How we use your personal information

Introduction

This policy is for people whose personal information we use as part of TCPL’s business.  We will update and amend it from time to time, so please check back to make sure you have read the most recent version.  The policy was last updated August 2018.

Please read this notice carefully to understand how we use your personal information and, importantly, your rights.  

Who we are

We are The Commerce Partnership Limited (TCPL, we, us, our).  We are registered in England and Wales (registered number 5790922).

 TCPL provides purpose-built solutions to some of the UK's largest retailers.  As well as handling personal information on behalf of our clients, we also collect the personal information of people we work with and people who visit our website.  

People who use our website

What personal information do we collect?

We do not routinely collect the personal information of anyone who visits our website except IP addresses.

However, if you complete one of our webforms to contact us we will collect your name, contact information and any other personal information you provide.

How do we use your personal information?

We collect and temporarily log IP addresses just as part of the routine operation of our website.  We do not use them for any other purpose.

If you contact us through the website, we will use your name, contact information and any other personal information you provide to respond to your query.

Legal ground for our use of your personal information

Our legal ground for using your IP address, and any other personal information you provide to us through the website, is that doing so is necessary for the purposes of the legitimate interests of our business.  We will always consider your rights and privacy before using your personal information for the purposes of our business.  Where your rights or privacy override our business interests, we will not use your personal information.

Sharing your personal information

We use IT and hosting providers to support our website.  These organisations handle your personal information on our behalf.  We have agreements in place so that these organisations only handle your personal information as we have instructed them to.  They are not able to make any further use of your personal information (except where required by law).

Separately from our business purposes, we will also use your personal information where we have a legal obligation to do so.  For example, if a regulator or official authority asks us for your personal information.  In very limited situations we may also use your personal information to exercise our legal rights (including in relation to legal proceedings).

If we collect information for one purpose and then intend to use it for a different purpose, we will seek your consent to do so and/or inform you where necessary or appropriate.
 
Transferring information outside the European Economic Area

Some of our services providers are based outside of the European Economic Area (EEA). When we send your personal information outside the EEA to a country or sector not recognised as providing appropriate protections, we put in place appropriate contracts, group agreements or other safeguards to ensure your rights are protected.

How long we keep your personal information

We keep IP addresses in a log for six months.  

We keep any other information you provide to us through the website for up to seven years after the date of our last interaction with you.

People we work with

What personal information do we collect?

As part of our business we work with a range of organisations – including clients and suppliers.  We think it is important to respect the privacy of the people who work for and as part of these organisations.  

We collect and use the following types of personal information about the people we work with:

•    Contact information (for example, address, email address and phone numbers).
•    Basic information about you (for example, name, organisation, job).
•    Details of any contact or correspondence we have had with you.
•    Financial details (for example, details of any payments we have made to or received from you (or your organisation).
•    Information about how you (or your organisation) use our services.

How we collect this information

We will mainly collect this personal information from you when you (or your organisation):

•    Enter into an agreement with us.
•    Enquire about our services.
•    Respond to an enquiry from us.
•    Correspond with us. 
•    Are refer to us by a third party.
•    Receive services from us.
•    Provide services to us.

What we use your personal information for

We use your information to:

•    Provide you (or your organisation) with our services and important information relating to our services.
•    Receive services from you (or your organisation).

We may also use your information to:

•    Ensure our work is well-targeted, relevant and effective.
•    Analyse and continually improve the services we offer and our website.
•    Keep our accounts, records and databases accurate and relevant.
•    Support and manage out staff.
•    Fulfil our legal obligations to regulators and official authorities.
•    Exercise our legal rights (including in relation to legal proceedings).

Legal grounds for using your personal information

Where we have a contract with you as an individual, we will also use your personal information where necessary for the purposes of the contract.  Importantly, if you do not provide us with enough personal information, we may not be able to enter into or fulfil a contract with you.

However, in most situations, our legal ground for the use of your personal information is that doing so is necessary for the purposes of the legitimate interests of our business.  We will always consider your rights and your privacy before using your personal information for the purposes of our business. Where your rights or privacy override our business interests, we will not use your personal information.

Separately from our business purposes, we will also use your personal information where we have a legal obligation to do so.  For example, if a regulator or official authority asks us for your personal information.  In very limited situations we may also use your personal information to exercise our legal rights (including in relation to legal proceedings).

If we collect information for one purpose and then intend to use it for a different purpose, we will seek your consent to do so and/or inform you where necessary or appropriate.

Sharing your personal information

We use a number of IT, hosting and service providers to support our business.  These organisations handle your personal information on our behalf.  We have agreements in place so that these organisations only handle your personal information as we have instructed them to.  They are not able to make any further use of your personal information (except where required by law). If you would like more information about these organisations please contact using the details below.

We may also share personal information with partner organisations and clients.

We may also share your personal information with regulators or official authorities where required.  We may also need to share your personal information to exercise our legal rights.

Transferring information outside the European Economic Area

Some of our offices, processors and the partners we work with are based outside of the EEA. When we send your personal information outside of the EEA to a country not recognised as providing appropriate protections, we put in place appropriate contracts, group agreements or other safeguards to ensure your rights are protected.

How long we keep your personal information

To ensure we are able to meet our legal obligations and exercise our legal rights, we will store your personal information for up to seven years after it was last potentially needed for business purposes.

Your rights and managing your information

It is important that you are familiar with and easily able to exercise the following rights:

You have the following rights – 

•    The right to be informed your personal information being used (which is what this privacy notice is for).
•    The right to access your personal information. 
•     The right to object to direct marketing. 
•    The right to object to the use of your personal information.
•    The right to erasure of your personal information.
•    The right of data portability.
•    The right to have your personal information rectified if it is inaccurate.
•    The right to have use of your personal data restricted. 

Please be aware that these rights are not always absolute and there may be some situations in which you cannot exercise them or they are not relevant.  To help you understand how they work, we have provided links to the Information Commissioner’s Office’s guidance on each of the rights.

To exercise any of your rights please contact us using the details below.  If you are unhappy about how we have used your personal information, please let us know.  If we are not able to resolve your concerns, you have the right to complain to the Information Commissioner's Office. 
 
Contact

TCPL
7-10 Beaumont Mews
Marylebone  
London
W1G 6EB 

www.tcpl.io/contact/
 

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Google Analytics

These cookies allow us to count page visits and traffic sources so we can measure and improve the performance of our site. Google stores the information collected by the cookie on servers in the United States. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google. 

Changes

Any material changes to the way in which we use your data will be described in future versions of this Privacy Policy. Each time you enter the Sites or upload material onto them, you agree that the Privacy Policy current at that time shall apply to all information which we hold about you.

Consent

By submitting data to us or using the Sites, you consent to our use of your data in the manner set out in this privacy policy.