This privacy policy outlines how we will meet the requirements of relevant legislation to protect your personal data, including what we will do to protect your personal information, and how we will use it within our business.
Thank you for trusting us with your personal information. If you have any queries, do please get in touch with us at www.livinglerwick.co.uk/contact
By providing us with your information you confirm that you are over 13 years of age.
Living Lerwick Ltd (referred to as "we", "us" or "our" in this privacy notice) is the data controller and as such is responsible for your personal data.
1. Introduction
This notice informs you of our policy regarding all information we hold and record about you. It sets out the conditions under which we may process any personal information that you provide to us. It covers information that could identify you ("personal information") and information that could not identify you. In the context of the law "process" means to collect, store, transfer, use or otherwise act on information.
We take the protection of your privacy and confidentiality seriously. We understand that all visitors to our website are entitled to trust that their personal information will not be used for any purpose unintended by them, and will not accidentally be transferred to a third party. Information we may collect about individuals with their consent though taking part in competitions or through the ShopSafe Alert! Scheme is also covered by this Privacy Policy.
We undertake to preserve the confidentiality of all information you provide to us, and trust that you reciprocate.
It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us.
Our policy complies with UK law including the requirements of General Data Protection Regulations and Privacy and Electronic Communications Regulations (PECR).
2. Who we are
| Legal name | Living Lerwick Ltd |
|---|---|
| Email address | [email protected] |
| Posal Address | 179 Commercial Street, Lerwick, Shetland, ZE1 0HX |
3. What information we collect, use, and why
We collect or use the following information for the operation of customer accounts and guarantees:
- Names and contact details
- Addresses
- Account information, including registration details
We collect or use the following information to prevent, detect, investigate or prosecute crimes:
- Physical description and, or, name if known.
- Biometric information (where used to identify someone)
We collect or use the following information for service updates or marketing purposes:
- Names and contact details
- Addresses
We collect or use the following personal information for dealing with queries, complaints or claims:
- Names and contact details
- Address
- Correspondence
We collect or use the following information to carry out Business Improvement District Operations:
- Names and contact details
- Customer or client accounts and records
- Financial transaction information
4. Lawful bases and data protection rights
Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.
Which lawful basis we rely on may affect your data protection rights which are in brief set out below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:
- Your right of access - You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for. You can read more about this right here.
- Your right to rectification - You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. You can read more about this right here.
- Your right to erasure - You have the right to ask us to delete your personal information. You can read more about this right here.
- Your right to restriction of processing - You have the right to ask us to limit how we can use your personal information. You can read more about this right here.
- Your right to object to processing - You have the right to object to the processing of your personal data. You can read more about this right here.
- Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you. You can read more about this right here.
- Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time. You can read more about this right here.
If you make a request, we must respond to you without undue delay and in any event within one month. To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.
5. Our lawful bases for the collection and use of your data
Our lawful bases for collecting or using personal information for the operation of customer accounts and guarantees are:
- Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
- Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability.
Our legitimate interests are:
- To ensure correct information is held for all member businesses and relevant information can be shared appropriately to benefit individual members.
- Public task – we have to collect or use your information to carry out a task laid down in law, which the law intends to be performed by an organisation such as ours. All of your data protection rights may apply, except the right to erasure and the right to portability.
Our lawful bases for collecting or using personal information to prevent, detect, investigate or prosecute crimes are:
- Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
- Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability.
Our legitimate interests are:
- The processing is founded on the grounds of legitimate interests, which involve safeguarding our premises and stakeholders from criminal threats. Our Legitimate Interest Assessment has concluded that the proactive prevention of crime considerably outweighs any potential impact on individual privacy.
Our lawful bases for collecting or using personal information for service updates or marketing purposes are:
- Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
- Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability.
Our legitimate interests are:
- To ensure relevant information is shared with all member businesses and no member business is disadvantaged by not receiving information which could be of benefit to the owner or business.
Our lawful bases for collecting or using personal information for Business Improvement District Operations are:
- Public task – we have to collect or use your information to carry out a task laid down in law, which the law intends to be performed by an organisation such as ours. All of your data protection rights may apply, except the right to erasure and the right to portability.
