This is the privacy notice of Handam – Refill Station CIC, Handam for short.
In this document, “we”, “our”, or “us” refer to Handam – Refill Station CIC.
Handam – Refill Station CIC is a registered community interest company, SC658333, Registered in Scotland.
The purpose of this policy is to explain to you how we control, process, handle and protect your personal information while using our website, contacting us or dealing with us off-site, including your rights under current laws and regulations.
If, as determined by us, the lawful basis upon which we process your personal information changes, we will notify you about the change and any new lawful basis to be used if required. We shall stop processing your personal information if the lawful basis used is no longer relevant. It covers information that could identify you (“personal information”) and information that could not. In the context of the law and this notice, “process” means collect, store, transfer, use or otherwise act on information. It tells you about your privacy rights and how the law protects you.
We are committed to protecting your privacy and the confidentiality of your personal information. Our policy is not just an exercise in complying with the law, but a continuation of our respect for you and your personal information.
We undertake to preserve the confidentiality of all information you provide to us and hope that you reciprocate.
Our policy complies with UK law accordingly implemented, including that required by the EU General Data Protection Regulation (GDPR).
Under the GDPR – your rights are as follows, depending on the lawful basis under which your data is processed (see above).
the right to be informed;
the right of access;
the right to rectification;
the right to erasure;
the right to restrict processing;
the right to data portability;
the right to object; and
the right not to be subject to automated decision-making including profiling.
The law requires us to tell you about your rights and our obligations to you regarding the processing and control of your personal data. You can read more about your rights here on the ICO (Information Commissioner’s Office) website and through Know Your Privacy Rights
You also have the right to complain to the ICO if you feel there is a problem with the way we are handling your data.
We handle subject access requests in accordance with the GDPR.
If you have any queries about this policy or would like to request the information, we hold on you or the deletion of it, you can do so by emailing us at firstname.lastname@example.org
If a dispute is not settled, then we hope you will agree to attempt to resolve it by engaging in good faith with us in a process of mediation or arbitration (please contact us if you wish to find out more information about what our procedure is).
If you are in any way dissatisfied with how we process your personal information, you have a right to lodge a complaint with the Information Commissioner’s Office (ICO). This can be done at https://ico.org.uk/make-a-complaint/.
3. What we will not do
We will never ask you for a password via email, phone or any other form of communication.
If you have any account problems or are sent an email from us which seem out of the ordinary or unwarranted, DO NOT give out financial or personal information until you have contacted us via our contact us link.
4. Data we process
We may collect, use, store and transfer different kinds of personal data about you. We have collated these into groups as follows:
Your identity includes information such as first name, last name, title, and other identifiers that you may have provided at some time.
Your contact information includes information such as billing address, delivery address, email address, telephone numbers and any other information you have given to us for the purpose of communication or meeting.
Transaction data includes details about payments or communications to and from you and information about products and services you have purchased from us.
Technical data includes your internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
Your profile includes information such as your name and surname, email or phone number, your interests, preferences, feedback and survey responses.
Marketing data includes your preferences in receiving marketing from us; communication preferences; responses and actions in relation to your use of our services.
We may aggregate anonymous data such as statistical or demographic data for any purpose. Anonymous data is data that does not identify you as an individual. Aggregated data may be derived from your personal data but is not considered personal information in law because it does not reveal your identity.
For example, we may aggregate profile data to assess interest in a product or service.
However, if we combine or connect aggregated data with your personal information so that it can identify you in any way, we treat the combined data as personal information and it will be used in accordance with this privacy notice.
5. Information we process with your consent
Through certain actions when otherwise there is no contractual relationship between us, such as when you browse our website or ask us to provide you more information about our business such as our newsletters, including our products and services, you provide your consent to us to process information that may be personal information.
We will collect and store any personal data that you may volunteer whilst using our services, e.g. placing an order, joining our e-mail newsletter or entering a prize draw or competition.
Individuals registering their details or subscribing to the newsletter online may do so on the understanding that they are aware of the intended purpose for the collection of data. An opt-out option is available by clicking on the unsubscribe link in the newsletter we may send you.
You may withdraw your consent at any time by instructing us at email@example.com
However, if you do so, you may not be able to use certain areas of our website or our services further, for example, receive alerts when your membership is due for renewal.
6. Information we process because we have a contractual obligation with you
When you buy a product or service from us, or otherwise agree to our terms and conditions, a contract is formed between you and us.
In order to carry out our obligations under that contract, we must process the information you give us. Some of this information may be personal information.
We may use it in order to:
verify your identity for security purposes
sell products to you
provide you with our services
provide you with suggestions and advice on products, services and how to obtain the most from using our website
We process this information on the basis there is a contract between us, or that you have requested we use the information before we enter into a legal contract.
We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.
7. Information we process for the purposes of legitimate interests
We may process the information on the basis there is a legitimate interest, either to you or to us, in doing so.
