Privacy Notice

Privacy Notice

WEBSITE PRIVACY POLICY

Welcome to A.B. Distributors Limited's trading as Gowan Home(we, us, “Gowan Home” or A.B. Distributors) website privacy policy. Gowan Home respects your privacy and is committed to protecting your personal data.

This privacy policy (policy) will inform you as to how we look after your personal data when you visit our website www.gowanhome.co.uk(our website) (regardless of where you visit it from). It aims to give you information on how we collect and process your personal data through your use of our website, including any data you may provide through our website when you contact us.

This policy also informs you about your privacy rights and how the law protects you. It does not cover any third-party website you have used to access our website or any third-party websites that you access from our website.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this policy together with any other privacy policy or fair processing policy we may provide 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 other notices and privacy policies and is not intended to override them.

1. IMPORTANT INFORMATION AND WHO WE ARE

1.1             CONTACT DETAILS

Our full details are:

Full name of legal entity: A.B. Distributors  Limited, a company incorporated in Northern Ireland under registered company numberNI008366.

Email address: mail@gowanhome.co.uk

Postal address: 2 Cromac Place, The Gasworks, Ormeau Road, Belfast, BT7 2JB

1.2             Under the UK General Data Protection Regulation or the EU General Data Protection Regulation (collectively GDPR) and other relevant data protection legislation, Gowan Home acts as the controller and is responsible for your personal data.

When Gowan Home collects personal data and determines the purposes and means of processing that personal data – for example, when Gowan Home stores information for administration, services access, or contact information as explained below – Gowan Home acts as a controller.

1.3             THIRD-PARTY LINKS

Our 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.

1. WHAT KIND OF PERSONAL DATA DO GOWAN HOME PROCESS?

INFORMATION YOU SUPPLY TO US

2.1             General Personal Data: This is personal information about you that you share with us as user of our website by online forms on our website, through email, through post, on the telephone, engage with our customer services team, or by any other means.

You may also provide personal data when you report any technical or service issues in relation to our websites, including relevant notes about any issues and how we responded to resolve these.

PERSONAL DATA WE COLLECT

2.2             Technical Data from our Website: We may use certain technical services (such as cookies) which gather technical data online whenever you interact with our website (as a visitor) including information about your device and your visits to our websites such as your IP address, geographical location, browser type, referral source, internet service provider (ISP), clickstream data, browser type and language, time zone, length of visit and pages viewed, date or time stamps weblogs and other communication data

You are not personally identifiable from any of the technical data we collect using such services.

personal data we receive from third-parties

2.3             Device Data: we may receive personal information from advertising networks such as Google based outside the EU; and search information providers such as Google based outside the EU.

2.4             Publicly Available Information: we may collect personal information about you from other publicly available sources. This can include your name, address and other publicly available information. As far as passible, we ensure that where any third-parties are involved in suppling such information, that they are compliant to do so. This may include credit reference agencies such as Experian, public registers such as the Companies House registry or the Electoral Register.

KEEPING YOUR PERSONAL DATA UP TO DATE

2.5             It is important that the data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

3. WHAT INFORMATION IS NOT COLLECTED?

3.1             We do not intentionally collect sensitive personal data or special category data (including details about your race or ethnicity, religious or philosophical beliefs, medical information, sex life, sexual orientation, political opinions, trade union membership, genetic and biometric data, social security numbers). Nor do we collect any information about criminal convictions and offences.

1. HOW IS INFORMATION USED?

4.1             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:

4.1.1         Where we need to perform the contract we are about to enter into or have entered into with you.

4.1.2         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.

4.1.3         Where we need to comply with a legal or regulatory obligation.

For the avoidance of doubt, the types of lawful basis that we will rely on to process your personal data have the following meanings:

• Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us 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.
• Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract, including for the purposes set out in the “Our Standard Business Operations” section below.
• Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

4.2             Generally, we do not rely on consent as a legal basis for processing your personal data.

4.3             Our Standard Business Operations:

4.3.1         To provide you with information that you request from us; and

4.3.2         To confirm your identity as a natural living person.

4.4             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.

4.5             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 wish to get 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.

4.6             Legal Requirements

We will keep and use your data in terms of any legal or regulatory requirements that we have and can use your data to protect our legal position, if legal action is required, including the recovery of any outstanding debts.

By way of further example, we will share your personal data with the relevant agencies and without notice, where we are requested to or suspect fraudulent activities, money laundering, terrorist related activities.

