Privacy Policy

Maintaining your privacy is really important to us. You entrust us with your information, and
we take that responsibility seriously.

We may modify or update this Privacy Policy from time to time to reflect the changes in our
business and practices, and so you should review this page periodically. When we change
the policy in a material manner we will let you know and update the ‘last updated’ header as
below.

This Privacy Policy was last amended on 7th November 2023

This policy was last updated on 7th November 2023 in line with GDPR requirements. It may be
updated in the future and we will post the new version here on our website. We will never
deviate from our overall philosophy of maintaining your privacy, though.

1. General Information

Garnetts Electronics Ltd ("we", "us", "our") take security and privacy seriously. This Privacy
Policy explains how we collect, store and use personal data when you browse garnettselectronics.com or otherwise provide your personal data to us. Please read this Privacy Policy
carefully to understand how we will treat your personal data.
This Privacy Policy should be read together with our Terms of Service.

2.1. Your Personal Data
When we say your "personal data", we mean any information that identifies any person that you provide to us, (or that you authorise a third party to give to us on your behalf).

Your "personal data" may also be contained in information that we collect about you in connection with your use of the garnettselectronics.com website, your order or otherwise interact with us, for example by electronic mail.

When it comes to your personal data, we comply with our obligations under the General Data Protection Regulation (GDPR) and any other applicable data protection legislation from time to time.

Your personal data includes the information you provide, or that you authorise someone else to provide information in your account profile, on the garnettselectronics.com website (including any forms you complete), during an electronic mail enquiry about you or any support enquiry about you and/or your organisation.

Examples of this personal data include your name, your email address, address including postcode which you provide to us when you set up your account and subsequently amend in the My Account section; and any correspondence when you contact us.

We shall periodically check that the personal data we store for you is accurate and update our records accordingly. If you would like to update the personal data we hold about you, please login to your Garnetts Electronics account or contact us by completing the form at https://www.garnettselectronics.com/page/contact-us with your request.

We do not knowingly collect or solicit any personal data from anyone under the age of eighteen or knowingly allow such persons to register for a Garnetts Electronics account, or purchase goods from us. Garnetts Electronics is

not directed at children under the age of eighteen. In the event that we learn that we have collected personal data from a child under eighteen without verification of parental consent, we will delete that information as quickly as possible.

If you contact us through social media messenger, we use a third-party provider Hootsuite.

We use a third party provider Google for our email services. Transport Layer Security (TLS) is used to encrypt and protect email traffic. If your email service does not support TLS, you should be aware that any emails we send or receive may not be protected in transit.

We will also monitor any emails sent to us, including file attachments, for viruses or malicious software. Please be aware that you have a responsibility to ensure that any email you send is within the bounds of the law.

2.4. People Who Call and/or Message Our Contact Telephone Number

To be completed

2.5. Information We Collect - We collect information about your website usage, to improve our service and to understand trends to enhance and customise our website. Some of this data may be "personal data", where it identifies a person. Here's the information that we collect and how we use it:

• We monitor patterns of usage, such as abandoned cart data, login dates and volumes of data, so we can understand how and what people are interesting in buying from Garnett Electronics, to develop and improve our products and understand customer behaviour.
• We also monitor patterns of usage so that we can tailor any communications we may send you or advertising you may receive. For example, we may tailor your newsletter with information about product features that you haven't tried yet, instead of features that you use frequently.
• For security reasons, to aid in monitoring patterns of usage and to improve user experience, we log your IP address when you use the website. This is your computer/device's individual identification number that is assigned to your computer/device when connected to the Internet.
• We monitor traffic information when you visit our site or read our emails, including things like page visits, email clicks, referring sites, and video viewings. We use this information to improve our website, advertising, promotions, and to understand customer purchasing behaviour. Please see Section 9: Use of Cookies below regarding Cookies
• Garnetts Electronics DOES NOT store any credit card data. When payments are processed via credit card, Garnetts Electronics uses third-party vendors that are PCI-DSS compliant. At no point does Garnetts Electronics have access to your credit card information. For further information on how we meet industry standards for credit card information security visit https://freewebstore.com/PCI_compliance.html

2.6. Information Others Provide To Us
We may receive information from others that you have authorised that third party to provide to us. This could include the information on whether a payment was paid or declined.

