Privacy and Cookie Policy 

1. Introduction and Purpose of this Privacy and Cookie Policy

1.1 UTV Products Ltd (hereinafter referred to as “we,” “us,” or “our”) is a registered company in England and Wales with company number 08457428. Our registered address is located at 316 Blackpool Road, Fullwood, Preston. This Privacy and Cookie Policy outlines our commitment to safeguarding the privacy of our website visitors.

1.2 The purpose of this Privacy and Cookie Policy is to explain how we collect and process your personal information when you use our website. This includes any data you provide when purchasing a product or service, or any other data you may provide to us.

1.3 When you visit our website for the first time, we will ask for your consent to use cookies in accordance with the terms outlined in this Privacy and Cookie Policy.

1.4 It is essential that you read this Privacy and Cookie Policy along with any other privacy policy or fair processing notice we may provide on specific occasions when we collect or process your personal data. This way, you will be fully aware of how and why we use your data. Please note that this policy supplements other notices and is not intended to override them.

1.5 Our website is not designed for children, and we do not knowingly collect data relating to children.

2. Controller and Third-Party Links

2.1 We act as the controller and are responsible for your personal data.

2.2 We have appointed a Data Privacy Manager who oversees all questions related to this Privacy and Cookie Policy. If you have any inquiries or requests to exercise your legal rights, please contact our Data Privacy Manager at sales@UTVproducts.co.uk.

2.3 If you have any concerns regarding your data, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). However, we encourage you to contact us first so that we can address your concerns.

2.4 Our website may contain links to third-party websites, plug-ins, and applications. When you click on these links or enable such connections, you may allow third parties to collect or share data about you. Please note that we do not control these third-party websites and are not responsible for their privacy statements. We recommend that you read the privacy policy of every website you visit when leaving our website.

3. Collecting Personal Data

3.1 Personal data, also known as personal information, refers to any information about an individual through which that person can be identified. It does not include data where the identity has been removed (anonymous data).

3.2 We may collect, use, store, and transfer various types of personal data about you, which we have grouped as follows:

• Identity Data, which includes your first name, last name, username, or similar identifier.
• Contact Data, which includes your billing address, delivery address, email address, and telephone numbers.
• Financial Data, which includes your bank sort code, account details, and payment card information.
• Transaction Data, which includes details of payments made to and from you, as well as other information related to products and services you have purchased from us.
• Technical Data, which includes your internet protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system, and other technology on the devices you use to access our website.
• Profile Data, which encompasses your username and password, purchase or order history, interests, preferences, feedback, and survey responses.
• Usage Data, which consists of information on how you use our website, products, and services, including traffic data.
• Marketing and Communications Data, which covers your preferences in receiving marketing communications from us and our third parties, as well as your communication preferences.

3.3 Additionally, we may also collect, use, and share Aggregated Data, which includes statistical or demographic data for various purposes. This data does not directly or indirectly reveal your identity. However, if we combine Aggregated Data with your personal data to identify you directly or indirectly, we will treat the combined data as personal data in accordance with this Privacy and Cookie Policy.

3.4 We do not collect any Special Categories of Personal Data about you, including information about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, health information, genetic or biometric data, or information about criminal convictions and offenses.

3.5 If we are required by law or have a contractual obligation to collect personal data from you, failure to provide the requested data may prevent us from fulfilling the contract or providing the goods and services you seek from us. In such cases, we will notify you if data is necessary for contract performance.

4. Personal Data Collection Methods

4.1 We use various methods to collect data from and about you, including:

• Direct Interactions: You may provide us with Identity, Contact, and Financial Data by filling in forms or corresponding with us through post, phone, email, or other means. This includes data you provide when you apply for our products or services, create an account, subscribe to our services or publications, request marketing information, give us your business card, enter a competition or survey, or provide feedback.
• Automated Technologies or Interactions: As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions, and patterns using cookies, server logs, and similar technologies. We may also receive Technical Data from other websites employing our cookies. For more details on the cookies we use and their purposes, please refer to our Cookie Policy.
• Third Parties or Publicly Available Sources: We may receive personal data about you from third-party analytics providers, advertising networks, providers of technical, payment, and delivery services, the business you represent, businesses referring or introducing you to us, and data brokers and aggregators.

