Jepson & Co takes its responsibilities regarding processing of personal data very seriously. We respect your privacy and we are committed to protecting your personal data. In this privacy notice we inform you of how we look after your personal data when you visit our website www.replacemyplates.com (regardless of where you visit it from) and tell you about the collection, use and disclosure of your personal data, and your privacy rights and how the law protects you. It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them. This privacy notice is provided in a layered format so that you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice, if you need to.
1. IMPORTANT INFORMATION AND WHO WE ARE PURPOSE OF THIS PRIVACY NOTICE
This privacy notice aims to give you information on how Jepson & Co Limited trading as replacemyplates.com (collectively referred to as “we”, “us” or “our” in this privacy notice) collects and processes your personal data through your use of this website, including any data you may provide through this website when you create an account on our website, or use our website to request products or services from a Collection Point. When we do so we are regulated under the General Data Protection Regulation (GDPR) which applies across the European Union (including in the United Kingdom) and we are responsible as ‘controller’ of that personal information for the purposes of those laws.
CONTACT DETAILS Our full details are: Full name of legal entity: Jepson & Co Limited Postal address: 44 East Bank Road, Sheffield, S2 3QN Telephone number: 0114 2731151 You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
CHANGES TO THE PRIVACY NOTICE AND YOUR PERSONAL DATA Any changes we may make to this privacy notice in the future will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to this privacy notice. This version was last updated on 11.07.2018. We want our website to be very useful for you and will do our best to keep your data up-to-date with all your preferences and correct business account data. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us. If any of your personal data as outlined below is incorrect, please contact us on firstname.lastname@example.org with the correct details and we will rectify them as a matter of priority.
THIRD-PARTY LINKS This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
OTHER TERMS WHICH MAY APPLY TO YOU Our Website Terms tell you the terms on which you may use our website replacemyplates.com, whether as a guest or a registered user.
If you choose to purchase a number plate via our website, for collection from a Collection Point, you will enter into a contract for the purchase of that number plate with the Collection Point of your choice (“Plate Supplier”), whose own terms and conditions of supply will apply to your purchase. We act only as agent for the Collection Point in connection with advertising their services and facilitating the purchase of number plates by you via our website. The terms and conditions of the Collection Point set out the basis of your contract with them for your purchase of a number plate [and you should request a copy of those terms from them]. Some Collection Points’ terms and conditions may limit or exclude their liability to you. If you are not happy with their terms and conditions, you should not place an order for the purchase and collection of a number plate from that Collection Point.
This website is not intended for children and we do not knowingly collect data relating to children.
2. THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
• Identity Data includes your first name, last name, your login data, email address, title, business name, and any other personal details you willingly provide to us. • Contact Data includes postal address, email address and telephone numbers. • Financial Data includes payment card details. We and our Collection Points do not view or access this data directly, it is controlled entirely by SagePay. • Transaction Data includes details about payments from you and other details of products and services you have purchased from via our website and details we and/or the Collection Point are required by DVLA to collect if you wish to proceed with an order, to identify you and the vehicle you wish to purchase a plate for: o proof of entitlement to the registration per DVLA’s requirements (such as, the V5C logbook and any details pertaining to the vehicle contained in the V5C); and o Proof of identification for you: personal identification document per DVLA’s requirements . • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website. • Profile Data includes your username and password, purchases or orders made by you, your preferences. • Usage Data includes information about how you use our website. • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences. We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
IF YOU FAIL TO PROVIDE PERSONAL DATA Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
HOW WE USE YOUR PERSONAL DATA We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances: • Where we need to perform the contract we are about to enter into or have entered into with you, or that you have or are about to enter into with a [Plate Supplier]. We act as the agent of a network of such businesses which handle the production and sale of vehicle number plates. • Where to need to respond to your query or provide you with information that you have asked us to provide. • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. • Where we need to comply with a legal or regulatory obligation. Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email or text message. We will only do this if you have given your consent. You have the right to withdraw consent to marketing at any time by Contacting us.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please Contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
We never make decisions based on your personal data (automated decision making) without the intervention of a human.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms: We may use your Identity, Contact, Transaction, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you have consented to receiving that marketing.
THIRD-PARTY MARKETING We will get your express opt-in consent before we share your personal data with any other company or business for marketing purposes.
WITHDRAWING YOUR CONSENT (OPTING OUT) You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by Contacting us at any time.
CHANGE OF PURPOSE We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please Contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
4. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above. • Collection Point if you choose to purchase a number plate via our website, for collection from that Collection Point. • Service providers based in the UK who provide IT, website and system administration services. • Professional advisers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services. • HM Revenue & Customs, DVLA, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances. • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
5. INTERNATIONAL TRANSFERS
We do not transfer your personal data outside the European Economic Area (EEA).
6. DATA SECURITY
All information you provide to us is stored on our secure servers in the UK or European Economic Area.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
7. DATA RETENTION
HOW LONG WILL YOU USE MY PERSONAL DATA FOR? We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. Our telephone calls are recorded for training and monitoring purposes. We always try to answer calls immediately but in the event of you leaving a voicemail, your voicemail (and any personal information you have given us) will be deleted [once it has been actioned (usually within 2 business days) OR after a period of 1 month from the date of the last call unless a query arises in which case they will be deleted after a maximum of 3 months from the date of the last call]. Our emails are deleted once processed (usually within 2 business days OR one month). Our faxes are shredded once processed (usually within 2 business days). Telephone recordings are deleted. By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes. In some circumstances you can ask us to delete your data: see section 9.2 Request erasure below for further information. In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
8. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
• Request access to your personal data. • Request correction of your personal data. • Request erasure of your personal data. • Object to processing of your personal data. • Request restriction of processing your personal data. • Request transfer of your personal data. • Right to withdraw consent. If you wish to exercise any of the rights set out above, please Contact us.
NO FEE USUALLY REQUIRED
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
WHAT WE MAY NEED FROM YOU We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
TIME LIMIT TO RESPOND We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
9.1 LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by Contacting us Performance of Contract means processing your data where it is necessary for the performance of a contract you have entered into with us, or that you have or are about to enter into with a [Plate Supplier]. We act as the agent of a network of such businesses which handle the production and sale of vehicle number plates (“Collection Points”). Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
9.2 YOUR LEGAL RIGHTS You have the right to: Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. Please Contact us if you wish to request access to your personal data. Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. Please Contact us if you wish to request correction of your personal data. Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. Please Contact us if you wish to request erasure of your personal data. Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. Please Contact us if you wish to object to processing of your personal data where we are relying on a legitimate interest (or those of a third party). Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. Please Contact us if you wish to request restriction of processing of your personal data. Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. Please Contact us if you wish to request the transfer of your personal data. Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. Please Contact us if you withdraw consent at any time where we are relying on consent to process your personal data.
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We use the following cookies:
• Essential cookies. These are cookies that are required for the operation of our site. They include, for example, cookies that enable you to log in to secure areas of our site, or use a shopping basket. • Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our site when they are using it. This helps us to improve the way our site works, for example, by ensuring that users are finding what they are looking for easily. • Functionality cookies. These are used to recognise you when you return to our site. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region). • Targeting cookies. These cookies record your visit to our site, the pages you have visited and the links you have followed. We will use this information to make our site and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose. You can find more information about the individual cookies we use and the purposes for which we use them in the table below:
Please find below a list, purpose and type of Cookies we use.
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Persistent or Session: Session
Category: Essential website cookies
Purpose: Google Analytics - Used to distinguish users.
Persistent or Session: 2 years
Category: Analytics and customisation cookies
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Persistent or Session: 24 hours
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Persistent or Session: 1 minute
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