PROTECTING YOUR PRIVACY

MacGregor Industrial Supplies Ltd

 

CONTENTS OF PRIVACY NOTICE

  1. Introduction
  2. What is MacGregor Industrial Supplies Ltd?
  3. Explaining the legal bases we rely on
  4. When do we collect your personal data?
  5. What sort of personal data do we collect?
  6. How and why do we use your personal data?
  7. Combining your data for personalised direct marketing
  8. How we protect your personal data
  9. How long will we keep your personal data?
  10. Who do we share your personal data with?
  11. Where your personal data may be processed
  12. What are your rights over your personal data?
  13. How can you stop the use of your personal data for direct marketing?
  14. MacGregor Industrial Supplies Finance
    14.1  How we use your personal data
    14.2  How our providers use your personal data
    14.3  Joint use of your personal data
  15. Contacting the Regulator
  16. If you live outside the UK
  17. Any questions?

 

  1. PRIVACY NOTICE
    1. Introduction

    This Privacy Notice explains in detail the types of personal data we may collect about you when you interact with us. It also explains how we’ll store and handle that data and keep it safe.

    We know that there’s a lot of information here, but we want you to be fully informed about your rights, and how MacGregor Industrial Supplies Limited uses your data; for example we will explain things such as our credit checking procedure, and how we combine data across MacGregor Industrial Supplies Limited to build a picture of you so that we can offer you the best customer service.

    Our privacy promises

    We promise:

    • To keep your data safe and private
    • Not to sell your date
    • To give you ways to manage and renew your marketing choices any time.

    We hope the following sections will answer any questions you have but if not, please do get in touch with us.

    It’s likely that we’ll need to update this Privacy Notice from time to time. We’ll notify you of any significant changes, but you’re welcome to come back and check it whenever you wish.

    1. What is MacGregor Industrial Supplies Limited?

    MacGregor Industrial Supplies Ltd is a company made up of several related businesses and divisions:

    • MacGregor Industrial Supplies divisions (see our website for divisions)
    • MIS Forest & Ground care
    • MacGregors Schoolwear
    • Highland Locksmiths and Security Systems and
    • Orkney Tool Hire
    • Kindling-Cracker

    For simplicity throughout this notice, ‘we’ and ‘us’ means the company and its brands.

    1. Explaining the legal bases we rely on

    The law on data protection sets out a number of different reasons for which a company may collect and process your personal data, including:

     

    Consent

    In specific situations, we can collect and process your data with your consent.

    For example, when you tick a box to receive email newsletters.

    When collecting your personal data, we’ll always make clear to you which data is necessary in connection with a particular service.

    Contractual obligations

    In certain circumstances, we need your personal data to comply with our contractual obligations.

    For example, if you order an item from us for delivery, we’ll collect your address details to deliver your purchase, and pass them to our despatch office or external courier.

    Legal compliance

    If the law requires us to, we may need to collect and process your data.  

    For example, we can pass on details of people involved in fraud or other criminal activity affecting the company to law enforcement.

    Legitimate interest

    In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests.

    For example, we may use your purchase history to send you or make available personalised offers. 

    We may also combine the shopping history of many customers to identify trends and ensure we can keep up with demand or develop new products/services.

    We will also use your address details to send you direct marketing information by post, telling you about products and services that we think might interest you.

    1. When do we collect your personal data?

    We will collect personal information about you from sources including:

