The new General Data Protection Regulation (GDPR) comes into effect on 25 May 2018 and we would like to take this opportunity to outline how we are complying with this legislation.
This is the privacy notice of LED Eco Lights Limited (whose brand names include Goodlight®, Bright Goods® and Light Boss™). In this document, “we”, “our”, or “us” refers to LED Eco Lights Ltd.
We are incorporated in the United Kingdom, with the company registration number 05747226.
- This is a notice to inform you of our policy about all information that we record about you. It sets out the conditions under which we may process any information that we collect from you, or that you provide to us. It covers information that could identify you (“personal information”) and information that could not. In the context of the law and this notice, “process” means collect, store, transfer, use or otherwise act on information.
- We regret that if there are one or more points below with which you are not happy, your only recourse is to leave our website immediately.
- We take seriously the protection of your privacy and confidentiality. We understand that all visitors to our website are entitled to know that their personal data will not be used for any purpose unintended by them, and will not accidentally fall into the hands of a third party.
- We undertake to preserve the confidentiality of all information you provide to us, and hope that you reciprocate.
- Our policy complies with UK law accordingly implemented, including that required by the EU General Data Protection Regulation (GDPR).
- The law requires us to tell you about your rights and our obligations to you in regards to the processing and control of your personal data. We do this now, by requesting that you read the information provided at www.knowyourprivacyrights.org
- Except as set out below, we do not share, or sell, or disclose to a third party, any information collected through our website.
What information we collect about you
We collect information about you when you provide it to us, when you use our Services, and when other sources provide it to us, as further described below.
Information you provide to us
We collect information about you when you fill out a form on our webpage or otherwise provide it directly to us.
- Account and Profile Information: We collect information about you when you register for an account, create or modify your profile, set preferences, sign-up for or make purchases through our webpage. For example, you provide your contact information and, in some cases, billing information when you create an account to make a purchase from us.
- Content you provide through our products: Where you engage in our products and services regarding LED lighting, you may also provide further data for us to ensure that you are choosing the right product(s) for your application. This content includes any information about you that you may choose to include.
- Content you provide through our websites: We collect other content that you submit through our websites – for example via our catalogue request page, quote basket page and through feedback and survey answers submitted.
- Information you provide through our support channels: We also provide you with customer support, where you may choose to submit information regarding a problem you are experiencing with a product/service. If you chose to submit such information you will be asked to provide contact information, a summary of the problem you are experiencing, and any other documentation, photographs or information that would be helpful in resolving the issue.
- Payment Information: We collect certain payment and billing information when you create an account with us. We never pass on or share these details with anyone.
Information we collect automatically when you use the Services
We collect information about you when you use our webpage, including browsing our websites and taking certain actions within the webpage.
- Your use of our webpage: We keep track of certain information about you when you visit and interact with our webpage.
- Device and Connection Information: We collect information about your computer, phone, tablet, or other devices you use to access our webpage. This device information includes your connection type and settings when you install, access, update, or use our webpage. We also collect information through your device about your operating system, browser type, IP address, URLs of referring/exit pages, device identifiers, and crash data. We use your IP address and/or country preference in order to approximate your location to provide you with a better Service experience. How much of this information we collect depends on the type and settings of the device you use to access the Services.
How we use the information we collect
- To provide good service and personalise your experience: we use information about you to provide goods and services to you including processing transactions and providing customer support.
- To communicate with you about our goods and services: we use your contact information to send transactional communications to you via email, for example to provide customer support and/or technical advice.
To communicate latest offers and developments within the company: We use your contact information to send promotional and informative e-newsletters to you. If you opt-in to receive our e-newsletters, you will be added to our mailing list as you have consented. We also market to B2B business addresses (only) under legitimate interests. This means that if you are a key decision maker and you hear from us, it is because we feel that our LED lighting is of a legitimate interest and clear benefit to your company. Of course, if you do not wish to be contacted, you can let us know at any time and we will immediately remove you from our database. All our e-newsletters contain ‘unsubscribe’ links by law, and you can unsubscribe at any time, and we will remove you from our mailing list with immediate effect. The opt-in forms can be found on our Quote Basket, Catalogue Request and Contact Us webpages. You can also contact us at any time to unsubscribe from any marketing communications by emailing firstname.lastname@example.org with ‘Unsubscribe from Marketing’ in the subject line.
To provide customer support: we use your information to resolve technical issues you encounter and to assist with any other enquiries you may have. When you contact us, whether by telephone, through our website or by e-mail, we collect the data you have given to us in order to reply with the information you need. We record your request and our reply in order to increase the efficiency of our business.
