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Last updated: February 2022
1. Who we are
This is the Privacy Policy of Shooting Brake Ltd, trading as shootingbrake.com, a company registered in England with company number 13108153 and its registered offices at 73 Park Lane, Croydon, Surrey CR0 1JG. (‘we’, ‘our’, or ‘us’) relates to your use of our website and our mailing list.
We operate the website at www.shootingbrake.com with correspondence address at Shooting Brake Ltd, 15 Reece Mews, Kensington, London, SW7 3HE
We are data controller for the purposes of the UK Data Protection Act 2018 and are responsible for your personal data.
2. Introduction to this Privacy Policy
‘Personal data’ or personal information, means information that clearly identifies you as an individual or which could be used to identify you if combined with other information. Acting in any way on personal data is referred to as ‘processing’. It does not include data where the identity has been removed (anonymous data).
This Privacy Policy describes how we collect, store, transfer and use personal data It tells you about your privacy rights and how the law protects you.
This Privacy Policy applies to personal data collected through our website and through Shooting Brake’s social media platforms and online retail platforms, including Youtube, Facebook, and Instagram.
Except as set out below, we do not share, or sell, or disclose to a third party, any personal data collected through our website.
3. How we collect your personal data
3.1 We use different methods to collect data from and about you, including through:
· Direct interactions: You may give us data by filling in forms or by corresponding with us. This includes personal data you provide when you: enquire about or purchase our services, request marketing to be sent to you, report a problem to us, enter a promotion or give us feedback.
· Third parties, service providers or publicly available sources. We may confirm some of the personal data you provide to us directly using data from other sources. We may also use other sources to add to the personal data we hold about you, sometimes to remove the need for you to provide it to us.
· For example, we may receive data from analytics providers such as Google or from a service provider such as our payment service provider, Stripe.
· Automated technologies or interactions. As you interact with our website, we will automatically collect data about your equipment, browsing actions and patterns as a result of monitoring how you use our website or our services.
3.2 Types of personal data we may collect from direct interactions
You will be able to access and browse our website without providing any personal data, however there are some actions that will require you to register for an account and log in e.g., to place a listing, to bid on a listing, or to comment on a listing. When you register as a shooting-brake.com user and when you buy a listing support package from us, we ask you to provide personal data. This can be categorised into the following groups:
· personal identifiers, such as your first and last names, your title and your date of birth
· contact information, such as your email address, your telephone number and your postal addresses for billing, delivery and communication
· account information, including your username and password
· payment information, such as a debit or credit card number and expiry date and bank account details
· records of communication between us including messages sent through our website, email messages and telephone conversations
· marketing preferences that tell us what types of marketing you would like to receive
· information you contribute to our community, including public comments
· information you give us in your capacity as a referral partner regarding visitors that you have referred to us, such as [insert]
3.3 Types of personal data we may collect from third parties, service providers or publicly available sources
· We may use third parties, service providers or publicly available sources to collect: information (First Name, Last Name, email, username, encrypted password, phone number, post code, address, city, country) that confirms your identity
· information that confirms your contact information and address
· indication of any fraudulent activity on your payment card
3.4 Types of personal data we collect from automated technologies or interactions
As you interact with our website, we may automatically collect:
· your username and password and other information used to access our website and our services
· technical information about the hardware and the software you use to access our website and use our services, including your Internet Protocol (IP) address, your browser type and version and your device’s operating system, time zone setting and location, plug-in types and versions, mobile numbers and type of tablet, IMEI number
· usage information, including the frequency you use our services, the pages of our website that you visit, whether you receive messages from us and whether you reply to those messages
· transaction information that includes the details of the services you have bought from us and payments made to us for those services
· your responses and actions in relation to your use of our services.
We do not collect any Special Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
3.5 Our use of aggregated information
We, or our third-party suppliers, such as the company which hosts our website, may also collect, use and share aggregated anonymous information such as statistical or demographic data, page view and conversion data for any purpose. Aggregated anonymous information is that which does not identify you as an individual. Aggregated information may be derived from your personal data but is not considered personal data in law because it does not reveal directly or indirectly your identity.
For example, we or they may aggregate usage information to assess whether a feature of our website is useful.
However, if we combine or connect aggregated information with your personal data so that it can identify you in any way, we treat the combined information as personal data, and it will be used in accordance with this Privacy Policy.
