WHO WE ARE
We are a partnership known as Innova Mill t/a Adventa (“we”). My Moments is our brand.
We are committed to protecting and respecting your privacy.
This policy (together with our Terms and Conditions [insert link] and any other documents referred to in it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Personal data means information about a living individual, and does not apply to information we hold about limited companies or other corporate bodies, unless such information identifies a living individual. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.
We act as data controller in respect of your personal data and we are responsible for your personal data. You can contact us by email to firstname.lastname@example.org, by telephone on 01686 625100 or by writing to us at Adventa, 83 Mochdre Industrial Park, Newtown, SY16 4LE.
PERSONAL DATA WE MAY COLLECT
The personal data we may hold about you primarily falls into two categories: personal data collected from you during your use of our website my-moments.com (Website) and personal data collected during the course of any business relationship we have with you or your employer/business.
The table below sets out personal data you or your employer/business may give to us, personal data we may collect from you and personal data we may receive from other sources. In each case, such personal data may include personal or business contact details but we treat both of these with the same level of privacy were necessary.
|Personal data you or your employer/business may give to us:
||(1) your name, email address, phone number and address when you submit an enquiry to us by our Website, by email, by phone or using any of our social media sites or when you report a problem with our Website.
(2) your name, phone number, address, email address, role/job title provided during the course of our business relationship with you or your employer/business including when you complete account opening and other forms whether in writing or on our Website. In the case of sole trader and partnership customers, this will include payment details which may contain personal data.
(3) your name, email address and other personal data required when you enter into a competition or promotion sponsored by us or complete a survey for research purposes.
|Personal data we may collect from you:
||technical information, including your internet protocol (IP) address, operating system and browser type in relation to the devices you use to access our Website.
|Personal data we may receive from other sources
||(1) if you engage with us on social media, we may receive your name and other profile information that you make publicly available.
(2) we may receive information about you from credit reference agencies if we request a credit check as part of your commercial relationship with us (or that or your employer/business).
(3) we may receive information about you from analytics providers and search information providers.
PERSONAL DATASTORAGE AND SECURITY
The personal data that we hold will be securely stored by us in the UK. None of your details will be sold to third parties.
We have put in place adequate security measures to prevent your personal data from being accidentally lost, used, accessed in an unauthorised way, altered or disclosed. All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using appropriate technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Website; any transmission is at your own risk.
Our Website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
We may monitor or record telephone calls for security purposes and to improve the quality of services that we provide to you. We will let you know if we are recording a call.
USES MADE OF THE INFORMATION
We will only use your personal data when the law allows us to. The table below sets out how we may use the personal data we hold about you and our lawful basis for such use.
||Use of Personal Data
|Name, email address, address and phone number provided to us when you contact us with any queries, including reporting a problem with our Website:
||To deal with and respond to your query.
To the extent that your query leads to us having a commercial relationship with you or your employer/business, we will use such personal data to supply our products and services to you (or your employer/business).
|To carry out our contract or potential contract with you (or your employer/business).
|Name, phone number, address, email address and role/job title:
||To carry out our commercial relationship and supply our products and services to you or your employer/business.
||To carry out our contract with you (or your employer/business).
|Name and email address:
||To send you regular email communications about the products, events, competitions and services we offer by email and to ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
||Where your employer/business is a corporate entity, including private limited companies, necessary for our legitimate interests (of promoting our products, events and services to our valued customers and keeping our customers up to date with our latest activities).
Where you have confirmed to us that you or your employer/business is a sole trader or partnership, we will only send you such communications with your consent.
|Technical information, including your internet protocol (IP) address, operating system and browser type:
||To administer and protect our Website (including troubleshooting, data analysis, testing, system administration and maintenance, support, reporting and hosting of data), to improve our Website and to deliver appropriate and effective content to you on our Website.
||Necessary for our legitimate interests (of keeping our Website up to date and relevant, developing our business and informing our marketing strategy).
|Name and other profile information from your social media profile:
||To respond to any communication you make with us via our social media accounts.
||To carry out our contract or potential contract with you (or your employer/business).
|Information about you from credit reference agencies:
||To determine our ability to carry out a commercial contract with you or your employer/business, supply our products and services to you or your employer/business and manage our payment risks.
||Necessary for our legitimate interests (to ensure prompt payment of amounts due to us).
|Information about you from analytics providers and search information providers:
||To improve our Website and deliver effective content to you.
||Necessary for our legitimate interests (to receive further information about our customers and potential customers, improve our Website and develop our marketing and business strategy).
|Name and email address and/or phone number:
||To support small potential customers by sending them contact details of our suppliers/distributors to deal with directly.
To support different customers in the same territories by making recommendations and sending them contact details.
|Necessary for our legitimate interests (of building and maintaining customer and supplier relationships).
DISCLOSURE OF YOUR PERSONAL DATA
We may share your personal data with selected third parties including the following:
- Our email platform, website host, order management system provider and other IT and service providers.
- Mailchimp (The Rocket Science Group LLC) or any other similar provider who may store our mailing databases and send communications on our behalf.
- Any marketing and website agencies or freelancers we may engage from time to time who may in turn use Mailchimp to send communications on our behalf as mentioned above.
- Our product delivery agents.
- Our payment processors and credit reference agencies.
- Our professional advisers, including lawyers, accountants and insurers, as required by them from time to time to enable them to effectively advise us.
- Any company within our group of companies (but we will not transfer any personal data we collect from individuals within the European Economic Area to any destination outside of the European Economic Area).
We may also disclose your personal data to third parties where required:
- In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
- If Adventa or substantially all of its assets are acquired by a third party, in which case personal data held by it about its 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, or in order to enforce or apply our Terms & Conditions and other agreements; or to protect the rights, property, or safety of Adventa, our customers, or others.
