The purpose of this policy is to explain to you what personal information we collect when you use this website and how we may use that information.
- About us
This website (https://shop.silversurfers.com/) is owned by Silverhairs Limited trading as Silversurfers (“Silversurfers”), a company registered in England no. 8211276, having its registered offices at 10 Queen Street Place, London, EC4R 1AG.
The website is operated on behalf of Silversurfers by D C Thomson & Co Ltd. (“D C Thomson”), a company registered in Scotland no. SC005830, having its registered offices at Courier Buildings, Albert Square, Dundee DD1 9QJ.
Silversurfers is committed to protecting your privacy and maintaining the security of any personal information received from you. We strictly adhere to the requirements of the data protection legislation in the UK, including the General Data Protection Regulation 2016 and the Data Protection Act 2018 and we are registered on the Data Protection Public Register number ZA115899.
- The Data Protection Officer (DPO)
Silversurfers is not currently required to appoint a DPO, but we will be happy to deal with any queries or requests you may have regarding the data we hold about you. We can be contacted using our web form at the following address: https://www.silversurfers.com/contact/ or by writing to us at Data Protection Team, Silverhairs Ltd, 10 Queen Street Place, London, EC4R 1AG.
- Information we collect about you and how we use it
When you register on our website or place an order, we may collect your name, address, email address, contact number and other contact details, order details, payment information and the delivery name and address if different. This allows us to process and manage your registration as well as process your order and provide the goods or service chosen.
We do not collect sensitive information (also known as special categories of information) about you except when you specifically knowingly provide it and have consented to this, e.g. if you have told us about a disability you may have that we should be aware of when your goods or services are delivered.
We do collect some information from cookies and similar software which allows us to understand how you arrive on our websites, and use and navigate round them so we can improve the sites. We obtain some information from google analytics which is anonymous and other social media platforms for example Facebook. The social media information provided is limited and only that which you have previously agreed with them that they can share.
- What we do with your information
We will use your personal information for a number of purposes including:
- To process your orders and provide our services, goods or online content, to provide you with information about them and to deal with your requests and queries.
- For administration purposes, which means we may contact you for reasons related to goods or services ordered or online content you have signed up for, to let you know that a service or online site has been suspended for maintenance, or if an online account has become dormant to ask if you wish to retain the account before we close it.
- To provide personalised communications.
- Where we provide personalised services, we may analyse the information you supply, as well as your activity on our (and other) services, so we can offer a more relevant, tailored service. For example, if you spend time on our website browsing gardening products, we may include gardening products and promotions in any personalised content we send you. You can opt out of any email services at any time by logging into your account or clicking unsubscribe on any received emails.
- If you do not wish to have a personalised service you can unsubscribe from these communications by clicking ‘unsubscribe’ on the relevant e-mail or by contacting us using our web form at the following address: https://www.silversurfers.com/contact/ .
- To show you relevant advertising on third party sites. See section 7 (on marketing)
- A certain amount of advertising is tailored to the individual based on viewing and/or purchase habits. This is a common practice known as online behavioural advertising. You can find out more in What is online behavioural advertising.
- Using IP addresses and device identifiers, to identify the location of users, to establish the number of visits from different countries, to limit/cap adverts of a certain type, personalise content and emails, and allow access to paywall protected content.
- To conduct analysis and research to improve our services and goods offered.
We may use and disclose information in aggregate (so no individuals are identified) for marketing and strategic development purposes.
- What if I don’t provide some or all of the information requested?
The impact of this will depend on what information you withhold but the main impacts may be:
- We may not be able to process or fully process your order.
- We may not be able to contact you to let you know of problems regarding your order or the goods/services provided.
- We may not be able to respond fully to requests and queries you may have.
- We cannot personalise the service you receive. So, if you are online you will have to search more for the content type you normally view or for similar/related products.
- We won’t be able to limit online adverts to products or services you have shown interest in and so you may receive adverts that mean nothing to you and are not related to your interests.
- Will you be contacted for marketing purposes?
