1. Introduction
1.1 We are committed to safeguarding the privacy
of our website visitors and customers; in this policy we explain how we will
handle your personal data.
1.2 This policy applies where we are acting as a
data controller with respect to your personal data; in other words, where we
determine the purposes and means of the processing of that personal data.
1.3 In this policy, "we",
"us" and "our" refer to WCG Sporting Ltd. For more information about us, see Section 17.
2. How we use your personal data
2.1 In this Section 2 we have set out:
(a) the general categories of personal data that
we may process;
(b) the purposes for which we may process
personal data; and
(c) the legal bases of the processing.
2.2 We may process data about your use of our
website and services ("usage data"). The usage data may
include your IP address, geographical location, browser type and version,
operating system, referral source, length of visit, page views and website
navigation paths, as well as information about the timing, frequency and
pattern of your service use. The source of the usage data is our analytics
tracking system. This usage data may be processed for the purposes of analysing
the use of the website and services. The legal basis for this processing is our
legitimate interests, namely monitoring and improving our website and services.
2.3 We may process your account data ("account
data"). The account data may include your name and email address. The
source of the account data is you. The account data may be processed for the
purposes of operating our website, providing our services, ensuring the
security of our website and services, maintaining back-ups of our databases and
communicating with you. The legal basis for this processing is our legitimate
interests, namely the proper administration of our website and business.
2.4 We may process information relating to
transactions, including purchases of goods and services, that you enter into
with us and/or through our website ("transaction data"). The
transaction data may include your contact details, your card details and the
transaction details. The transaction data may be processed for the purpose of
supplying the purchased goods and services and keeping proper records of those
transactions. The legal basis for this processing is the performance of a
contract between you and us and/or taking steps, at your request, to enter into
such a contract and our legitimate interests, namely the proper administration
of our website and business.
2.5 We may process information that you provide
to us for the purpose of subscribing to our email notifications and/or
newsletters ("notification data"). The notification data may
be processed for the purposes of sending you the relevant notifications and/or
newsletters. The legal basis for this processing is the performance of a
contract between you and us and/or taking steps, at your request, to enter into
such a contract.
2.6 We may process information contained in or
relating to any communication that you send to us ("correspondence data").
The correspondence data may include the communication content and metadata
associated with the communication. Our website will generate the metadata
associated with communications made using the website contact forms. The
correspondence data may be processed for the purposes of communicating with you
and record-keeping. The legal basis for this processing is our legitimate
interests, namely the proper administration of our website and business and
communications with users.
2.7 We may process any of your personal data
identified in this policy where necessary for the establishment, exercise or defense
of legal claims, whether in court proceedings or in an administrative or
out-of-court procedure. The legal basis for this processing is our legitimate
interests, namely the protection and assertion of our legal rights, your legal
rights and the legal rights of others.
2.8 We may process any of your personal data
identified in this policy where necessary for the purposes of obtaining or
maintaining insurance coverage, managing risks, or obtaining professional
advice. The legal basis for this processing is our legitimate interests, namely
the proper protection of our business against risks.
2.9 In addition to the specific purposes for
which we may process your personal data set out in this Section 2, we may also
process any of your personal data where such processing is necessary for
compliance with a legal obligation to which we are subject, or in order to
protect your vital interests or the vital interests of another natural person.
3. Automated decision-making
N/A
4. Providing your personal data to others
4.1 We may disclose your personal data to our
insurers and/or professional advisers insofar as reasonably necessary for the
purposes of obtaining or maintaining insurance coverage, managing risks,
obtaining professional advice, or the establishment, exercise or defense of
legal claims, whether in court proceedings or in an administrative or
out-of-court procedure.
4.3 We may disclose account and transaction data
to our suppliers insofar as reasonably necessary for resolving disputes;
queries; warranties etc.
4.4 Financial transactions relating to our
website and services are handled by our payment services providers; SAGEpay and
Paypal. We will share transaction data with our payment services providers only
to the extent necessary for the purposes of processing your payments, refunding
such payments and dealing with complaints and queries relating to such payments
and refunds. You can find information about the payment services providers' privacy
policies and practices at https://www.sagepay.co.uk/policies
https://www.paypal.com/uk/webapps/mpp/ua/privacy-full
4.5 In addition to the specific disclosures of
personal data set out in this Section 4, we may disclose your personal data
where such disclosure is necessary for compliance with a legal obligation to
which we are subject, or in order to protect your vital interests or the vital
interests of another natural person. We may also disclose your personal data
where such disclosure is necessary for the establishment, exercise or defense
of legal claims, whether in court proceedings or in an administrative or
out-of-court procedure.
