Privacy policy

PRIVACY POLICY

Highland Spring Limited, a company incorporated in Scotland and having its registered office at Stirling Street, Blackford, Perthshire, PH4 1QA (“we” or “us”), respect your privacy and are committed to protecting your personal data.

For the purpose of the relevant laws concerning the protection of personal data and information collected by us, including the General Data Protection Regulation (EU) 2016/679 (the “GDPR”) (collectively the “Data Protection Laws”), Highland Spring Limited is the data controller.

Purpose

This privacy policy aims to give you information on how we collect and process your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter, contact us (directly via the website or via post, phone or email using the contact details on the website) or take part in a competition.

Our website is not intended for use by children.

It is important that you read this privacy policy together with any other privacy notice we may provide to you on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements any other notice provided to you and is not intended to override any other notice.

Third-Party Links

This 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 policies, nor how they use your data. When you leave our website, we encourage you to read the privacy policy of every website you visit.

The Data We Collect About You

“Personal data” means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follow:

Identity Data includes first name, surname, title;
Contact Data includes postal address, email address and telephone numbers;
Technical Data includes IP address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website;
Usage Data may include information about how you use our website, products and services; and
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

How is Your Personal Data Collected?

We collect data from and about you through direct interactions and your use of the website. You may give us your identity and contact data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

request services from us;
fill in forms on our website or otherwise post on the website;
use of the website; and
otherwise contact us either directly via the website or by post, e-mail or phone.

How Do We Use Your Personal Data?

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Where you have consented to your personal data being used for a specific purpose, for example to receive marketing communications from us;
Where we need to perform the contract we are about to enter into or have entered into with you;
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; and/or
Where we need to comply with a legal or regulatory obligation.

Purposes for Which We Will Use Your Personal Data

We use your Data:

To enable us to supply you with the goods, services and information which you have requested;
To analyse the information we collect so that we can administer, support, improve and develop our business and services we offer;
To contact you in order to send you details of our goods, services, competitions or other information which may be of interest to you; and
To help us better understand how our website works and to make improvements to give you the most valuable experience.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please Contact Us if you need details about the specific legal ground we are relying on to process your personal data.

We may contact you by post or telephone as well as by e-mail. If you change your mind about being contacted in the future by any of these means then please let us know.

We will not use data to contact you about any third party marketing campaigns.

Marketing

You will receive marketing communications from us if you have requested information from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have provided your consent to receive such marketing communications from us. You have the right to withdraw your consent to marketing at any time by Contacting Us or by using the unsubscribe link at the bottom of the email.

Change of Purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you would like an explanation as to how the processing for the new purpose is compatible with the original purpose, please Contact Us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Disclosures of Your Personal Data

We may disclose your personal data to third parties who act for us for the purposes as set out in this privacy policy or for purposes approved by you, including to suppliers who provide cloud computing or email marketing services. We require any such third parties to respect the security of your data and to treat it in accordance with the law.

In addition, if our business enters into a joint venture with or is sold to or merged with another business entity, your personal data may be disclosed to our new business partners or owners.

Unless required to do so by law, we will not otherwise share, sell or distribute any of the personal data you provide to us without your consent.

International Transfers

The third parties we may share your personal data with may be located outside the European Economic Area (EEA) and therefore transferring the personal data to them will involve transferring your data outside the EEA.

Whenever we transfer your personal data out of the EEA, we use our best endeavours to ensure a similar degree of protection is afforded to it. To do this, we have put in place appropriate measures to ensure that your personal information is treated in a way consistent with the Data Protection Laws and will only transfer personal data outside of the EEA in limited circumstances. We will, at all times, ensure that adequate technical and organisational safeguards are in place to ensure that any personal data transferred remains secure and is protected.

Please Contact Us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

Data Security

The personal data you provide to us will be treated as confidential.

We employ security measures to protect your personal data from access by unauthorised persons and against unlawful processing, accidental loss, destruction or damage.

Please help us keep our records updated by informing us of any changes to your e-mail address and other contact details. Please Contact Us if you require to do so.

How Long Will We Use 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.

Details of retention periods for different aspects of your personal data are available by Contacting Us.

Your Rights

You have the right to:

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.

No Fee Usually Required

You will not have to pay a few 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 may refuse to comply with your request in these circumstances.

What We May Need from You

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 access 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.

Time Limit to Respond

We try to respond to all legitimate requests within 30 days. Occasionally it may take us longer than 30 days 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.

Changes to Our Privacy Policy

We may amend this privacy policy from time to time. If we make any substantial changes we will notify you by positing a prominent notice on our website.

This version was last updated on 14 May 2018.

Contact Details

Our full details are:

Highland Spring Limited

Data Controller

Stirling Street

Blackford

Perthshire

PH4 1QA



Email address: data.protection@highlandspringgroup.com



You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority 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 we ask you please contact us in the first instance.