PROTECTING YOUR PRIVACY
This privacy notice explains the types of personal data we may collect about you when you interact with us. It also explains how we handle this data and keep it safe. Equipment for the Physically Challenged (also known as EPC Wheelchairs) wants to keep your trust, and takes your privacy seriously.
It is likely that we will need to amend this privacy notice from time to time. We’ll notify you of any significant changes, but you can revisit it whenever you wish on our website (www.epc-wheelchairs.co.uk), or ask us for a paper copy if you prefer.
2. Who is EPC?
Equipment for the Physically Challenged is a partnership. It is often referred to as ‘EPC Wheelchairs’.
We will shortly be changing our status to become EPC Wheelchairs Ltd. The partnership will be gradually phased out, and all business will continue in the new incorporated company, which will be run by the 2 existing partners (Peter Norfolk OBE and Linda Norfolk) as the only 2 directors of the new company.
3. Explaining the legal basis we rely on to hold your personal information
The law on data protection (GDPR) sets out a number of different reasons for which a company may collect and process your personal data, including:
In several circumstances, we need your personal data to comply with our contractual obligations.
For example, if you order an item from us on the website or by phone, we’ll collect your contact details to enable us to fulfil this order. To deliver your purchase, we will pass your relevant details to our courier.
If the law requires us to, we may need to collect and process your data.
For example, if you wish to make a VAT exempt purchase, and are eligible to complete a VAT exemption declaration form. We must keep these details, which include your description of your disability.
In specific situations, we can collect and process your data with your consent.
For example, when you tick a box to receive email newsletters.
When collecting your personal data, we’ll make clear to you which data is necessary in connection with a particular service.
In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests.
For example, we will use your purchase history to send you service reminders, or let you know about related new products/ services.
4. When do we collect your personal data?
We collect data:-
- When you visit our website, and use your account to buy products and services.
- When you create an account with us.
- When you purchase a product or service in the showroom, or by phone.
- When you engage with us on social media.
- When you contact us by any means with queries, complaints etc.
- When you book any kind of appointment with us.
- When you choose to complete any surveys we send you.
- When you comment on or review our products and services.
- Any individual may access personal data related to them, including opinions. So if your comment or review includes information about an individual, it may be passed on to them if requested.
- When you fill in any forms. For example, if an accident happens in the showroom, we may collect your personal data.
- When you’ve given a third party permission to share with us the information they hold about you, e.g. a Wheelchair Service, charity, or business.
- When you use our showrooms, which usually have CCTV systems operated for the security of both customers and employees. These systems may record your image during your visit.
5. What sort of personal data do we collect?
- We usually collect:- your name, billing/delivery address, orders and receipts, email and telephone number.
- If you have a web account, in addition, we’ll also keep an encrypted record of your login / password.
- Details of your interactions with us through phone contact, in the showroom, online or by email.
For example, we collect notes from our conversations with you, details of any complaints or comments you make, details of purchases you made, items viewed or added to your basket, brands you show interest in, web pages you visit, and how and when you contact us.
- Details of your visits to our websites, and which site you came from to ours.
- Personal details which help us to recommend items of interest.
For example, if you are an active wheelchair user.
We’ll only ask for and use your personal data collected for recommending items of interest and to tailor your experience with us. Of course, it’s your choice whether you share such details with us.
- Payment card information.
- Your comments and product reviews.
- Your image may be recorded on CCTV when you visit a showroom, or car park.
- Your car number plate may be recorded when you park at our showrooms as part of the premises security systems administered by our landlords.
- To deliver the best possible web experience, we collect technical information about your internet connection and browser as well as the country and telephone code where your computer is located, the web pages viewed during your visit, the advertisements you clicked on, and any search terms you entered. Learn more about this.
- Your social media username, if you interact with us through those channels, to help us respond to your comments, questions or feedback.
6. How and why do we use your personal data?
The data privacy law allows us to use personal data as part of our legitimate interest in understanding our customers and providing the highest levels of service to you.
If you wish to change how we use your data, you’ll find details in the ‘What are my rights?’ section below. However, if you choose not to share your personal data with us, or refuse certain contact permissions, we might not be able to provide some services you’ve asked for.
For example, if you’ve asked us to let you know when an item comes back into stock, we can’t do that if you’ve withdrawn your general consent to hear from us.