    • When you visit any of our websites, and use your account to buy products and services, or redeem vouchers from the Company on the phone, in a shop or online.
    • When you create an account with us through information provided on a credit application form.
    • When you purchase a product or service in store or by phone but don’t have (or don’t use) an account.
    • When you engage with us on social media.
    • When you contact us by any means with queries, complaints etc.
    • When you ask one of our divisions or suppliers to email you information about a product or service.
    • When you enter prize draws or competitions.
    • When you book any kind of appointment with us for example, Highland Locksmith and Security Systems call out or a servicing repair
    • When you comment on or review our products and services.
    • Any individual may access personal data related to them, including opinions. So if your comment or review includes information about the division who provided that service, it may be passed on to them if requested.
    • When you fill in any forms. For example, if an accident happens in store, a division or branch may collect your personal data.
    • When you’ve given a third-party permission to share with us the information they hold about you.
    • When our Finance suppliers and partners – such as John Deere finance – share information with us about the product you have purchased.
    • We collect data from publicly-available sources when you have given your consent to share information or where the information is made public as a matter of law.
    • When you use our car parks and shops which have CCTV systems operated for the security of both customers and branches. These systems may record your image during your visit.
    • Our vehicles have tracker technology installed.  These systems will record the routes our vehicles have taken and the addresses they have visited.
    • We have a Customer Relationship Database installed.  This will record when you have been contacted, sales leads and visits to you premises.
    1. What sort of personal data do we collect?
    • If you have an estore account with us: your name, billing/delivery address, orders and receipts, email and telephone number. For your security, we’ll also keep an encrypted record of your login password.
    • Details of your interactions with us through contacts, in store or online.

    For example, we collect notes from our conversations with you, details of any complaints or comments you make, details of purchases you made, items viewed redemptions, brands you show interest in, web pages you visit and how and when you contact us.

    • Copies of documents you provide to prove your age or identity where the law requires this. (including your passport and driver’s licence). This will include details of your full name, address, date of birth and facial image. If you provide a passport, the data will also include your place of birth, gender and nationality.
    • Details of your visits to our websites, and which site you came from to ours.
    • Information gathered by the use of cookies in your web browser.
    • Personal details which help us to recommend items of interest.

    We’ll only ask for and use your personal data collected for recommending items of interest, tailor your shopping experience with us or to prove your identity. It’s always your choice whether you share such details with us.

    • Payment card information and bank account details
    • Your comments and product reviews.
    • Your image or your vehicle may be recorded on CCTV when you visit a shop or car park.
    • Your car number plate may be recorded when hiring equipment
    • Your social media username, if you interact with us through those channels, to help us respond to your comments, questions or feedback.
    • Signatures
    • Photo ID in the form of passport or driving licence
    • Key and lock details of your premises
    1. How and why do we use your personal data?

    We want to give you the best possible customer experience. One way to achieve that is to get the best picture we can of who you are by combining the data we have about you.

    We then use this to offer you promotions, products and services that are most likely to interest you.

    The data privacy law allows this as part of our legitimate interest in understanding our customers and providing the highest levels of service.

    Of course, if you wish to change how we use your data, you’ll find details in the ‘What are my rights?’ section below.

    Remember, if you choose not to share your personal data with us, or refuse certain contact permissions, we might not be able to provide some services you’ve asked for.

    For example, if you’ve asked us to let you know when an item comes back into stock, we can’t do that if you’ve withdrawn your general consent to hear from us.

    Here’s how we’ll use your personal data and why:

    • To process any orders that you make by using our websites, email, through an MIS employee, telephone contact or in store. If we don’t collect your personal data during checkout, we won’t be able to process your order and comply with our legal obligations.

    For example, your details may need to be passed to a third party to supply or deliver the product or service that you ordered, and we may keep your details for a reasonable period afterwards in order to fulfil any contractual obligations such as refunds, guarantees and so on.

    • To respond to your queries, refund requests and complaints. Handling the information you sent enables us to respond. We may also keep a record of these to inform any future communication with us and to demonstrate how we communicated with you throughout. We do this on the basis of our contractual obligations to you, our legal obligations and our legitimate interests in providing you with the best service and understanding how we can improve our service based on your experience.
    • To protect our business and your account from fraud and other illegal activities. This includes using your personal data to maintain, update and safeguard your account. We’ll also monitor your browsing activity with us to quickly identify and resolve any problems and protect the integrity of our websites. We’ll do all of this as part of our legitimate interest.

    For example, by checking your password when you login and using automated monitoring of IP addresses to identify possible fraudulent log-ins from unexpected locations.

