Privacy Policy (United Kingdom)

Blue Seal Privacy & Cookies Policy 1 March 2017


We, Blue Seal Limited (a company registered in England and Wales with registration number 343726 and registered address Unit 67 Gravelly Industrial Park, Erdington, Birmingham, West Midlands, B24 8TQ) are committed to compliance with our obligations under the Data Protection Act 1998 which is relevant in the UK and the Data Protection Acts 1988 and 2003 (as amended) which are relevant in the Republic of Ireland.

Please take a moment to read this Privacy and Cookies Policy as its purpose is to set out our information handling practices and to explain how Blue Seal Limited uses, discloses, transfers and otherwise processes your personal data collected through your use of the website at www.blue-seal.co.uk (the “Website”), and how we use cookies in the operation of the Website.  Except where otherwise indicated, all references in this Policy to “we”, “our” and “us” means Blue Seal Limited. 
We are a data controller of your personal data (as detailed below) which is collected through the Website and we process it to fulfil orders placed through the Website (including the sales platform on the Website). As a data controller, we maintain a notification of our data processing activities with the Information Commissioner’s Office (ICO) (www.ico.org.uk).  [Our ICO registration number is A8128824. Users of this website in the Republic of Ireland please note, as a data controller, we maintain a notification of our data processing activities with the Office of the Data Protection Commissioner (ODPC) (www.dataprotection.ie).

1. What personal data we collect from you


For the purpose of this Privacy and Cookies Policy, "personal data" is data which relates to a living individual who can be identified from the data or from that data and other information which is in the possession of, or likely to come into the possession of, Blue Seal Limited (as data controller).

The type of personal data collected by us may differ depending on the information you provide to us when you place an order or submit an enquiry through the Website. The type of personal data we may collect includes (but is not limited to):
  • your title, forename and surname;
  • your personal or work related e-mail address (depending on which you choose to submit and on whether you are a consumer customer or representative of a business customer) and your password (which enable us to create a user account and your unique customer ID);
  • your other personal or work related contact details (depending on which you choose to submit) such as your fax numbers, postal address and telephone number(s) (including mobile number(s)) (in addition to your e-mail address mentioned above);
  • your payment card details (in respect of any purchase you make through the Website).

If applicable, in particular if you are a business customer, we may also require details of your company's registration number, financial information including bank account and credit card details, profit and loss statements, balance sheets, your employer details and your occupation.

Furthermore, when you visit the Website, we may make a record of your visit. The following standard information may be logged and used for the statistical purposes and to help us improve the operation of the Website:
  • your internet protocol (IP) address (which in certain circumstances may constitute your personal data);;
  • the date and time of your visit to our Website;
  • the pages that you have accessed or downloaded on or from our Website; and
  • the type of operating system and browser you are using to access the Website.

Our collection of this type of information may also involve the use of cookies. Please refer to the Cookies section below for more information. 

2. For what purposes do we collect and otherwise process your personal data through the Website?


The personal data we collect is what is required for us to be able to provide you with our products and services, to manage and administer the product and service and for incidental purposes such as the prevention of fraud. In addition, we may use your personal data for the following more general purposes:
  • providing quality assurance for our products and services;
  • responding to your enquiries and feedback regarding our business, our products and our services;
  • monitoring the performance of our business, including but not limited to how quickly and efficiently orders via the Website are processed ;
  • enforcing the terms and conditions of sale/supply with you;
  • the management of our database(s);
  • to analyze trends and customer journeys when using the Website;
  • to administer the Website;
  • for internal record keeping;
  • to contact you by fax, post, e-mail or phone for any of the above reasons;
  • subject to your prior consent, to carry out direct marketing including to send you marketing communications (further information below);
  • to notify you of changes in information about and updates concerning the Website;
  • to process payments which you make through the Website,
  • where necessary, as part of any restructuring or sale of the our respective businesses or assets; and
  • For compliance with our legal, regulatory and other good governance obligations.

This list is not intended to be exhaustive and may be updated from time to time as business needs and legal requirements dictate. Some of the personal data that we maintain will be kept in paper files, while other personal data will be included in computerized files and electronic databases.

In addition, we may use your personal information as necessary for the exercise of our legitimate business interests and needs (subject to data protection laws).