4. How we use your personal data
We will use your personal data for the following purposes:
· to register you as a new customer
· to provide services to you
· to acknowledge, confirm or send receipts for any services you purchase from us
· to deal with enquiries, complaints and feedback from you and our service providers
· to manage payments, fees and charges and collect and recover money owed to us
· to manage, improve, protect and administer our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
· for our internal business and technical operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes and as part of our efforts to keep our Site secure
· to enforce or apply other of our terms or to investigate potential breaches of them
· to our data analysis service provider, Google Analytics. Google uses data collected from the Site to track and examine the use of the Site, to prepare reports on its activities and may share them with other Google services. If you enable ‘Do Not Track’ in your web browser, the application of Google Analytics can be reduced
· to notify you of changes to our website, services, terms or this Privacy Policy
· to enable you to participate in a prize draw, promotion, competition or survey
· if you have consented, to send you newsletters, surveys and other communications. If you complete a survey for us, we may process the information you choose to submit in response
· To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you, or
· to resolve any disputes
5. Disclosures of your personal data
We may share your personal data in accordance with this policy with the following third parties:
· selected third parties who act on our behalf to support our operations, for example our IT suppliers, payment service providers to take payments from you, website service providers, communications tools providers, CRM providers, fraud prevention agencies and credit reference agencies;
· an acquirer if we, or substantially all of our assets, are acquired;
· a prospective seller or buyer if we sell or buy any assets;
· law enforcement or regulatory agencies if we are under a legal or regulatory obligation to do so; and
· other companies and organisations for the purposes of fraud protection and credit risk reduction, or to protect the rights, property, or safety of Northshore, Our users, suppliers, contractors or others.
· Another user of our services, provided that you consent, in the event of a dispute between you and that user
· we may pass your contact information to advertising agencies to use to promote our services to you
6. Cookies
Cookies are small text files that are placed on your computer's hard drive by your web browser when you visit a website that uses them. They allow information gathered on one web page to be stored until it is needed for use at a later date.
They are commonly used to provide you with a personalised experience while you browse a website, for example, allowing your preferences to be remembered.
They can also provide core functionality such as security, network management, and accessibility; record how you interact with the website so that the owner can understand how to improve the experience of other visitors; and serve you advertisements that are relevant to your browsing history.
Some cookies may last for a defined period of time, such as one visit (known as a session), one day or until you close your browser. Others last indefinitely until you delete them.
Your web browser should allow you to delete any cookie you choose. It should also allow you to prevent or limit their use. Your web browser may support a plug-in or add-on that helps you manage which cookies you wish to allow to operate.
The law requires you to give explicit consent for use of any cookies that are not strictly necessary for the operation of a website.
When you first visit our website, we ask you whether you wish us to use cookies. If you choose not to accept them, we shall not use them for your visit except to record that you have not consented to their use for any other purpose.
If you choose not to use cookies or you prevent their use through your browser settings, you may not be able to use all the functionality of our website.
We use cookies in the following ways:
· to track how you use our website
· to record whether you have seen specific messages we display on our website
· to keep you signed into our website
· to record your answers to surveys and questionnaires on our site while you complete them
· to record the conversation thread during a live chat with our support team
We use cookies to remember your preferences and track your ads, for this reason, you must have cookies enabled in your browser to use our Site and Services. Additionally, some or all of our cookies may be accessible by third parties. If you do not wish cookies to be placed on your computer or wish to restrict the type of cookies you accept you can adjust the privacy settings of your web browser.
You can manage cookies yourself and learn more about them, including how to block them or delete them, at: http://www.direct.gov.uk/managingcookies or http://www.aboutcookies.org/ .
7. Re-marketing
Re-marketing involves placing a ‘tracking technology’ such as a cookie, a ‘web beacon’ (also known as an ‘action tag’ or a ‘single-pixel GIF’) to track which pages you visit and to serve you relevant adverts for our services when you visit some other website.
A benefit of re-marketing technology is that we can provide you with more useful and relevant adverts, and not show you ones repeatedly that you may have already seen.
We may use a third-party advertising service to provide us with re-marketing services from time to time. If you have consented to our use of such tracking technologies, you may see advertisements for our products and services on other websites.