    • To protect our customers, premises, assets and businesses from crime, we operate CCTV systems in our branches and car parks which record images for security. We do this on the basis of our legitimate business interests.
    • To process payments and to prevent fraudulent transactions. We do this on the basis of our legitimate business interests. This also helps to protect our customers from fraud.
    • If we discover any criminal activity or alleged criminal activity through our use of CCTV, fraud monitoring and suspicious transaction monitoring, we will process this data for the purposes of preventing or detecting unlawful acts. We aim to protect the individuals we interact with from criminal activities.
    • With your consent, we will use your personal data, preferences and details of your transactions to keep you informed by email, web, text, telephone and through our sales representatives about relevant products and services including tailored special offers, discounts, promotions, events, competitions and so on.

    Of course, you are free to opt out of hearing from us by any of these channels at any time.

    • To send you relevant, personalised communications by post in relation to updates, offers, services and products. We’ll do this on the basis of our legitimate business interest.

    You are free to opt out of hearing from us by post at any time.

    • To send you communications required by law or which are necessary to inform you about our changes to the services we provide you. For example, updates to this Privacy Notice, product recall notices, and legally required information relating to your orders. These service messages will not include any promotional content and do not require prior consent when sent by email or text message. If we do not use your personal data for these purposes, we would be unable to comply with our legal obligations.
    • To administer any of our prize draws or competitions which you enter, based on your consent given at the time of entering.
    • To develop, test and improve the systems, services and products we provide to you. We’ll do this on the basis of our legitimate business interests.
    • To comply with our contractual or legal obligations to share data with law enforcement.

    For example, when a court order is submitted to share data with law enforcement agencies or a court of law

    • To send you survey and feedback requests to help improve our services. These messages will not include any promotional content and do not require prior consent when sent by email or text message. We have a legitimate interest to do so as this helps make our products or services more relevant to you.

    Of course, you are free to opt out of receiving these requests from us at any time by informing us

    • To build a rich picture of who you are and what you like, and to inform our business decisions, we’ll combine data captured from across the Company, third parties and data from publicly-available lists as we have described in the section ‘What Sort of Personal Data do we collect?’ We’ll do this on the basis of our legitimate business interest.

    For example, by combining this data, this will help us personalise your experience and decide which inspiration or content to share with you. We also use anonymised data from customer purchase histories to identify trends in different areas of the country. This may then guide which products we display in particular stores.

    • To process your booking/appointment requests (for example with a locksmith or service engineer). Sometimes, we’ll need to share your details with a third party who is providing a service (such as delivery couriers or a fitter visiting your home). We do so to maintain our appointment with you. Without sharing your personal data, we’d be unable to fulfil your request.
    1. Combining your data for personalised direct marketing

    We want to bring you offers and promotions that are most relevant to your interests at particular times. To help us form a better, overall understanding of you as a customer, we combine your personal data gathered as described above, for example your shopping history. For this purpose we also combine the data that we collect directly from you with data that we obtain from third parties to whom you have given your consent to pass that data onto us.

    1. How we protect your personal data

    We know how much data security matters to all our customers. With this in mind we will treat your data with the utmost care and take all appropriate steps to protect it.

    We take all necessary technical and organisational measures to protect the confidentiality and security of your personal information collected through the various methods described in this privacy notice

    These efforts include but are not limited to storing your personal information in secure operating environments that are not available to the public and accessed only by our authorised staff

    We secure access to all transactional areas of our websites using ‘https’ technology.

    Access to your personal data is password-protected, and sensitive data (such as payment card information) is secured by SSL encryption.

    We regularly monitor our system for possible vulnerabilities and attacks, and we carry out penetration testing to identify ways to further strengthen security.

    1. How long will we keep your personal data?

    Whenever we collect or process your personal data, we’ll only keep it for as long as is necessary for the purpose for which it was collected.

    At the end of that retention period, your data will either be deleted completely or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning.

    Some examples of customer data retention periods: 

    Orders

    When you place an order, we’ll keep the personal data you give us for seven years, so we can comply with our legal and contractual obligations.  Our computer systems will retain customer details indefinitely until a request is made to anonymise it.  However, the 7-year rule will apply.

    For example, you have not dealt with us for 8 years and we still hold your details.  You request for your details to be anonymised, this can be done.  If you have dealt with us in year 5 then we will need to wait until year 7 to anonymise you.

