In this Policy the following terms shall have the following meanings:

"Account" means an account required to access and/or use certain areas and features of Our Site;

"Cookie" means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in Part 14, below; and

"Cookie Law" means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;

Our Site is owned and operated by Orthoform Wire Ltd, a limited company registered in England under company number 08574213.

Registered address: 94 Park Lane, Hornchurch, Essex, RM11 1BE, United Kingdom.

VAT number: GB166397372.

Our Data Protection Officer can be contacted by email at: info@orthoformwire.com, by telephone on: 01708 726 535, or by post at: Data Protection Officer, Orthoform Wire Ltd, 94 Park Lane, Hornchurch, Essex, RM11 1BE.

This Privacy Policy applies only to your use of Our Site. Our Site may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

Under the GDPR, you have the following rights, which we will always work to uphold:

• The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 15.
• The right to access the personal data we hold about you. Part 13 will tell you how to do this.
• The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 15 to find out more.
• The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Part 15 to find out more.
• The right to restrict (i.e. prevent) the processing of your personal data.
• The right to object to us using your personal data for a particular purpose or purposes.
• The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
• Rights relating to automated decision-making and profiling.

For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 15.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office

When you visit our Site, we automatically collect certain information about your device, including:

• Information about your web browser
• Your IP address
• Your location time zone
• Some of the cookies that are installed on your device

As you browse our Site, we collect additional information:

• The individual web pages or products that you view
• What websites or search terms referred you to our Site
• Information about how you interact with our Site.

We refer to this automatically-collected information as “Device Data.” We collect Device Data using the following technologies:

“Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information please see Part 14 on our use of Cookies and similar technologies and our Cookie Policy, or visit allaboutcookies.org

“Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.

“Web beacons,” “tags,” and “pixels” are electronic files used to record information about how you browse the Site.

Additionally, when you make a purchase or attempt to make a purchase through the Site, we collect the following information from you:

• Your name;
• Your Email address;
• Your Telephone number;
• Your business/company name;
• Your business/company shipping and billing address;
• Purchases and orders placed by you; and
• Your payment card details

We refer to this information as “Order Data.” When we talk about “Personal Data” in this Privacy Policy, we are talking both about Device Data and Order Data.

Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data may be used for the following purposes:

• Providing and managing your Account;
• Providing and managing your access to Our Site;
• Personalising and tailoring your experience on Our Site;
• Supplying our products and services to you. Your personal details are required in order for us to enter into a contract with you.
• Personalising and tailoring our products and services for you.
• Communicating with you. This may include responding to emails or calls from you.
• Supplying you with information by email and/or post that you have opted-in to (you may unsubscribe or opt-out at any time by clicking the unsubscribe button at the bottom of any email you receive).
• Analysing your use of Our Site and gathering feedback to enable us to continually improve Our Site and your user experience.

With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email, telephone, text message and post with information, news, and offers on our products. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.

Third Parties (including Shopify Inc, Bold Innovation Group Ltd, and Mascot Software Technologies Ltd) whose content appears on Our Site may use third-party Cookies, as detailed below in Part 14. Please refer to Part 14 for more information on controlling cookies.

We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):

• When you place an order with us we’ll keep the personal data you give us for six years, or for as long as your account remains active, so we can comply with our legal and contractual obligations;
• When you subscribe/opt-in to our email newsletter we’ll keep the data you provide for as long as you remain subscribed to the list. You can unsubscribe at any time by clicking the link at the bottom of any email.

We may store or transfer some or all of your personal data in countries that are not part of the European Economic Area, such as USA, Canada and New Zealand (the ‘EEA’ consists of all EU member states, plus Norway, Iceland, and Liechtenstein). This means that we will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR as follows.

We will only transfer your personal data to countries that the European Commission has deemed to provide an adequate level of personal data protection, where that third party is certified on the EU-US Privacy Shield or where we have a contract in place with that third party which includes the European Commission's standard data protection clauses. More information is available from the European Commission.

The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:

• We secure access to all transactional areas of our website using ‘https’ technology which ensures all data is encrypted and remains private.
• Account access and personal data is password-protected and any sensitive data such as payment card details is processed securely via a certified Level 1 PCI DSS compliant payment gateway. Your purchase transaction data is stored only as long as is necessary to complete your purchase transaction. After that is complete, your purchase transaction information is deleted. All direct payment gateways adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover.
• Our system undergoes regular security scans to monitor for possible vulnerabilities and attacks.

We may sometimes contract with third parties to supply certain services to you on our behalf. These include payment processing, delivery of goods, and marketing. In some cases, those third parties may require access to some or all of your personal data that we hold.

For example, we use Shopify to power our online store - you can read more about how Shopify uses your Personal Information here. We also use Google Analytics to help us understand how our customers use the Site - you can read more about how Google uses your Personal Information here. You can also opt-out of Google Analytics here.

If any of your personal data is required by a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 9.

If any personal data is transferred outside of the EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR, as explained above in Part 9, and with the additional policy applied:

• We provide only the information they require to carry out their specific service, and nothing more;
• We ensure they only use your data for the purpose we specify in our contract with them.
• If we cease using a third party service, any of your data held by them will either be deleted or anonymised.

In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

• In addition to your rights under the GDPR, set out in section 5, when you submit personal data via Our Site, you may be given options to restrict Our use of your data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details and by managing your Account preferences).
• You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.

You may access certain areas of Our Site without providing any personal data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.

You may restrict our use of Cookies. For more information, see Part 14 and our Cookie Policy.

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 15.

There is not normally any charge for a subject access request, however, if your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We will respond to your subject access request within 28 days and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

Our Site may place and access certain first party Cookies on your computer or device. First party Cookies are those placed directly by Us and are used only by Us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve Our services.

By using Our Site, you may also receive certain third party Cookies on your computer or device. Third party Cookies are those placed by services, and/or parties other than Us. Third party Cookies are used on Our Site for apps integrated into our platform which improve your shopping experience, such as Favourites Wishlist, and Multi-Buy Discounts.

In addition, Our Site uses analytics services provided by Google Analytics, which also use Cookies. Website analytics refers to a set of tools used to collect and analyse usage statistics, enabling Us to better understand how people use Our Site. For more details, please refer to our Cookie Policy.

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details (for the attention of Data Protection Officer):

• Email address: info@orthoformwire.com
• Telephone number: +44 (0)1708 726 535
• Postal Address: Orthoform Wire Ltd, 94 Park Lane, Hornchurch, Essex, RM11 1BE

We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date.

This notice was last updated on 23/05/2018