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Privacy Policy
Protecting your personal details on our website.
Last updated: 21 January 2019
PNM Kits Limited understands that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who visits our website, www.thejollyturtle.co.uk (the ‘Website’) and will only collect and use personal data in ways that are described here, and in a manner that is consistent with Our obligations and your rights under the law. Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of Our Privacy Policy is deemed to occur upon your first use of the Website. If you do not accept and agree with this Privacy Policy, you must stop using the Website immediately.
Definitions and Interpretation
In this Policy, the following terms shall have the following meanings:
| “Account” | means an account that is associated with the supply of Our products and/or services to You |
| “Cookie” | means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 13, below; |
| “Cookie Law” | means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003; |
| “Personal Data” | means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via the Website. This definition shall, where applicable, incorporate the definitions provided in EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”); |
| “SaaS” | means Software As A Service which is software that is centrally hosted and accessed via a web browser; |
| “We/Us/Our” | means PNM Kits Limited (trading as The Jolly Turtle), a limited company registered in England under company number 10365431, whose registered address is 183 Main Street, Yaxley, Peterborough, PE7 3LD. |
2. Information About Us
The Website is owned and operated by PNM Kits Limited, a limited company registered in England under company number 10365431, whose registered address is 183 Main Street, Yaxley, Peterborough, Cambridgeshire, PE7 3LD.
3. What Does This Policy Cover?
This Privacy Policy applies only to your use of the Website. The Website may contain links to other websites. Please note that We have no control over how your data is collected, stored, or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to them.
4. Your Rights
When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.
4.1 As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:
4.1.1 The right to be informed about Our collection and use of personal data;
4.1.2 The right of access to the personal data We hold about you (see section 12);
4.1.3 The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us using the details in section 14);
4.1.4 The right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you (We only hold your personal data for a limited time, as explained in section 6 but if you would like Us to delete it sooner, please contact Us using the details in section 14);
4.1.5 The right to restrict (i.e. prevent) the processing of your personal data;
4.1.6 The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);
4.1.7 The right to object to Us using your personal data for particular purposes; and
4.1.8 Rights with respect to automated decision-making and profiling.
4.2 If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided in section 14 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK’s Information Commissioner’s Office.
4.3 For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.
5. What Data Do We Collect?
5.1 Depending upon your use of the Website, We may collect some or all of the following personal and non-personal data (please also see section 13 on Our use of Cookies and similar technologies):
5.1.1 name and date of birth;
5.1.2 gender;
5.1.3 business/company name;
5.1.4 residential or business address;
5.1.5 job title or profession;
5.1.6 contact information such as email addresses and telephone numbers;
5.1.7 demographic information such as postcode;
5.1.8 financial information such as credit/debit card numbers;
5.1.9 IP address;
5.1.10 a list of URLs starting with a referring site as well as your activity on the Website; and
5.1.11 web browser type.
6. How Do We Use Your Data?
6.1 All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the GDPR at all times. For more details on security see section 7, below.
6.2 Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of your personal data (e.g. by subscribing to Our newsletter), or because it is in Our legitimate interests. Specifically, We may use your data for the following purposes:
6.2.1 Providing and managing your Account;
6.2.2 Providing and managing your access to the Website;
6.2.3 Personalising and tailoring your experience on the Website;
6.2.4 Supplying Our products and services to you (please note that We require your personal data in order to enter into a contract with you);
6.2.5 Personalising and tailoring Our products and services for you;
6.2.6 Replying to emails from you;
6.2.7 To help prevent and detect fraud or loss;
6.2.8 Supplying you with emails that you have opted into such as a newsletter (you may unsubscribe or opt-out at any time by following the instructions at the bottom of the email);
6.2.9 Analysing your use of the Website and gathering feedback to enable Us to continually improve the Website and your user experience;
6.3 We employ companies and individuals to perform functions on our behalf and we may disclose personal data for the purposes set out in 6.2.1 to 6.2.9 or for example, for fulfilling orders, delivering packages, sending postal mail and email providing search results and links (including paid listings and links), processing credit and debit card payments and providing customer service. Those parties are bound by strict contractual provisions with us and only have access to personal data needed to perform their functions and must not use it for other purposes. Further they must process the personal data in accordance with this Privacy Policy and as permitted by the GDPR.
6.4 With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email with information, news and offers on Our products and services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003.
