This policy is intended to provide information about how Tower Supplies will use (or “process”) personal data about individuals including: its staff (and prospective staff); users of its digital services; its customers (including prospective customers), and the employees of its customers; its suppliers (including prospective suppliers), and the employees of its suppliers.
This Privacy Notice applies alongside any other information that Tower Supplies may provide about its use of personal data, for example when collecting data via an online or paper form.
This Privacy Notice also applies in addition to Tower Supplies’ other relevant terms and conditions and policies, including:
Tower Supplies Terms of Trading;
any contract between Tower Supplies and its staff or customers;
the Tower Supplies’ CCTV policy;
the Tower Supplies’ retention of records policy;
as to how concerns or incidents are recorded;
the Tower Supplies’ IT policies; and
the Tower Supplies’ health and safety policies, including:
Anyone who works for, or acts on behalf of, the Tower Supplies (including staff, work experience and service providers) should also be aware of and comply with this Privacy Notice and the Tower Supplies Data Protection Policy for staff, which also provides further information about how personal data about those individuals will be used.
This privacy notice aims to explain:
Why Tower Supplies needs to process personal data
To carry out its ordinary duties to staff and customers, Tower Supplies needs to process a range of personal data about individuals as part of its daily operations.
Some of this activity Tower Supplies will need to carry out to fulfil its legal rights, duties or obligations – including those under a contract with its staff, or customers.
Other uses of personal data will be made in accordance with Tower Supplies’ legitimate interests, provided that these are not outweighed by the impact on individuals and provided it does not involve special category or sensitive types of data.
The types of personal data we collect and process
This may include the following categories, by way of example:
How Tower Supplies collects data
Generally, Tower Supplies receives personal data from the individual directly. This may be via a sales order, an account application form, correspondence, submission of a CV or simply in the ordinary course of interaction or communication, including use of digital services.
However, in some cases personal data will be supplied by third parties (for example via a business customer providing personal data of an employee to fulfil an order, or from an agency with whom an individual has provided data for the purposes of seeking employment).
The legal basis of our use of your personal data
Tower Supplies identifies that personal data is used under the following legal bases:
On the basis of fulfilling our contractual obligations:
On the basis of its legitimate interests:
On the basis of meeting our legal or regulatory obligations:
On the basis of consent:
Where Tower Supplies is relying on consent as a means to process personal data, any person may withdraw this consent at any time.
In addition, Tower Supplies will on occasion need to process special category personal data (e.g. concerning health, ethnicity, religion, biometrics or gender) or criminal records information (such as when carrying out DBS checks) in accordance with rights or duties imposed on it by law, or from time to time by explicit consent where required. These reasons will include:
On The basis of Vital Interests:
Disclosure of your details to others
Occasionally, Tower Supplies will need to share personal information relating to its operations with third parties, such as:
For the most part, personal data collected by Tower Supplies will remain within the business and will be processed by appropriate individuals only in accordance with access protocols (i.e. on a ‘need to know’ basis). Particularly strict rules of access apply in the context of medical records held and accessed only by the HR Manager or otherwise only with the express consent of the individual.
Finally, in accordance with Data Protection Law, some of the Tower Supplies’ processing activity is carried out on its behalf by third parties, such as IT support providers, web developers or cloud storage and other digital service providers. This is always subject to contractual assurances that personal data will be kept securely and only in accordance with the Tower Supplies’ specific directions.
How long we will keep your information for?
Tower Supplies will retain personal data securely and only in line with how long it is necessary to keep for a legitimate and lawful reason. Typically, the legal recommendation for how long to keep ordinary staff personnel files is up to 7 years following departure from the business. However, incident reports and safeguarding files will need to be kept much longer, in accordance with specific legal requirements.
We have defined retention periods for different categories of personnel data according to these principles and this information is held in the Tower Supplies Retention Policy.
Individuals have various rights under Data Protection Law to access and understand personal data about them held by Tower Supplies, and in some cases ask for it to be erased or amended or have it transferred to others, or for Tower Supplies to stop processing it – but subject to certain exemptions and limitations.
Any individual wishing to access or amend their personal data, or wishing it to be transferred to another person or organisation, or who has some other objection to how their personal data is used, should put their request in writing (see ‘Contact us’ section below).
Tower Supplies will endeavour to respond to any such written requests as soon as is reasonably practicable and in any event within statutory time-limits (which is one month in the case of requests for access to information).
Tower Supplies will be better able to respond quickly to smaller, targeted requests for information. If the request for information is manifestly excessive or similar to previous requests, Tower Supplies may ask you to reconsider, or require a proportionate fee (where Data Protection Law allows it).
The right of access is limited to your own personal data, and certain data is exempt from the right of access. This will include information which identifies other individuals, or information which is subject to legal privilege (for example legal advice given to or sought by Tower Supplies, or documents prepared in connection with a legal action).
The rights under Data Protection Law belong to the individual to whom the data relates.
When someone visits our websites, we collect standard internet log information and details of visitor behaviour patterns. This is to allow us to monitor user behaviour and visit rates. This information is anonymous. Where we gather personal information, this will be made clear.
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.
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.
Where we link to third party websites, they will have their own privacy and cookies policies and it is your responsibility to review these. We cannot accept any responsibility or liability for the policies of third party websites.
How we protect your data
We conduct information processing in a manner that ensures appropriate security of personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical and organisational measures.
Your acceptance of these terms
Through engaging with Tower Supplies, you signify your acceptance of this policy. Your continued engagement following a change to this policy will be deemed your acceptance of those changes.
How to contact us
If you have any questions about this privacy notice or our treatment of your personal
data, including withdrawal of previously given consent, please write to us by email or by letter to this address:
Data Projection, Tower Supplies, 3 Yarrow Road, Poole, Dorset. BH12 4TS
The table below lists the cookies we collect and what information they store.
|COOKIE name||COOKIE Description|
|CART||The association with your shopping cart.|
|CATEGORY_INFO||Stores the category info on the page, that allows to display pages more quickly.|
|COMPARE||The items that you have in the Compare Products list.|
|CURRENCY||Your preferred currency|
|CUSTOMER||An encrypted version of your customer id with the store.|
|CUSTOMER_AUTH||An indicator if you are currently logged into the store.|
|CUSTOMER_INFO||An encrypted version of the customer group you belong to.|
|CUSTOMER_SEGMENT_IDS||Stores the Customer Segment ID|
|EXTERNAL_NO_CACHE||A flag, which indicates whether caching is disabled or not.|
|FRONTEND||You sesssion ID on the server.|
|GUEST-VIEW||Allows guests to edit their orders.|
|LAST_CATEGORY||The last category you visited.|
|LAST_PRODUCT||The most recent product you have viewed.|
|NEWMESSAGE||Indicates whether a new message has been received.|
|NO_CACHE||Indicates whether it is allowed to use cache.|
|PERSISTENT_SHOPPING_CART||A link to information about your cart and viewing history if you have asked the site.|
|POLL||The ID of any polls you have recently voted in.|
|POLLN||Information on what polls you have voted on.|
|RECENTLYCOMPARED||The items that you have recently compared.|
|STF||Information on products you have emailed to friends.|
|STORE||The store view or language you have selected.|
|VIEWED_PRODUCT_IDS||The products that you have recently viewed.|
|WISHLIST||An encrypted list of products added to your Wishlist.|
|WISHLIST_CNT||The number of items in your Wishlist.|