4.7             Enhancing our Services

We may use personal data for the purposes of providing, enhancing, or improving our IP geolocation, fraud detection, demographic targeting, and other services and products.

4.8             Website Administration and Customisation

We may use the information we collect about you for a variety of website administration and customisation purposes. For example, we use your information to provide you with services and communications that you have requested, send you email updates and other communications, customise features that appear on our websites, deliver our websites content to you, measure Website traffic, measure user interests and traffic patterns, and improve our websites and the services and features offered via our websites.

4.9             Aggregated or Non-Identifying Information

Non-identifying information includes information collected from or about you that does not personally identify you – including aggregated information. Gowan Home treats IP addresses, log file information, user agent strings, computer IDs, and related information as non-identifying information, except if applicable law suggest us to do otherwise. Gowan Home may use non-identifying information for any purpose.

We may also combine your non-identifying information with third party data sources (including data obtained from offline sources and data obtained from our users using the Services) in our effort to improve our Services. We may share such non-identifying information with users, affiliates, and other third parties for any purpose.

Certain jurisdictions, including the European Union, may deem IP addresses and/or Unique IDs, to be personal data. Accordingly, for persons in such jurisdictions, our use of Non-Identifying Information as described in this policy should be assumed to include IP address and Unique ID data.

1. WHAT INFORMATION IS SHARED?

5.1             We may share your personal data with the parties set out below for the purposes set out in above.We do not disclose personal data outside Gowan Home, except in the situations listed in this section or in the section below on Compelled Disclosure, but may have to share your personal data with the categories of processors or controllers set out below for the purposes set out above or otherwise below:

5.1.1         any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006;

5.1.2         with your employer or the other person or entity by whom you have been authorised to contact us, who can access all information you input, store or process using our website;

5.1.3         with HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances);

5.1.4         with third party purchasers, if we buy, sell or merge any business or assets of our business and are required to share data as part of the buying, selling or merger agreement or if our assets are acquired by a third-party, and data is transferred as part of the purchased assets. If any such change happens, we will ensure that it is under terms that preserve the confidentiality of your personal data, and we will notify you on our website or by email before any transfer of your personal data. Any purchaser would be bound by the terms of this policy;

5.1.5         with professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services, where they have a need to know same for any of the purposes set out above

5.1.6         with reputable and trusted third-parties where we have asked them to contact you on our behalf, where you have given us consent, it is part of our contractual agreement, is a legal requirement or there is clear legitimate interest between us (these services may include sending you email, calling you by telephone, sending you information through the post etc.);

5.1.7         with specific selected third parties, determined by us, if you breach any agreement with us, including so as to enforce our rights against you, including credit-reference agencies, debt-collection firms or service providers, solicitors or barristers and law enforcement agencies (if applicable) and

5.1.8         with service providers acting as processors based in the European Union or United Kingdom or the United States who provide IT and system administration services, including for the performance of our contract with you, as set out below: When we transfer your data to our service providers, we remain responsible for it:

• with processors offering software tools, or EU, UK or USA based external servers (including externally provided original and backup servers), that are used to store personal data provided by you on our behalf. By default, and unless we have agreed otherwise in writing with the location of these servers will be within the UK or EU where the organisation on whose behalf you are using the Services is based in the UK or EU, or the USA, where the organisation on whose behalf you are using the Services is based in the USA has requested this.

5.2             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 the minimal personal data required for the specified purposes, in accordance with our instructions, where they have agreed to privacy restrictions similar to our own policy.

5.3             We do not share, sell, rent, or trade personal data with third parties for their commercial purposes.

5.4             We may also share personal data with your permission, so we can perform services you have requested.

1. HOW IS MY INFORMATION SECURED?

6.1             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.

6.2             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.

1. HOW IS INFORMATION COLLECTED AND STORED GLOBALLY?

7.1             Information that we collect will be stored and processed in the United Kingdom in accordance with this policy. / We share your personal data within the Gowan Home Group. This will involve transferring your data outside the UK.

7.2             However, where any of the third party service providers listed above have access to personal data, they must comply with applicable data privacy laws, including signing data transfer agreements such as EU standard contractual clause agreements, where required by law.