You can if you wish use this Website for “information only” i.e. without placing orders, making payments or submitting queries to us.  However, where you do not wish to provide us with your personal data, we may not be able to provide you with requested products or services or responses to your enquiries.  However, where it is unnecessary to collect personal data for the purposes of certain activities (for example when taking a survey), you have the option of not identifying yourself or using a pseudonym. 

We will collect your personal data in a fair and lawful manner, and not in an unreasonably intrusive way. All personal data that is collected via the Website will be transferred to and stored on our electronic server (which is located in Australia, where our parent company Moffat Group Pty Ltd is located – see below for further details on data transfers outside the EEA, in internal computers and in hard copy files.  This transfer includes but is not limited to the transfer of a record of what you have purchased, for the purpose of providing the goods purchased.

Where practical, we collect personal data directly from you (when you make an order or submit an enquiry). However, there may be circumstances in which we collect personal data about you from publically available sources.

We destroy or permanently anonymise your personal data (which means we are no longer able to identify you from it) when it is no longer necessary for its purpose and we are not required by law to keep it.  In addition, we may convert your personal data into anonymous form and use it (normally on an aggregated statistical basis) for research and analysis purposes, such as to improve the content on the Website.

3. How do we collect your personal data in connection with this Website?


We will collect your personal data in a number of ways including:
  • from you when you provide us with this information by telephone or by completing an online purchase, enquiry, or when you send us an email,  submit application forms, complete customer service satisfaction surveys, or supply it in relation to contracts or any other documents provided by you to us;
  • from publicly available sources of information; and
  • from our own records.


4. Cookies

4.1 What are cookies?

Cookies are text files that are stored on your computer, smartphone or other electronic Internet-enabled device when you first access the Website and when you revisit certain pages of the Website. 

4.2 How do we use cookies?

Some of the cookies we use help us to identify and fix errors relating to the Website, while others remember the pages and products you look at when you first visited the Website – to improve your experience of using the Website.

We use cookies to track how you use the Website by providing usage statistics. Whilst this information on its own does not usually constitute your personal data, we may combine the information we collect by cookies with personal data that we have collected from you in order to learn more about how you use the  Website and to improve the Website.  In addition, we use cookies on this Website to record your default language and currency (English and GBP).  Users of this website in Republic of Ireland please note, we use cookies on this Website to record your default language and currency (English and EUR). A full list of cookies and how we use them can be found below in the section “Cookies we use”.  We may update this list from time to time.  As mentioned, steps will be taken to draw this to the user’s attention and to collect appropriate new consents at that time, where necessary.

4.3 How to control and delete cookies

When you use the Website you will be using a browser and this means that you can control, block or restrict cookies through your browser settings. Information on how to do this can be found within the Help section of your browser. All cookies are browser specific. Therefore, if you use multiple browsers or devices to access websites, you will need to manage your cookie preferences across all of these elements.

There are also several online resources that can give you more information on cookies and how you can control them within a variety of different web browsers. You can visit either http://www.aboutcookies.org or http://www.allaboutcookies.org for more information.

If you are using a mobile device to access the Website, you will need to refer to your instruction manual or other help/settings resource in order to find out how you can control cookies on your particular device.

Please note: if you restrict or delete cookies, you may experience a loss of functionality while accessing the Website and you will be treated as a first time visitor the next time you visit the Website.

4.4 Cookies we use

We  use  session  cookies   (which  expire  once  you  close  your  web  browser).  We may also use persistent cookies (these remain on your computer or other device when you close your web browser – until such time as they expire or you delete them).

We have grouped our cookies into the following categories, to make it easier for you to understand why we use them:
  • Strictly Necessary: these cookies are strictly necessary for the Website to work properly and for us to keep to seek it secure. They are needed to allow you to use the Website and its features, including to provide your user login details and password and to move between pages of the Website.
  •  
  • Functionality: these cookies enable technical performance of the Website and allow us to ‘remember’ the choices you make and your preferences.  They allow us to give a better online experience, such as to make the login process faster by ‘remembering you’ or your user name when you next access the Website.  They also help us to track performance of the Website. 
  •  
  • Performance/Analytical:  these cookies allow us to collect certain information about how you navigate the Website.  They help us to understand which parts of the Website are interesting to you and which are not as well as what we can do to improve the Website.  They also help us to identify when lots of people give up on an application process at a particular step – so we can try to make that step easier to use.

