Our Privacy Principles:

This privacy policy sets out how Downey & Co Ltd (“we”, “us” or “our”) uses and protects, any information that you (“your”, “your”) give Downey & Co Ltd when you use this website (the “website”), or place an order with us (“order”).

Downey & Co Ltd is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using this website or ordering from us, you can be assured that it will only be processed in accordance with this privacy policy and our own data protection policy.

Please read this policy carefully to understand our views and practices regarding your personal data and how we will treat it.  By visiting the website you are accepting and consenting to the practices described in this policy.  By providing any personal data to us, you fully understand and clearly consent to such use and transfers as set out in this policy.  This policy also sets out how we use cookies on our website.

In this privacy policy the terms “personal data”, “data controller” and “data processor” each have a special meaning that is set by legislation (the “data protection legislation”).  The Data Protection Legislation is: from the date it comes into force in the United Kingdom, the EU General Data Protection Regulation (EU) 2016/679.

 

Our contact information:

We may be contacted by email at [email protected] or by telephone on 02077398696

 

Your data controller: 

For the purposes of data protection legislation, we are the data controller of the personal data that you provide to us.

 

Information that we collect:

We obtain your personal data from the following sources:

• Directly from you

You will know what personal data we obtain from you, because you will have provided it to us.  Examples of how we obtain personal data from you include: when you make an enquiry (such as submitting an enquiry form to us), when you give us information via email, during a telephone conversation with us, during face-to-face discussions with us, information you provide via our website, via social networking messages or if you report something to us, such as a problem with our website.

 

• From marketing sources

We love to receive new customers as a result of recommendations from our existing customers, and we also actively seek new customers via marketing.  We obtain contact details about prospective new customers, and enquiries from prospective and existing customers, from:

• your responses to our online marketing or direct marketing to you, whether you respond by electronic mail, telephone, post, social media or other means;
• our website uses cookies to help us and our service providers to collect information about how you use our website.  See the section below titled “Cookies” for more information.

 

• From our other service providers

We receive personal data about you from the following third parties who provide services to us:

• our bank or providers who process payments from you, to confirm the outcome of payment transactions;
• our digital media and marketing service provider(s) who provide us with personal data obtained via social media, being the contact details detailed below (see under the heading, “Information that you provide to us and your choices”) and details of any enquiry that You make via social media; and
• data supplied by third party suppliers who may refer on enquiries to us.

 

Information that you provide to us and your choices:

To complete an order, as a minimum, we will need the following information as a contractual requirement:

·         name and job title (if relevant);

·         postal address and where you would like us to deliver work to you;

·         phone number;

·         contact information, including email address;

·         authorisation by the holder of parental responsibility for a child under 16 to process the personal data of that child (if relevant);

·         demographic information such as postcode, preferences and interests;

·         your payment details.

 

In addition, if you submit an enquiry using our website, as a minimum we will need the following information to enable to us to deal with your enquiry and get in touch with you:

·         your contact details; and

·         description of your enquiry (ie. the services that you would like us to provide).

Other information that you may provide:

·         other information relevant to customer surveys that you have completed; and

·         other information that you choose to provide to us when placing an order or getting in contact with us.

 

If you prefer for us to use less personal data, you can choose to make less available to us.

How to withhold personal data: You can control all of our sources of your personal data.  You can:

·         provide less personal data than we request;

·         exercise choice about what personal data you provide as long as it is true and accurate (for example, you may have a choice about which payment details you provide to us);

·         not respond to our marketing and communications (and you also have rights to stop our direct marketing to you: see below);

·         change your settings and connections in the social networks that you use; and/or

·         change your internet browser settings to prohibit cookies.

·         email us at [email protected] to tell us to stop contacting you with our marketing;

 

Impact of withholding personal data: Withholding your personal data from us will mean the updates, offers and communications (via advertisements, direct marketing or messages) you receive from us are not personalised or relevant to you, or (if you withhold the contact details, or tell us not to contact you) that you do not receive them at all. 

If you make an enquiry or place an order with us, withholding your personal data may mean that our response to your enquiry is not personalised or fully suitable for you or we are unable to process your order.