8. Your posts on our website
Our website allows you to post information with a view to that information being read, copied, downloaded, or used by other people.
For example, when you create a listing, comment on a listing, or reply to a comment on a listing on our website, we will reasonably assume that you consent for the text/message to be seen by others.
We may include your username with your message, and your message may contain information that is personal data e.g., your email or telephone number, e.g., in order to arrange a viewing.
In posting personal data in this way, it is up to you to satisfy yourself about the privacy level of every person who might see and/or use it. We have no control over what any individual third party may do with it. We accept no responsibility for their actions at any time
We store your posts, but do not currently use the information contained within them except to allow your post to be displayed or shared.
Provided there is no legal basis for us to retain it, then we may agree to delete personal data that you have posted on our website upon request. You can make a request by contacting us via email to: sbsupport@shootingbrake.com or via the Contact Us section on our website.
9. The bases on which we may process your personal data
The law requires us to determine under which of certain defined bases we process different categories of your personal data, and to notify you of the basis for each category.
If a basis on which we process your personal data is no longer relevant, then we shall immediately stop processing your data.
If the basis changes, then if required by law we shall notify you of the change and of any new basis under which we have determined that we can continue to process your personal data.
We may process your personal data under the following bases:
When you create an account on our website, buy a service from us, or otherwise agree to our terms and conditions, a contract is formed between you and us.
In order to carry out our obligations under that contract, we may process the information you give us. Some of this information may be personal data. We may use it in order to:
· verify your identity for security purposes when you use our services
· provide you with our services
· provide you with suggestions and advice on products, services and how to obtain the most from using our website
We process this information on the basis there is a contract between us, or that you have requested we use the information before we enter into a legal contract.
We will continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.
Through certain actions when otherwise there is no contractual relationship between us, such as when you browse our website or ask us to provide you more information about our services, you provide your consent to us to process information that may be personal data.
Wherever possible, we aim to obtain your explicit consent to process this information, for example, we may ask you to agree to our use of certain cookies when you access our website.
We will continue to process your personal data on this basis until you withdraw your consent, or until it can be reasonably assumed that your consent no longer exists.
You may withdraw your consent at any time by instructing us via email at sbsupport@shootingbrake.com or via the Contact Us section on our website.
However, if you do so, you may not be able to use our website or our services further.
We aim to process your personal data with your consent wherever possible. However, while we take your consent into account in decisions about whether or not to process your personal data, the withdrawal of your consent does not necessarily prevent us from continuing to process it. The law may allow us to continue to process your personal data, provided that there is another legitimate basis on which we may do so. For example, we may have a legal obligation to do so.
We may process personal data on the basis there is a legitimate interest, either to you or to us, of doing so.
Where we process your personal data on this basis, we do after having considered:
· whether the same objective could be achieved through other means
· whether processing (or not processing) might cause you harm
· whether you would expect us to process your data, and whether you would, in the round, consider it reasonable to do so
For example, we may process your data on this basis for the purposes of:
· improving our services
· record-keeping for the proper and necessary administration of our site
· responding to an unsolicited communication from you to which we believe you would expect a response
· preventing fraudulent use of our services
· exercising our legal rights, including to detect and prevent fraud and to protect our intellectual property
· insuring against or obtaining professional advice that is required to manage our business risk
· protecting your interests where we believe we have a duty to do so
Sometimes, we will process your personal data in order to comply with a statutory obligation. For example, we may be required to give your personal data to legal authorities if they so request and if they have the proper authorisation such as a search warrant or court order. 4.5 Personal data we Personal data we process to protect vital interests
In situations where processing personal data is necessary to protect someone’s life, where consent is unable to be given and where other lawful bases are not appropriate, we may process personal data on the basis of vital interests. For example, we may inform relevant organisations if we have a safeguarding concern about a vulnerable person.
10. Your Legal rights
· to access your personal data, and some related data (your right of access), 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.
· to require any inaccurate personal data that we hold about you to be corrected or deleted (your right to rectification). We may need to verify the accuracy of any new data you provide to us.
· in certain circumstances to require us to delete your personal data (your right to erasure). 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.
· to object to our use of your personal data (your right to object to processing). You may object to our processing 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 certain circumstances to require us to restrict or block the processing of your personal data (your right to restriction of processing); This enables you to ask us to suspend the processing of your personal data in the following scenarios:
· If you want us to establish the data's accuracy.
