The Independent Newspaper for Islay and Jura

Ileach Privacy Policy 2018

Ileach Ltd is committed to protecting and respecting your privacy. This privacy policy (together with our Terms and Conditions) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us and tell you about your privacy rights and how the law protects you. By visiting ileach.co.uk ("our site") or contacting us by written letter, or e-mail, you are accepting and consenting to the practices described in this policy.
Important information and who we are
This privacy policy aims to give you information on how Ileach Ltd collects and processes your personal data, including any data you may provide when you become a paid member, purchase a product or service or take part in a competition.
Our business and website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements any other policies and is not intended to override them.
Controller
For the purposes of the General Data Protection Regulation (EU) the data controller is Ileach Ltd of Main Street, Bowmore, Isle of Islay Scotland PA43 7LA.
If you have any questions about this privacy notice, including details of the company, or any requests to exercise your legal rights, please contact us using the details set out below.
Contact Email address: ileach@ileach.co.uk
Postal address: Ileach Ltd, Main Street, Bowmore, Isle of Islay, Scotland PA43 7LA
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), or the equivalent regulatory authority in your country. However, we would like to deal with your concerns before you approach the ICO (or other regulator) so please contact us in the first instance.
Changes to the privacy notice and your duty to inform us of changes
Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to our privacy policy.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third-party links
This website 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 notice of every website you visit.
Information we may collect from you Personal data, or personal information, means any information from an individual can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
a) Identity Data includes first name, maiden name, last name, or similar identifier, title, date of birth and gender.
b) Contact Data includes delivery address, email address and telephone numbers.
c) Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
d) Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences, if any.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data).
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time. How is your personal data collected.
We use different methods to collect data from and about you including through:
1) Information you give us. You may give us your Identity, Contact and Financial Data by corresponding with us by phone, email, or otherwise. This includes personal data you provide when you:
2) Apply for our products or services;
3) Subscribe to our service or publications;
4) Request marketing to be sent to you;
5) Enter a competition, promotion or survey;
6) Give us some feedback; or
7) When you apply for a job position.
8) Information we receive from other sources. We may receive personal data about you from various third parties and public sources as set out below:
9) Contact, Financial and Transaction Data from providers of technical, payment and delivery services;
Use of personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
a) Where we need to perform the contract we are about to enter into or have entered into with you and to provide you with the information, products and services that you request from us.
b) To provide you with information about other goods or services we offer that are similar to those that you have already purchased or enquired about.
c) Where we have a legitimate interest and your interests and fundamental rights do not override those interests.
d) To comply with a legal or regulatory obligation, including exchanging information with other companies and organisations for the purposes of fraud protection.
e) We may combine information we receive from other sources with information you give to us and information we collect about you and use it for the purposes set out above.
Where you opt out of receiving marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
Purposes for which we will use your personal data
We have set out below, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out below.
PURPOSE/ACTIVITY
To register you as a new customer
TYPE OF DATA
(a) Identity
(b) Contact
LAWFUL BASIS FOR PROCESSING INCLUDING BASIS OF LEGITIMATE INTEREST
Performance of a contract with you
PURPOSE/ACTIVITY
To process and deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
TYPE OF DATA
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications
LAWFUL BASIS FOR PROCESSING INCLUDING BASIS OF LEGITIMATE INTEREST
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
PURPOSE/ACTIVITY
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey
TYPE OF DATA
(a) Identity (b) Contact (c) Profile (d) Marketing and Communications
LAWFUL BASIS FOR PROCESSING INCLUDING BASIS OF LEGITIMATE INTEREST
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
PURPOSE/ACTIVITY
To enable you to partake in a prize draw, competition or complete a survey
TYPE OF DATA
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
LAWFUL BASIS FOR PROCESSING INCLUDING BASIS OF LEGITIMATE INTEREST
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
PURPOSE/ACTIVITY
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
TYPE OF DATA
(a) Identity (b) Contact (c) Technical
LAWFUL BASIS FOR PROCESSING INCLUDING BASIS OF LEGITIMATE INTEREST
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation, such as the payment of corporation tax, or if compelled by order of a Court, or as part of legal proceedings.
PURPOSE/ACTIVITY
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
TYPE OF DATA
(a) Technical
(b) Usage
LAWFUL BASIS FOR PROCESSING INCLUDING BASIS OF LEGITIMATE INTEREST
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform ourmarketing strategy)
PURPOSE/ACTIVITY
To make suggestions and recommendations to you about goods or services that may be of interest to you.
TYPE OF DATA
(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
LAWFUL BASIS FOR PROCESSING INCLUDING BASIS OF LEGITIMATE INTEREST
Necessary for our legitimate interests (to develop our products/services and grow our business)
PURPOSE/ACTIVITY
To assess whether you are suitable for a job at the company
TYPE OF DATA
(a) Identity
(b) Contact
(c) Profile
LAWFUL BASIS FOR PROCESSING INCLUDING BASIS OF LEGITIMATE INTEREST
(a) Necessary for our legitimate interest
(b) Performance of a contract with you
Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out above.
a) Internal Third Parties as set out in the Glossary.
b) External Third Parties as set out in the Glossary.
c) In the event that we sell or buy (or plan to sell or buy) any business or assets or seek investment from a third party investor, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets, or investor, as the case may be.
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 personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Data retention
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
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 unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see Request erasure below for further information.
Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data:
Request access to your personal data (commonly known as a 'data subject access request'). 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 the personal data that we hold about you. 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 erasure of your personal 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 personal 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 personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, such as where we are obliged by law, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. An example of this may be where we have obligations to process your Financial data for the purposes of complying with our tax obligations.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
For further information on your individual rights, please visit https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/. If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
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 personal 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 in relation to your request to speed up our response.
Time limit to respond We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Glossary
LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
THIRD PARTIES
External Third Parties
a) Service providers acting as processors based in the UK,
b) Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK above who provide consultancy, banking, legal, insurance and accounting services.
c) HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

Contact:ileach@ileach.co.uk