5. Using Personal Data

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

• To perform a contract with you: We use your data to register you as a new customer, manage your account, and fulfill our obligations under any contract we have with you.
• For our legitimate interests: We process your data when it is necessary for our legitimate interests (or those of a third party), provided your interests and fundamental rights do not override these interests. This includes using your data for marketing and advertising, improving our products and services, protecting our business, and managing our website.
• To comply with a legal obligation: We may process your data to fulfill any legal or regulatory obligations we are subject to.

5.2 We generally do not rely on consent as a legal basis for processing your personal data, except in specific circumstances, such as when you are not an existing customer or represent a corporate business and have provided us with your business card or when sending third-party marketing communications via email or text message. You have the right to withdraw your consent for marketing at any time by contacting us.

5.3 Below is a table that outlines all the ways we plan to use your personal data, along with the legal basis for processing it:

Purpose/Activity Type of Data Lawful Basis for Processing

• To register you as a new customer, administer your account, and manage our relationship with you.

Identity, Contact Performance of a contract with you

• To process and deliver your order

5.4  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 where more than one ground has been set out in the table below.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new customer, administer your account and manage our relationship with you	(a) Identity (b) Contact	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to administer your account and manage our relationship with you)
If you are a representative of a business, to manage our relationship with that business or to discharge our contractual obligations to the business that referred your business to us	(a) Identity (b) Contact (c) Transaction	(a) Necessary for our legitimate interests (to manage our relationship with the business you represent, and to discharge our contractual obligations to the business who referred your business to us) (b) Necessary for the legitimate interests of the business you represent (to manage their relationship with us)
To process and deliver your order including: (a) Managing communications traffic (b) Managing payments, fees and charges (c) Preventing and detecting fraud (d) Collecting and recovering money owed to us or otherwise enforcing our legal rights	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Usage (f) Marketing and Communications	(a) Performance of a contract with you (b) Legal obligation (providing accurate billing information) (c) Necessary for our legitimate interests (traffic management; prevention and detection of fraud; recovering debts due to us or otherwise enforcing our legal rights)
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy and cookie policy (b) Asking you to leave a review or take a survey (c) Dealing with enquiries and complaints	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications (e) Financial (f) Transaction (g) Usage	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (providing accurate billing information and handling complaints) (c) Necessary for our legitimate interests (keeping our records updated and to study how customers use our products/services)
To enable you to partake in a promotion 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/services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	(a) 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) (b) Necessary to comply with a legal obligation
To deliver relevant website content and 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/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	(a) Technical (b) Usage	Necessary for our legitimate interests (using diagnostic analytics to assess the number of visitors, posts, page views, reviews and followers in order to optimise future marketing campaigns)
To make suggestions and recommendations to you about goods or services that may be of interest to you	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile	Necessary for our legitimate interests (to develop our products/services and grow our business)

5.5 Use and Publication of Personal Information

5.5.1 If you choose to submit personal information for publication on our website, we may use and publish that information in accordance with the license you grant to us. By providing us with such information, you grant us the right to use, reproduce, modify, adapt, publish, translate, distribute, and display it in any media worldwide. This license will be non-exclusive, royalty-free, and perpetual.

5.6 Marketing Preferences and Opt-out Mechanisms

5.6.1 At UTV Products Ltd, we respect your choices regarding the use of your personal data for marketing purposes. We strive to provide you with control over your data through the following mechanisms:

Promotional Offers from UTV Products Ltd

5.6.2 We may use your Identity, Contact, Technical, Usage, and Profile Data to understand your preferences and interests better. Based on this information, we may tailor marketing communications and offers that we believe may be relevant to you. This process helps us personalize our marketing efforts to enhance your overall experience.

5.6.3 You will receive marketing communications from us if you have requested information or purchased goods or services from us. Additionally, if you provided your details when registering for a promotion and have not opted out of receiving marketing messages, you may receive communications from us.

