ETFC Ltd is a company registered in England and Wales, Reg Company Number 04270717. Registered office address: Queen Elizabeth Stadium, Donkey Lane, Enfield, Middlesex, EN1 3PL
Maintaining the security of your data is a high priority at ETFC, and we are committed to respect your privacy rights and want to be transparent about what data we collect about you and how we use it. This policy applies when you visit our website and shares information with you on how we use your data, what we collect, how we ensure privacy is maintained and your legal rights relating to your personal Data.
What Personal Data Do We Collect
ETFC Ltd may collect the following information about you:
- Your name
- Your contact details: postal address, billing address and despatch address (if different), telephone numbers (including mobile number) and e-mail address
- Purchases and orders made by you
- Your browsing activity while on the ETFC website
- Your password if you create a registered account (not compulsory)
- Payment details (your card information is not held by us, it is collected by our third party payment processors, who specialise in the secure online capture and processing of credit/debit card transactions)
- Location via IP Address
- Device information when navigating our website
This list is not exhaustive and we may collect additional information under specific instances. Some of the above data is collected directly, for example if you email our customer services team or create a order. Other personal data is collected indirectly, for example through your browsing and shopping on our site, which we anonymise where possible.
How We Collect Information About You
When you visit our website we may automatically collect information about your computer, including your ip address, information about your visit, your browsing history, and how you use our website. This information is combined with other information for example, completing contact forms or when you order, we need to have your name, e-mail address, card number and card expiry date. Without this information we will not be able to process your request or notify you of acceptance of your order. A contact telephone number may also be required so that we may contact you urgently if there is a problem with your order.
How We Use Your Personal Information
We use personal information about you for the following purposes:
General
- When processing your order or contact query
- Providing information about our products which can be personalised based on the information we have collected about you
- To verify your Identity
- For crime and fraud prevention, detection and related purposes
Site Performance
- We process information to produce anonymous usage information on visitors to our site.
Marketing
- Make suggestions and recommendations to you and other users of our site about the products we offer when you browse online.
Security Of Your Data
Our secure payment is via the highly respected and secure Square online payment system and information between you and us is 256 bit encrypted. We perform malware scans and restrict data access and have a internal confidentiality policy as follows:
Within ETFC Ltd we protect your privacy in 3 ways:
1. Access to customer account information is limited to those who need access for the performance of their job
2. We use full login and password controls on our sales control system
3. Data is retained for a limited period of time.
3rd Party Data Access
As with many businesses ETFC relies on core service providers who help fulfil our promise to you when you place an order, these may include our delivery partners, our payment gateway and others within IT infrastructure to help our business run smoothly. Other than the payment process, these partners are not electronically connected.
We use Square to process payments their privacy policy can be found at https://squareup.com/gb/en/legal/general/privacy-no-account
Your Rights
Right of Access – If, for any reason, you are unsure about the personal and account information we are holding in your name, please contact us. We will review your data and update the records if required . You can contact us by email, clubshop@etfc.london.
Right to be Forgotten – You have a right for your data to be forgotten and erased (anonymised personal data) from our systems. if you would like this to happen please email clubshop@etfc.london with the Subject Line “Right to be Forgotten Request”. We will need to confirm your identity before doing this. Please note under some circumstances we refuse this request for example the HMRC requires companies to keep records of VAT for up to 6 years plus under terms of good of sale, we may delay the erasure process until after the 14 days returns and refunds policy has expired after your last purchase.
Please note that the data cleansing process is total and we will have no records of your previous interaction. This can occur due to a specific request or due to the data retention periods.
Cookies
Our cookies can contain personal information about you and are used only to determine your browser and user preferences for our site. We believe that this can greatly assist us in providing you with the service that you desire and to enhance your browsing experience.
Legal Basis For ETFC Processing Customer Data
General
ETFC Collects and uses customers’ personal data because it is necessary for the purposes of complying with our duties and exercising our rights under a contract for the sale of goods to a customer; or complying with our legal obligations. Customers have the right to withdraw consent at any time. Where consent is the only legal basis for processing we will cease to process data after consent is withdrawn.
Our Legitimate Interests
It is necessary for the legitimate interests of ETFC Ltd to process customer data as follows:
- Selling and supplying goods and services to our customers
- Protecting customers, employees and other individuals and maintaining there safety, health and welfare
- Personalising communications or content within emails and onsite
- Understanding customers behaviour, activities, preferences and needs
- Improving existing or developing new products and services
- Complying with legal and regulatory obligations
- Preventing, Investigating and detecting crime, fraud, or anti-social behaviour and prosecuting offenders, including working with law enforcement agencies
- Protecting ETFC, its customers, suppliers and employees, by taking appropriate legal action against third parties who have committed criminal acts or are in breach of legal obligations to ETFC
- Fulfilling our duties to our customers, colleagues, shareholders and other stakeholders
For more information around GDPR and Legitimate interest please see the ICO website guide here.
Transfer Your Data Outside of Europe
As part of the services offered to you through this website, the information which you provide to us may be transferred to countries outside the European Economic Area (EEA) by our 3rd Party Providers. For example International customers could be redirected to a 3rd party payment system outside of the EU. These countries may not have similar data protection laws to the UK. By submitting your personal data, You’re agreeing to this transfer, storing and processing by our 3rd Party Providers.
Data Retention Policy
Any information relating to your account (including order history, communications and correspondence records) is kept while you are still an active customer.
- All orders are retained for 7 years and all order data is safely destroyed.
- If you have not bought from us in a year, and you have an online account it will be deleted, but orders will be retained.
- Cancelled orders will be retained for 14 days
- Pending orders will be kept for 7 days
- Failed orders will be kept for 1 day
Please note that the data cleansing process is total and we will have no records of your previous interaction. This is specific interest to rules following the Right to be Forgotten, which in turn may mean in the future you become a customer and we will have no knowledge that you were once a previous customer.
We retain anonomised data to understand the performance of our website.
External Links
Please note that within our website there could be external links to other websites and companies, if you click on these then you will be subject to that 3rd parties privacy policies and not ETFC.
Contact
Please address any questions, comments and/or requests regarding our data processing practices to clubshop@etfc.london or in writing to our registered address.
DATE: 25th July 2020
