Data Privacy Manager
Name: Andrew Dukelow Email address: email@example.com
Postal address: The Old Hall I Scarcliffe Lanes I Upper Langwith I NG20 9RH
This version was last updated on 18.05.2018.
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.
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 follows:
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does 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).
We do not collect any information about criminal convictions and offences or personal data relating to children.
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.
We use different methods to collect data from and about you including through
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:
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to 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.
Purposes for which we will use your personal data
We have set out in the table on the following page, 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.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as a new customer||(a) Identity
|Performance of a contract with you|
|To process and deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(e) Marketing and Communications
|(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
|To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey
(d) Marketing and Communications
|(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)
|To enable you to partake in a prize draw, competition or complete a survey||(a) Identity
(e) Marketing and Communications
|(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)
|To administer and protect our business||(a) Identity
|(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
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||(a) Identity
(e) Marketing and Communications
|Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences||(a) Technical
|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 our marketing strategy)
|To make suggestions and recommendations to you about goods or services that may be of interest to you||(a) Identity
|Necessary for our legitimate interests (to develop our products/services
and grow our business)
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any company outside of Sanitaryware Supplies Limited for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by contacting our Data Privacy Manager following the opt-out links on any marketing message sent to you.
Where you opt out of receiving these 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.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We may have to share your personal data with the parties set out below for the purposes set out in the table on the previous page.
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.
In the event that you do not wish to have your personal data disclosed to the third parties listed above you should contact us. You may also change your personal preferences to indicate the format, frequency and subject matter of communications you wish to receive from third parties as a result of this disclosure. Please note that this may prevent us from performing the contract entered into with you and we will notify you if this is the case.
We do not transfer your personal data outside the European Economic Area (EEA).
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.
How long will you use my personal data for?
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 up to 7 years after they cease being customers for tax purposes.
In some circumstances we may 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.
Under data protection laws, in certain circumstances, you have the right to:
Request access to your personal data (known as a “data subject access request”). enabling 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 any incomplete or inaccurate personal data that we hold about you. We may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. You may 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, 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 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. You may 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 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. 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.
If you wish to exercise any of the rights set out above, please contact our Data Privacy Manager.
If you are unhappy with the way in which your personal data has been processed 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). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance using the contact details above so that your concerns may be dealt with via our internal complaints procedure.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of your legal rights). 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.
Our terms and conditions
All quotations issued and orders received are subject to these Conditions of Sales and no alterations shall take effect unless confirmed in writing by The Sanitaryware Supplies Company Ltd Limited, (hereinafter referred to as “the Seller”). No terms, condition or warranty not recorded herein shall be binding on the Seller, except where such is necessarily imported into the contract under any Statute or at Common Law.
(i) Errors and omissions are subject to correction
(ii) Unless otherwise stated in writing, prices charged would be those ruling at the date of the order being received by the company.
(iii) Unless otherwise specified, prices include for the supply and delivery only of the goods but not for their off-loading, positioning and installation.
(iv) All prices shown are subject to VAT at the standard rate. Prices are correct at the time of printing but are subject to alteration without prior notification.
(i) In respect of an initial order and whenever else specified by the Seller, the Buyer shall pay the Seller in full as a condition precedent to despatching the goods. In all other cases where credit accounts are in place, payment must be made in full by no later than 30 days from the date of the invoice or end of the month, whatever terms have been agreed on the account.
(ii) Where payment is not received by the due date, the Seller reserves the right to charge interest on outstanding amounts for each month or part of any month that payment is overdue, under the Late Payment of Commercial Debts Regulations 2013 to add interest and late payment compensation to the sum outstanding and/or at the Seller’s option to suspend all processing and deliveries of all goods to the Buyer.
(iii) Should the Seller be prevented by the Buyer from effecting delivery on the due date, the full price of the goods shall become payable as if the goods had been delivered.
(i) Any time expressed for delivery shall be deemed to be an estimate only, time not being of the essence for the contract unless separately agreed to in writing by the Seller. The Seller accepts no liability for any loss sustained by the Buyer through late delivery and further where a time for delivery has been agreed but delivery is delayed for any reason beyond the control of the Seller, a reasonable extension of time shall be allowed to the Seller.
(ii) Where working drawings have to be approved by either the Buyer or his agent then the estimated delivery period is to be applied from the date of receipt in writing by the Seller of this approval.
(iii) Where a time for delivery is agreed and the Buyer fails for whatever reason to accept the delivery, the Seller reserves the right to make a reasonable charge for storage. Should delivery not be possible after one week’s delay the Seller shall be entitled to submit his invoice and the normal conditions of payment will apply.
(iv) The Buyer shall provide adequate labour and unloading facilities at the place of delivery at his own risk and expense.
(v) If advance notice of the approximate arrival time of the delivery vehicle is required this must be stated on the order.