Prospective Clients

5.6.4 If you are not an existing customer or do not represent a corporate business and have voluntarily provided us with your business card, we may use your Identity and Contact Data to better understand your potential interests or needs. This will allow us to offer products or services that align with your preferences.

Third-Party Marketing

5.6.5 Before we share your personal data with any other company for marketing purposes, we will obtain your express opt-in consent. This means you will have the opportunity to decide whether your data is shared with third parties for marketing purposes.

Opting Out

5.6.6 You have the right to withdraw your consent for receiving marketing messages from us or third parties at any time. To exercise this right, you can contact us through the provided contact information. If you opt out of marketing communications, it will not affect the processing of personal data related to product/service purchases, warranty registrations, product/service experiences, or other transactions.

5.7 Purpose Limitation and Data Compatibility

5.7.1 UTV Products Ltd will only use your personal data for the purposes for which it was originally collected, unless we reasonably consider that another purpose is compatible with the original one. If you wish to understand how the new processing purpose aligns with the original purpose, please contact us for further details.

5.8 Unrelated Purposes and Legal Basis

5.8.1 In the event that we need to use your personal data for a purpose unrelated to the original purpose, we will notify you and explain the legal basis that allows us to do so. Our goal is to ensure transparency in all data processing activities and respect your rights.

5.9 Legally Required or Permitted Processing

5.9.1 In compliance with applicable rules and regulations, there may be instances where we process your personal data without seeking your knowledge or consent. We will always abide by the legal principles governing such processing activities.

6. Disclosure of Personal Data

6.1 UTV Products Ltd may share your personal data with the following parties for the purposes outlined in section 5:

• Service Providers: We may engage service providers based in the United Kingdom and Republic of Ireland who offer database, IT, and system administration services.
• Marketing Services Providers: We may collaborate with marketing services providers in the United Kingdom and Republic of Ireland to offer direct marketing services.
• Payment Services Providers: In some cases, we may require payment services from providers based in the United Kingdom and Republic of Ireland.
• Specific Third Parties: For certain requested products or services, we may need to share your personal data with specific third parties.
• Businesses Referring Clients: We may share your data with businesses that have referred your business to us.
• Professional Advisers: We may involve professional advisers such as lawyers, bankers, auditors, and insurers based in the United Kingdom and Republic of Ireland for consultancy, legal, insurance, and accounting services.
• HM Revenue & Customs and Regulators: In specific circumstances, we may report processing activities to HM Revenue & Customs, regulators, and other authorities in the United Kingdom.
• Business Changes: In the event of selling, transferring, or merging parts of our business or assets, we may share personal data with relevant third parties. If we acquire or merge with other businesses, new owners may use personal data in accordance with this Privacy and Cookie Policy.

6.2 All third parties receiving personal data are required to respect its security and process it lawfully. We do not allow third-party service providers to use personal data for their own purposes, and they can only process it for specified purposes following our instructions.

7. International Data Transfers (For UK Residents)

7.1 Transfers of personal data outside the United Kingdom and Republic of Ireland are subject to special rules under UK Data Protection Legislation.

7.2 We may also transfer your personal data to providers based in the European Economic Area (EEA). The UK Government recognizes the EEA as providing an appropriate level of protection for individuals’ data protection rights.

8. International Data Transfers (For EEA Residents)

8.1 Transfers of personal data of individuals based in the EEA outside the EEA are subject to special rules under EU Data Protection Legislation.

8.2 If you are based outside the EEA, we may receive and transfer your personal data to the country where you are based. We have entered into the Standard Contractual Clauses with worldwide subsidiaries and other parties based in the EEA to safeguard your personal data.

9. Security of Personal Data

9.1 UTV Products Ltd prioritizes the security of your personal data and has implemented appropriate measures to prevent unauthorized access, disclosure, alteration, or loss of your data. We limit access to personal data to authorized personnel, agents, contractors, and other third parties who require the information for legitimate purposes. These entities process data on our instructions and are bound by confidentiality obligations.

9.2 In the event of a suspected personal data breach, we have established procedures to handle such incidents and will notify you and relevant regulators as required by law.

9.3 Please note that while we take all reasonable measures to secure your data, the transmission of information over the internet is inherently insecure. Therefore, we cannot guarantee the absolute security of data sent over the internet.

