Privacy Policy

FRONT OF THE PACK

Privacy Notice

Take a look around to learn more about how we take care of your personal data. Please note we may make changes to this Privacy Notice by reposting, so please check back from time to time.

For definitions of key terms see the Information Commissioner’s Office’s glossary here. The Information Commissioner’s Office (ICO) is the body that upholds data protection rights in the UK. Their website https://ico.org.uk/ is a useful source of information about data protection.

  1. Who is the data controller

Paws Group Limited (t/a Front of the Pack) is the ‘data controller’ where we have collected your personal data through our website or through correspondence with you. This means we are responsible for the purpose and means of how we use it.

We are registered with the ICO, with registration number ZA326373.

  1. Our use of your personal data – what, how and why?

Personal data does not include anonymous data (where your identity has been removed).

Please see the table below which sets out the type of information we collect, the purpose and use of such data, and the legal basis on which we use your data.

Data collected

How is data collected

How we use data

Purpose for use

Legal basis

Email address

Provided by you when signing up to receive emails

Stored on our systems in your customer records. In any email exchanges with you. Stored on internal Google sheets.

To provide you with updates and marketing information about our business.

Consent

Technical data including your IP address, browser types and versions

Collected automatically when you interact with our websites by cookies, server logs and other similar technologies.

May also be collected by third party sources such as analytics providers or search information providers

Typically such data would be aggregated to perform analysis we will strip out any personal identifiers where possible.

To study our users and how they use our website to enable us to develop and grow our business.

Legitimate interests

Usage data including data about how you use our website

Collected automatically when you interact with our websites by cookies, server logs and other similar technologies.

May also be collected by third party sources such as analytics providers or search information providers

Where used for analytic purposes, such data would be aggregated to perform analysis we will strip out any personal identifiers where possible.

To study our users and how they use our website to enable us to develop and grow our business.

Legitimate interests

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

You have the right to withdraw consent to marketing at any time -  contact us.

Promotional offers from us

You will receive marketing communications from us if you have signed up to receive emails about our business. By signing up to receive such communications you consent to receiving such emails from us.

We may use you Technical and Usage Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

Opting out

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

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see Cookie policy.

  1. Change of purpose

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

  1. Sharing with third parties

We may have to share your data with the parties set out below:

  • Internal third parties – Other companies in our extended group of companies who are based in our offices and provide legal,  or accounting or human resources support to us.
  • External third parties – (a) service providers acting as processors who provide IT and system administration services including, but not limited to, third party couriers. These service providers may be based outside the EEA as set out below, (b) professional advisors such as lawyers, auditors and insurers, (3) Regulators and other authorities who require reporting in certain circumstances required by law.

Where we do so, we require the third party to respect the security of your personal data and treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for the specified purposes and in accordance with our instructions.

We may share your personal data with external third parties based outside the European Economic Area (EEA). Where we do so, we will ensure your personal data has a similar degree of protection by ensuring at least one of the following safeguards is in place:

  • We will only transfer your data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
  • We may use specific contracts approved by the European Commission which gives personal data the same protection it has in Europe.
  • Where we use US-based providers, we may transfer data to them if they are part of the Privacy Shield, which requires them to provide adequate protection.
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  1. Data Security

We have put in place appropriate security measures to prevent your personal data being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Our employees, agents, contracts and other third parties who have a business need to know will process your personal data on our instructions and they are subject to a duty of confidentiality.

Procedures have been put in place to deal with any suspected personal data breaches and we will notify you and any regulator where legally required to do so.

  1. How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data, and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances you can ask us to delete your data (see Your Rights below for more information).

Sometimes we will anonymise your personal data so it can no longer be associated with you for research or statistical purposes. In this case we may use such information indefinitely without further notice to you.

  1. Your Rights

You have rights in certain circumstances under data protection laws in relation to your personal data, as set out below:.

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.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

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 products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Please see the ICO link here for more information.

If you wish to exercise any of these rights, please contact us.

We won’t usually require any fee for access to your personal data (or exercise of other rights). However, if your request is clearly unfounded, repetitive or excessive we may charge a reasonable fee or refuse to comply with your request.

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.

We may contact you to ask for further information to speed up our response to any requests.