1. Important information and who we are 2. The data we collect about you 3. How is your personal data collected? 4. How we use your personal data 5. Disclosures of your personal data 6. International transfers 7. Data security 8. Data retention 9. Your legal rights 10. Glossary
##### Important information and who we are
This notice applies to the processing of personal data collected by us when you:
- Use our service(s) whether it is through our web platform or our mobile applications. This notice is then applicable to our customers, and their users:
- Visit our websites - Visit our offices - Receive communications from us
This website is not intended for children, and we do not knowingly collect data relating to children.
Snowfall Limited 10-12 East Parade Leeds LS1 2BH Email: firstname.lastname@example.org
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)
Information Commissioner’s Office Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF Helpline number: 0303 123 1113
We take our commitment to your Privacy extremely seriously and we would, therefore, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance. Alternately if you live in the EU or elsewhere, you may complain to your local data protection supervisory authority.
2. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person 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 as follows:
Identity Data: first name, last name, username or similar identifier, title, passport or driver’s licence.
Contact Data: billing address, delivery address, email address and telephone numbers.
Financial Data: bank account details.
Transaction Data: details about payments to and from you and other details of products and services you have purchased from us.
Technical Data: internet protocol (IP) address, your login data, 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.
Usage Data: information about how you use our website, products, and services.
Marketing and Communications Data: your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share “Aggregated Data” such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity.
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). Nor do we collect any information about criminal convictions and offences.
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.
3. How is your personal data collected? We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise.
This includes personal data you provide when you: - Use our products or services - Request marketing to be sent to you - Request help solving technical issues - Give us feedback - Contact us
Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns.
4. How we use your 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:
- Where we need to perform the contract, we are about to enter or have entered with you. - Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. - Where we need to comply with a legal obligation.
Click here to find out more about the types of lawful basis that we will rely on to process your personal data.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
We have set out below a description of the types of personal data, the purpose for which we may use that personal data and the lawful basis for processing in relation to 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.
Types of personal data: 1. Identity 2. Contact 3. Financial 4. Transaction 5. MarketingCommunications 6. Profile 7. Technical 8. Usage 9. FinancialandGovernmentalData
Toprocessanddeliveraservicetoyouasacustomerincludingmanaging payments, fees, and charges, collect and recover money owed to us, foreign money exchange.
Toadministerandprotectourbusinessandthiswebsite(includingtroubleshooting, data analysis, testing, system maintenance, support, reporting, hosting of data, and anti-money laundering checks).
To deliver relevant website content.
Tousedataanalyticstoimproveourwebsite,products/services,marketing, customer relationships and experiences.
Tomakesuggestionsandrecommendationstoyouaboutservicesthatmaybeof interest to you. Lawful basis for processing including basis of legitimate interest
Necessaryforourlegitimateinterests(tokeepourrecordsupdatedandtostudy how customers use our products/services)
Necessaryforourlegitimateinterests(forrunningourbusiness,provisionof administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
Necessaryforourlegitimateinterests(tostudyhowcustomersuseourproducts/ services, to develop them, to grow our business and to inform our marketing strategy)
5. Disclosure of your personal data
We may share your personal data with the parties set out below for the purposes set out in the above:
- Internal Third Parties as set out in the Glossary. - External Third Parties as set out in the Gossary
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.
6. International Transfers
We share your personal data within the Snowfall Group and selected third parties. Some of the Snowfall Group as well as external parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries. - Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
In the absence of an adequacy decision or appropriate contractual safeguards we may rely on derogations for specific situations. For further details, see GDPR Article 49: Derogations for specific situations.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
7. 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.
8. Data retention
For how long will you be using my personal data?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.
We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. 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, regulatory, tax, accounting or other requirements.
By law we must keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for 6 years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see your legal rights below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
- Request access to your personal data. - Request correction of your personal data. - Request erasure of your personal data. - Object to processing of your personal data. - Request restriction of processing your personal data. Request transfer of your personal data. - Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us using the details above.
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 could 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.
Tine limit to respond We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.
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 such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
- Internal Third Parties Other companies in the Snowfall Group acting as joint controllers or processors and who are based in UK, EEA and UAE and provide IT and system administration services, product development and undertake leadership reporting.
External Third Parties
- Service providers acting as processors based in the USA, UK, EEA, and UAE who provide IT and system administration services.
Professional advisers acting as processors or joint controller including lawyers, bankers, auditors, and insurers based in UK, EEA and UAE who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the UK and EEA who require reporting of processing activities in certain circumstances.
Other third parties acting as processors include recruitment agencies, debt collecting agencies and fraud prevention agencies based in UK and EEA, who provide consultancy, debt recovery, credit checks and anti-money laundering services.
Your legal rights You have the right to: 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 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, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
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:
- If you want us to establish the data's accuracy.
- Where our use of the data is unlawful, but you do not want us to erase it.
- 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.
- 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, machine-readable 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.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.