Cookie is set byNamePurpose
Google Analytics_utma
_utmb
_utmc
_utmv
_utmz
These cookies are used to collect information about how visitors use our Website. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited.

Click here for an overview of privacy at Google.

[COMPANY NAME]
[Blue Seal Limited] OR
[Our parent company Moffat Group Pty Ltd]

PHPSESSID

We use this cookie to keep track of any information you have entered and selections you make during your current browsing session.  Expiry: When your current browsing session ends. 

[COMPANY NAME]
[Blue Seal Limited] OR
[Our parent company Moffat Group Pty Ltd]

Currency

We use this cookie to show you product prices in your preferred currency.  Expiry: 30 days.

[COMPANY NAME]
[Blue Seal Limited] OR
[Our parent company Moffat Group Pty Ltd]

Language

We use this cookie to show you content in your preferred language.  Expiry: 30 days.

4.5 Cookies set by third parties

You might notice that some cookies on the Website are not related to Blue Seal Limited (i.e. the company which operates the Website).  This is because some of the pages on our site contain embedded content from third party websites – such as video from YouTube for example.  Because this content is from another website, we don’t control the cookies which relate to this.  If you want to change your cookie preferences to block these third party cookies, check the third party websites for information on how to manage their cookies.

4.6 Social Sharing

We may also embed social sharing icons throughout the Website. These sharing options are designed to enable users to easily share our content with their friends using a variety of different social networks. These social sharing sites may set a cookie when you are logged into their service. Please note that we do not control the dissemination of these cookies and you should consult the relevant third party website for information on how these cookies are used and how you can control them.

5. Do we share your personal data with third parties?


We will share your personal data with other companies within our corporate group, to third party organisations who are our service providers (or who provide services to our corporate group) including but not limited to providers of management, accounting, legal, logistics, audit, compliance, information technology, third party payment processors, and other services, for the purposes mentioned above and where this is permitted by applicable data protection law.  These companies may use information about you to perform functions on our behalf.

We may disclose specific personal data about you upon lawful request by the HMRC, government authorities, law enforcement and regulatory authorities where required or permitted by law.  Users of this website in the Republic of Ireland please note, we may disclose specific personal data about you upon lawful request by the Office of the Revenue Commissioner, government authorities, law enforcement and regulatory authorities where required or permitted by law. Personal data may also be released to external parties in response to legal process, and when required to comply with applicable laws and regulations, or to enforce our agreements, corporate policies, and terms of use, or to protect the rights, property or safety of our businesses, our employees, agents, customers, and others.  Your personal data may also be shared with parties to whom you authorize us to release it.

Please note the payment card details submitted through the Website are not stored by us on any of our systems.  Instead this information is handled and managed by a third party payment processor.  As indicated, your payment card details will necessarily be processed by that third party for the purpose of effecting your payment(s) to us. 

Normally we will not disclose your personal data to third parties unless:
  • you have previously consented or agreed to such disclosure;
  • it is necessary to provide you with the goods and services requested and such disclosure is made on a confidential basis;
  • it is required by law or required for co-operation with any government authority; and
  • it is necessary for any of the purpose mentioned above.

We will not sell, rent or trade your personal data without your prior consent where that consent is required by law.  We may, however, disclose it to purchasers as part of a restructuring or sale of our businesses or assets.

We, and our agents, will only use and disclose your personal data in accordance with our purposes listed above and as permitted by the Data Protection Act 1998 which is relevant in the UK and the Data Protection Acts 1988 and 2003 (as amended) which are relevant in the Republic of Ireland.

6. Will your personal data be transferred abroad?


We have described above how your personal data may be disclosed outside of Blue Seal Limited.  Pursuant to this, including for instance where we engage providers of services and/or where companies within our corporate group provide services to us (for example, hosting databases containing your personal data), your personal data may be transferred to countries or territories located outside of the European Economic Area (EEA) which do not have adequate protection for personal data.  Steps will be taken with a view to protecting your personal data in that instance consistent with applicable data protection law.

