2023
This Privacy Policy describes how W F Howes Limited ("we", “us” or "our") processes personal data that we collect through our digital or online properties or services that link to this Privacy Policy (including as applicable, our website, platform, social media pages, marketing activities, live events and other activities described in this Privacy Policy (collectively, the “Service”)). We may provide additional or supplemental privacy policies to individuals for specific products or services that we offer at the time we collect personal data.

Controller.

W F Howes Limited is the controller in respect of the processing of your personal data covered by this Privacy Policy for purposes of European data protection legislation (i.e., the EU GDPR and the so-called ‘UK GDPR’ (as and where applicable, the “GDPR”)).

Index

Personal data we collect
How we use your personal data
How we share your personal data
Our legal bases for processing
Your rights and choices
Other sites and services
Security
International Data Transfers
Children
Changes to this Privacy Policy
Retention
How to contact us

Personal data we collect

Information you provide to us. Personal data you, as a buyer or seller on our platform, may provide to us through the Service or otherwise includes:

Contact data, such as your first and last name, salutation, email address, billing and mailing addresses, professional title and company name, and phone number.
Profile data, such as the username and password that you may set to establish an online account on the Service, and any other information that you add to your account profile.
Communications data based on our exchanges with you, including when you contact us through the Service, complete our surveys, communicate with us via chat features, social media, or otherwise.
Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
Payment data needed to complete transactions, including payment card information or bank account number.
Buyer transaction data, such as information about orders buyers initiate through the Service, along with overall buying behavior (e.g., what buyers search, which items they add to cart, etc.).
Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Third-party sources.

We may combine personal data we receive from you with personal data we obtain from other sources, such as government agencies, public records, social media platforms, and other publicly available sources.

Automatic data collection.

We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications and other online services, such as:

Device data, such as your computer or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers, language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area.
Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.

Cookies. Some of our automatic data collection is facilitated by cookies and similar technologies. For more information, see our Cookie Notice. We will also store a record of your preferences in respect of the use of these technologies in connection with the Service.
No obligation to provide personal data. You do not have to provide personal data to us. However, where we need to process your personal data either to comply with applicable law or to deliver our Services to you, and you fail to provide that personal data when requested, we may not be able to provide some or all of our Services to you. We will notify you if this is the case at the time.

No sensitive personal data. We ask that you not provide us with any sensitive personal data (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Services, or otherwise to us. If you provide us with any sensitive personal data to us when you use the Services, you must consent to our processing and use of such sensitive personal data in accordance with this Privacy Policy. If you do not consent to our processing and use of such sensitive personal data, you must not submit such sensitive personal data through our Services.

How we use your personal data

We may use your personal data for the following purposes or as otherwise described at the time of collection:

Service delivery and operations.

We may use your personal data to:

provide and operate the Service and our business;
personalize the Service, including remembering the devices from which you have previously logged in and remembering your selections and preferences as you navigate the Service;
establish and maintain your user profile on the Service;
support and process orders, risk and fraud screening, authentication and payments;
enable security features of the Service, such as by sending you security codes via email or SMS, and remembering devices from which you have previously logged in;
communicate with you about the Service, including by sending Service-related announcements, updates, security alerts, and support and administrative messages;
understand your needs and interests, and personalize your experience with the Service and our communications; and
provide support for the Service, and respond to your requests, questions and feedback.

Research and development.

We may use your personal data for research and development purposes, including to analyze and improve the Service and our business and to develop new products and services. As part of these activities, we may create aggregated, de-identified and/or anonymized data from personal data we collect. We make personal data into de-identified or anonymized data by removing information that makes the data personally identifiable to you. We may use this aggregated, de-identified or otherwise anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business and will not attempt to reidentify any such data.

Marketing.

We and our service providers may collect and use your personal data for marketing purposes. We may send you direct marketing communications and may personalize these messages based on your needs and interests. You may opt-out of our marketing communications as described in the Opt-out of marketing section below.

Events, promotions and contests.

We may use your personal data to:

administer promotions and contests;
communicate with you about promotions or contests in which you participate; and
contact or market to you after collecting your personal data at an event.

Service improvement and analytics.

We may use your personal data to analyze your usage of the Service, improve the Service, improve the rest of our business, help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails, and to develop new products and services.

Compliance and protection.

We may use your personal data to:

comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas, investigations or requests from government authorities;
protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
audit our internal processes for compliance with legal and contractual requirements or our internal policies;
enforce the terms and conditions that govern the Service; and
prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

With your consent.

In some cases, we may specifically ask for your consent to collect, use or share your personal data, such as when required by law.

No Automated Decision-Making and Profiling. As part of the Services, we do not engage in automated decision-making and/or profiling, which produces legal or similarly significant effects. We will let you know if that changes by updating this Privacy Policy.