9.4 It is your responsibility to keep your password confidential when accessing our website. We will never ask you for your password unless you log in to our website.

10. Retention of Personal Information

10.1 We will retain your personal data for as long as necessary to fulfill the purposes for which it was collected, including legal, accounting, or reporting requirements.

10.2 To determine the appropriate retention period, we consider the nature, sensitivity, and purpose of the personal data, the potential risk of unauthorized use or disclosure, and the applicable legal requirements.

10.3 In certain cases, we may anonymize your personal data for research or statistical purposes. Anonymized data may be used indefinitely without further notice.

11. Updating Information

11.1 Ensuring the accuracy and currency of your personal data is essential. Please inform us promptly if your personal data changes during your relationship with us.

12. Your Legal Rights

12.1 Under data protection laws, you have certain rights regarding your personal data. We are committed to upholding these rights and providing you with the necessary information and assistance to exercise them effectively. Below are the rights you have in relation to your personal data:

(a) Request Access to Your Personal Data

12.1.1 You have the right to request access to the personal data that we hold about you. This is commonly known as a “data subject access request.” Upon receiving such a request, we will provide you with a copy of the personal data we have and confirm that we are lawfully processing it.

(b) Request Correction of Your Personal Data

12.1.2 If you believe that the personal data we hold about you is inaccurate or incomplete, you have the right to request the correction of such data. Upon receiving your request, we will verify the accuracy of the data and correct any errors promptly.

(c) Request Erasure of Your Personal Data

12.1.3 You have the right to request the erasure of your personal data when:

• The data is no longer necessary for the purposes for which it was collected.
• You withdraw your consent, and there is no other legal basis for processing the data.
• You object to the processing, and there are no overriding legitimate grounds for continued processing.
• The data has been unlawfully processed.
• Erasure is required to comply with legal obligations.

12.1.4 Please note that certain legal requirements may prevent us from fulfilling your request for erasure in specific circumstances. We will notify you of any applicable legal exceptions when responding to your request.

(d) Object to Processing of Your Personal Data

12.1.5 You have the right to object to the processing of your personal data if it is based on legitimate interests or for direct marketing purposes. We will carefully assess the grounds of your objection and determine if we have compelling legitimate grounds that override your interests.

(e) Request Restriction of Processing of Your Personal Data

12.1.6 You may request the restriction of processing your personal data under certain circumstances. This means we will temporarily suspend the processing of your data, usually while we assess the accuracy or lawfulness of the data.

(f) Request the Transfer of Your Personal Data

12.1.7 Upon your request, we will provide you or a third party you have chosen with your personal data in a structured, commonly used, and machine-readable format. This right applies to data that you initially provided consent for or that we used to perform a contract with you.

(g) Right to Withdraw Consent

12.1.8 If we process your personal data based on your consent, you have the right to withdraw that consent at any time. Withdrawing consent will not affect the lawfulness of processing that occurred before your withdrawal.

12.2 Exercising Your Rights

12.2.1 To exercise any of the rights listed above or if you have any questions regarding your rights, please contact us using the provided contact information. We will respond to all legitimate requests within one month. If your request is complex or involves multiple requests, we may extend the response time, but we will notify you and keep you informed of the progress.

12.2.2 In some cases, we may need to verify your identity or request additional information to process your request effectively. This is a security measure to ensure that personal data is not disclosed to unauthorized individuals.

13. About Cookies

13.1 Our website uses cookies to distinguish you from other users and improve your browsing experience. Cookies are small files stored on your browser or computer’s hard drive if you agree. These files contain information that helps us provide a better user experience and improve our site’s functionality.

13.2 Cookies can be either “persistent” or “session” cookies. Persistent cookies remain on your device until their set expiry date, while session cookies expire when you close your web browser.

13.3 Cookies enable web servers to identify and track users as they navigate different pages on a website, helping to remember users and their preferences.

14. Our Cookies

14.1 Our website utilizes both session and persistent cookies to enhance your browsing experience. You have the option to block cookies by adjusting your browser settings. However, blocking all cookies, including essential ones, may limit your access to certain parts of our site.

