Privacy Policy

Introduction

This Privacy Policy explains how personal data is collected and used by Reframe Brands Ltd Limited (company number: 13390917) and any other entities within our group or under common ownership from time to time (together referred to as “Reframe”, “we”, “us”, “our” throughout this Privacy Policy).

This Privacy Policy will inform you as to how we collect, use, handle and disclose your personal data, as well as telling you about your privacy rights and how the law protects you.

Please use the Glossary to understand the meaning of some of the terms used in this Privacy Policy, including “personal data” and “personal information”.

Important information

Purpose of this Privacy Policy

This Privacy Policy aims to give you information on how Reframe collects and processes your personal data, including any data you may provide when you contact us via email or through social media or any data that you provide through this website (https://www.reframebrands.com)

It is important that you read this Privacy Policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data. This Privacy Policy supplements the other notices and is not intended to override them.

Controller

Reframe is the “controller” for the purposes of data protection law and is therefore responsible for your personal data. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights (see section 9 below), please contact us on the details below

E-mail address: hello@reframebrands.com

Address: 180 Runcorn Road, Barnton, Northwich, England, CW8 4JA

You have the right to make a complaint at any time to the Information Commissioner's Office (“ICO”) contact details below, the UK supervisory authority for data protection issues (www.ico.org.uk).

Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Helpline number: 0303 123 1113

ICO website: https://www.ico.org.uk

Changes to the Privacy Policy

This version was last updated on 31 July 2023.

Data protection principles

Reframe adheres to the principles set out in data protection legislation when handling personal data. These principles require personal data to be:

Processed lawfully, fairly and in a transparent manner.

Collected only for specified, explicit and legitimate purposes.

Adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed.

Accurate and where necessary kept up to date.

Not kept in a form which permits identification of data subjects for longer than is necessary for the purposes for which the data is processed.

Processed in a manner that ensures its security using appropriate technical and organisational measures to protect against unauthorised or unlawful processing and against accidental loss, destruction or damage.

Not transferred to another country without appropriate safeguards being in place.

Made available to data subjects and allow data subjects to exercise certain rights in relation to their personal data.

We are also responsible and accountable for ensuring that we can demonstrate compliance with the data protection principles listed above.

How we collect information about you

We may collect, use, store and transfer different kinds of personal data about you. We collect and process personal data about you when you:

register on this website or the websites relating to our training material;

subscribe to our mailing list;

request any of our other services;

respond to a customer survey;

request information from us about our services;

contact us via email or through social media; and/or

submit an enquiry to us.

Personal data is usually collected from you through direct interaction with us (either in person, by phone, by email, by post, via social media or through this website). For example, you will provide your personal information if you sign up for Retail Ready.

We may also collect personal data when you use this website, through automated technologies, analytics providers or search engine providers. We use cookies to assist the site running as effectively as possible. For further details, please see our Cookies Policy here.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of our contract with you, and you fail to provide that data when requested, we may not be able to provide our services. If so, we may have to terminate our contract with you but we will notify you if this is the case at the time.

What information we collect and how we use it

The personal data that we collect will include:

Contact details including your name and role held within your company, telephone number, e-mail address, account log-in details and social media details;

Payment information, including credit/debit card details and bank account details;

Contact history, such as any communications with us previously about our services or any other service or website relation to Reframe;

Marketing preferences.

We will generally use your personal data to:

Provide you with the information and services that you request from us;

Provide you with access to our email newsletter;

Personalise your experience on our website and our Retail Ready training material platform;

Contact you by e-mail, telephone and via social media regarding the services and information that you have requested from us;

Process any financial transactions (including collection of payments, management of any additional charges and fees and administration of any refunds);

Create and administer your account on our website and our Retail Ready training material platform;

Generally administer our relationship with you;

Respond to any enquiries that you submit to us;

Send you information by email about new services, products, offers and updates (see the “Marketing” section below for further details);

Comply with our legal and regulatory obligations;

Keep a record of your relationship with us;

Prevent and detect fraud;

Provide customer service and support (including investigating complaints);

Review and improve our services and newsletters;

Use data analytics to improve our website, marketing, customer relationships, user experience and our organisation in general; and

Administer and protect the website and our organisation (including troubleshooting, data analysis, testing and system maintenance and network security).

Lawful basis for using your information

In some cases, we will only use your personal information where we have your consent or because we need to use it in order to fulfil a contract with you (for example, because you have ordered services from us and we need to provide them).

However, there are other lawful reasons that allow us to process your personal information, including where we have a “legitimate interest”. This means that the reason that we are processing information is because there is a legitimate interest for Reframe to process your information.

Whenever we process your personal data on the basis of a “legitimate interest”, we make sure that we take into account your rights and interests and will not process your personal information if we feel that there is a disproportionate privacy impact on you.

Marketing

We may use your contact details to send you marketing communications if you are a consumer and you have expressly given consent to receive those marketing communications.

If you are not a consumer and you have requested information from us or if you have signed up to our mailing list, or we have obtained your information from a third party source, we may also use your contact details to send you marketing communications unless you have opted-out of receiving that marketing.

You can ask us to stop sending you marketing messages by contacting us at any time.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out above.

Any suppliers, sub-contractors and/or agents we work with to provide you with the services that you have subscribed to or otherwise purchased from us.

Professional advisers acting as processors or joint controllers including lawyers, bankers, experts, accountants, insurers and other third parties who provide legal, banking, consultancy, accounting, insurance and other related services.

HM Revenue & Customs, law enforcement agencies, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law.

We do not and will not sell your personal data to any third party.

Data security

We limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

Data retention

We retain your personal data unless and until you ask us to delete it. We will then dispose of your information by deleting it from our records.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please go to the below headings to find out more about these rights:

Request access to your personal data.

Request correction of your personal data.

Request erasure of your personal data.

Object to processing of your personal data.

Request restriction of processing your personal data.

Request transfer of your personal data.

Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Glossary

“Personal data”, or “personal information”, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

“Sensitive Personal Data” means information revealing racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, physical or mental health conditions, sexual life, sexual orientation, biometric or genetic data, and personal data relating to criminal offences and convictions.

LAWFUL BASIS

“Legitimate interest” means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the privacy impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

“Performance of contract” means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

“Comply with a legal or regulatory obligation” means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

YOUR LEGAL RIGHTS

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.