We use your personal information to update you about new products/services by post, email and SMS text message. We will only contact you with your consent. You will provide this either when you fill in a form to provide your data, by signing up for a newsletter, selecting your preferences in your online account or when you call us.
If you give your consent as above, we may personalise our message content based on information you provide us with, purchases you make and your use of the Silversurfers shop.
We may use information which we hold about you to show you relevant advertising on third party sites (e.g. Facebook, Google, Instagram, Snapchat and Twitter). This could involve showing you an advertising message where we know you have a Silversurfers shop account and/or have used our products and services. If you don’t want to be shown targeted advertising messages from us, some third party sites allow you to request not to see messages from specific advertisers on that site in future. If you want to stop personalised services from Silversurfers, including targeted advertising messages on third party sites you can do so by contacting us using our web form at the following address: https://www.silversurfers.com/contact/ .
Please note that you are entitled to withhold consent and opt out from receiving such communications at any time. You can do this by not giving your consent on the form (paper or web) that collects your details or by telling the operator when you call. You can also update these options by logging into your account (if you have one) and adjusting your preferences, contacting us using our web form at the following address: https://www.silversurfers.com/contact/ or by writing to us at: Data Protection Team, Silverhairs Ltd, Lychgate House, Holmbury St Mary, Dorking, Surrey, RH5 6PB. Please use 10 Queen Street Place, London, EC4R 1AG
We will always provide you with a way of opting out of receiving future marketing messages from us, each time we send them to you.
- What grounds (legal basis) are we processing your information under?
We have a number of grounds, or legal bases, on which to process your personal information. These are:
- Contractual – we need the information to perform the contract for goods or services you have requested/ordered including payment, delivery etc.
- Legal – should we be legally required to contact you concerning a product e.g. a product recall.
- Legitimate interest – this means we have a legitimate, reasonable business purpose for carrying out the processing, for example it enables us to manage the customer relationship effectively and efficiently and improve the goods and/or services we provide by better understanding how our online provisions are used and which goods are popular with which groups of individuals.
- Consent – where you have given us consent to market to you.
- Sharing your information with third parties
We share your personal information with D C Thomson, who operate this website for us, to allow them to carry out the following functions/processes on our behalf:
- Collecting your order information.
- Carrying out the administrative processes to ensure payments are properly processed and that you receive the goods and/or services ordered.
- Providing a customer support service in relation to your orders.
- Sending you, where you have consented, promotional information and marketing in relation to the Silversurfers online shop.
- Maintaining a record of marketing consent and associated opt-out and unsubscribes.
- Conducting occasional surveys and requesting feedback about our website and the products and services we offer.
D C Thomson may from time to time provide your personal information to third parties for the purposes of providing you with our goods and services. These third party providers include payment processors, providers of card validation services, credit referencing providers, third party sales processor (includes fulfilment services) and service providers who assist us with hosting our marketing campaigns. They do not decide what is done with your data and only process it on our behalf. These third parties may be located outside the European Economic Area (EEA); however we only use providers that provide adequate protection for your information at all times.
When transferring any personal information outside the EEA we only do so under one of the legally recognised transfer mechanisms for ensuring the data is safeguarded. These are:
- The country in question has been deemed safe for data transfer by the European Commission. Also known as an adequacy finding.
- The contract for data processing contains the standard contractual clauses laid down by the European Commission to safeguard the transfer of personal data.
- Binding corporate rules – this is where a large company’s own internal processes for international data transfer have been signed-off and agreed by the European Commission as safeguarding the data.
- Appropriate certification schemes
We will not provide your data to other third parties for marketing purposes unless you have specifically consented to this when you first provided your data to us. You are entitled to withhold this consent and opt out from receiving such third party communications at any time by not giving your consent on the form (paper or web) that collects your details or telling the operator when you call. You can also update these options by logging into your account and adjusting your preferences, contacting us using our web form at the following address: https://www.silversurfers.com/contact/ or by writing to us at: Data Protection Team, Please use 10 Queen Street Place, London, EC4R 1AG
Lychgate House, Holmbury St Mary, Dorking, Surrey, RH5 6PB. .
