1. Introduction
This Privacy Notice explains in detail the types of personal data we may collect about you when you interact with us. It also explains how we'll store and handle that data, and keep it safe.
We know that there's a lot of information here but we want you to be fully informed about your rights, and how Card Personalisation Solutions Limited uses your data.
We hope the following sections will answer any questions you have but if not, please do get in touch with us.
It's likely that we'll need to update this Privacy Notice from time to time. We'll notify you of any significant changes, but you're welcome to come back and check it whenever you wish.
2. Who is Card Personalisation Solutions Limited?
Card Personalisation Solutions Limited - which we'll refer to as 'the Company' in this document - is the legal entity of Card Personalisation Solutions Limited, that also operates a number of related brands:
cardps.com (our main corporate website), identity2u.net (our main webstore), and perfectpoints2u.com (our loyalty programme solution)
For simplicity throughout this notice, 'we' and 'us' means the Company and its brands.
3. Explaining the legal bases we rely on
The law on data protection sets out a number of different reasons for which a company may collect and process your personal data, including:
Consent
In specific situations, we can collect and process your data with your consent.
For example, when you tick a box to receive email newsletters.
When collecting your personal data, we'll always make clear to you which data is necessary in connection with a particular service.
Contractual obligations
In certain circumstances, we need your personal data to comply with our contractual obligations.
For example, if you order an item from us for home delivery, we'll collect your address details to deliver your purchase, and pass them to our courier.
Legal compliance
If the law requires us to, we may need to collect and process your data.
For example, we can pass on details of people involved in fraud or other criminal activity affecting the Company to law enforcement.
Legitimate interest
In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests.
For example, we will use your purchase history to send you or make available personalised offers.
We also combine the shopping history of many customers to identify trends and ensure we can keep up with demand, or develop new products/services.
We will also use your address details to send you direct marketing information by post, telling you about products and services that we think might interest you.
4. When do we collect your personal data?
When you visit any of our websites, and use your account to buy products and services, or place an order the Company on the phone, or online.
When you create an account with us.
When you purchase a product or service by phone or by email but don't have (or don't use) an account.
When you engage with us on social media.
When you download or install one of our apps.
When you contact us by any means with queries, complaints etc.
When you ask one of our employees to email you information about a product or service.
When you enter prize draws or competitions.
When you book any kind of appointment with us or book to attend an event or meeting.
When you choose to complete any surveys we send you.
When you comment on or review our products and services. Any individual may access personal data related to them, including opinions.
When you fill in any forms.
When you've given a third party permission to share with us the information they hold about you.
We collect data from publicly available sources (such as Land Registry) when you have given your consent to share information or where the information is made public as a matter of law.
When you use our car park or business premises which usually have CCTV systems operated for the security of both customers and Company. These systems may record your image during your visit.
5. What sort of personal data do we collect?
If you have a web account with us: your name, billing/delivery address, orders and receipts, email and telephone number. For your security, we'll also keep an encrypted record of your login password.
Details of your interactions with us through contact centres, online or by using one of our apps.
For example, we collect notes from our conversations with you, details of any complaints or comments you make, details of purchases you made, items viewed or added to your basket, voucher redemptions, web pages you visit and how and when you contact us.
Details of your visits to our websites or apps, and which site you came from to ours.
Personal details which help us to recommend items of interest.
For example, you might tell us which type of technology you use for access control and let you know when a new product is added to that range, or if that product range is reaching it's end if life and what alternatives are available.
We'll only ask for and use your personal data collected for recommending items of interest and to tailor your shopping experience with us. Of course, it's always your choice whether you share such details with us.
Your comments and product reviews.
Your image may be recorded on CCTV when you visit our offices or car park.
To deliver the best possible web experience, we collect technical information about your internet connection and browser as well as the country and telephone code where your computer is located, the web pages viewed during your visit, the advertisements you clicked on, and any search terms you entered.
Your social media username, if you interact with us through those channels, to help us respond to your comments, questions or feedback.
6. How and why do we use your personal data?
We want to give you the best possible customer experience. One way to achieve that is to get the richest picture we can of who you are by combining the data we have about you.
The data privacy law allows this as part of our legitimate interest in understanding our customers and providing the highest levels of service.
Of course, if you wish to change how we use your data, you'll find details in the 'What are my rights?' section below.
