ZwitchZ Ltd is a company registered in England and Wales.
ICO Member Number: ZA356900
ZwitchZ uses your personal data:
- to provide goods and services to you;
- to make a tailored website available to you;
- to manage any registered account(s) that you hold with us;
- to verify your identity;
- for crime and fraud prevention, detection and related purposes;
- with your agreement, to contact you electronically about promotional offers and products and services which we think may interest you;
- for market research purposes – to better understand your needs;
- to enable ZwitchZ to manage customer service interactions with you; and
- where we have a legal right or duty to use or disclose your information (for example in relation to an investigation by a public authority or in a legal dispute).
ZwitchZ uses your personal data for electronic marketing purposes (with your consent) and may send you postal mail to update you on our latest products.
ZwitchZ aims to update you about our products which are of interest and relevance to you as an individual.
You have the right to opt-out of receiving promotional communications at any time, by:
- making use of the simple “unsubscribe” link in emails.
- contacting us via the contact channels set out in this Policy.
Sharing data with third parties:
Our service providers
So we can post your orders to you, we will need to share your personal data (your shipping address) with a courier service, we mostly use Royal Mail.
We use a third-party provider, MailChimp, to deliver our newsletter. We gather statistics around email opening and clicks using industry standard technologies to help us monitor and improve our e-newsletter. For more information, please see MailChimp’s privacy notice. You can unsubscribe to general mailings at any time by clicking the unsubscribe link at the bottom of any of our emails or by emailing our data protection officer at [email protected]
Other third parties:
Aside from our service providers, we will not disclose your personal data to any third party, except as set out below. We will never sell or rent our customer data to other organisations for marketing purposes.
We may share your data with:
- credit reference agencies where necessary for card payments;
- governmental bodies, regulators, law enforcement agencies, courts/tribunals and insurers where we are required to do so: –
- to comply with our legal obligations;
- to exercise our legal rights (for example in court cases);
- for the prevention, detection, investigation of crime or prosecution of offenders; and
- for the protection of our employees and customers.
How long do we keep your data?
We will not retain your data for longer than necessary for the purposes set out in this Policy. Different retention periods apply for different types of data, however the longest we will normally hold any personal data is 6 years.
WHAT PERSONAL DATA DO WE COLLECT?
ZwitchZ may collect the following information about you:
- your name, age/date of birth and gender;
- your contact details: postal address including billing and delivery addresses, telephone numbers (including mobile numbers) and e-mail address;
- purchases and orders made by you;
- your online browsing activities on ZwitchZ.com;
- your password(s) – encrypted, we can’t see them;
- when you make a purchase or place an order with us, your payment card details;
- your communication and marketing preferences;
- your feedback and any survey responses;
- your location;
- your correspondence and communications with ZwitchZ; and
- other publicly available personal data, including any which you have shared via a public platform (such as a Twitter feed or public Facebook page).
Our website is not intended for children and we do not knowingly collect data relating to children.
We may need to collect additional data for the purposes set out in this Policy. Some of the above personal data is collected directly, for example when you set up an online account on our website, or send an email to us. Other personal data is collected indirectly, for example your browsing or shopping activity. We may also collect personal data from third parties who have your consent to pass your details to us, or from publicly available sources.
HOW WE PROTECT YOUR DATA
ZwitchZ is committed to keeping your personal data safe and secure.
Our security measures include:
- encryption of data;
- regular cyber security assessments of all service providers who may handle your personal data;
- a plan to ensure we are ready to respond to cyber security attacks and data security incidents.
HELP PROTECT YOUR DATA
We will never ask you to confirm any payment details via email. If you receive an email claiming to be from us asking you to do so, delete it straight away and contact us directly to confirm any action.
If you are using a device in a public location, we recommend that you always log out and close the website browser when you complete an online session.
In addition, we recommend that you take the following security measures to enhance your online safety both in relation to ZwitchZ and more generally:
- keep your account passwords private. Remember, anybody who knows your password may access your account;
- when creating a password, use at least 8 characters. A combination of letters and numbers is best, do not use dictionary words, your name, email address, or other personal data that can be easily obtained. We also recommend that you frequently change your password;
- avoid using the same password for multiple online accounts.
You have the following rights:
- the right to ask for a copy of personal data that we hold about you (the right of access);
- the right (in certain circumstances) to request that we delete personal data held on you; where we no longer have any legal reason to retain it (the right of erasure or to be forgotten);
- the right to ask us to update and correct any out-of-date or incorrect personal data that we hold about you (the right of rectification);
- the right to opt-out of any marketing communications that we may send you and to object to us using / holding your personal data if we have no legitimate reasons to do so (the right to object);
- the right (in certain circumstances) to ask us to ‘restrict processing of data’; which means that we would need to secure and retain the data for your benefit but not otherwise use it (the right to restrict processing); and
- the right (in certain circumstances) to ask us to supply you with some of the personal data we hold about you in a structured machine-readable format and/or to provide a copy of the data in such a format to another organisation (the right to data portability).
If you wish to exercise any of the above rights, please contact us at [email protected]
Legal basis for processing customer personal data
ZwitchZ collects and uses customers’ personal data because is it necessary for:
- the pursuit of our legitimate interests (as set out below);
- the purposes of complying with our duties and exercising our rights under a contract for the sale of goods to a customer; or
- complying with our legal obligations.
In general, we only rely on consent as a legal basis for processing personal data in relation to sending direct marketing communications to customers via email.
You have the right to withdraw consent at any time. Where consent is the only legal basis for processing, we will cease to process data after consent is withdrawn.
Our legitimate interests
The normal legal basis for processing customer data, is that it is necessary for the legitimate interests of ZwitchZ, including:-
- selling and supplying goods and services to our customers;
- protecting customers, employees and other individuals and maintaining their safety, health and welfare;
- promoting, marketing and advertising our products and services;
- sending promotional communications which are relevant to our customers;
- understanding our customers’ behaviour, activities, preferences, and needs;
- improving existing products and services and developing new products and services;
- complying with our legal obligations;
- handling customer contacts, queries, complaints or disputes;
- protecting ZwitchZ, its employees and customers, by taking appropriate legal action against third parties who have committed criminal acts or are in breach of legal obligations to ZwitchZ;
- effectively handling any legal claims or regulatory enforcement actions taken against ZwitchZ; and
- fulfilling our duties to our customers and colleagues.
DATA PROTECTION OFFICER
ZwitchZ has appointed a Data Protection Officer to ensure we protect the personal data of our customers (and others) and comply with data protection legislation.
If you have any questions about how we use your personal data that are not answered here, or if you want to exercise your rights regarding your personal data, please contact our Data Protection Officer:
- e-mail: [email protected] or
- write to: Data Protection Officer, ZwitchZ Ltd, 119a High Street, Beckenham, Kent, BR3 1AG
You have the right to lodge a complaint with the Information Commissioner’s Office. Further information, including contact details, is available at https://ico.org.uk.
This policy was last updated in May 2018.