    In the case of certain products, such as electrical and nursery items, we’ll keep the data for 10 years.

    Warranties

    If your order included a warranty, the associated personal data will be kept until the end of the warranty period.

    Locksmiths

    Lock, key and alarm information is kept indefinitely on our Locksmiths system until requested to be removed.  This information is kept on file in order to provide a high level of customer service.

    1. Who do we share your personal data with?

    We sometimes share your personal data with trusted third parties.

    For example, delivery couriers, technicians visiting your home, for fraud management, to handle complaints, our external auditors, to help us personalise our offers to you and so on.

    Here’s the policy we apply to those organisations to keep your data safe and protect your privacy:

    • We provide only the information they need to perform their specific services.
    • They may only use your data for the exact purposes we specify in our contract with them.
    • We work closely with them to ensure that your privacy is respected and protected at all times.
    • If we stop using their services, any of your data held by them will either be deleted or rendered anonymous depending upon their legal and contractual obligations.

    Examples of the kind of third parties we work with are:

    • IT companies who support our website and other business systems.
    • Suppliers for registering products and warranties.
    • Operational companies such as delivery couriers.
    • Direct marketing companies who help us manage our electronic communications with you.
    • Google/Facebook to show you products that might interest you while you’re browsing the internet. This is based on either your marketing consent or your acceptance of cookies on our websites.
    • Data insight companies to ensure your details are up to date and accurate.
    • Company external auditors
    • Credit checks with credit agencies

    Sharing your data with third parties for their own purposes:

    We will only do this in very specific circumstances, for example:

    • With your consent, given at the time you supply your personal data, we may pass that data to a third party for their direct marketing purposes.

    For example, if you enter a competition and tick a box agreeing that the company can send you promotional information directly. Or if we run a joint event with a restaurant, and you agree to receive direct communications from them.

    • For fraud management, we may share information about fraudulent or potentially fraudulent activity in our premises or systems. This may include sharing data about individuals with law enforcement bodies.
    • We may also be required to disclose your personal data to the police or other enforcement, regulatory or Government body, in your country of origin or elsewhere, upon a valid request to do so. These requests are assessed on a case-by-case basis and take the privacy of our customers into consideration.
    • We may, from time to time, expand, reduce or sell the business and this may involve the transfer of divisions or the whole business to new owners. If this happens, your personal data will, where relevant, be transferred to the new owner or controlling party, under the terms of this Privacy Notice.
    • For further information please contact our Data Protection Officer.

    To help personalise your journey through Company websites we currently use the following companies, who will process your personal data as part of their contracts with us:

    • Google
    • Facebook
    • Twitter
    1. Where your personal data may be processed

    Sometimes we will need to share your personal data with third parties and suppliers outside the European Economic Area (EEA)

    International orders

    If you are based outside the UK and place an order with us, we will transfer the personal data that we collect from you to the Company in the UK.

    Protecting your data outside the EEA

    The EEA includes all EU Member countries as well as Iceland, Liechtenstein and Norway. We may transfer personal data that we collect from you to third-party data processors in countries that are outside the EEA.

    For example, this might be required in order to fulfil your order, process your payment details or provide product support services.

    If we do this, we have procedures in place to ensure your data receives the same protection as if it were being processed inside the EEA. For example, our contracts with third parties stipulate the standards they must follow at all times. If you wish for more information about these please contact our Data Protection Officer.

    Any transfer of your personal data will follow applicable laws and we will treat the information under the guiding principles of this Privacy Notice.

    1. What are your rights over your personal data?

    An overview of your different rights

    You have the right to request:

    • Access to the personal data we hold about you, free of charge in most cases.
    • The correction of your personal data when incorrect, out of date or incomplete.
    • For example, when you withdraw consent, or object and we have no legitimate overriding interest, or once the purpose for which we hold the data has come to an end (such as the end of a warranty).
    • That we stop using your personal data for direct marketing (either through specific channels, or all channels).
    • That we stop any consent-based processing of your personal data after you withdraw that consent.
    • Review by the company of any decision made based solely on automatic processing of your data (i.e. where no human has yet reviewed the outcome and criteria for the decision).