Remember, if you choose not to share your personal data with us, or refuse certain contact permissions, we might not be able to provide some services you've asked for.
For example, if you've purchased a product in the past and this will soon be discontinued so we would need to advise you of a replacement, we can't do that if you've withdrawn your general consent to hear from us.
Here's how we'll use your personal data and why:
To process any orders that you make by using our websites, apps or email. If we don't collect your personal data during checkout, we won't be able to process your order and comply with our legal obligations.
For example, we may keep your details for a reasonable period afterwards in order to fulfil any contractual obligations such as refunds, guarantees and so on.
To respond to your queries, refund requests and complaints. Handling the information you sent enables us to respond. We may also keep a record of these to inform any future communication with us and to demonstrate how we communicated with you throughout. We do this on the basis of our contractual obligations to you, our legal obligations and our legitimate interests in providing you with the best service and understanding how we can improve our service based on your experience.
To protect our business and your account from fraud and other illegal activities. This includes using your personal data to maintain, update and safeguard your account. We'll also monitor your browsing activity with us to quickly identify and resolve any problems and protect the integrity of our websites. We'll do all of this as part of our legitimate interest.
For example, by checking your password when you login and using automated monitoring of IP addresses to identify possible fraudulent logins from unexpected locations.
To protect our customers, premises, assets and employees from crime, we operate CCTV systems in our offices and car parks which record images for security. We do this on the basis of our legitimate business interests.
To process payments and to prevent fraudulent transactions. We do this on the basis of our legitimate business interests. This also helps to protect our customers from fraud.
If we discover any criminal activity or alleged criminal activity through our use of CCTV, fraud monitoring and suspicious transaction monitoring, we will process this data for the purposes of preventing or detecting unlawful acts. We aim to protect the individuals we interact with from criminal activities.
With your consent, we will use your personal data, preferences and details of your transactions to keep you informed by email, web, text, telephone and through our contact teams about relevant products and services including tailored special offers, discounts, promotions, events, competitions and so on.
Of course, you are free to opt out of hearing from us by any of these channels at any time.
To send you relevant, personalised communications by post in relation to updates, offers, services and products. We'll do this on the basis of our legitimate business interest.
You are free to opt out of hearing from us by post at any time.
To send you communications required by law or which are necessary to inform you about our changes to the services we provide you. For example, updates to this Privacy Notice, product recall notices, and legally required information relating to your orders. These service messages will not include any promotional content and do not require prior consent when sent by email or text message. If we do not use your personal data for these purposes, we would be unable to comply with our legal obligations.
To display the most interesting content to you on our websites or apps, we'll use data we hold about your favourite brands or products and so on. We do so on the basis of your consent to receive app notifications and / or for our website to place cookies or similar technology on your device.
For example, we might display a list of items you've recently looked at, or offer you recommendations based on your purchase history and any other data you've shared with us.
To administer any of our prize draws or competitions which you enter, based on your consent given at the time of entering.
To develop, test and improve the systems, services and products we provide to you. We'll do this on the basis of our legitimate business interests.
For example, we'll record your browser's Session ID to help us understand more when you leave us online feedback about any problems you're having.
To comply with our contractual or legal obligations to share data with law enforcement.
For example, when a court order is submitted to share data with law enforcement agencies or a court of law.
To send you survey and feedback requests to help improve our services. These messages will not include any promotional content and do not require prior consent when sent by email or text message. We have a legitimate interest to do so as this helps make our products or services more relevant to you.
Of course, you are free to opt out of receiving these requests from us at any time by by updating your preferences in your online account.
To build a rich picture of who you are and what you like, and to inform our business decisions, we'll combine data captured from across the Company, third parties and data from publicly-available lists as we have described in the section What Sort of Personal Data do we collect? We'll do this on the basis of our legitimate business interest.
For example, by combining this data, this will help us personalise your experience and decide which inspiration or content to share with you. We also use anonymised data from customer purchase histories to identify trends.
Sometimes, we'll need to share your details with a third party who is providing a service (such as delivery couriers). Without sharing your personal data, we'd be unable to fulfil your request.
7. How we protect your personal data
We know how much data security matters to all our customers. With this in mind we will treat your data with the utmost care and take all appropriate steps to protect it.
