Privacy Policy

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share any information relating to you (your personal data) in connection with your use of our website. It also explains your rights in relation to your personal data and how to contact us or a relevant regulator in the event you have a complaint.

We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation (UK GDPR).

Given the nature of our website and business, we do not expect to collect the personal data of anyone under 18 years old. If you are aware that any personal data of anyone under 18 years old has been shared with us please let us know so that we can delete that data.

This privacy policy is divided into the following sections:

1. What this policy applies to
2. Personal data we collect about you
3. How your personal data is collected
4. How and why we use your personal data
5. Marketing
6. Who we share your personal data with
7. How long your personal data will be kept
8. Transferring your personal data out of the UK
9. Your rights
10. Keeping your personal data secure
11. How to complain
12. Changes to this privacy policy
13. How to contact us

This privacy policy relates primarily to your use of our website.

Throughout our website we may link to other websites and/or mobile applications owned and operated by certain trusted third parties to make additional products and services available to you. Those third party websites and/or mobile applications may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to those third party websites and/or mobile applications, please consult their privacy policies as appropriate.

The personal data we collect about you depends on the particular activities carried out through our website. We will collect and use the following personal data about you:

• your name, and email address
• location data (address provided by you)
• your billing information, transaction and payment card or other payment method information
• bank account and payment details
• medical details and other personal information disclosed in our Client Questionnaire
• details of any information, feedback or other matters you give us by phone, email, post, or other review or feedback websites or mobile applications or via social media
• your account details, such as username and login details
• your activities on, and use of, our website
• information about the services we provide to you
• your contact history, purchase history and saved items
• information about how you use our website
• your responses to surveys, competitions and promotions
• your social media online presence, e.g. Facebook profile
• We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below.

We collect personal data from you:

• directly, when you enter or send us information, such as when you register with us, complete a health questionnaire, when you contact us (including via email), send us feedback, purchase products or services via our website, post material to our website & social media, and complete customer surveys
• indirectly, such as your browsing activity while on our website

Under data protection law, we can only use your personal data if we have a proper reason, eg:

• where you have given consent
• to comply with our legal and regulatory obligations
• for the performance of a contract with you or to take steps at your request before entering into a contract, or
• for our legitimate interests or those of a third party.

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You can obtain details of this assessment by contacting us (see ‘How to contact us’ below).

The table below explains what we use your personal data for and why.

Create and manage your account with usTo perform our contract with you or to take steps at your request before entering into a contractProviding products and/or services to youTo perform our contract with you or to take steps at your request before entering into a contract

To provide safe, responsible services

To meet our insurance and professional / regulatory bodies obligations

To enforce legal rights or defend or undertake legal proceedingsDepending on the circumstances:

—to comply with our legal and regulatory obligations

—in other cases, for our legitimate interests or those of a third party, i.e. to protect our business, interests and rights or those of others

Retaining and evaluating information on your recent visits to our website, tracking how you move around different sections of our website for analytics purposes. This helps us to understand how people use our website and is for our own purposes so that we can make it more intuitive or check our website is working as intendedFor our legitimate interests, to provide the best service to you at the best price, and for you to be able to track the classes which you have done.Communications with you not related to marketing, including about changes to our terms or policies or changes to the products and/or services or other important noticesDepending on the circumstances:

— to comply with our legal and regulatory obligations

— in other cases, for our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service to you at the best price

Statistical analysis to help us manage our business, e.g. establishing class views, in relation to our financial performance, customer base, product range or other efficiency or teacher or class performance measuresFor our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service to you at the best priceUpdating and enhancing customer recordsDepending on the circumstances:

— to perform our contract with you or to take steps at your request before entering into a contract

— to comply with our legal and regulatory obligations

— where neither of the above apply, for our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about existing orders and new products

Marketing our services to existing and former customersFor our legitimate interests or those of a third party, i.e. to promote our business to existing and former customers

See ‘Marketing’ below for further information

External audits and quality checks, e.g. for the audit of our accountsFor our legitimate interests or those of a third partyTo share your personal data with members of our group and third parties in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency

In such cases, information will be anonymised where possible and only shared where necessary

Depending on the circumstances:

— to comply with our legal and regulatory obligations

— in other cases, for our legitimate interests or those of a third party, i.e. to protect, realise or grow the value in our business and assets

See ‘Who we share your personal data with’ for further information on the steps we will take to protect your personal data where we need to share it with others.

We may use your personal data to send you updates (by email, text message, telephone or post) about our products and/or services, including exclusive offers, promotions or new products and/or services.

We have a legitimate interest in using your personal data for marketing purposes (see above ‘How and why we use your personal data’). This means we do not usually need your consent to send you marketing information. However, where consent is needed, we will ask for this separately and clearly.