6. Where we get personal information from
- Directly from you
7. How long we keep information
Commercial contracts:
Type of record | Retention period | Where is it stored? | Reason | Method of deletion |
Contracts with suppliers | 7 years after last action | Cloud storage, secure microsoft account | Supply of contract | Deletion from cloud storage and shred any paper copies |
Marketing records:
Type of record | Retention period | Where is it stored? | Reason | Method of deletion |
Mailing lists | 5 years after last action | Cloud storage, online mailing account | To share relevant information with members | [SPECIFY] |
Tax and Accounting Records:
Type of record | Retention period | Where is it stored? | Reason | Method of deletion |
Tax returns | 7 years from end of financial year | Cloud, locked filing cabinet in storage shed | Audit or accountability | Shred /incinerate and delete files |
Accounting & financial management information | 7 years from end of financial year | Cloud, locked filing cabinet in storage shed | Audit or accountability | Shred /incinerate and delete files |
Purchase orders and invoices | 7 years from end of financial year | Cloud, locked filing cabinet in storage shed | Audit or accountability | Shred /incinerate and delete files |
Operational records:
Type of record | Retention period | Where is it stored? | Reason | Method of deletion |
Equipment and tools | Keep asset and depreciation records for 7 years after end of financial year to which they relate. | Cloud, locked filing cabinet in storage shed | Audit or accountability | Shred /incinerate and delete files |
Policies/Procedures | 7 years or until superseded | Cloud storage | Business operations | Delete files |
Complaints | 7 years from end of financial year | Cloud or filing cabinet in secure office | Audit or accountability | Shred /incinerate and delete files |
Insurance documents | 7 years after last action | Cloud storage | Business operations | [SPECIFY] |
Register of members | Life of company | ACT online database | To administer member services | Manual deletion from server |
Memorandum of association | Life of company | Cloud and filing cabinet in secure office | Business operations | Deletion and shred / incinerate |
Register of directors and secretaries | Life of company | Cloud and filing cabinet in secure office | Business operations | Deletion and shred / incinerate |
Employer’s liability insurance certificates | Life of company | Cloud and filing cabinet in secure office | Business operations | Deletion and shred / incinerate |
Public Records
Type of record | Retention period | Where is it stored? | Reason | Method of deletion |
Spend at da Street entry card (name /phone) | One month | Secure office | To select competition winner | Shred /incineration |
Competition entry forms, including from U18s | One month | Secure office | To select competition winner | Shred /incineration |
ShopSafe Alert Report | 12 months from report of incident | Secure online server (app) | Maintain safety and security for staff and customers | Delete data from app |
8. Who we share information with
Others we share personal information with
- Professional or legal advisors
- Relevant regulatory authorities
- Organisations we’re legally obliged to share personal information with
- Suppliers and service providers
9. How to complain
If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice.
If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.
The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
Website: https://www.ico.org.uk/make-a-complaint
Use of information we collect through automated systems when you visit our website
9. Cookies and Local Storage
Cookies
Cookies are small text files that are placed on your computer's hard drive by your web browser when you visit any website. They allow information gathered on one web page to be stored until it is needed for use on another, allowing a website to provide you with a personalised experience and the website owner with statistics about how you use the website so that it can be improved.
Some cookies may last for a defined period of time, such as one day or until you close your browser. Others last indefinitely.
Our website uses cookies. They are placed by software that operates on our servers, and by software operated by third parties whose services we use.
Some examples of how cookies may be used:
- to track how you use our website
- to record what is held in a shopping basket
- to record whether you have seen specific messages we display on our website
- to record your answers to surveys and questionnaires on our site while you complete them.
Local storage
Local storage is a component of the Web storage application programming interface. It is a method by which Web pages locally store named key/value pairs inside a client's Web browser. Similar to cookies, this saved data exists even when you close a browser tab, surf away from the current website or close the main browser.
Use
You can find more information about the individual cookie and local storage data we use and the purposes for which we use them below:
| Cookie / Local Storage | Example Name(s) | Purpose |
|---|---|---|
| Content Management System | This website uses a content management system, and session cookies are required for aspects of this website to work. | |
| Cookie Consent | cookieconsent_status | This cookie stores the status of the cookie consent message that appears when you first use this website. |
| Facebook Plugins | datr fr sb wd | This website uses Facebook plugins to enhance your experience. For more information on Facebook's cookies, please visit https://www.facebook.com/policies/cookies/. |
| Google Analytics | _ga _gat _gid _utma _utmb _utmc _utmt _utmz | This website uses Google Analytics, a web analytics service provided by Google Inc. ("Google"). Google Analytics uses cookies to help collect data on how users use this website. Information about the cookies set by Google, and their purpose, can be found at: https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage. Google's Privacy Policy can be found at: https://policies.google.com/privacy To opt-out of analysis by Google Analytics, both on this website and other websites, please see https://tools.google.com/dlpage/gaoptout. |
| YouTube | VISITOR_INFO1_LIVE PREF | On some pages on this website, we may embed videos from YouTube. YouTube uses cookies to track visitor views, and to remember user preferences when viewing YouTube videos embedded in our website web pages. More information about YouTube cookies. |
Your web browser should allow you to delete any cookies or local storage that you choose. It also should allow you to prevent or limit their use.