Here’s how we’ll use your personal data and why:
- To process any orders that you make by using our website, or in the showroom. If we don’t collect your personal data at point of sale, we won’t be able to process your order and comply with our legal obligations.
For example, your details may need to be passed to a third party to deliver the product that you ordered, and we may keep your details for a reasonable period afterwards in order to fulfil any contractual obligations such as refunds, guarantees and so on.
- To respond to your queries, refund requests and complaints. Handling the information you sent enables us to respond. We may also keep a record of these to inform any future communication with us and to demonstrate how we communicated with you throughout. We do this on the basis of our contractual obligations to you, our legal obligations and our legitimate interests in providing you with the best service and understanding how we can improve our service based on your experience.
- To protect our business and your account from fraud and other illegal activities. This includes using your personal data to maintain, update and safeguard your account. We’ll also monitor your browsing activity with us to quickly identify and resolve any problems and protect the integrity of our websites. We’ll do all of this as part of our legitimate interest.
For example, by checking your password when you login.
- To protect our customers, premises, assets and employees from crime, we operate CCTV systems in our showrooms, and car parks which record images for security. We do this on the basis of our legitimate business interests.
- To process payments and to prevent fraudulent transactions. We do this on the basis of our legitimate business interests. This also helps to protect our customers from fraud.
- If we discover any criminal activity or alleged criminal activity through our use of CCTV, fraud monitoring and suspicious transaction monitoring, we will process this data for the purposes of preventing or detecting unlawful acts. We aim to protect the individuals we interact with from criminal activities.
- With your consent, we will use your personal data, and details of your transactions to keep you informed by email, web, text, telephone about products and services including offers, discounts, promotions, events, competitions and so on.
Of course, you are free to opt out of hearing from us by any of these channels at any time.
- To send you communications required by law or which are necessary to inform you about our changes to the services we provide you. For example, updates to this Privacy Notice, product recall notices, and legally required information relating to your orders. These service messages will not include any promotional content and do not require prior consent when sent by email or text message. If we do not use your personal data for these purposes, we would be unable to comply with our legal obligations.
- To develop, test and improve the systems, services and products we provide to you. We’ll do this on the basis of our legitimate business interest.
- To comply with our contractual or legal obligations to share data with law enforcement.
For example, when a court order is submitted to share data with law enforcement agencies or a court of law.
- To send you survey and feedback requests to help improve our services. These messages will not include any promotional content and do not require prior consent when sent by email or text message. We have a legitimate interest to do so as this helps make our products or services more relevant to you.
Of course, you are free to opt out of receiving these requests from us at any time by updating your preferences in your online account.
- To process your booking/appointment requests (for example with an Engineer).
Here’s more information on how we share personal data with third parties.
7. How we protect your personal data
We know how much data security matters to all our customers. With this in mind we will treat your data with the utmost care and take appropriate steps to protect it.
Access to all transactional areas of our website is secured using ‘https’ technology. Access to your personal data is password-protected, and sensitive data such as payment card information) is secured and tokenised to ensure it is protected.
Our system is regularly monitored by our provider (Fusemetrix Group Ltd) for possible vulnerabilities and attacks, and they carry out penetration testing to identify ways to further strengthen security.
8. How long we will keep your personal data?
Whenever we collect or process your personal data, we’ll only keep it for as long as is necessary for the purpose for which it was collected. At the end of that retention period, your data will either be deleted completely or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning.
Some examples of customer data retention periods:
When you place an order, we’ll keep the personal data you give us for six years so we can comply with our legal and contractual obligations. In the case of certain products, e.g. if you are still using a product, we’ll keep the data longer as required.
If your order included a warranty, the associated personal data will be kept until the end of the warranty period.
9. Who do we share your personal data with?
We sometimes share your personal data with trusted third parties.
For example, delivery couriers, for fraud management, to handle complaints, and so on.
Here’s the policy we apply to those organisations to keep your data safe and protect your privacy:
- We provide only the information they need to perform their specific services.
- They may only use your data for the exact purposes we specify in our contract with them.
- We work closely with them to ensure that your privacy is respected and protected at all times.
- If we stop using their services, any of your data held by them will either be deleted or rendered anonymous.
Examples of the kind of third parties we work with are:
- IT companies who support our website and other business systems.
- Operational companies such as delivery couriers.
- Google / Facebook to show you products that might interest you while you’re browsing the internet. This is based on either your marketing consent or your acceptance of cookies on our websites. See our Cookies Notice for details.