3. How We Use The Information We Collect

3.1. We Use Your Personal Data For legitimate business reasons, for example; email you when your order has been received. It will also enable us to contact you by email, fax, post, SMS, social media or telephone where necessary concerning Garnetts Electronics or an order you have placed; to record your personal preferences; to personalise our services to you (such as by pre-populating fields to make it easier for you to provide information when you return to the Garnetts Electronics store. It will also enable us to produce reports you request as part of the services we provide.

3.2. Improving Garnetts Electronics Ltd 

We will also use and analyse your personal data so that we can provide you with customer service and support about the features of the Garnetts Electronics Website and Garnetts Electronics Ltd generally. We will also use and analyse your personal data so that we can improve and develop our business. We may use third parties to assist us in doing these things from time to time, and in those cases may pass on your personal data to them. We will only share your data with third parties that we trust, and where there are assurances in place as to how they will protect the data.

3.3. Contacting You For Marketing Purposes
We may use your personal data to contact you by email, fax, post, SMS, social media and/or telephone to let you know about our other Garnetts Electronics and/or third-party services, content, offers or product ranges which may be of interest to you. We will only use your data in this way where you have provided consent,

we have legitimate business reasons for doing so, or where we are otherwise entitled by law to do so. If you would like us to stop providing you with such notifications, just contact us using the details in Section “How to Contact Us” at the end of this policy. Please note, this may take up to one working day to take effect. To stop receiving emails from Garnetts Electronics itself, you should unsubscribe from our mailing list or cancel your Garnetts Electronics account.

3.4. Cookies
We may further use, or permit selected third parties to use, your personal data to enable us to track and analyse Garnetts Electronics website traffic and visitor trends, improve your browsing experience and to personalise and enhance the content and advertising we display. For further details, please see Section 8: Use of Cookies below.

3.5. Legal Requirements
We may use your personal data to comply with any legal obligations to which we are subject.

4. Why Do We Use Your Personal Data?

We collect and use your personal data for a variety of reasons. We need some data to enter into and perform our contract with you. The lawful basis for processing your personal data is

Consent as you have consented to provide your personal details to us to allow us to provide a service to you. If you fail to provide such data we will be unable to provide our service to you.

Other information we collect because we have legitimate business interests, for example, in:

• Fulfilling your order and providing updates on the order.
• Understanding how our customers use our products, services and website(s);
• Understanding and responding to customer feedback;
• Researching and analysing the services our customers want;
• Improving our product and better understanding how our customers use it.

5. How We Share Information We Collect

Except as described in this policy, Garnetts Electronics does not divulge any personal information gathered via its services to third parties.

We may share your personal data with third parties in certain circumstances:

• We may disclose your data to any member of our group (which means our subsidiaries or our ultimate holding company);
• in the event that we, our business, or substantially all of its assets are acquired by a third party (in which case personal information about customers will be one of the transferred assets);
• if we are under a duty to disclose or share your personal data in order to comply with any legal obligation; to cooperate with law enforcement officials in the investigation of unlawful activities of Garnetts Electronics website users or relating to Garnetts Electronics users; or in order to enforce or apply any contract with you; or to protect our rights, property, or safety of our employees, customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection or unlawful activity.

We also utilise a number of carefully selected third parties to help provide our services to you. Examples of these functions include website creation and hosting, email, providing marketing assistance and data analysis, data management, handling credit card transactions and providing customer service. In choosing to work with any such third parties, we will always ensure that the security policies and confidentiality arrangements of those third parties adhere to the same requirements we ourselves impose and expect, as a minimum.

No ownership rights to the data will be transferred to any third party.

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA who work for us, one of our group companies or for one of our suppliers. Such staff maybe engaged in, among other things, the processing of your payment details and the provision of support services. By submitting your data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

For a full list of sub processors and details of the adequate safeguards in place in respect of data transfers within and outside the EEA, please see below:

Sub-processors We Use:

Name	Location	Service Provided	Link
freewebstore		eCommerce provider for website design, hosting and data storage.	https://freewebstore.com/privacy.htm
Google		Gmail, email provider Shopping Webmaster Tools Adsense Order Conversion Tracking	https://policies.google.com/privacy?hl=en-GB
Paypal		Payment handler
Meta/Facebook		Messenger Marketplace

We only store your data for as long as necessary for the purposes of processing set out in this policy.