Where we process your information on this basis, we do after having given careful consideration to:
whether the same objective could be achieved through other means
whether processing (or not processing) might cause you harm
whether you would expect us to process your data, and whether you would, in the round, consider it reasonable to do so
For example, we may process your data on this basis for the purposes of:
record-keeping for the proper and necessary administration of our business
responding to unsolicited communication from you to which we believe you would expect a response
protecting and asserting the legal rights of any party
insuring against or obtaining professional advice that is required to manage business risk
protecting your interests where we believe we have a duty to do so
8. Links to Other Websites
Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website.
Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement.
You should always exercise caution and look at the privacy statement applicable to the website in question, despite us only recommending websites and using links we personally trust as we cannot be held accountable.
9. Complaints regarding any content on our website
If you wish to complain about any of the content on our website (www.handam.co.uk) please contact us through our Contact Us page, we shall investigate your complaint.
If we feel it is justified, or if we believe the law requires us to do so, we shall remove the content while we investigate.
Free speech is a fundamental right, so we have to make a judgement as to whose right will be obstructed: yours or that of the person who posted the content that offends you.
If we think your complaint is vexatious or without any sufficient grounds, we shall not correspond with you about it.
10. Information relating to your method of payment
Payment information is never taken by us or transferred to us either through our website or otherwise. Our employees and contractors never have access to it. At the point of payment, you are transferred to a secure page on the website of PayPal. That page is not controlled by us therefore we cannot control what happens when you are transferred to make a payment.
While we process card payment transaction in the shop, we offer an option to email you a receipt via our Zettle payment system. Once your email address is provided it is assigned to your card and coded. We don't have access to this data and won't ever use it, it is secured by Zettle.
11. Other collected information, including payment and communications
The type of information that we will collect will include – Your title and name, known address, contact telephone numbers, e-mail address, order and payment details. Details may be forwarded securely to other parties in order to fulfil this order only. These will include delivery and payment partners.
When you contact us, whether by telephone, through our website or by e-mail, we collect the data you have given to us in order to reply with the information you need.
We record your request and our reply in order to increase the efficiency of our business. We keep personally identifiable information associated with your messages, such as your name and email address so as to be able to track our communications with you to provide a high-quality service.
12. Cookies and data
Cookies are small text files that are placed on your computer’s hard drive by your web browser when you visit any website. They allow information gathered on one web page to be stored until it is needed for use on another, allowing a website to provide you with a personalised experience and the website owner with statistics about how you use the website so that it can be improved.
Some cookies may last for a defined period of time, such as one day or until you close your browser. Others last indefinitely.
Your web browser should allow you to delete any you choose. It also should allow you to prevent or limit their use.
You can choose to accept or decline cookies, you can modify your browser security settings to block Cookies although you should be warned that changing cookie settings can adversely affect the performance of our website.
to track how you use our website
to record whether you have seen specific messages we display on our website
to record your answers to surveys and questionnaires on our site while you complete them
13. Personal identifiers from your browsing activity
Requests by your web browser to our servers for web pages and other content on our website are recorded.
We record information such as your geographical location, your Internet service provider and your IP address. We also record information about the software you are using to browse our website, such as the type of computer or device and the screen resolution.
We use this information in aggregate to assess the popularity of the pages and products on our website and how we perform in providing content to you.
If combined with other information we know about you from previous visits, the data possibly could be used to identify you personally, even if you are not signed in to our website.
14. Re-marketing using cookies
Re-marketing involves placing a cookie on your computer when you browse our website in order to be able to serve to you an advert for our products or services when you visit some other website.
15. Combating fraud and credit referencing
To assist in combating fraud, we share information with credit reference agencies, so far as it relates to clients or customers who instruct their credit card issuer to cancel payment to us without having first provided an acceptable reason to us and given us the opportunity to refund their money.
16. Data may be processed outside the European Union
We may use outsourced services in countries outside the European Union from time to time in other aspects of our business. Accordingly, data obtained within the UK or any other country could be processed outside the European Union. For example, some of the software our website uses may have been developed in the United States of America or Australia. For example, we use Google Docs for maintaining our membership database and MailChimp and Wix for managing our newsletter emails.
We use the following safeguards with respect to data transferred outside the European Union:
the processor is within the same corporate group as our business or organisation and abides by the same binding corporate rules regarding data processing.
17. Retention period for personal data
Except as otherwise mentioned in this privacy notice, we keep your personal information only for as long as required by us:
to provide you with the services you have requested;
to comply with other law, including for the period demanded by our tax authorities;
to support a claim or defence in court.
18. Compliance with the law
If you think it fails to satisfy the law of your jurisdiction, we should like to hear from you.
However, it is ultimately your choice as to whether you wish to use our website.
We may update this privacy notice from time to time as necessary according to the law.
The terms that apply to you are those posted here on our website on the day you use our website.
20. Contacting us
If you believe that any information, we are holding on you is incorrect or incomplete, please write to or email us as soon as possible, at the below address. We will promptly correct any information found to be incorrect.
Handam – Refill Station CIC
11 The Square