InstallerCLUB Privacy Policy

This privacy policy sets out how Stuart Turner Limited uses and protects the personal data you share through your InstallerCLUB membership. This privacy policy is provided in a layered format so you can click through to the specific areas set out below.

1. IMPORTANT INFORMATION AND WHO WE ARE

   1. Stuart Turner Limited is the controller and responsible for your personal data (collectively referred to as "we", "us" or "our" in this privacy policy).
   2. If you have any questions about this privacy policy, including any requests to exercise your legal rights (paragraph 9), please contact us using the information set out in the contact details section (paragraph 10).
   3. This privacy policy gives you information about how Stuart Turner Limited collects and uses your personal data through your engagement with InstallerCLUB including becoming an InstallerCLUB Member, including any data you may provide when you:
      1. apply for an InstallerCLUB membership account;
      2. register for extended product warranties;
      3. apply for and attend Stuart Turner training courses;
      4. enter into a prize draw or other competition;
      5. submit an online redemption form for a Reward;
      6. contact us by telephone or email; or
      7. an online enquiry through our enquiry form.
   4. For details of the InstallerCLUB Membership, please visit the InstallerCLUB terms and conditions here. Any defined terms used in this InstallerCLUB privacy policy are defined in the InstallerCLUB terms and conditions.

2. WHAT INFORMATION WE MAY COLLECT ABOUT YOU

   1. Personal data means any information about an individual from which that person can be identified.
   2. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
      
      

      Identity Data	first name, last name, any previous names, username, InstallerCLUB membership number, title, profession, date of birth and gender.
      Contact Data	address, email address and telephone numbers of the InstallerCLUB account holder and any nominated recipients of the Rewards.
      Transaction Data	details about payments to and from you and other details of products you have purchased from us.
      Technical Data	internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access this website.
      Profile Data	your username and password, product warranty registration made by you, total points awarded, details of Rewards redeemed.
      Usage Data	information about how you interact with and use the InstallerCLUB membership on the dedicated section of our website.
      Marketing and Communications Data	your preferences in receiving marketing from us and our third parties and your communication preferences.

      
      
      
   3. We may also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.

3. HOW IS YOUR PERSONAL DATA COLLECTED?

   We use different methods to collect data from and about you including through:

   1. Your interactions with us.	You may give us your personal data by: creating an InstallerCLUB membership account; register for extended product warranties; submit an online redemption form for a Reward; by corresponding with us by phone, email or otherwise; sign up for marketing and special offers to be sent to you; and give us feedback or contact us.
      Automated technologies or interactions.	As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy [LINK] for further details.
      Third parties or publicly available sources.	We will receive personal data about you from various third parties including: Technical Data is collected from analytics providers, advertising networks, and search information providers. Identity and Contact Data is collected from data brokers or aggregators. Identity and Contact Data is collected from publicly available sources

4. HOW WE USE YOUR PERSONAL DATA

   Legal basis

   1. The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:
      
      

      Performance of a contract with you	Where we need to perform the contract we are about to enter into or have entered into with you, for example when you make a Qualifying Purchase and qualify for points to be added to your InstallerCLUB account or when you have completed an online redemption form to redeem a Reward.
      Legitimate interests	We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) 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 impact on you (unless we have your consent or are otherwise required or permitted to by law).
      Legal obligation	We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis. Such legal obligations may include conducting checks to identify you and verify your identity or to communicate with you on changes to our terms and policies, changes to our products or other important notices.
      Consent	We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to our marketing mailing list or you consent to the use of cookies when you first visit our website.

      
      
      Purposes for which we will use your personal data

   2. We have set out below a description of all the ways we plan to use the various categories of your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
      