Please note that, as detailed at paragraph 2 above, all personal data collected via the Website (including but not limited to a record of what you have purchased and for the purpose of providing the goods purchased) will be transferred to and stored on our electronic server (which is located in Australia, where our parent company Moffat Group Pty Ltd is located.  

In addition, for the purposes described at paragraph 2 above, we may transfer your personal data to the other members of the Moffat group of companies, of which we are a part, and they are currently located in Australia, New Zealand, the United Kingdom and the United States of America.

7. Quality of your Personal Information and your rights of correction


We rely upon the accuracy of your personal data to provide our products and services to you. To assist us with this, please contact us immediately if any of your personal data ceases to be current (for instance, if you change your email address or any other contact details).

Similarly, if for any reason you believe that the personal data we hold about you is not accurate and complete, contact us at peter.barnes@moffat.com.au and we will make the appropriate correction. If we believe that the personal data we hold about you is inaccurate, out-of-date, incomplete, irrelevant or misleading, we will make the appropriate correction.

We will respond to your request within a reasonable period after the request is made and may, if permitted by law, refuse to change our records of your personal data. If this occurs, we will provide you with reasons why this has occurred.

8. Your rights to access your personal data


You have the right to access the personal data that we hold about you upon request. However there are some circumstances in which we may refuse to provide access or only provide partial access to this personal data. If your request for access is not granted, we will explain our reasons to you.

A nominal fee may apply to enable us to recover the reasonable costs of making such information available to you.

To exercise your rights to access your personal data you would need to contact us in writing.  For this purpose please contact us at Moffat Pty Limited, 740-742 Springvale Road Mulgrave VIC 3170, Australia or at peter.barnes@moffat.com.au .

9. What choices do we offer you with regard to direct marketing communications?


We may wish to provide you with information about new products, services, promotions and offers from ourselves, other members of our group of companies, and from carefully selected third parties from outside our group of companies, in each case which we consider may be of interest to you.  This may occur by e-mail, telephone, post or SMS or other methods which are made clear to you from time to time.  Before using your personal data for any direct marketing purpose we would need to obtain your prior consent and to advise you of how to opt-out of receiving such communications in accordance with applicable data protection law. If you do consent to this, then please note you may change your mind and opt-out of direct marketing communications at any time by sending an e-mail to peter.barnes@moffat.com.au.

10. Security of your Personal Information


We regard the security of your personal data as paramount. To this end, we take all steps required by data protection legislation to protect your personal data from unlawful or unauthorised processing. .

Only authorised people within our organisation are entitled to access your personal data for approved purposes. All our employees and agents are requires to sign a confidentiality agreement as a condition of their employment.

Please note that this Website does not provide systems for secure transmission of personal data across the Internet except where otherwise indicated. You should be aware that there are inherent risks in transferring personal data over the Internet and that, except where applicable law requires otherwise, we accept no responsibility for personal data provided through an unsecure page. 

11. Changes to our Privacy and Cookies Policy


From time to time we may decide to amend or update this Privacy and Cookies Policy. When this occurs we will post the new version of the Privacy and Cookies Policy on our website. The date at the bottom of this Policy will be updated accordingly.  We encourage you to periodically view this Privacy and Cookies Policy so that you remain informed as to how we are protecting your Personal Information.  We may, where necessary, notify you of any modified versions of this Privacy and Cookies Policy that might materially affect the way we use, disclose or otherwise process your personal data.  We may do this by posting an update on the Website which you will see at your next visit.

12. How to contact us


Should you have any queries or concerns in relation to our personal data handling practices, or if you wish to discuss any aspect of this Privacy and Cookies Policy, please do not hesitate to contact our Privacy Compliance Officer at peter.barnes@moffat.com.au . You may also write to us care of our Privacy Compliance Officer:

Moffat Pty Limited
740-742 Springvale Road
Mulgrave VIC 3170
Australia
Attn: Peter R Barnes

13. How we handle complaints


Any complaint made to us in connection with this Privacy and Cookies Policy and our information handling practices will be directed to our General Manager - Finance where it will be assessed giving due regard to the nature of your complaint, your circumstances and our ability to address the issue in question.  Irrespective of our decision, we will respond to your complaint within a reasonable period of time.

1st March 2017