How we share your personal data

We may share your personal data with the following parties and as otherwise described in this Privacy Policy, in other applicable notices, or at the time of collection.
Affiliates. Our corporate parent, subsidiaries, and affiliates.
Service providers. Third parties that provide services on our behalf or help us operate the Service or our business (such as hosting, information technology, online chat functionality providers, customer support, email delivery, marketing, consumer research and website analytics).
Business and marketing partners. Third parties with whom we co-sponsor events or promotions, with whom we jointly offer products or services, or whose products or services may be of interest to you.
Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.
Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the Compliance and protection purposes described above.
Business transferees. We may disclose personal data in the context of actual or prospective business transactions (e.g., investments activities, financing activities, public stock offerings, or the sale, transfer or merger of all or part of our business, assets or shares). For example, we may need to share certain personal data with prospective counterparties and their advisers. We may also disclose your personal data to an acquirer, successor, or assignee of us as part of any merger, acquisition, sale of assets, or similar transaction, and/or in the event of an insolvency, bankruptcy, or receivership in which personal data is transferred to one or more third parties as one of our business assets.
Our legal bases for processing
In respect of each of the purposes for which we use your personal data, the GDPR requires us to ensure that we have a “legal basis” for that use.

Our legal bases for processing your personal data described in this Privacy Policy are listed below.

Where we need to process your personal data to deliver our Services to you (including our Site) (“Contractual Necessity”).
Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests (“Legitimate Interests”). More detail about the specific legitimate interests pursued in respect of each Purpose we use your personal data for is set out in the table below.
Where we need to comply with a legal or regulatory obligation (“Compliance with Law”).
Where we have your specific consent to carry out the processing for the Purpose in question (“Consent”).

We have set out below, in a table format, the legal bases we rely on in respect of the relevant Purposes for which we use your personal data – for more information on these Purposes and the data types involved, see How we use your personal data above.

Purpose	Categories of personal data involved	Legal basis
Service delivery and operations	Contact data Profile data Communications data Buyer transaction data	Contractual Necessity
Research and development; Service improvement and analytics	Any and all data types relevant in the circumstances	Legitimate interest. We have legitimate interest in understanding what may be of interest to our customers, improving customer relationships and experience, delivering relevant content to our customers, measuring and understanding the effectiveness of the content we serve to customers. Consent, in respect of any optional cookies used for this purpose.
Marketing / Events, promotions and contests	Contact data Profile data Communications data Payment data Buyer transaction data Marketing data	Legitimate Interests. We have a legitimate interest in promoting our operations and goals as an organisation and sending marketing communications for that purpose. Consent, in circumstances or in jurisdictions where consent is required under applicable data protection laws to the sending of any given marketing communications.
Compliance and protection	Any and all data types relevant in the circumstances	Compliance with Law. Legitimate interest. Where Compliance with Law is not applicable, we and any relevant third parties have a legitimate interest in participating in, supporting, and following legal process and requests, including through co-operation with authorities. We and any relevant third parties may also have a legitimate interest of ensuring the protection, maintenance, and enforcement of our and their rights, property, and/or safety.
Further uses	Any and all data types relevant in the circumstances	The original legal basis relied upon, if the relevant further use is compatible with the initial purpose for which the Personal data was collected. Consent, if the relevant further use is not compatible with the initial purpose for which the personal data was collected.

Your rights and choices

European data protection laws give you certain rights regarding your personal data. If you are located in Europe, you may ask us to take any of the following actions in relation to your personal data that we hold:

Access. Provide you with information about our processing of your personal data and give you access to your personal data.

Correct. Update or correct inaccuracies in your personal data. If you have registered for an account with us through the Service, you may review and update certain account information by logging into the account.
Delete. Delete your personal data where there is no lawful reason for us continuing to store or process it, 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 that will be notified to you, if applicable, at the time of your request.
Portability. Port a machine-readable copy of your personal data to you or a third party of your choice, in certain circumstances. Note that this right only applies to automated information for which you initially provided consent for us to use or where we used the information to perform a contract with you.
Restrict. Restrict the processing of your personal data, if, (i) you want us to establish the personal data's accuracy; (ii) where our use of the personal data is unlawful but you do not want us to erase it; (iii) where you need us to hold the personal data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (iv) you have objected to our use of your personal data but we need to verify whether we have overriding legitimate grounds to use.
Object. Object to our processing of your personal data where we are relying on legitimate interests (or those of a third party) and there is something about your particular situation that makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedom – you also have the right to object where we are processing your personal data for direct marketing purposes.
Withdraw Consent. When we use your personal data based on your consent, you have the right to withdraw that consent at any time. This will not affect the lawfulness of any processing carried out before you withdraw your consent. You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.