If you ask us to erase your personal data we may be unable to comply with your previous instructions to us about your personal data.  For example, if we erase records of your instruction not to email you, you may receive emails from us if we subsequently lawfully acquire your email address from a third party.

 

Detailed Information on our use of your personal data:

We require this information to understand your needs and provide you with a better service or to provide you with our services. We will use your personal data for any of the following purposes, whether we obtained it directly from you or from another source:

P (Purpose)
LB (Legal Basis)

1. P - To respond to your enquiries relating to our website and/or services.

LB - Our legitimate interest in responding to your requests and enquiries, e.g. by email, telephone, post or social networks.

2. P - To provide you with our services in accordance with our contract with you, once you have placed an order.

LB - Processing by us, and by our data processors, will be necessary for us to perform the contract with you or to take steps (at your request) before we enter into the contract with you. 

3. P - To process your payment for our services.

LB  - Our legitimate interest in obtaining payment before and after performing our contract with you.

4. P - To provide you with credit

LB - Our legitimate interest in ensuring that you can meet your payment obligations to us

5. P - To check and confirm that we carry out your instructions accurately, to enable us to review and improve our services and operations and develop new and changed services and operations.

LB - Our legitimate interest in providing services, choices, operations and websites that meet the requirements of our existing and prospective customers.

6. P - To manage any account you may have with us

LB - processing by us, and by our data processors, will be necessary for us to perform the contract with you or to take steps (at your request) before we enter into a contract with you so that we can process orders made by you.

7. P - To prepare, and send you, solicited or unsolicited direct marketing (unless you ask us to stop), consisting of online advertising directed to you via our service providers or of direct correspondence with you, and containing relevant information about services that we provide information that we think you may find interesting. Also to select or de-select you for each of our direct marketing initiatives.

LB - If you are an existing customer: Our legitimate interest in staying in touch with you to discuss potential repeat business.

If you are a prospective customer: our legitimate interest in sending you direct marketing to seek business from you, unless you ask us to stop (in which case we will stop).

We may send notifications by email. You can stop these notifications at any time by contacting [email protected].

8. P - Processing the data of a child under the age of 16 years

LB - We will only process the data of a child under 16 years old if required as part of the order, only after consent is given or authorised by the holder of parental responsibility and when that consent has been verified, taking into account available technology.

9. P - To provide us with information about how you use the website, so we and our service providers can review the information and ensure that the website is presented in the most effective manner for you and for your devices, and that it is an effective sales and communication tool.

LB - Our legitimate interest in providing services, choices, operations and websites that meet the requirements of our existing and prospective customers. We use Cookies.  See the “Cookies” section below for more information.

10. P - For us to take legal or administrative action, including collecting debts, resolve disputes with you, and deal with regulators.

LB - Our legitimate interest in enforcing our contract with you and in resolving any disputes with you, in dealing with regulators and as necessary for us to establish, exercise or defend legal claims.

11. P - To contact you by email.

LB - For prospective customers: normally we will ask for your consent and will not contact you by email if you have specifically withheld or withdrawn your consent to this.

For existing customers: It is lawful for us to contact you by email provided that we give you an easy method to unsubscribe. You can stop us contacting you by email at any time by contacting [email protected].

 

Disclosure of your personal data:

For as long as we have access to your personal data, we may share any of it with any of the following to the extent that they need to have access to your personal data in order to perform their role:

• Any employee within our organisation;
• Selected third parties who help us to perform our contract with you.  This includes third parties who help us directly (such as our software providers, platform providers) we do not share your personal information with third parties for their own marketing purposes.
• Our banks and other payment processing service providers who process your payments to us.
• Credit agencies if we provide you with an option to obtain credit from us.
• Our IT service providers who provide, maintain, improve, manage, optimise or fix the IT facilities that we use or rely on in our business or which we may provide to you depending on the services that we provide, including computing devices, computer networks, connectivity, telecommunications, software and our website.
• Our online service providers, who provide networking opportunities, information about networking groups, marketing and advertising placement services for us, including providers of search engines, analytics services, behavioural marketing services, advertisement placement services, social media and online software applications.
• Our professional service providers, such as accountants, auditors, legal advisers and insurance brokers.
• Any third party company or companies in the event that we go through a business transition, such as a merger, being acquired by another person or company, or selling a portion of our assets.