7.3             In particular:

7.3.1         we provide clear methods of unambiguous, informed consent at the time of data collection, when we do collect your personal data and if applicable. Where consent is not the applicable ground for processing, we will ensure that it has an appropriate ground for processing any personal data (including but not limited to contractual obligation or legitimate interest);

7.3.2         we collect only the minimum amount of personal data necessary, unless you choose to provide more. We encourage you to only give us the amount of data you are comfortable sharing;

7.3.3         we offer you simple methods of accessing, correcting, or deleting the data we have collected; and

7.3.4         we provide our users notice, choice, accountability, security, and access, and we limit the purpose for processing. We also provide our users a method of recourse and enforcement.

1. WHAT HAPPENS IF I HAVE A COMPLAINT?

8.1             If you have concerns about the way Gowan Home is handling your personal data, please let us know immediately. We want to help and there are several ways available that you can contact us. You may also email us directly at  mail@gowanhome.co.uk with the subject line "Data Privacy". We will respond within the relevant timeframes required under data protection legislation.

8.2             If you are a data subject based in the UK or European Union, you may 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), or other competent supervisory authority of an EU member state if the Services are accessed outside the UK. We would appreciate the chance to deal with your concerns before you approach such bodies so would ask that you please contact us in the first instance.

1. HOW DO YOU RESPOND TO COMPELLED DISCLOSURE REQUIREMENTS?

9.1             Gowan Home may disclose personal data or other information we collect about you to law enforcement in response to a valid subpoena, court order, warrant, or similar governmental order, or when we believe in good faith that disclosure is reasonably necessary to protect our property or rights, or those of third parties or the public at large.

9.2             In complying with court orders and similar legal processes, we strive for transparency. When permitted, we will make a reasonable effort to notify users of any disclosure of their information, unless we are prohibited by law or court order from doing so, or in rare, exigent circumstances.

10. HOW CAN I ACCESS MY OWN PERSONAL INFORMATION?

10.1           Under certain circumstances, where you are a citizen of the European Union or UK, you have rights under data protection laws in relation to your personal data under GDPR and UK GDPR.

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.
• Please 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 (or object to processing) 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.

If you wish to exercise any of the rights set out above, please contact us.

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.

Where you exercise one of your rights, we may need to request specific information from you to help us confirm your identity and ensure your right to exercise such 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.

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.

1. DATA RETENTION AND DELETION

Personal Data Generally

11.1           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.

11.2           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. Personal data which Gowan Home considers to be of less relevance to the performance of a contract, such as miscellaneous correspondence or telephone records, may be deleted earlier.

11.3           We will keep your personal data for the term you have consented to, the contracted term between us where there is a legitimate interest for us to remain in contact with you, or for the legally required period, whichever is the longest.

11.4           By law we have to keep basic information about any of our users (including contact, identity, and transaction data) for six years after you cease being a user for tax purposes. For the purposes of contract administration, we will also store all data as long as the contract you have placed through us endures and for the six year limitation period thereafter in case you raise any claims in relation to any services you or your employer or other person by whom you have been authorised to use our services have purchased from us.

11.5           In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

11.6           If you would like to initiate deletion of your personal data, you can contact us to request this.

1. HOW DO YOU COMMUNICATE WITH USERS?

12.1           We will use your email address to communicate with you, if you have confirmed we may do so, and only for the reasons you have permitted. Emails by default are not disclosed with other users, even if you belong to the same organisation.

1. WILL YOUR WEBSITE PRIVACY POLICY CHANGE?

13.1           Unless legally necessary (in which case you will be notified by email), any changes we may make to this privacy notice in the future will be posted on this page without further recourse or notice to you. If there are material changes to this policy or in how we use your personal data, we will prominently post such changes prior to implementing the change. We encourage you to periodically review this policy to be informed of how we are collecting and using your information.

13.2           We keep this policy under regular review, for example, to reflect changing business circumstances and legal developments.

13.3           Although most changes are likely to be minor, it may change and if it does, these changes will be posted on this page. Any changes shall be applicable without further notice.

13.4           This version one of this policy was last updated on 8 July 2022. Historic versions, where applicable, can be obtained by contacting us.

1. HOW CAN I CONTACT GOWAN HOME?

Questions regarding this policy or our information practices should be directed to us via one of the contact methods that we have provided in this policy.

1. LEGAL

This policy shall be governed by and interpreted in accordance with the laws of Northern Ireland and you irrevocably agree that the courts of Northern Ireland shall have exclusive jurisdiction to settle any dispute which may arise out of, under, or in connection with this policy.