We secure access to all transactional areas of our websites and apps using 'https' technology.
Access to your personal data is password-protected, and sensitive data is secured by SSL encryption.
We regularly monitor our system for possible vulnerabilities and attacks, and we carry out penetration testing to identify ways to further strengthen security.
8. How long will we keep your personal data?
Whenever we collect or process your personal data, we'll only keep it for as long as is necessary for the purpose for which it was collected.
At the end of that retention period, your data will either be deleted completely or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning.
Some examples of customer data retention periods:
Orders
When you place an order, we'll keep the personal data you give us for five years so we can comply with our legal and contractual obligations. In the case of certain products, such as electrical and nursery items, we'll keep the data for 10 years.
Inactive accounts
If you've not used your account for more than two years, it will be flagged as inactive and we'll contact you to ask whether you want to keep it open. Unless you reply to say 'yes', we'll close the account and delete or anonymise the personal data associated with it.
Warranties
If your order included a warranty, the associated personal data will be kept until the end of the warranty period.
9. Who do we share your personal data with?
We sometimes share your personal data with trusted third parties.
For example, delivery couriers, technicians from manufacturers to help resolve an issue.
Here's the policy we apply to those organisations to keep your data safe and protect your privacy:
We provide only the information they need to perform their specific services.
They may only use your data for the exact purposes we specify in our contract with them.
If we stop using their services, any of your data held by them will either be deleted or rendered anonymous.
Examples of the kind of third parties we work with are:
IT companies who support our website and other business systems.
Operational companies such as delivery couriers.
For fraud management, we may share information about fraudulent or potentially fraudulent activity in our premises or systems. This may include sharing data about individuals with law enforcement bodies.
We may also be required to disclose your personal data to the police or other enforcement, regulatory or Government body, in your country of origin or elsewhere, upon a valid request to do so. These requests are assessed on a case-by-case basis and take the privacy of our customers into consideration.
For further information please contact our Data Protection Officer.
Sometimes we will need to share your personal data with third parties and suppliers outside the European Economic Area (EEA), this will only be done on a case-by-case basis when you require technical support from a product manufacturer.
The limit of this transfer of information will be your name, company name (if applicable), email address, nature of technical issue.
10. What are the rights over your personal data?
An overview of your different rights
You have the right to request:
Access to the personal data we hold about you, free of charge in most cases.
The correction of your personal data when incorrect, out of date or incomplete.
That we stop using your personal data for direct marketing.
That we stop any consent-based processing of your personal data after you withdraw that consent.
Review by a Company employee of any decision made based solely on automatic processing of your data (i.e. where no human has yet reviewed the outcome and criteria for the decision).
You can contact us to request to exercise these rights at any time as follows:
To ask for your information please contact The Data Protection Officer, CPS Limited, Unit 2 The Bramery, Alstone Lane, Cheltenham, Gloucestershire GL51 8HE or email DPO@cardps.com. To ask for your information to be amended please update your online account or contact our customer services team.
If we choose not to action your request we will explain to you the reasons for our refusal.
Your right to withdraw consent
Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent.
Where we rely on our legitimate interest
In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation.
We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.
Direct marketing
You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We must always comply with your request.
Checking your identity
To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Notice.
If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.
11. How can you stop the use of your personal data for direct marketing?
There are several ways you can stop direct marketing communications from us:
Click the 'unsubscribe' link in any email communication that we send you. We will then stop any further emails from that particular channel.
If you have an account, log in into your account, visit the 'Account' area and change your preferences.
Write to Card Personalisation Solutions Limited, Unit 2, The Bramery, Alstone Lane, Cheltenham, Gloucestershire GL51 8HE.
Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated.
14. Contacting the Regulator
If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the Information Commissioner's Office.
You can contact them by calling 0303 123 1113.
Or go online to www.ico.org.uk/concerns (please note we can't be responsible for the content of external websites).
15. Any questions?
We hope this Privacy Notice has been helpful in setting out the way we handle your personal data and your rights to control it.
If you have any questions that haven't been covered, please contact our Data Protection Officer who will be pleased to help you:
Email us on DPO@cardps.com
Or write to us at
Data Protection Officer
Card Personalisation Solutions Limited
Unit 2, The Bramery
Alstone Lane
Cheltenham
Gloucestershire GL51 8HE