 

We reserve the right to disclose your personal data to other third parties if we have lawful grounds to do so, or are under a legal obligation to disclose or share it with them, or in order to establish, exercise or defend our legal rights, or to protect the rights, property, or safety of Downey or our employees or subcontractors.

 

Place of processing:

Our paper records and our internal IT systems on which we store your personal data are all within the European Economic Area.

 

Retention Time:

Your personal data is kept for the time necessary to provide the services to you or until we find that your contact details are not current or we are notified that you are deceased or you or a regulator asks us to stop processing and erase your personal data after our contract with you has expired. See the section below titled “Your rights” for more information.  

 

Your rights:

Under the data protection legislation:

• You have the right to access personal data that we hold about you.  Your right of access can be exercised in accordance with the data protection legislation.  You can submit a data access request at any time. In order to do this, please contact us at [email protected].

• If you become aware of any inaccuracies in your personal data which we process on your behalf, you have a right to ask us to rectify the inaccuracies.
• To the extent that (a) we no longer need to use your personal data (e.g. you no longer wish to receive marketing from us) for purposes described in this policy, or (b) we rely on your consent and you have withdrawn it, or (c) you object to our legitimate interests for using your personal data and no exception applies to permit us to keep using it, or (d) it is established that we did not have the lawful right to process your personal data, or (e) the law requires us to erase your personal data, you may ask us to erase your personal data.  If we erase your personal data, your ability to order our services and receive information from us will be affected, as described above.
• You have the right to ask us not to process your personal data for marketing purposes (including profiling).  You may unsubscribe at any time by emailing us directly at [email protected].
• You have the right to object to our processing of your personal data to the extent that (a) we use the personal data on grounds of our legitimate interests and no exception applies to permit us to keep using it, or (b) we use it for direct marketing purposes, or (c) we use it for scientific or historical research purposes or statistical purposes and no exception applies to permit us to keep using it. 
• You have the right to ask us to restrict our processing of your personal data to the extent that (a) you have questioned the accuracy of the personal data and we are still checking its accuracy, (b) it is established that we did not have the lawful right to process the personal data, (c) we no longer need to use your personal data for the purposes we collected or used it for but you need it to be preserved for the purposes of legal claims, or (d) you have exercised your right to object to our use of your personal data and no exception applies to permit us to keep using it.
• If we rely on your consent for processing your personal data, you can withdraw your consent at any time.
• You have the right to complain to the Information Commissioner (http://www.ico.gov.uk/) if you have any concerns in respect of the handling of your personal data by us.

If you would like to exercise any of the above rights, including to withdraw your consent (where our processing of your personal data relies on your consent), please contact us at [email protected].

You have the right to request a copy of the information that we hold about you either to learn about the content or to verify the accuracy of the data. If you would like a copy of some, or all, of your personal data please email us at [email protected] or write to us at Downey & Co Ltd 472 Hackney Road, Unit 1, Peterley Business Centre, London E2 9EQ.

If you believe that any information we are holding on you is incorrect or incomplete, please write to, or email us as soon as possible, at the above address. We will promptly correct any information found to be incorrect.

 

Changes to Policy:

We keep our privacy policy under regular review and we will place any updates on our website. If you do not agree to the changes that we make from time to time, please tell us by emailing us at [email protected]. This privacy policy was last updated on the 25th May 2018.

 

Our protection of your personal data:

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the personal data that we process about you.

 

How we use cookies:

A cookie is a small file which is stored on your devices internal storage whilst you are browsing the internet. The cookie helps us analyse web traffic around our website which helps us provide a better online experience.

To find out more about cookies, please visit www.allaboutcookies.org   

• Our use of cookies

Our website uses traffic log cookies to monitor web performance.

A cookie in no way gives us access to your computer or any information about you. For information about our legal basis for using cookies, please refer to our privacy policy above. 

Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer and most mainstream browsers will allow you to turn off cookies completely. How this is done depends on the browser that you use. 

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control.  These cookies are likely to be analytical/performance cookies or targeting cookies.  To opt-out of third-parties collecting any data regarding your interaction on our website, please refer to their websites for further information.

 

 

Joseph Turner, 

Managing Director

 

End of policy