British Harlequin plc - Privacy Policy & Cookies Policy

Our Privacy Policy British Harlequin plc

Document Version & History
Version 0.1 – Dated 09.05.2018 until superseded.
We have versioned and dated our policies so as our customers (Data Subjects) have full Transparency over the Privacy, Data Protection & Processing terms in which they will have engaged with at the time of their interaction. Policies are not static and need to be updated as and when legal and business needs arise. However, this does not mean that the obligations and rights confided in those historical policies should be forgotten for the Data Subject and British Harlequin plc as the Data Controller

Purpose
This document sets out the way British Harlequin plc (Data Controller) and any 3rd parties we engage with (Data Processors) will collect, process and handle your Personal Data and your rights in that relationship as Data Subjects.

Basis in Law
This Policy is written to align with the General Data Protection Regulation (GDPR) Legislation, enacted in April 2016 for EU Member states, and to be enforced as of 25th May 2018. The UK will replace / repeal the Data Protection Act (DPA) and replace it with the GDPR version.
Whilst the UK is currently under the regulation of the DPA, this policy goes much further than is currently required under the obligations of the DPA.

Principles
We will adhere to the following principles of the GDPR with respect to this Policy and our behaviours in which we are Guardians, not owners, of your personal data. These are:
• Lawfulness, Fairness & Transparency
• Purpose Limitation
• Data minimisation & Proportionality
• Data Quality & Accuracy
• Storage Limitation
• Integrity & Confidentiality
• Accountability

Direct / Active Personal Data Collection
Information Provision by you directly, by being aware of the act of doing so, that contains Personal Data.
We will, where possible BEFORE we collect your data, always notify you of:
• the Data Protection Officer (DPO) of British Harlequin plc and ICO registration.
• the Purpose of Data Collection and Processing.
• the Legal Basis of Data Collection and Processing.
• the intention to transfer (or not) of Personal Data to a 3rd party or organisation.
• the intention to transfer (or not) of Personal Data to a 3rd country and the legal basis of that.
• the duration / time we will store your information.
• your rights as a Data Subject in terms of your personal data:
Right of Access
Right to Object
Right to Portability
Right of Restriction
Right to Erasure
Right to be Forgotten

Passive / Indirect Personal Data Collection
Information Provision by you, indirectly collected by not necessarily being aware of the act of doing so, that contains your Personal Data.
We will, where possible before we collect your data or within 1 month, always notify you of:
• the Source of the Personal Data collected.
• the Data Protection Officer (DPO) of British Harlequin plc and ICO registration.
• the Purpose of Data Collection and Processing.
• the Legal Basis of Data Collection and Processing.
• the intention to transfer (or not) of Personal Data to a 3rd party or organisation.
• the intention to transfer (or not) of Personal Data to a 3rd country and the legal basis of that.
• the duration / time we will store your information.
• your rights as a Data Subject in terms of:
Right of Access
Right to Object
Right to Portability
Right of Restriction
Right to Erasure
Right to be Forgotten

3rd Party Indirectly Acquired Personal Data Collection
Information Provision to us about you indirectly collected whereby you are not aware of the act of doing so, that contains your Personal Data.
We will, as soon as possible and within 1 month, always notify you of:
• the Source of the Personal Data collected.
• the Data Protection Officer (DPO) of British Harlequin plc and ICO registration.
• the Purpose of Data Collection and Processing.
• the Legal Basis of Data Collection and Processing.
• the intention to transfer (or not) of Personal Data to a 3rd party or organisation.
• the intention to transfer (or not) of Personal Data to a 3rd country and the legal basis of that.
• the duration / time we will store your information.
• your rights as a Data Subject in terms of:
Right of Access
Right to Object
Right to Portability
Right of Restriction
Right to Erasure
Right to be Forgotten

Terms
Term Definition
British Harlequin plc ‘us’ ‘the company’ ‘Data Controller’
3rd Party ‘Data Processor’ / ‘Contracted Entity’ / ‘Indirect Source’
Privacy Policy This document and its contents
Personal Data Any information relating to and identified or identifiable natural person
Data Collection Method of Personal Data acquired by the Data Controller about the Data Subject.
Data Processing Method by which Personal Data may be manipulated.
Data Subject The natural person for which personal data applies to and is processed
Data Controller The legal entity or person that makes decisions on collecting and processing personal data. ‘British Harlequin plc’
Data Processor The legal entity or person that processes personal data on behalf of the data controller. ‘3rd Party’ ‘Contracted Entity’
3rd Party Indirectly Acquired Personal Data Collection Information Provision to us about you indirectly collected whereby you are not aware of the act of doing so, that contains your Personal Data e.g bought in marketing details
Passive / Indirect Personal Data Collection Information Provision by you indirectly collected by not necessarily being aware of the act of doing so, that contains your Personal Data e.g Cookies via our website

Direct / Active Personal Data Collection Information Provision by you directly by being aware of the act of doing so, that contains your Personal Data e.g Contact Us website form



Our Cookie Policy British Harlequin plc

Cookie Policy
British Harlequin is committed to protecting and respecting your privacy. This Cookie Policy sets out how British Harlequin uses and protects any information we collect from you, or that you provide to us, when you use our website www.harlequinfloors.com.

Please read the policy to understand our views and practices regarding cookie data and how we will treat it. By using our site, you indicate that you accept these terms of use and that you agree to abide by them.

In order to provide full access to our website we sometimes need to collect information about you and how it will be used. This Cookie Policy provides details on the use of cookies on the website and how you can control and delete these cookies. This policy therefore applies to information we collect about:
Visitors to our website;
Feedback information you provide to us through the website

Visitors to our website
When someone visits our website at www.harlequinfloors.com we collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. We collect this information in a way which does not identify anyone. We do not make any attempt to find out the identities of those visiting any part of our website. We will not associate any data gathered from this site with any personally identifying information from any source. If we do want to collect personally identifiable information through our website, we will be up front about this.

We will make it clear when we collect personal information and we will explain what we intend to do with it.

Use of cookies and how to control and delete cookies
British Harlequin will not use cookies to collect personally identifiable information about you. However, if you wish to restrict or block the cookies which are set by the website, or indeed any other website, you can do this through your browser settings. The Help function within your browser should tell you how. Alternatively, you may wish to visit www.aboutcookies.org which contains comprehensive information on how to do this on a wide variety of browsers. You will also find details on how to delete cookies from your computer as well as more general information about cookies. For information on how to do this on the browser of your mobile phone you will need to refer to your handset manual. Please be aware that restricting cookies may impact on the functionality of the website.

Third Party Cookies
We use Google Analytics to supply site analytics for our website usage to improve the way we present our website. Google – policies.google.com/privacy

When you visit a page with content embedded from, for example, Facebook, or Twitter, you may be presented with cookies from these websites. British Harlequin does not control the dissemination of these cookies. You should check the relevant third-party website for more information about these and urge you to review these as they will govern the use of information you submit, or which is collected by cookies whilst visiting these websites.
Facebook – www.facebook.com/about/privacy
Twitter - www.twitter.com/privacy

To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.aboutcookies.org

To opt out of being tracked by Google Analytics across all websites visit tools.google.com/dlpage/gaoptout.