to help us administer certain activities and services on our behalf, such as analysing usage of our website, storing information and fulfilling orders. We may share Personal Information about you with such third party service providers solely for the purpose of enabling them to perform services on our behalf, and they will operate only in accordance with our instructions. Here are examples of third party service providers we use:
- Analytics Service Providers. Analytics providers are used to assist us in understanding the usage of our products and other services, to enable us to improve our site. See section 5 below called "Cookies and Tracking".
- Payment Providers – we use Sagepay and PayPal to facilitate payments made by you for our products (See section 4 called "Payment Providers" below).
- Delivery agents. We use Royal Mail and DHL to facilitate efficient delivery of your order.
- Marketing Communications. We may use third parties to assist us in promoting our business and in informing you about our products which may be of interest to you. We may use FetchCommerce, a cookie-based tracking service, to assist us in doing this.
Third Parties when required by law or to protect our products or website.
We will disclose your Personal Information to comply with applicable law or respond to valid legal process, including from our regulators, law enforcement or other government agencies; to protect our customers (e.g. to prevent spam or attempts to defraud users of our products); to operate and maintain the security of our products (e.g. to prevent or stop an attack on our systems or networks); or to protect our rights and property, including enforcing any terms or agreements about our products.
4. Payment Providers
Making sure you can buy safely online is a priority for us and we have made strenuous efforts to ensure that store security is one of our highest priorities. We use industry-standard Secure Sockets Layer (SSL) technology to allow for the encryption of potentially sensitive information such as your name and address.
In respect of the payments made by you through our website we have outsourced to Sagepay the collection of all credit and debit card payments which are subject to the same high SSL encryption standards and security as referred to above. No payment information is stored on the Gemondo server. Gemondo also offers direct sales from you by telephone, e-mail or fax. We will then input your debit or credit card information into the Sagepay website on your behalf. This allows you to pay with all major debit and credit cards. We will hold this personal financial data, but will use it solely for the purpose of processing your payment and communicating with Sagepay. Your data will be held in accordance with all relevant data protection legislation and will not be stored by us for any longer than is necessary for communicating with Sagepay and settling your payment.
You may also make payment via your PayPal account, during this process you will be redirected to the PayPal website and no payment data will be stored on the Gemondo server.
We take the security of your personal data very seriously and trust that the payment methods and procedures set out above reflect this. It is also your responsibility to keep your personal data safe. By our joint efforts we believe that your order with Gemondo should be safe, secure and efficient.
We hope that once you understand the measures we take to help ensure secure transactions and privacy, and the steps you can take yourself, you will be as happy about the safety of your online transaction and order information as we are.
5. Cookies and Tracking
- Cookie Tracking. We may store information about you using cookies. Cookies are small text files that can be read by a web server in the domain that put the cookie on your hard drive. Cookies are assigned to and stored in a user's internet browser on a temporary (for the duration of the online session only) or persistent basis (cookie stays on the computer after the internet browser or device has been closed).
- We use the following cookie-based tracking services to enhance our website performance and improve our website:
- Google Analytics, which collects anonymised data regarding your movements and browsing habits, and anonymous sales information.
- Google AdWords and Bing Ads, which collect anonymised sales performance data from sales achieved by advertisements we place.
- FetchCommerce, which tracks anonymised customer browsing habits to recommend products to future customers based on previous product views.
- Social media organisations including Facebook, Instagram, Twitter and Pinterest, which collect anonymised customer buying habits and anonymous sales information for advertising performance review.
- If you want to delete any cookies that are already on your computer please refer to the instructions on your file management software, which locates the file or directory that stores cookies. Information on deleting or controlling cookies is available at www.aboutcookies.org. Please note that by deleting our cookies or disabling future cookies you may not be able to access certain areas of our site until you log in manually.
6. Website Security
We offer the use of a secure server when you access your account detail and profile information. We have put in place appropriate physical and technical measures to safeguard your Personal Information. In addition, we limit access to your Personal Information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Information on our instructions and they are subject to a duty of confidentiality. However, please note that although we take appropriate steps to protect your Personal Information, no website, product, device, online application or transmission of data, computer system or wireless connection is completely secure and therefore we cannot guarantee the security of your Personal Information.