(vi) A minimum of 5% of the value of the order will be charged for site delivery for all consignments delivered to addresses other than the Buyer’s Warehouse, the charge to be quoted at the time of requesting a site delivery.
(vii) Normal standard product consignments will be delivered on the UK Mainland, with a minimum £15 charge, up to an order value of £2,000. Consignments above this value may require special transport and The Sanitaryware Supplies Company Ltd reserve the right to charge as necessary. All deliveries to Republic of Ireland, Scottish Highlands and the Channel Islands are on a standard 3 day carrier service and these deliveries are priced on an “ex-works” basis. Deliveries to Northern Ireland are chargeable on a standard 3 day carrier. Deliveries that cannot be completed due to fault of the customer are to be charged for.
(i) The Sanitaryware Supplies Company Ltd reserve the right to charge as necessary for special deliveries or timed deliveries (including Saturdays), made at the request of the customer.
5. Restocking Charges
(i) Products can be accepted for return provided that they are in the current price list, are less than 3 months old and in their original packaging for a restocking charge of 35% of the original invoice value, with a minimum charge of £100, up to a value of £5,000. Nonstandard products cannot be accepted for return. An Authorisation to return goods needs to be issued by The Sanitaryware Supplies Company Ltd before any goods will be accepted.
6. Cancellation of Order
(i) Standard Items – A cancellation charge prior to delivery of 25% of the net invoice value will be made.
(ii) Special item orders cannot be cancelled and if delivered cannot be accepted for return. The Seller will invoice the full amount whether or not the product is still required.
(iii) Once goods have been delivered they are not in any circumstances returnable without the Seller’s agreement in writing.
7. Damage or Loss in Transit
(i) The Seller’s responsibility ends with the arrival of goods at the designated delivery point. The Seller is not liable for any damage or loss during unloading or thereafter.
(ii) The Buyer or his agent should examine goods on arrival and details of any damage or loss entered on the Carrier’s note.
(iii) In the event of non-arrival or shortage of goods, no claim will be accepted unless notification is given to the Seller within 7 days from the date of the Seller’s invoice.
(iv) Damaged goods will not be replaced or repaired if they have been used or installed.
(i) An additional charge will normally be made for packing and delivery outside the mainland of the United Kingdom.
(ii) A handling charge, inclusive of postage, packaging and administrative costs will be made on small orders as stated on the Seller’s current price list.
(iii) Any special delivery arrangements by passenger train, carriers or similar requests by the Buyer will be charged at cost.
9. Property and Risk
(i) Title to each item of the goods supplied by the Seller remains vested in the Seller until the purchase price and all other monies owing by the Buyer in relation to those goods or the price (whether or not due) are paid in full.
(ii) In addition, and without prejudice to sub-condition (i) above, title to goods supplied by the Seller remains vested in the Seller until such time as there are no monies owing by the Buyer to the Seller on any account (whether or not due).
(iii) Notwithstanding this reservation of title the Buyer may resell any goods in the ordinary course of business which remains the property of the Seller, in which event the Buyer shall remit the proceeds of sale to the Seller and in such a way that they are kept separate and are readily identifiable.
(iv) The Seller shall be entitled (but not obliged) at any time to recover and dispose of any goods to which it has retained title under this clause and the Buyer will be deemed to have granted to the Seller an irrevocable licence, for so long as any monies shall remain owing to the Seller to enter the Buyer’s premises to inspect and recover any such goods.
(v) The Buyer agrees to undertake in respect of all goods that remain the property of the Seller:
(a) To store the same in such a way that they are readily identifiable as the property of the Seller.
(b) To insure the same to their full value.
(c) To hold the same in all respects as bailee for the Seller.
(vi) Where the property in the goods has not passed, the Seller may nevertheless maintain an action against the Buyer for the purchase prices and all other monies then owing to the Company in relation to the goods notwithstanding Section 49 of the Sales of Goods Act 1979.
(vii) If the Seller repossesses or resells its goods is shall credit the Buyer in the Seller’s accounts (in each case after deduction of all expenses of recovery and/or sale) with the lesser of
(i) the net value or proceeds of sale (as the Seller may elect) of the goods and
(ii) the invoiced price (excluding value added tax) to the Buyer of the goods.
(viii) Notwithstanding the provisions of Condition 8(i) and 8(ii) above the goods shall be at the risk of the Buyer from the time when they are tendered for the delivery at an agreed destination or are available for collection by the Buyer or cease to be in the Seller’s possession and in particular when they are delivered into the possession or custody of a carrier, forwarding agent, warehouseman or other bailee or agent for the purposes of transmission whether or not such person contracts with or is instructed by the Seller or Buyer.
All drawings by the Seller shall remain the Seller’s property and copyright, and therefore must not be wholly or partially used or copied without the Seller’s written permission.
Illustrations and dimensions, in the Seller’s catalogue or documents, although correct in general detail, do not constitute a sale by description. The Seller’s policy is one of continuing improvement and the Seller reserves the right to vary or modify the design, specification, or surface finish without notice, unless written undertaking has been given to the contrary.