    You have the right to request a copy of any information about you that we hold at any time, and also to have that information corrected if it is inaccurate. To ask for your information, please contact Data Protection Officer, MacGregor Industrial Supplies Limited, 15-17 Henderson Road, Longman Industrial Estate, Inverness IV1 1SN.  To ask for your information to be amended, contact our Customer Services team.

    If we choose not to action your request we will explain to you the reasons for our refusal.

    Your right to withdraw consent

    Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent.

    Where we rely on our legitimate interest

    In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.

    Direct marketing

    You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We must always comply with your request.

    Checking your identity

    To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Notice. If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.

    1. How can you stop the use of your personal data for direct marketing?

    There are several ways you can stop direct marketing communications from us:

    • Click the ‘unsubscribe’ link in any email communication that we send you. We will then stop any further emails from that particular division.
    • Write to Data Protection Officer, 15-17 Henderson Road, Longman Industrial Estate, Inverness IV1 1SN
    • Sign in to our website and change your opt in settings

    Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated.

    1. MacGregor Industrial Supplies Finance

    MacGregor Industrial Supplies Limited is a company authorised by the financial conduct authority.

    14.1 How we use your personal data

    When you purchase a product or service from MacGregor Industrial Supplies Limited, we may refer your personal details to third party financing companies to assist you with financing your purchase we will only do this with your permission of the information you supplied. If you agree to receive marketing communications from us, we will use your data to personalise what we send you. You are free to opt out of receiving marketing communications from us at any time.

    Find out more about the use of your data for marketing in section 7.

    14.2 How our providers use your personal data

    When you then apply for a product or service from one of our chosen providers, your data will be collected and used by them under the terms of their own separate privacy policies.

    14.3 Joint use of your personal data

    We will share data with our providers to bring you relevant offers, updates, products and services.

    We may check your details with appropriate third parties (for example credit reference agencies, such as Experian) before we send you promotions for our financial services products, to ensure your information is accurate and fulfils our legal and regulatory obligations, and to tailor those offers to you.

    Rest assured that all applications for financial services products will be assessed on a case-by-case basis.

    1. Contacting the Regulator

    If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.

    You can contact them by calling 0303 123 1113. Or go online to www.ico.org.uk/concerns (opens in a new window; please note we can’t be responsible for the content of external websites)

    If you are based outside the UK, you have the right to lodge your complaint with the relevant data protection regulator in your country of residence. Details can be found in Section 16.

    1. If you live outside the UK

    For all non-UK customers

    By using our services or providing your personal data to us, you expressly consent to the processing of your personal data by us or on our behalf. Of course, you still have the right to ask us not to process your data in certain ways, and if you do so, we will respect your wishes.

    Sometimes we’ll need to transfer your personal data between countries to enable us to supply the goods or services you’ve requested. In the ordinary course of business, we may transfer your personal data from your country of residence to ourselves and to third parties located in the UK.

    By dealing with us, you are giving your consent to this overseas use, transfer and disclosure of your personal data outside your country of residence for our ordinary business purposes.

    This may occur because our information technology storage facilities and servers are located outside your country of residence and could include storage of your personal data on servers in the UK.

    We’ll ensure that reasonable steps are taken to prevent third parties outside your country of residence using your personal data in any way that’s not set out in this Privacy Notice. We’ll also make sure we adequately protect the confidentiality and privacy of your personal data.

    For the purposes of this Privacy Notice, ‘personal data’ means any information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether or not the information or opinion is true, and whether or not the information or opinion is recorded in a material form.

    1. Any questions?

    We hope this Privacy Notice has been helpful in setting out the way we handle your personal data and your rights to control it.

    If you have any questions that haven’t been covered, please contact our Data Protection Officer who will be pleased to help you:

    • Write to us at Data Protection Officer, MacGregor Industrial Supplies Limited, 15-17 Henderson Road, Longman Industrial Estate, Inverness IV1 1SN

    This notice was last updated on 24/05/2018