6.5 You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it.6.6 We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected.
7. How and Where Do We Store Your Data?
7.1 We only keep your personal data for as long as We need to in order to use it as described above in section 6, and/or for as long as We have your permission to keep it.
7.2 Your data will only be stored within the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein) or with certain SaaS providers outside of EEA who comply with EU data export restrictions and fully comply with GDPR.
7.3 Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure data collected through the Website.
8. Do We Share Your Data?
8.1 Subject to sections 6.3 and 8.2, We will not share any of your data with any third parties for any purposes.
8.2 In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal obligations, a court order, or a governmental authority.
9. What Happens If Our Business Changes Hands?
9.1 We may, from time to time, expand or reduce Our business and this may involve the sale and/or the transfer of control of all or part of Our business. Any personal data that you have provided will, where it is relevant to any part of Our business that is being transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use that data only for the same purposes for which it was originally collected by Us.
9.2 In the event that any of your data is to be transferred in such a manner, you will be contacted in advance and informed of the changes. When contacted you will, however, be given the choice to have your data deleted or withheld from the new owner or controller.
10. How Can You Control Your Data?
In addition to your rights under the GDPR, set out in section 4, when you submit personal data via the Website, you may be given options to restrict Our use of your data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details and by managing your Account).
11. Your Right to Withhold Information
You may access certain areas of the Website without providing any data at all. However, to use all features and functions available on the Website you may be required to submit or allow for the collection of certain data.
12. How Can You Access Your Data?
You have the right to ask for a copy of any of your personal data held by Us (where such data is held). Under the GDPR, no fee is payable and We will provide any and all information in response to your request free of charge. Please contact Us for more details at hello@thejollyturtle.co.uk, or using the contact details below in section 15.
13. Our Use of Cookies
13.1 The Website may place and access certain first party Cookies on your computer or device. First party Cookies are those placed directly by Us and are used only by Us. We use Cookies to facilitate and improve your experience of the Website and to provide and improve Our services. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.
13.2 By using the Website you may also receive certain third party Cookies on your computer or device. Third party Cookies are those placed by websites, services, and/or parties other than Us. For more details, please refer to section 6, above, and to section 13.6 below. These Cookies are not integral to the functioning of the Website and your use and experience of the Website will not be impaired by refusing consent to them.
13.3 All Cookies used by and on the Website are used in accordance with current Cookie Law.
13.4 Before Cookies are placed on your computer or device, you will be shown a message requesting your consent to accept those Cookies. By giving your consent to the placing of Cookies you are enabling Us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of the Website may not function fully or as intended.
13.5 Certain features of the PNM Sites depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. Your consent will not be sought to accept these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings, but please be aware that the Website may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.
13.6 The Website use analytics services provided by Google Analytics. Website analytics are a set of tools used to collect and analyse website usage information on an anonymous basis, and enabling Us to better understand how the Website are used. This, in turn, enables Us to improve the Website and the services offered through it. You do not have to allow Us to use these Cookies, however whilst Our use of them does not pose any risk to your privacy or your safe use of the Website, it does enable Us to continually improve the Website, making it a better and more useful experience for you.
13.7 The analytics service used by the Website does use Cookies to gather the required information.
13.8 In addition to the controls that We provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party Cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
13.9 You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access the Website more quickly and efficiently including, but not limited to, login and personalisation settings.
13.10 It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
14. Protecting information
14.1 We have strict security measures to protect personal data. We work to protect the security of your information during transmission by using Secure Sockets Layer (SSL) software which encrypts information that you input.
14.2 We reveal only the last five digits of your credit card numbers when confirming an order. Of course we transmit the entire credit card number to the appropriate credit card company during order processing.
14.3 We maintain physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of personal data.
15. Contacting Us
If you have any questions about the Website or this Privacy Policy, please contact Us by email at hello@thejollyturtle.co.uk or by post at PNM Kits Limited, 183 Main Street, Yaxley, Peterborough, Cambridgeshire, PE7 3LD. Please ensure that your query is clear, particularly if it is a request for information about the data We hold about you (as under section 12, above).
16. Changes to Our Privacy Policy
We may change this Privacy Policy from time to time (for example, if the law changes). Any changes will be immediately posted on the Website and you will be deemed to have accepted the terms of the Privacy Policy on your first use of the Website following the alterations. We recommend that you check this page regularly to keep up-to-date.