Where the goods supplied by the Seller are of the Seller’s design and manufacture the Seller will make good any defects in those goods subject to the following conditions:-
(i) The Buyer shall notify the Seller in writing at the Seller’s address, The Sanitaryware Supplies Company Limited, 2, The Old Hall, Scarcliffe Lanes, Upper Langwith NG20 9RH within 7 days of the date of delivery.
(ii) The Seller shall be provided with an adequate opportunity to examine the goods.
(iii) The Seller shall not be obliged to replace any goods or make any allowances or other arrangement if, in the reasonable opinion of the Seller, the defect has arisen from accident, misuse, neglect, installation, lack of reasonable maintenance, or any other cause beyond the reasonable control of the Seller.
(iv) Where the defect is reasonably attributed to the fault of the Seller, the Seller shall replace or repair the defective goods, but shall not be liable for any costs of removal of the defective goods, or installation of replacement goods, nor any consequential loss or damage arising there from.
(v) The Seller will not accept any charges for remedial work that is carried out without his express authority and approval.
(vi) The Seller’s liability shall be limited to the repair or replacement of materials and components manufactured by the Seller. No goods are guaranteed by the Seller for any specific length of time but are warranted to be free from defect in workmanship and materials at time of delivery. No liability can be accepted in respect of products that have become defective due to contact with corrosive liquids such as strong bleaching solutions and fluids, photographic developing liquids, immersion type silver cleaning fluids and the like that are injurious to stainless steel.
(vii) Where goods and components supplied by the Seller are not of the Seller’s design and manufacture, the Seller’s liability shall be limited to the guarantee provided by the manufacturer of such goods and components.
(viii) The Seller shall not be under any duty arising from Section 11 of these Conditions of Sale if the Buyer is in breach of any provision of the Contract with the Seller until the Buyer has remedied the breach.
The Buyer shall indemnify the Seller against all damages, penalties, costs and expenses to which the Seller may be liable if any work done in accordance with the Buyer’s specification infringes any third party property right.
(i) All warning data sheets, diagrams and other information as to the construction, assembly use, storage or disposal of the goods made available to the Buyer before, at the time of, or after the time of supply of the goods to the Buyer shall be supplied by the Buyer to any person to whom the Buyer supplies the goods or any product in which the goods are incorporated and the Buyer shall impose a similar requirement on such person. The Buyer shall indemnify the Seller in full against all liabilities costs claims demands and expenses resulting from any failure by any person other than the Seller to make such warnings data sheets, diagrams and other information available to any other person.
(ii) Where an indication as to time limits for the use of the goods has been supplied to the Buyer shall procure that all persons into whose hands the goods may come are aware of such time limits and shall not supply the goods after such time limits have been exceeded.
(iii) The Buyer will notify the Seller of any intended application of the goods other than that contemplated in the information referred to in sub-section
(i) above so as to enable the Seller to verify that the goods will be safe for use in such application.
If the Buyer commits any breach of these conditions, or if in the opinion of the Seller, the financial standing of the Buyer becomes unsatisfactory, the Seller may, without prejudice to its other rights and remedies, terminate this contract and any other contract with the Buyer. The Seller shall also be entitled to require immediate payments for all goods delivered. In the event of termination under the provisions of this clause the Seller shall be relieved of all liability under this contract and any other contract so terminated.
16. Force Majeure
In the event of war, invasion, act of foreign enemy, hostility (whether war has been declared or not). civil war, rebellion, revolution, insurrection or military or usurped powers, the Seller shall be relieved of liabilities incurred under the contract whatsoever and to the extent to which fulfilment of such obligations is presented, frustrated or impeded as a consequence of any such events or by status, rules,regulations, order or requisition issued by any Government Department, Council, or duly constituted authority, or from strikes, lock-outs, breakdown of plant or any other causes (whether or not like nature) beyond the Seller’s control.
17. Law and Arbitration
(i) All contracts entered into by the Seller shall be subject to English Law.
(ii) In the event of any dispute between the parties the same shall be submitted to an appropriate arbitrator selected by the Seller.
(i) Any notice to be given under these conditions may be delivered by hand, or sent by first class post, addressed to the party to be served at its registered office for the time being or (if not a company) the address for the party giving the notice. Notices served by post shall (except where expressly provided otherwise) be deemed served on the second business day after the date of posting, ‘business day’ shall mean a day other than a Saturday or Sunday or an English Bank or Statutory Public Holiday,
(ii) No failure or delay by the Seller in exercising any of its rights under this contract shall operate as a waiver thereof.
(iii) In the event that any of these conditions shall become or shall be declared by any court of competent jurisdiction to be invalid or unenforceable in any way, such invalidity or unenforceability shall in no way impair or affect any of the other conditions hereof all of which shall remain in full force and effect.
(iv) Clause headings are for ease of reference only and do not affect construction.
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