4.6 We may from time to time share your
information with Trading Software in relation to the maintenance of our
Business Management System and website data purely for the purpose of maintain;
upgrading our software and troubleshooting IT issues. Trading Software are the
providers of our Business Management System.
Trading Software’s privacy policy can be viewed at http://trading-software.co.uk/helpdesk/knowledgebase.php?article=155
5. International transfers of your personal
data
5.1 You acknowledge that personal data that you
submit for publication through our website or services may be available, via
the internet, around the world. We cannot prevent the use (or misuse) of such
personal data by others.
6. Retaining and deleting personal data
6.1 This Section 6 sets out our data retention
policies and procedure, which are designed to help ensure that we comply with
our legal obligations in relation to the retention and deletion of personal
data.
6.2 Personal data that we process for any
purpose or purposes shall not be kept for longer than is necessary for that
purpose or those purposes.
6.3 Notwithstanding the other provisions of this
Section 6, we may retain your personal data where such retention is necessary
for compliance with a legal obligation to which we are subject, or in order to
protect your vital interests or the vital interests of another natural person.
7. Amendments
7.1 We may update this policy from time to time
by publishing a new version on our website.
7.2 You should check this page occasionally to
ensure you are happy with any changes to this policy.
8. Your rights
8.1 In this Section 8, we have summarised the
rights that you have under data protection law. Some of the rights are complex,
and not all of the details have been included in our summaries. Accordingly,
you should read the relevant laws and guidance from the regulatory authorities
for a full explanation of these rights.
8.2 Your principal rights under data protection
law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory
authority; and
(h) the right to withdraw consent.
8.3 You have the right to confirmation as to
whether or not we process your personal data and, where we do, access to the
personal data, together with certain additional information. That additional
information includes details of the purposes of the processing, the categories
of personal data concerned and the recipients of the personal data. Providing
the rights and freedoms of others are not affected, we will supply to you a
copy of your personal data. The first copy will be provided free of charge, but
additional copies may be subject to a reasonable fee. You can access your
personal data by visiting https://www.wcgsporting.co.uk/index.php?route=account/login
when logged into our website.
8.4 You have the right to have any inaccurate
personal data about you rectified and, taking into account the purposes of the
processing, to have any incomplete personal data about you completed.
8.5 In some circumstances you have the right to
the erasure of your personal data without undue delay. Those circumstances
include: the personal data are no longer necessary in relation to the purposes
for which they were collected or otherwise processed; you withdraw consent to
consent-based processing; you object to the processing under certain rules of
applicable data protection law; the processing is for direct marketing
purposes; and the personal data have been unlawfully processed. However, there
are exclusions of the right to erasure. The general exclusions include where
processing is necessary: [for compliance with a legal obligation; or for the
establishment, exercise or defense of legal claims.
8.6 In some circumstances you have the right to
restrict the processing of your personal data. Those circumstances are: you
contest the accuracy of the personal data; processing is unlawful but you
oppose erasure; we no longer need the personal data for the purposes of our
processing, but you require personal data for the establishment, exercise or defense
of legal claims; and you have objected to processing, pending the verification
of that objection. Where processing has been restricted on this basis, we may
continue to store your personal data. However, we will only otherwise process
it: with your consent; for the establishment, exercise or defense of legal
claims; for the protection of the rights of another natural or legal person; or
for reasons of important public interest.
8.7 You have the right to object to our
processing of your personal data on grounds relating to your particular
situation, but only to the extent that the legal basis for the processing is
that the processing is necessary for: the performance of a task carried out in
the public interest or in the exercise of any official authority vested in us;
or the purposes of the legitimate interests pursued by us or by a third party.
If you make such an objection, we will cease to process the personal
information unless we can demonstrate compelling legitimate grounds for the
processing which override your interests, rights and freedoms, or the
processing is for the establishment, exercise or defense of legal claims.
8.8 You have the right to object to our
processing of your personal data for direct marketing purposes (including
profiling for direct marketing purposes). If you make such an objection, we
will cease to process your personal data for this purpose.
8.9 You have the right to object to our
processing of your personal data for scientific or historical research purposes
or statistical purposes on grounds relating to your particular situation,
unless the processing is necessary for the performance of a task carried out for
reasons of public interest.