Sharing your data with third parties for their own purposes:
We will only do this in very specific circumstances, for example:
- For fraud management, we may share information about fraudulent or potentially fraudulent activity in our premises or systems. This may include sharing data about individuals with law enforcement bodies.
- We may also be required to disclose your personal data to the police or other enforcement, regulatory or Government body, in your country of origin or elsewhere, upon a valid request to do so. These requests are assessed on a case-by-case basis and take the privacy of our customers into consideration.
- We may, from time to time, expand, reduce or sell the Partnership and this may involve the transfer of divisions or the whole business to new owners. If this happens, your personal data will, where relevant, be transferred to the new owner or controlling party, under the terms of this Privacy Notice.
For further information please contact our Data Protection Officer.
To assist your journey through our website we currently use the following companies, who will process your personal data as part of their contracts with us:
Fusemetrix PayPal WorldPay FaceBook Google YouTube Twitter Instagram
10. Where your personal data may be processed
Sometimes we will need to share your personal data with third parties and suppliers outside the European Economic Area (EEA), such as Australia or the USA.
Protecting your data outside the EEA
The EEA includes all EU Member countries as well as Iceland, Liechtenstein and Norway. We may transfer personal data that we collect from you to third-party data processors in countries that are outside the EEA.
For example, this might be required in order to fulfil your order, process your payment details or provide support services.
If we do this, we have procedures in place to ensure your data receives the same protection as if it were being processed inside the EEA. For example, our contracts with third parties stipulate the standards they must follow at all times. If you wish for more information about these contracts please contact our Data Protection Officer.
Any transfer of your personal data will follow applicable laws and we will treat the information under the guiding principles of this Privacy Notice.
11. What are your rights over your personal data?
An overview of your different rights:-
You have the right to request
- Access to the personal data we hold about you, free of charge in most cases.
- The correction of your personal data when incorrect, out of date or incomplete.
For example, when you withdraw consent, or object and we have no legitimate overriding interest, or once the purpose for which we hold the data has come to an end (such as the end of a warranty).
- That we stop using your personal data for direct marketing (either through specific channels, or all channels).
- That we stop any consent-based processing of your personal data after you withdraw that consent.
You have the right to request a copy of any information about you that we hold at any time. To ask for your information, please contact Data Protection Officer, EPC Wheelchairs, Unit 3, Cligga Industrial Units, St George’s Hill, Perranporth, Cornwall TR6 0EB, or firstname.lastname@example.org .
You have a right to have that information corrected if it is inaccurate. To do this, please update your online account, or contact our Sales or Accounts team.
If we choose not to action your request we will explain to you the reasons for our refusal.
Your right to withdraw consent
Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent.
Where we rely on our legitimate interest
In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.
You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We must always comply with your request.
Checking your identity
To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Notice. If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.
12. How can you stop the use of your personal data for direct marketing?
Here are several ways you can stop direct marketing communications from us:
- Click the ‘unsubscribe’ link in any email communication that we send you. We will then stop any further emails from that particular division.
- If you have an account, log in into your account, visit the ‘My Account’ area and change your preferences.
- Write to EPC Wheelchairs, Unit 3, Cligga Industrial Units, St George’s Hill, Perranporth, Cornwall TR6 0EB
Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated.
13. Contacting the regulator
If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
If you are based outside the UK, you have the right to lodge your complaint with the relevant data protection regulator in your country of residence.
14. If you live outside the UK
For all non-UK customers
By using our services or providing your personal data to us, you expressly consent to the processing of your personal data by us or on our behalf. Of course, you still have the right to ask us not to process your data in certain ways, and if you do so, we will respect your wishes.
By dealing with us, you are giving your consent to transfer and disclosure of your personal data outside your country of residence for our ordinary business purposes. Our information technology storage facilities and servers are located outside your country of residence, and could include storage of your personal data on servers in the UK.
15. Any Questions?
We hope this Privacy Notice has been helpful in setting out the way we handle your personal data and your rights to control it.
If you have any questions that haven’t been covered, please contact our Data Protection Officer who will be pleased to help you:
- Email us at email@example.com
- Or write to us at Data Protection Officer, EPC Wheelchairs, Unit 3, Cligga Industrial Units, St George’s Hill, Perranporth, Cornwall TR6 0EB
This notice was last updated on 17/05/2018