- To HM Revenue & Customs, regulatory and other authorities who require this information for any purpose.
We may exchange information with other companies and organizations for the purposes of fraud protection and credit risk reduction. If we search your record at the credit reference agencies, they will add to your record details of our search and your application for credit and this will be seen by other organizations that make searches. Information held about you by the credit reference agencies may already be linked to records relating to one or more of your partners. For the purposes of this application you may be treated as financially linked and your application will be assessed with reference to “associated” records.
If you are a joint applicant or if you have told us of some other financial association with another person, you must be sure that you are entitled to:
- disclose information about your joint applicant and anyone referred to by you;
- authorise us to search, link or record information at credit reference agencies about you or anyone referred by you.
An “association” between joint applicants and between you and anyone you tell us is your financial partner will be created at credit reference agencies. This will link your financial records, each of which will be taken into account in all future applications by either or both of you. This will continue until one of you successfully files a disassociation at credit reference agencies.
We may use a credit scoring system when assessing your application.
We may also add to your record with the credit reference agencies details of your registration with us, the orders you make and any payments you make under them and any default or failure to keep to the Terms & Conditions. It is important that you give us accurate information. We will check your details with fraud prevention agencies and if you give us false or inaccurate information and we suspect fraud, we will record this.
These records will be shared with other organisations and used by us and them to help make decisions about credit and credit related services such as insurance for you and members of your household.
For these purposes we or they may make further searches. Although these searches will be added to your record, they will not be shared with others.
Please contact us if you want to have details of those credit reference and fraud prevention agencies from whom we obtain and to whom we pass information about you. You have a legal right to these details.
Mailchimp (referred to above) is located in the United States. Mailchimp participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework and is committed to protecting your personal information.
HOW LONG WE STORE YOUR PERSONAL DATA
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.
Details of retention periods for your personal data are set out below:
- We will keep information you provide to us when you contact us in respect of a query (in cases where we do not have a business relationship with you or your employer/business) for [12 months] following the date on which we finish dealing with your query.
- We will keep information you provide to us to enable us to supply our products and services to you or your employer/business for the period during which we supply our products and services and for a period of up to [six years]
- We will only keep personal payment details where you request the same to be stored by us for future orders in which case they will be kept until you request these to be deleted or, if later when you close your account with us.
- We will keep technical information collected about you for [one month].
- We do not retain (other than within our own social media profile) or export to our system any personal data we obtain from your social media profile for any purpose
- We will keep information we obtain from credit reference agencies for [3 months] following collection unless you (or your employer/business) become(s) our customer in which case we may retain such information for such time as we are a party to a contract with you (or your company) and [3 months] thereafter.
Where we send you email marketing communications as a sole trader or partnership customer on the lawful basis of “consent” (please refer to the above table), you are able to withdraw your consent to such processing at any time by either contacting us at email@example.com or by following the “opt-out/unsubscribe” option in any email marketing communication sent to you.
Where we send you email marketing communications as a corporate entity customer on the lawful basis of our legitimate interests (please refer to table above) we will send you these marketing communications by email unless you tell us that you do not want to continue receiving these messages by contacting us at firstname.lastname@example.org or by following the “opt out/unsubscribe” option in any marketing communications we send to you.
You have rights under data protection laws in relation to the personal data we hold about you, including the following:
- a right of access to a copy of such data;
- a right to object to processing on the basis of our legitimate interests that is likely to cause or is causing you damage or distress;
- a right to object to processing for direct marketing;
- a right in certain circumstances to have inaccurate personal data rectified, blocked or destroyed;
- a right to request that we restrict our processing of your personal data in certain circumstances;
- a right in certain circumstances to request that your personal data be transferred to you or another provider; and
- a right to request erasure of the personal data we hold about you.
If you wish to exercise any of these rights, please contact us using the details set out below.
You also have the right to make a complaint to your data protection regulator (in the UK, this will be the Information Commissioner’s Office (ICO)( www.ico.org.uk ). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us first before escalating your complaint.
It is important that the personal data we hold about you is accurate and current so please let us know (using the contact details above) if your personal data changes during your relationship with us. We may also contact you by phone to update our customer records to make sure the personal data we hold is accurate and current.
We may obtain information about your general internet usage by using a cookie file which is stored on the hard drive of your computer. Cookies contain information that is transferred to your computer’s hard drive. They help us to improve our website and to deliver a better and more personalised service. They enable us:
- To estimate our audience size and usage pattern
- To store information about your preferences, and so allow us to customise our Website according to your individual interests
- To speed up your searches
- To recognise you when you return to our Website.
[INSERT COOKIES TABLE]
Advent also use Google Analytics to help analyses the usage of our Website. Google Analytics uses “cookie” technology as described above and the information generated (including the IP address) will be transmitted to and stored on Google servers within the United States. This information is then used to evaluate visitors’ usage of the Website and to compile statistical reports on Website activity for Adventa.
Google Analytics may also transfer this information to third parties where:
- they are required to do so by law.
- third parties process the information on Google’s behalf
Google Analytics will not associate your IP address with any other data held by Google
Adventa will not (and will not allow any third party) use Google Analytics to track or collect any personally identifiable information of visitors to our Website. We will not associate any data gathered from this site with any personally identifiable information from any other source as part of our use of Google Analytics.
By using our Website you consent to the processing of data about you by Google Analytics in the manner and for the purposes set out above. Neither Advent nor Google Analytics will link, or seek to link an IP address with the identity of a computer user.
For more information on Google Analytics, please see the official Google Analytics web page.