You have the right to opt-out of receiving marketing communications at any time by:

• contacting us at info@A1firstaid.co.uk
• using the ‘unsubscribe’ link at the bottom of all our marketing emails

We may ask you to confirm or update your marketing preferences if you ask us to provide further products and/or services in the future, or if there are changes in the law, regulation, or structure of our business.

We will always treat your personal data with the utmost respect and never sell or share it with other organisations for marketing purposes.

For more information on your right to object at any time to your personal data being used for marketing purposes, see ‘Your rights’ below.

We routinely share personal data with:

• third parties we use to help deliver our products and/or services to you, eg payment service providers, warehouses and delivery companies
• other third parties we use to help us run our business, eg marketing agencies or website hosts and website analytics providers
• our bank(s) and payment providing system

We or the third parties mentioned above may occasionally also need to share personal data with:

• external auditors, eg in relation to the audit of our accounts, in which case the recipient of the information will be bound by confidentiality obligations
• professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations
• law enforcement agencies, courts, tribunals, HMRC and regulatory bodies to comply with our legal and regulatory obligations to other parties in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised but this may not always be possible, however, the recipient of the information will be bound by confidentiality obligations

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 at least six years after they cease being customers for tax purposes.

In some circumstances, you can ask us to delete your data and 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.

The EEA, UK and other countries outside the EEA and the UK have differing data protection laws, some of which may provide lower levels of protection of privacy.

It sometimes may be necessary for us to share your personal data to countries outside the UK and EEA. In those cases we will comply with applicable UK and EEA laws designed to ensure the privacy of your personal data.

As we are based in the UK we may also transfer your personal data from the EEA to the UK.

Under data protection laws, we can only transfer your personal data to a country outside the UK/EEA where:

• in the case of transfers subject to UK data protection law, the UK government has decided the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy regulation’) further to Article 45 of the UK GDPR,
• in the case of transfers subject to EEA data protection laws, the European Commission has decided that the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy decision’) further to Article 45 of the EU GDPR. In addition, EEA data protection laws provide that transfers of personal data to the UK are lawful under an interim arrangement (UK interim bridge) while the European Commission seeks to determine if the UK can be granted a longer-term adequacy decision, there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you, or
• a specific exception applies under relevant data protection law.

Where we transfer your personal data outside the UK we do so on the basis of an adequacy regulation or (where such is not available) legally-approved standard data protection clauses recognised or issued further to Article 46(2) of the UK GDPR. In the event we cannot or choose not to continue to rely on either of those mechanisms at any time we will not transfer your personal data outside the UK unless we can do so on the basis of an alternative mechanism or exception provided by UK data protection law.

Where we transfer your personal data outside the EEA we do so on the basis of the UK interim bridge or an adequacy decision or (where such is not available) legally-approved standard data protection clauses issued further to Article 46(2) of the EU GDPR. In the event we cannot or choose not to continue to rely on either of those mechanisms at any time we will not transfer your personal data outside the EEA unless we can do so on the basis of an alternative mechanism or exception provided by applicable data protection law.

Any changes to the destinations to which we send personal data or in the transfer mechanisms we use to transfer personal data internationally will be notified to you in accordance with the section on ‘Change to this privacy policy’ below.

You generally have the following rights, which you can usually exercise free of charge:

Access to a copy of your personal dataThe right to be provided with a copy of your personal dataCorrection (also known as rectification)The right to require us to correct any mistakes in your personal dataErasure (also known as the right to be forgotten)The right to require us to delete your personal data—in certain situationsRestriction of useThe right to require us to restrict the use of your personal data in certain circumstances, eg if you contest the accuracy of the dataData portabilityThe right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situationsTo object to useThe right to object:

— at any time to your personal data being used for direct marketing (including profiling)

— in certain other situations to our continued use of your personal data, eg where we use your personal data for our legitimate interests.

Not to be subject to decisions without human involvementThe right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

We do not make any such decisions based on data collected by our website and/or mobile application.

For further information on each of those rights, including the circumstances in which they do and do not apply, please contact us (see ‘How to contact us’ below).

If you would like to exercise any of those rights, please email, call or write to us—see below: ‘How to contact us’. When contacting us please:

• provide enough information to identify yourself (your full name and address) and any additional identity information we may reasonably request from you, and
• let us know which right(s) you want to exercise and the information to which your request relates

We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

Please contact us if you have any queries or concerns about our use of your information (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.

You also have the right to lodge a complaint with:

• the Information Commissioner in the UK, and
• a relevant data protection supervisory authority in the EEA state of your habitual residence, place of work or of an alleged infringement of data protection laws in the EEA

The UK’s Information Commissioner may be contacted at https://ico.org.uk/make-a-complaint or by telephone: 0303 123 1113.

We may change this privacy policy from time to time—when we make significant changes we will take steps to inform you, for example by including a prominent link to a description of those changes on our website for a reasonable period or by other means, such as email.

You can contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.

Our contact details are shown below:

info@a1firstaid.co.uk

ARIC t/a A1 First Aid.