- Cookies and web browser information
Currently we do not have the ability to react to ‘do not track’ being set in the browser, if you wish to opt out of tracking we suggest downloading an ad-blocking technology such as Ghostery.
- What if I am aged under 16?
If you are aged 16 or under, please get your parent/guardian's permission before you provide any personal information to Silversurfers as this website is not aimed at under 16s.
- How we protect your information
We follow strict security procedures in the storage, use and disclosure of information which you have given us, to prevent unauthorised access to, and loss, misuse or alteration of your personal information in accordance with the UK data protection legislation. These include access control, firewalls and virus checking procedures.
You are responsible for keeping any confidential passwords or other login or access details which you select or which we allocate to you secret. Whilst we take steps to ensure the security of your information, there is a risk that any information transmitted over the Internet and stored on a computer may be intercepted or accessed by an unauthorised party. If you think that someone has accessed your information held by us without your permission or gained unauthorised access to your login details, you must notify us promptly using our web form at the following address: https://www.silversurfers.com/contact/ .
We also recommend that if you use a shared computer or a computer in a public place such as a library that you close your browser when you have finished you session.
- How long we hold your information for
Some of the personal information you provide to us is necessary to carry out repeated tasks, such as verifying your identity when signing in to use an account or providing our goods and services to you or you using an online checkout. We will keep this information for as long as you remain a registered user of any of our sites or an active customer plus a reasonable time (approximately 36 months) beyond this to deal with queries or issues.
Some information may be required for longer periods such as financial information for HMRC purposes, usually a maximum of 7 years.
Neither Silversurfers nor D C Thomson retain your payment card information. It is keyed directly into the payment processor’s system when you provide it.
We may retain anonymised information for analytical purposes.
- Your rights regarding your information
Under the Data Protection law you have a number of rights with respect to your personal information which are:
- Correcting your information
You are entitled to have your personal information updated to ensure it is up-to-date and accurate. This can be done by following the instructions below.
You have the right to withdraw your consent to any processing that is currently being done on the basis that you have consented to it, e.g. marketing. Consent can be withdrawn for some processing by updating your preferences in your online account. You can also follow the process below.
- Obtaining a copy of your information
You are entitled to receive a copy of the personal information we hold about you.
- Deleting your information
You can request that we delete personal information in certain circumstances. These will be specific to each case.
You are entitled to have us transfer to another controller the personal information that you have provided us with.
You can request a restriction on the processing of your data in some limited circumstances. Examples are if you have concerns over data accuracy or if we no longer require to hold your data, but you want us not to delete it so you can use it to help you in a legal matter.
- Right to object to processing
You are entitled to request that we stop processing your data for marketing purposes and in other limited circumstances such as asking us not to process your data by wholly automated means or not to analyse your information for targeted content etc (also known as profiling).
You can action any of these rights by contacting us using our web form at the following address:
- Sale of the Business
All of your personal information that we collect may be transferred to a third party if we undergo a merger, acquisition, insolvency or other transaction in which that third party assumes control of our business (in whole or in part). Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.
- Right of complaint to the Regulator for Data Protection
The data protection laws in the UK are enforced by the Information Commissioner’s Office (ICO). Each individual has the right to raise a concern/complaint to the ICO if they have any concerns about how their personal information and/or privacy is treated. You can do this by:
Visiting the ICO’s website (https://ico.org.uk/concerns) and selecting the ‘live chat’ option;
Calling the ICO helpline on 0303 123 1113;
Emailing firstname.lastname@example.org; or
Writing to: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
- Links to third party websites
- Updates to this policy
We may update this Policy at any time without notice. We will tell you that we have updated the policy by emailing you at the email address you have provided to us and/or by posting an announcement on the website. By continuing to use the website after we have emailed you or posted a notice informing you of an update, you accept the changes to this Policy.
- Contacting us
If you have any questions about privacy, or wish to update your details or action any of your other data rights at any time, please contact us using our web form at the following address: https://www.silversurfers.com/contact/