8.10 To the extent that the legal basis for our
processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the
performance of a contract to which you are party or in order to take steps at
your request prior to entering into a contract,
and such processing is carried out by
automated means, you have the right to receive your personal data from us in a
structured, commonly used and machine-readable format. However, this right does
not apply where it would adversely affect the rights and freedoms of others.
8.11 If you consider that our processing of your
personal information infringes data protection laws, you have a legal right to
lodge a complaint with a supervisory authority responsible for data protection.
You may do so in the EU member state of your habitual residence, your place of
work or the place of the alleged infringement.
8.12 To the extent that the legal basis for our
processing of your personal information is consent, you have the right to
withdraw that consent at any time. Withdrawal will not affect the lawfulness of
processing before the withdrawal.
8.13 You may exercise any of your rights in
relation to your personal data by written notice to us.
9. Third party websites
9.1 Our website includes hyperlinks to, and
details of, third party websites.
9.2 We have no control over, and are not
responsible for, the privacy policies and practices of third parties.
10. Personal data of children
10.1 Our website and services are targeted at persons
over the age of 18.
10.2 If we have reason to believe that we hold
personal data of a person under that age in our databases, we will delete that
personal data.
11. Updating information
11.1 Please let us know if the personal information
that we hold about you needs to be corrected or updated.
12. About cookies
12.1 A cookie is a file containing an identifier (a
string of letters and numbers) that is sent by a web server to a web browser
and is stored by the browser. The identifier is then sent back to the server
each time the browser requests a page from the server.
12.2 Cookies may be either "persistent"
cookies or "session" cookies: a persistent cookie will be stored by a
web browser and will remain valid until its set expiry date, unless deleted by
the user before the expiry date; a session cookie, on the other hand, will
expire at the end of the user session, when the web browser is closed.
12.3 Cookies do not typically contain any
information that personally identifies a user, but personal information that we
store about you may be linked to the information stored in and obtained from
cookies.
13. Cookies that we use
13.1 We use cookies for the following purposes:
(a) authentication - we use cookies to identify
you when you visit our website and as you navigate our website
(b) status - we use cookies [to help us to
determine if you are logged into our website
(c) shopping
cart - we use cookies to maintain the state of your shopping cart as you
navigate our website
(d) personalisation - we use cookies to store
information about your preferences and to personalise our website for you
(e) analysis
- we use cookies to help us to analyse the use and performance of our website
and services
14. Cookies used by our service providers
14.1 Our service providers use cookies and those
cookies may be stored on your computer when you visit our website.
14.2 We use Google Analytics to analyse the use of
our website. Google Analytics gathers information about website use by means of
cookies. The information gathered relating to our website is used to create
reports about the use of our website. Google's privacy policy is available at: https://www.google.com/policies/privacy/.
14.3 Our website host (Siteground) supply web
traffic monitoring services, namely AWStats and Webalizer which record IP
addresses of visitors in order that we may monitor web traffic. This data may
be shared with Trading Software Ltd. in order that they might assist with
website traffic monitoring. The data is hosted by Siteground who would be the
Data Processor. This data is not deleted.
15. Managing cookies
15.1 Most browsers allow you to refuse to accept
cookies and to delete cookies. The methods for doing so vary from browser to
browser, and from version to version. You can however obtain up-to-date
information about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647?hl=en
(Chrome);
(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
(Firefox);
(c) http://www.opera.com/help/tutorials/security/cookies/
(Opera);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies
(Internet Explorer);
(e) https://support.apple.com/kb/PH21411
(Safari); and
(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy
(Edge).
15.2 Blocking all cookies will have a negative
impact upon the usability of many websites.
15.3 If you block cookies, you will not be able to
use all the features on our website.
16. Cookie preferences
16.1 You can manage your preferences relating to
the use of cookies on our website by adjusting the settings in your browser.
17. Our details
17.1 This website is owned and operated by WCG
Sporting Ltd
17.2 We are registered in England and Wales under
registration number8964973, and our registered office is at Poole Court Farm,
Langford Budville, Wiveliscombe, Somerset.
17.3 Our principal place of business is at West
Country Guns, 9 The Square, Wiveliscombe, Somerset, Ta4 2JT.
17.4 You can contact us:
(a) by post, to the postal address given above;
(b) using our website contact form;
(c) by telephone, on the contact number
published on our website from time to time; or 01984 623829
(d) by email, at sales@wcgsporting.co.uk
18. Representative within the European Union
N/A
19. Data protection officer
N/A