We keep personally identifiable information associated with your message, such as your name and email address so as to be able to track our communications with you to provide a high-quality service.
To process a complaint: when we receive a complaint, we record all the information you have given to us and we use that information to resolve your complaint.
If your complaint reasonably requires us to contact some other person, we may decide to give to that other person some of the information contained in your complaint. We do this as infrequently as possible, but it is a matter for our sole discretion as to whether we do give information, and if we do, what that information is.
We may also compile statistics showing information obtained from this source to assess the level of service we provide, but not in a way that could identify you or any other person.
To process payment of your order with us: payment information is never saved by us or transferred either through our website or otherwise. Our employees and contractors never have access to it.
For security and safety: we use information about you and your account to verify accounts and activity and to monitor suspicious or fraudulent activity.
Cookies are small text files that are placed on your computer’s hard drive by your web browser when you visit any website. They allow information gathered on one web page to be stored until it is needed for use on another, allowing a website to provide you with a personalised experience and the website owner with statistics about how you use the website so that it can be improved.
Some cookies may last for a defined period of time, such as one day or until you close your browser. Others last indefinitely.
Your web browser should allow you to delete any you choose. It also should allow you to prevent or limit their use.
- to track how you use our website (via Google Analytics)
- to record whether you have seen specific messages we display on our website
- to keep you signed in our site
- to record your answers to surveys and questionnaires while you complete them
Personal identifiers from your browsing activity
Requests by your web browser to our servers for web pages and other content on our website are recorded.
We record information such as your geographical location, your Internet service provider and your IP address. We also record information about the software you are using to browse our website, such as the type of computer or device and the screen resolution.
We use this information in aggregate to assess the popularity of the webpages on our website and how we perform in providing content to you.
If combined with other information we know about you from previous visits, the data possibly could be used to identify you personally, even if you are not signed in to our website.
Our use of re-marketing
Re-marketing involves placing a cookie on your computer when you browse our website in order to be able to serve to you a digital advert for our products or services when you visit some other website.
The bases on which we process information about you
The law requires us to determine under which of six defined bases we process different categories of your personal information, and to notify you of the basis for each category.
If a basis on which we process your personal information is no longer relevant then we shall immediately stop processing your data.
If the basis changes then if required by law we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information.
- Information we process because we have a contractual obligation with you
When you create an account with us (via through our sales representative or online), buy a product or service from us, or otherwise agree to our terms and conditions, a contract is formed between you and us.
In order to carry out our obligations under that contract we must process the information you give us. Some of this information may be personal information.
We may use it in order to:
- verify your identity for security purposes
- sell products to you
- provide you with our goods and services
- provide you with suggestions and advice on products, services and how to obtain the most from using our website
We process this information on the basis there is a contract between us, or that you have requested we use the information before we enter into a legal contract.
Additionally, we may aggregate this information in a general way and use it to provide class information, for example to monitor our performance with respect to a particular service we provide.
We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.
Information we process with your consent
- Through certain actions when otherwise there is no contractual relationship between us, such as when you browse our website or ask us to provide you more information about our business, including our products and services, you provide your consent to us to process information that may be personal information.
- If you have given us explicit permission to do so, we may from time to time pass your name and contact information to selected associates whom we consider may provide services or products you would find useful. We continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists.
- You may withdraw your consent at any time by instructing us at email@example.com with ‘Unsubscribe from Marketing’ in the subject line. However, if you do so, you may not be able to use our website or our services further.
Information we process for the purposes of legitimate interests
We may process information on the basis there is a legitimate interest, either to you or to us, of doing so.
Where we process your information on this basis, we do after having given careful consideration to:
- whether the same objective could be achieved through other means
- whether processing (or not processing) might cause you harm
- whether you would expect us to process your data, and whether you would, in the round, consider it reasonable to do so
For example, we may process your data on this basis for the purposes of:
- record-keeping for the proper and necessary administration of our business
- responding to unsolicited communication from you to which we believe you would expect a response
- protecting and asserting the legal rights of any party
- insuring against or obtaining professional advice that is required to manage business risk
- protecting your interests where we believe we have a duty to do so
Information we process because we have a legal obligation
We are subject to the law like everyone else. Sometimes, we must process your information in order to comply with a statutory obligation.
For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order.
This may include your personal information.
Disclosure and sharing of your information
Sharing with Third Parties
We share information with third parties that help us operate, provide, improve, integrate, customize, support and market our Services.