Exercising These Rights. You may submit these requests by email to [email protected], at which point your request will be forwarded to the Data Protection Officer employed by W.F. Howes. We may request specific information from you to help us confirm your identity and process your request. Whether or not we are required to fulfill any request you make will depend on a number of factors (e.g., why and how we are processing your personal data), if we reject any request you may make (whether in whole or in part) we will let you know our grounds for doing so at the time, subject to any legal restrictions. Typically, you will not have to pay a fee to exercise your rights; however, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. We try to respond to all legitimate requests within a month. It may take us longer than a month if your request is particularly complex or if you have made a number of requests; in this case, we will notify you and keep you updated.
Your Right to Lodge a Complaint with your Supervisory Authority. In addition to your rights outlined above, if you are not satisfied with our response to a request you make, or how we process your personal data, you can make a complaint to the data protection regulator in your habitual place of residence.

For users in the European Economic Area – the contact information for the data protection regulator in your place of residence can be found here: https://edpb.europa.eu/about-edpb/board/members_en.
For users in the UK – the contact information for the UK data protection regulator is below:

The Information Commissioner’s Office
Water Lane, Wycliffe House
Wilmslow - Cheshire SK9 5AF
Tel. +44 303 123 1113
Website: https://ico.org.uk/make-a-complaint/
Cookies. For information about cookies employed by the Service and how to control them, see our Cookie Notice.
Delete your content or close your account. You can choose to delete certain content through your account. If you wish to request to close your account, please contact us.

Other sites and services

The Service may contain links to third party websites, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions nor are they subject to this Privacy Policy. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.

Security

We have put in place procedures designed to deal with breaches of personal data. In the event of such breaches, we have procedures in place to work with applicable regulators. In addition, in certain circumstances (including where we are legally required to do so), we may notify you of breaches affecting your personal data.

International data transfers

Many of our service providers, advisers, partners, or other recipients of data are based in the US. This means that, if you use the Services, your personal data will necessarily be accessed and processed in the US. It may also be provided to recipients in other countries outside Europe.
It is important to note that that the US is not the subject of an ‘adequacy decision’ under the GDPR – basically, this means that the US legal regime is not considered by relevant European bodies to provide an adequate level of protection for personal data, which is equivalent to that provided by relevant European laws.
Where we share your personal data with third parties who are based outside Europe, we try to ensure a similar degree of protection is afforded to it in accordance with applicable privacy laws by making sure one of the following mechanisms is implemented:

Transfers to territories with an adequacy decision. We may transfer your personal data to countries or territories whose laws have been deemed to provide an adequate level of protection for personal data by the European Commission or UK Government (as and where applicable) (from time to time).
Transfers to territories without an adequacy decision. We may transfer your personal data to countries or territories whose laws have not been deemed to provide such an adequate level of protection (e.g., the US, see above). However, in these cases:
- we may use specific appropriate safeguards, which are designed to give personal data effectively the same protection it has in Europe – for example, standard-form contracts approved by relevant authorities for this purpose; or
- in limited circumstances, we may rely on an exception, or ‘derogation’, which permits us to transfer your personal data to such country despite the absence of an ‘adequacy decision’ or ‘appropriate safeguards’ – for example, reliance on your explicit consent to that transfer.

You may contact us if you want further information on the specific mechanism used by us when transferring your personal data out of Europe.

Children

The Service is not intended for use by anyone under the age of majority. If you are a parent or guardian of a child from whom you believe we have collected personal data in a manner prohibited by law, please contact us. If we learn that we have collected personal data through the Service from a child without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service or other appropriate means. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Service after the effective date of any modified Privacy Policy indicates your acknowledging that the modified Privacy Policy applies to your interactions with the Service and our business.

Retention

We retain personal data for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for compliance and protection purposes, unless specifically authorized to be retained longer.
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 unauthorized 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.
When we no longer require the personal data, we have collected about you, we will either delete or anonymize it or, if this is not possible (for example, because your personal data has been stored in backup archives), then we will securely store your personal data and isolate it from any further processing until deletion is possible. If we anonymize your personal data (so that it can no longer be associated with you), we may use this information indefinitely without further notice to you.

How to contact us

Email: [email protected]
Mail: Rearsby Business Park, Unit 5, St George's House Business Park, Gaddesby Ln, Rearsby, Leicester LE7 4YH
Phone: 01664 423000

Privacy Policy

Controller. W F Howes Limited is the controller in respect of the processing of your personal data covered by this Privacy Policy for purposes of European data protection legislation (i.e., the EU GDPR and the so-called ‘UK GDPR’ (as and where applicable, the “GDPR”)).