7. International Transfer of Personal Information
The Personal Information that we collect from you may be stored and processed in your region, or transferred to, stored at or otherwise processed outside the European Economic Area ("EEA"), including but not limited to the United States of America, or any country where Gemondo or Gemondo's affiliates or service providers maintain facilities.
By using our website and/or providing us with your Personal Information, you acknowledge that we will collect, transfer, store and process your Personal Information outside of the EEA. We will take all steps reasonably necessary to ensure that your Personal Information is kept secure and treated in accordance with this Privacy Notice and the requirements of applicable law wherever the data is located. Where we transfer your Personal Information outside of the EEA to other members of the Gemondo group, we do so in accordance with EU regulations. Where we transfer your Personal Information to our third party service providers, we do so to organisations which have certification on the EU/US Privacy Shield.
- Access to your account is password protected and we never release details of this to third parties. If you have forgotten your password please visit the ‘Forgotten Password’ section of the Gemondo web site to request your Password and Username.
- Gemondo cannot be held responsible for any activity in your account that has resulted from a member not keeping their account details secure.
- Gemondo will never contact you to ask for your Username or Password.
We retain Personal Information for as long as necessary to fulfil the purposes for which your Personal Information has been collected as outlined in this Privacy Notice, unless a longer retention period is required by law. When your Personal Information is no longer required for the purpose it was collected, or as required by applicable law, it will be deleted and/or returned to you in accordance with applicable law.
10. Order Contract Information:
We store the contract's content and will send you the details of your orders as well as our general terms via email. You can find the terms here at all times. The details about your recent orders can be found in your customer login.
11. Your Rights
You have the following rights in relation to your Personal Information:
- To request access to the Personal Information which we may hold or process about you.
- Rectification. You have the right to require us to correct any inaccuracies in your Personal Information. To the extent required by applicable law, we will rectify or update any incorrect or inaccurate Personal Information about you.
- Withdraw consent. Where you have consented to our processing your Personal Information, you have the right to withdraw such consent at any time. In the event you wish to withdraw your consent to processing, please contact us using the details provided in section 12.
- Data portability. In certain circumstances you may request us to port (i.e. transmit) your Personal Information directly to another organisation.
- Erasure. In certain specified situations you have the right to have your Personal Information "erased". This is the "right to be forgotten".
- Restriction of processing – you have the right in certain specified situations to require us to stop processing your Personal Information and to only store such Personal Information.
- Object to processing – you have the right to object to specific types of processing of your Personal Information, such as, where we are processing your Personal Information for the purposes of direct marketing
- Prevent automated decision-taking – in certain circumstances, you have the right not to be subject to decision being taken solely on the basis of automated processing.
- Complain to the regulator – if you are concerned that we have not complied with your legal rights under applicable data protection laws, you may contact the Information Commissioner's Office (www.ico.gov.uk) which is the data protection regulator in the UK which is where Gemondo is located. Alternatively, if you are based outside the UK, you may contact your local data protection supervisory authority.
If you wish to enforce any of our rights under applicable data protection laws, then please contact us using the details provided in section 12. We will respond to your request without undue delay and by no later than one month from receipt of any such request, unless a longer period is permitted by applicable data protection laws, and we may charge a reasonable fee for dealing with your request which we will notify to you. Please note that we will only charge a fee where we are permitted to do so by applicable data protection laws
12. Further information on data protection and personal privacy:
For further information from us on data protection and privacy contact:
The Data Protection Manager,
Pranda UK Limited T/A Gemondo.
PO Box 98
Information on data protection legislation is also on the Information Commissioner's website at www.informationcommissioner.gov.uk
Use of this Site is subject to our Terms and Conditions
Pranda UK Limited T/A Gemondo is a company registered in England. Registered number 2858435. VAT Registration Number: GB 644 1218 62
PRIVACY NOTICE OF Pranda UK Limited T/A Gemondo
Version May 2018