When you cancel your account with Garnetts Electronics you can either delete your customer data immediately, or we will automatically delete your data within 180 days.

To ensure the integrity of our systems and your data, we utilise various technologies to continually take secure, encrypted backups. Data remains archived within these backups and these are maintained according to our defined two-year data retention policy, after which they are removed.

Data Retention Policy

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.

In some circumstances you can ask us to delete your data: see 7.4 Right to 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.

7. How To Access and Control Your Information

You are free to change your personal details in the My Account section of your account at any time, if you have
set up an account with us.
You can also ask us for a copy of your personal data that we hold. We may ask for proof of your identity before 
providing any information and reserve the right to refuse to provide information requested if identity is not established. Please see “Your Individual Rights” below. Generally, we will retain your personal data for a reasonable period, or for as long as the law requires.

If you are signed up to marketing communications, cancelling your Garnetts Electronics account will not cancel your marketing preference. If you would like to unsubscribe, you can do so using the unsubscribe link in the email received. Alternatively, please complete your request on the form available at https://www.garnettselectronics.com/page/contact-us

Your Individual Rights

7.1. Access To Your Personal Data: You can ask us to confirm if we are processing your personal data and you
may request a copy of your personal data by contacting us. See Section “How to Contact Us” at the end of this policy.

7.2. Right To Change or Withdraw Your Consent: Where you have given us consent to make use of your personal data for any of the purposes outlined in this policy, you may withdraw that consent at any time by contacting us using the details located at Section “How to Contact Us” at the end of this policy. If you wish to change your contact preferences or no longer wish to be contacted for marketing purposes, use the unsubscribe link in the email or get in touch. See Section “How to Contact Us” at the end of this policy.

7.3. Right to Rectification: You may ask us to update out of date or inaccurate information we hold about you. To do so, please log on to your Garnetts Electronics account and update your information or get in touch using the details at Section “How to Contact Us” at the end of this policy.

7.4. Right to Erasure: In certain circumstances you may ask us to erase your Personal Data. If you would like us to erase the personal data we hold about you, please get in touch using the details at Section “How to Contact Us” at the end of this policy.

7.5. Right to Data Portability: In certain circumstances you may ask us to provide you with the personal data that we hold about you in a structured, commonly used, machine readable form, or ask for us to send such personal data to another data controller.

7.6. Right to Object: In certain circumstances you may object to our processing of your personal data. Please get in touch using the details at Section “How to Contact Us” at
the end of this policy.

7.7. Right to Restrict Processing: You can ask us to restrict the processing of personal data we hold about you in certain circumstances. Please get in touch using the details at Section “How to Contact Us” at the end of this policy.

7.8. Make a Complaint: You may make a complaint about our data processing activities, please contact us. See Section “How to Contact Us” at the end of this policy.

7.9. Getting In Touch: To make enquiries and/or to exercise any of your rights in this privacy policy please contact us. See “How to Contact Us” at the end of this policy.

8. Use of Cookies

9. Data Security

We take security and privacy seriously. We will endeavour to take all reasonable steps to keep your personal data secure once it has been transferred to our systems. We adopt
appropriate, industry standard data collection, storage and processing practices and security measures to protect against unauthorised access, alteration, disclosure or destruction.

Garnetts Electronics uses a third-party vendor and hosting partner to provide the necessary hardware, software, networking and storage to run its services. This provider has been selected for their high standards of both physical and technological security, including ISO and SSAE16 certifications.

When payments are processed via credit card, Garnetts Electronics uses third-party vendors that are PCI-DSS compliant. At no point does Garnetts Electronics have access to your credit card information. For further information on how we meet industry standards for credit card information security, please see our PCI Compliance page.

You should bear in mind that submission of information over the Internet is never entirely secure. Garnetts Electronics cannot guarantee the security of information you submit whilst in transit over the Internet and any such transmission is at your own risk.

Where we have given you (or where you have chosen) a password which enables you to access certain parts of the Garnetts Electronics Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

10. How to Contact Us

If you have any queries relating to this Privacy Policy or Garnetts Electronics Ltd use of your personal or financial data, please email: garnettselectronicsltd@gmail.com or alternatively write to:
Garnetts Electronics Ltd
124-128 City Road

London

EC1V 2NX

United Kingdom