If you choose to prevent the use of cookies through your browser settings, you will not be able to use all the functionality of our website.
10. Personal identifiers from your browsing activity
Requests by your web browser to our servers for web pages and other content on our website are recorded.
We record information such as your geographical location, your Internet service provider and your IP address. We also record information about the software you are using to browse our website, such as the type of computer or device and the screen resolution.
We use this information in aggregate to assess webpage popularity and server performance.
If combined with other information we know about you from previous visits, the data possibly could be used to identify you personally, even if you are not signed in to our website.
Disclosure and sharing of your information
11. Information we obtain from third parties
Although we do not disclose your personal information to any third party (except as set out in this notice), we sometimes receive data that is indirectly made up from your personal information from third parties whose services we use. No such information is personally identifiable to you.
12. Data may be processed outside the European Union
This website is hosted in the United Kingdom.
We may also use outsourced services in countries outside the European Union from time to time in other aspects of our business.
Accordingly, data obtained within the UK or any other country could be processed outside the European Union.
For example, some of the software our website uses may have been developed in the United States of America or in Australia.
We use the following safeguards with respect to data transferred outside the European Union:
- the processor is bound to data protection requirements within their own country – for example the US/EU Privacy Shield, the Canadian Privacy Act, the Australian Privacy Act etc.
- the data protection clauses in our contracts with data processors include transfer clauses written by or approved by a supervisory authority in the European Union, specifically that in the country of the United Kingdom
- we comply with a code of conduct approved by a supervisory authority in the European Union, specifically that in the country of the United Kingdom
Access to your own information
13. Your Rights
You have the right to ask us not to process your personal information for marketing purposes. If you do not wish to receive further communication from us please contact us.
14. Access to your personal information
To obtain a copy of any information that is not provided on our website you may send us a request at [email protected]. After receiving the request, we will confirm we have received your request and will provide you with the information within the 28 day period required.
15. Removal of your information
If you wish us to remove personally identifiable information from our website, you may contact us at [email protected]. This may limit the service we can provide to you.
16. Verification of your information
When we receive any request to access, edit or delete personal identifiable information we shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.
Other matters
17. Links
When you click on links on our website, they may direct you away from our site. We are not responsible for the privacy practices of other sites and encourage you to read their privacy statements.
18. Use of site by children
We do not sell products or provide services for purchase by children, nor do we market to children.
If you are under 18, you may use our website only with consent from a parent or guardian.
19. Encryption of data sent between us
We use Secure Sockets Layer (SSL) certificates to verify our identity to your browser and to encrypt any data you give us.
Whenever information is transferred between you and us, you can check that it is done using SSL by looking for a closed padlock symbol or other trust mark in your browser's URL bar or toolbar.
20. How you can complain
If you are not happy with our privacy policy or if have any complaint then you should contact us.
If a dispute is not settled then we hope you will agree to attempt to resolve it by engaging in good faith with us in a process of mediation or arbitration.
If you are in any way dissatisfied about how we process your personal information, you have a right to lodge a complaint with the Information Commissioner's Office. This can be done at https://ico.org.uk/concerns/
21. Retention period for personal data
Except as otherwise mentioned in this privacy notice, we keep your personal information only for as long as required by us:
- to provide you with the services you have requested;
- to comply with other law, including for the period demanded by our tax authorities;
- to support a claim or defence in court.
22. Compliance with the law
Our privacy policy has been compiled so as to comply with the law of every country or legal jurisdiction in which we aim to do business. If you think it fails to satisfy the law of your jurisdiction, we should like to hear from you. It is your choice as to whether you wish to use our website.
23. Review of this privacy policy
We will update this privacy notice from time to time as necessary. The terms that apply to you are those outlined here on our website on the day you use our website. If you have any questions regarding our privacy policy, please contact us.
24. Further information on General Data Protection Regulations
For up to date information on your rights under the General Data Protection Regulations, please check the website of the Information Commissioner: ico.org.uk.