· Where our use of the data is unlawful, but you do not want us to erase it.
· 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.
· You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
· to obtain your personal data from us, in a structured, commonly used and machine-readable format in certain circumstances (your right to data portability). We will provide you, or a third party you have chosen with your personal data in a structured, commonly used, machine-readable format.
· to 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.
· 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.
· 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.
· We try to respond to all legitimate requests within one month. Occasionally it could 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.
· 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.
11. Data Security
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 us, you can check that it is done so using SSL by looking for a closed padlock symbol or other trust mark in your browser’s URL bar or toolbar.
While we take measures to protect you and your data, we also recommend that you use anti-virus software, routine credit checks, firewalls, and other precautions to protect yourself from security and privacy threats.
12. Where your personal data is processed
Our websites are hosted in the UK.
In order for us to provide our services, your personal data may be transferred to - and maintained on - computers or servers located outside of your =country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. This is because our suppliers, or staff working for them, may operate in countries around the world. These staff may for example be engaged in the fulfilment of your request or the processing of your payments or provide IT support services to us.
We may transfer personal data to and/or outside of the UK and process it there. Your consent to this Privacy Policy and your submission of such personal data represents your agreement to that transfer.
13. Communications with you using third party communication software
With your consent, we may communicate with you using software provided by a third party such as Facebook (WhatsApp), Apple (Facetime), Microsoft (Skype) or Zoom Video Communications (Zoom).
Whilst the providers of such software should comply with all applicable privacy laws, rules, and regulations, including the GDPR, we have no control over such providers are not responsible for their actions.
If you have any concerns about using a particular software for communication or would prefer that we contact you via alternative means, please tell us.
14. Third-party advertising on our website and links to third-party websites on our website
Third parties may, in the future, advertise on our website. In doing so, those third parties may use technology that automatically collects information about you when their advertisement is displayed on our website. They may also use other technology such as cookies or JavaScript to personalise the content of, and to measure the performance of their adverts.
We do not have control over these technologies or the data that these parties obtain. Accordingly, this Privacy Policy does not cover the data privacy practices of these third parties.
Our website may contain 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. For privacy information relating to these third-party websites, please consult their privacy policies. We do not control third-party websites and are not responsible for their privacy practices and/or actions.
We will inform you before collecting your personal data if we intend to use your personal data for marketing purposes or if we intend to disclose your information to any third party for marketing purposes. You have the right to withdraw consent to marketing at any time by contacting us at sbsupport@shootingbrake.com .
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at sbsupport@shootingbrake.com or via the Contact Us page on our website.
16. How long do we keep your personal data?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including:
· to provide you with the services you have requested
· to comply with any legal, regulatory, tax, accounting or reporting requirements
· to support a claim or defence in court
17. Complaints
If you are not happy with any element of this Privacy Policy, or if you have a complaint of any other nature, then you should tell us via email to: sbsupport@shootingbrake.com or via the Contact Us section on our website.
We aim to investigate all complaints relating to user generated content. However, we may not be able to do so as soon as a complaint is made. If we feel that it is justified or if we believe that the law requires us to do so, we shall remove the content while we conduct our investigation.
Making a complaint may not result in the removal of the content. Ultimately, we have to make a judgment as to whose right will be obstructed: yours, or that of the person who posted the content that offends you.
If we think your complaint is vexatious or without any basis, we reserve the right not to correspond with you about it.
If your complaint reasonably requires us to notify another person, we may decide to give that other person some of the information contained in your complaint. We do this as infrequently as possible, but it is a matter for our sole discretion whether we do give information, and if we do, what that information is.
We may also compile statistics showing information obtained from this source to assess the level of service we provide, but not in a way that could identify you.
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.
You have the right to make a complaint to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk) at any time. We would, however, appreciate the opportunity to talk to you about your concern before you approach the ICO.
18. Changes to this Privacy Policy
We keep our Privacy Policy under regular review. Any changes we may make to our Privacy Policy in the future will be posted on this page. Please check back frequently to see any updates. If we make any material changes, we will notify you either by email or when you next visit our website.
19. Contact
Questions, comments or requests regarding this Privacy Policy should be addressed to sbsupport@shootingbrake.com