      Purpose/Use	Type of data	Legal basis
      To register you as a member of InstallerCLUB.	(a) Identity (b) Contact	Necessary for our legitimate interests (of creating customer accounts)
      To credit points to your InstallerCLUB account.	(a) Identity (b) Contact (c) Transaction	Performance of a contract with you
      To deliver Rewards to you.	(a) Identity (b) Contact	Performance of a contract with you
      To manage our relationship with you which will include: (a) Notifying you about changes to our InstallerClub terms and conditions or privacy policy; (b) Dealing with your requests, complaints and queries	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and manage our relationship with you).
      To enable you to take part in a prize draw, competition or complete a survey,	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications	(a) Performance of a contract with you. (b) Necessary for our legitimate interests (to study how customers use our products to develop them, to grow our business and to inform our marketing strategy).
      To administer and protect our business and our InstallerCLUB Membership (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
      To deliver relevant content and online advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical	Necessary for our legitimate interests (to study how customers use our products to develop them, to grow our business and to inform our marketing strategy).
      To use data analytics to improve our website, products, customer relationships and experiences and to measure the effectiveness of our communications and marketing	(a) Technical (b) Usage	Necessary for our legitimate interests (to define types of customers for our products, to keep our website updated and relevant, to develop our business and to inform our marketing strategy).
      To send you relevant marketing communications and make personalised suggestions and recommendations to you about goods that may be of interest to you based on your Profile Data	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications	(a) Necessary for our legitimate interests (to carry out direct marketing, develop our products and grow our business); or (b) Consent, having obtained your prior consent to receiving direct marketing communications.
      To carry out market research through your voluntary participation in surveys	(a) Identity (b) Contact (c) Marketing and Communications.	(a) Necessary for our legitimate interests (to study how customers use our products/services and to help us improve and develop our products and services). (b) Consent, having obtained your prior consent to use your data collected to improve and develop our products and services

      
      
      Direct marketing

   3. You will receive marketing communications from us from time to time.
   4. We may also analyse your Identity, Contact, Technical, Usage and Profile Data to form a view which products and offers may be of interest to you so that we can then send you relevant marketing communications.
      
      Third-party marketing
   5. We will get your express consent before we share your personal data with any third party for their own direct marketing purposes.
      
      Opting out of marketing
   6. You can ask us to stop sending you marketing communications at any time by following the opt-out links within any marketing communication sent to you or by contacting us at sales@stuart-turner.co.uk.
   7. If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes for example relating to product warranty
   registrations, Rewards and communicating updates to our Terms and Conditions.

5. DISCLOSURES OF YOUR PERSONAL DATA

   1. We may share your personal data where necessary with the parties set out below for the purposes set out in the table Purposes for which we will use your personal data above:
      1. third parties who provide products and services that are included in our Reward scheme;
      2. our external auditors, e.g., in relation to the audit of our accounts, in which case the recipient of the information will be bound by confidentiality obligations.
      3. our professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations.
      4. law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations.
      5. other parties that have or may acquire control or ownership of our business (and our or their professional advisers) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised but this may not always be possible. The recipient of any of your personal data will be bound by confidentiality obligations.
   2. 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 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 specified purposes and in accordance with our instructions.

6. INTERNATIONAL TRANSFERS

   1. We do not transfer your personal data outside the UK.

7. DATA SECURITY

   1. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, 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.
   2. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. DATA RETENTION

   How long will you use my personal data for?

   1. By law we have to keep basic information about our customers (including Contact and Identity) for six years after you stop being a customer with us for tax purposes. If you close your InstallerCLUB membership account, we may still retain your details if you continue to purchase goods and services from us.
   2. We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including as follows:
   1. For [x] years for personal data provided as part of your InstallerCLUB membership account, following closure of your InstallerCLUB membership account;
   2. For six years for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.
      We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
   3. 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, regulatory, tax, accounting or other requirements.
   4. In some circumstances you can ask us to delete your data: see paragraph 9 below for further information.

9. YOUR LEGAL RIGHTS

   1. You have a number of rights under data protection laws in relation to your personal data.
   2. You have the right to:
      (a) Request access to your personal data (commonly known as a "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.
      (b) 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.
      (c) Request erasure of your personal data in certain circumstances. 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.
      (d) Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
      (e) You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes (see OPTING OUT OF MARKETING in paragraph 4 for details of how to object to receiving direct marketing communications).
      (f) 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.
      (g) Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
      (i) If you want us to establish the data's accuracy;
      (ii) Where our use of the data is unlawful but you do not want us to erase it;
      (iii) 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
      (iv) You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
   3. If you wish to exercise any of the rights set out above, please contact us see Contact details (paragraph 10) No fee usually required
   4. 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 could refuse to comply with your request in these circumstances. What we may need from you
   5. 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.

10. CONTACT DETAILS

    1. If you have any questions about this privacy policy or about the use of your personal data or you want to exercise your privacy rights, please contact us by emailing sales@stuart-turner.co.uk.

11. COMPLAINTS

    1. You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

12. CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

    1. We keep our privacy policy under regular review. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address.

13. THIRD-PARTY LINKS

    1. Our dedicated InstallerCLUB membership website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.