14.2 The cookies we use fall into the following categories:

(a) Strictly Necessary Cookies

• These cookies are essential for the operation of our website. They allow you to log into secure areas, use a shopping cart, or access e-billing services.

(b) Analytics/Performance Cookies

• These cookies help us analyze website usage by counting the number of visitors and tracking their movements. This information helps us improve the website’s functionality and user experience.

(c) Functionality Cookies

• Functionality cookies recognize you when you return to our website, enabling us to personalize content and greet you by name. These cookies remember your preferences, such as language or region choices.

(d) Targeting Cookies

• Targeting cookies record your visit, the pages you viewed, and the links you followed. We use this data to make our website and advertisements more relevant to your interests. In some cases, we may share this information with third parties for similar purposes.

14.3 Third-Party Cookies

14.3.1 Our website may also use third-party cookies, such as those from embedded YouTube videos. These cookies are likely to be analytical/performance cookies or targeting cookies.

14.3.2 Please note that we have no control over third-party cookies used by our website, such as advertising networks or web traffic analysis services. Third-party cookies may track your online activities and tailor advertisements to your interests based on your browsing history.

15. Analytics Cookies

15.1 We utilize Google Analytics to analyze the use of our website and gather valuable insights into user behavior.

15.2 Google Analytics generates statistical information about website usage through cookies.

15.3 The analytics cookies used by our website have the following names: _ga, _gat, __utma, __utmt, __utmb, __utmc, __utmz, and __utmv.

15.4 The information generated by these cookies helps us create reports about website usage, allowing us to enhance the user experience.

15.5 Google Analytics’ privacy policy is available at: https://policies.google.com/privacy?hl=en.

16. Third-Party Cookies

16.1 Additionally, our website uses cookies from third-party providers to enhance user experience and functionality. Some examples of third-party cookies on our website include:

(a) what3words.com (id)

(b) zopim.io (_cfduid, cookie_utm_last_touch, refer_info, zte2095)

(c) Google.com (DSID, IDE)

16.2 Third-party cookies are managed and controlled by the respective providers, and we do not have direct control over their data processing practices. For more information about these providers’ privacy policies and their use of cookies, please refer to their respective websites.

17. Glossary

17.1 Lawful Basis

• Comply with a legal or regulatory obligation: Processing personal data when necessary to comply with legal or regulatory requirements that we are subject to.
• Legitimate Interest: Processing personal data based on the legitimate interests of our business to provide the best services and experiences while considering your rights and interests.
• Performance of Contract: Processing personal data when necessary to fulfill a contract you are a party to or take steps at your request before entering into a contract.

18. Your Legal Rights

18.1 You can exercise your rights in relation to your personal data by contacting us using the provided contact information. Please note the following:

• Request access, correction, erasure, restriction, or transfer of your personal data: Generally, we will not charge you for these requests unless they are unfounded, excessive, or repetitive. We may need to verify your identity before processing your request to protect your data.
• Object to processing: If we rely on legitimate interests for processing your data, you have the right to object. We will assess the request and cease processing unless we have compelling legitimate grounds.
• Withdraw consent: If we rely on consent, you have the right to withdraw it at any time. This will not affect prior processing based on your consent.

18.2 We aim to respond to all legitimate requests within one month. If your request is complex or numerous, we may extend the response time, but we will inform you and keep you updated throughout the process.

19. Amendments

19.1 We may update this Privacy and Cookie Policy from time to time by publishing a new version on our website.

19.2 The last update was on 01 September 2022. For historical versions of the policy, please contact us at sales@UTVproducts.co.uk.

19.3 We encourage you to check this page occasionally to stay informed of any changes.

19.4 We may also notify you of significant policy changes by email or through the private messaging system on our website.

In conclusion, UTV Products Ltd is committed to safeguarding your privacy and protecting your personal data. This comprehensive Privacy and Cookie Policy outlines our data practices and your rights regarding the information we collect. If you have any questions or concerns about this policy or your personal data, please do not hesitate to contact us. Your privacy and trust are of utmost importance to us, and we will always strive to be transparent and responsible custodians of your data.