- Service Providers: We work with third-party service providers to provide website and application development, hosting, maintenance, backup, storage, virtual infrastructure, payment processing, analysis and other services for us, which may require them to access or use information about you. If a service provider needs to access information about you to perform services on our behalf, they do so under instruction from us, including abiding by policies and procedures designed to protect your information.
- LED Eco Lights Partners: We work with third parties who provide consulting, marketing, sales, support and technical services to deliver and implement customer solutions
- With your consent: We share information about you with third parties when you give us consent to do so. For example, we often display testimonials of satisfied customers on our public websites. With your consent, we may post your name alongside the testimonial.
- Compliance with Enforcement Requests and Applicable Laws; Enforcement of Our Rights: In exceptional circumstances, we may share information about you with a third party if we believe that sharing is reasonably necessary to:
- comply with any applicable law, regulation, legal process or governmental request, including to meet national security requirements,
- enforce our agreements, policies and terms of service,
- protect the security or integrity of our products and services,
- protect LED Eco Lights, our customers or the public from harm or illegal activities, or
- respond to an emergency which we believe in good faith requires us to disclose information to assist in preventing the death or serious bodily injury of any person.
- Credit reference: to assist in combating fraud, we share information with credit reference agencies, so far as it relates to clients or customers who instruct their credit card issuer to cancel payment to us without having first provided an acceptable reason to us and given us the opportunity to refund their money.
- Our Suppliers and/or Agents: where you have entered into a contract with us for the supply of goods and services, we may need to share your information with our Suppliers and/or Agents to ensure fulfilment of this contract.
For example, if you enter into a contract with us to supply LED lighting, it will be necessary for us to provide our couriers with certain information (delivery address and contact), to fulfil the contract.
The information will only be shared if it is necessary to the fulfilment of the contract.
Access to your own information
- Access to your personal information: at any time you may review or update personally identifiable information that we hold about you, by contacting us at firstname.lastname@example.org or by calling us on 01276 691 230
- To obtain a copy of any information that is not provided on our website you may send us a request at email@example.com. After receiving the request, we will tell you when we expect to provide you with the information, and whether we require any fee for providing it to you.
- Removal of your information: You have the right to be forgotten. If you wish us to remove personally identifiable information from our website and/or database, you may contact us at firstname.lastname@example.org. This may limit the service we can provide to you.
- Opt-out of communications: you may opt-out of receiving promotional and/or informative communications from us by using the unsubscribe link within each email or by contacting us at email@example.com
- Verification of your information: when we receive any requests to access, edit or delete personal identifiable information we shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.
- Responding to your requests: we will deal with your subject access request without undue delay and in any event within one month of receipt of your request.
- We will not charge a fee for dealing with your request unless it is manifestly unfounded or excessive. If we charge a fee, we will inform you of this and explain the reasons for doing so.
- We will explain what steps have been taken in dealing with your request i.e. we will set out the source of your personal information we have gathered.
- If you are not satisfied by our actions, you can outline your dissatisfaction by email to us at firstname.lastname@example.org. If you remain dissatisfied, you have the right to refer the matter to the Information Commissioner or seek recourse through the courts.
Right To Be Forgotten
You have the right to be forgotten – if you wish to not be contacted by us at all (i.e. opt out of all communications), you must contact us by emailing email@example.com with ‘Right To Be Forgotten’ in the subject line.
- Use of site by children: we do not sell products or provide services for purchase by children, nor do we market to children. If you are under 18, you may use our website only with consent from a parent or guardian
- Encryption of data sent between us: we use Secure Sockets Layer (SSL) certificates to verify our identity to your browser and to encrypt any data you give us.
- Whenever information is transferred between us, you can check that it is done so using SSL by looking for a closed padlock symbol or other trust mark in your browser’s URL bar or toolbar. You can also verify this by ensuring that the URL starts with HTTPS:// (as opposed to HTTP://)
- How you can complain:
- If a dispute is not settled then we hope you will agree to attempt to resolve it by engaging in good faith with us in a process of mediation or arbitration.
- oIf you are in any way dissatisfied about how we process your personal information, you have a right to lodge a complaint with the Information Commissioner’s Office. This can be done at https://ico.org.uk/concerns/
- Retention period for personal data: except as otherwise mentioned in this privacy notice, we keep your personal information only for as long as required by us:
- o to provide you with the services you have requested;
- o to comply with other law, including for the period demanded by our tax authorities;
- o to support a claim or defence in court.
Effective Date: 21st May 2018.