Terms, conditions & data protection

1. Introduction
   Please read these terms of sale carefully.
   You will be asked to expressly agree to these terms of sale before you place an order for products.
2. Interpretation
   In these terms of sale, “we” means Saffron Bells Ltd (and “us” and “our” will be construed accordingly); and “you” means our customer or potential customer for products (and “your” will be construed accordingly).
3. Order process
   The advertising of products on our website constitutes an “invitation to treat”; and your order for products constitutes a contractual offer. No contract will come into force between you and ourselves unless and until we accept your order in accordance with the procedure detailed below.
   In order to enter into a contract to purchase products from us, you will need to take the following steps:
   (a) you must add the products you wish to purchase to your shopping cart, and then proceed to the checkout;
   (b) you must then enter your delivery details, and confirm your consent to these terms of sale;
   (c) next, you will be given the opportunity to review your order for input errors, and correct any errors using the website interface; and
   (d) to complete your order, you must make payment by submitting your credit or debit card details.
   After you have submitted your credit or debit card details, you will be taken to a confirmation page, which you should print and retain for your records. We will also send you an initial acknowledgement. Once we have checked whether we are able to meet your order, we will either: (i) send you an order confirmation (at which point your order will become a binding contract); or (ii) we will confirm by email that we will not meet your order.
   We reserve the right to refuse to accept any order. Examples of the reasons that an order may be refused include: (i) the product ordered is out-of-stock; (ii) the Address Verification Service (AVS) and/or CV2 code you provide when paying does not match; (iii) the nature of the order has given rise to a suspicion of fraud or potential fraud; or (iv) the delivery address given makes it unusually difficult or expensive to arrange delivery. Where we refuse to accept an order, we will promptly refund to you any amounts paid in respect of the order in accordance with Section 10.
   If we inform you that we cannot meet an order as an item is out-of-stock, we may give you the choice to wait for the item to be in stock, or to cancel the order and receive a refund. In these circumstances, we will provide you with an estimate of when the item will be back in stock – but we cannot guarantee the accuracy of any such estimate.
   We will not file a copy of these terms of sale specifically in relation to your order. We may update the version of these terms of sale on the website from time to time, and we do not guarantee that the version you have agreed to will remain accessible. We therefore recommend that you download, print and retain a copy of these terms of sale for your records.
   The only language in which we provide these terms of sale is English.
4. Price and payment
   Payment must be made upon the submission of your order. We will withhold the products and/or cancel the contract between us if the price is not received from you in full in cleared funds.
   The prices on the website include all value added taxes (where applicable).
   Payment for all products must be made by credit or debit card (the cards accepted are stated on our website from time to time).
   Prices for products are liable to change at any time, but changes will not affect contracts which have come into force in accordance with Section 3.
5. Chargebacks
   If you dispute any payment made to us you must contact us immediately and provide full details of your claim.
   If you submit an unjustified credit or debit card charge-back then you will be liable to pay us within 7 days following the date of the charge-back:
   (a) an amount equal to the amount of the charge-back;
   (b) all third party expenses incurred by us in relation to the charge-back (including charges made by our or your bank or payment processor or card issuer);
   (c) an administration fee of £30; and
   (d) all our reasonable costs, losses and expenses incurred in recovering the amounts detailed above (including without limitation legal fees and debt collection costs).
   Without prejudice to our other rights, if you submit an unjustified credit or debit card charge-back then we may terminate any contracts between you and us under these terms of sale by giving you written notice of termination.
   For the avoidance of doubt and without limitation, if you fail to recognise or remember the source of an entry on your credit or debit card statement, and make a charge-back as a result, this will constitute an unjustified charge-back.
6. Your warranties
   You warrant to us that:
   (a) you are legally capable of entering into binding contracts, and you have full authority, power and capacity to agree to these terms of sale;
   (b) the information provided in your order is accurate and complete;
   (c) you will be able to accept delivery of the products;
   (d) you are at least 18 years of age; and
   (e) the sale of the products purchased by you under these terms of sale to you is not illegal or unlawful under the law of your jurisdiction.
7. Delivery policy
   We will arrange for the products to be delivered to the address for delivery indicated in your order.
   We will use reasonable endeavours to deliver products to any UK delivery address by:
   (a) any delivery date specified by us in your order confirmation or otherwise; or
   (b) if no such delivery date is specified, within 1–3 working days of the date of our order confirmation. However, we cannot guarantee delivery by this date.
8. “Cooling off” period
   This Section applies to consumers only (not business customers).
   Under the Distance Selling Regulations, you may cancel a distance contract to purchase a product or products from us at any time within 7 working days after the day you received the relevant products or products (subject to the limitations set out below).
   In order to cancel a contract in this way, you must give to us written notice of cancellation.
   You will not have any such right insofar as a contract relates to:
   (i) the supply of any products which have been unsealed (or bangles ‘expanded’) by you;
   (ii) the supply of products the price of which is dependent upon fluctuations in financial markets which we cannot control;
   (iii) the supply of goods made to your specifications or clearly personalised.
   If you cancel a contract on this basis, you must promptly return the products to us, in the same condition in which you received them.
   If you cancel a contract on this basis, you will be refunded in full (including the cost of sending the products to you). However, you will be responsible for paying the cost of returning the product to us.
   If you cancel a contract on this basis and you do not return the products to us, we may recover the products and charge you for the costs we incur in doing so. Similarly, if you return the products at our expense, we may pass that expense on to you.
9. Statutory rights
   Nothing in these terms of sale affects your mandatory statutory rights under applicable law.
10. Refunds
    If you cancel a contract and are entitled to a refund, we will usually refund any money received from you using the same method originally used by you to pay for your purchase.
    We will usually process any refund due to you within two working days of the cancellation of the contract or receipt of your valid notice of cancellation. In any event, we will always process such a refund within 30 days of the day of cancellation of the contract or receipt of your valid notice of cancellation.
11. Limitations of liability
    Nothing in the terms of sale will: (a) limit or exclude the liability of a party for death or personal injury resulting from negligence; (b) limit or exclude the liability of a party for fraud or fraudulent misrepresentation by that party; (c) limit or exclude any liability of a party under Section 12, 13, 14 or 15 of the Sale of Goods Act 1979 or Part I of the Consumer Protection Act 1987; (d) limit any liability of a party in any way that is not permitted under applicable law; or (e) exclude any liability of a party that may not be excluded under applicable law.
    The limitations and exclusions of liability set out in the terms of sale: (a) are subject to the preceding paragraph; and (b) govern all liabilities arising under the terms of sale or in relation to the subject matter of the terms of sale, including liabilities arising in contract, in tort (including negligence) and for breach of statutory duty.
    We will not be liable to you in respect of any losses arising out of any event or series of events beyond our reasonable control.
    We will not be liable to you in respect of any business losses.
    We will not be liable to you in respect of any loss of or damage to profits, income, revenue or anticipated savings.
    We will not be liable to you in respect of any loss of use or production.
    We will not be liable to you in respect of any loss of business, contracts or commercial opportunities.
    We will not be liable to you in respect of any damage to goodwill.
    Subject to the first paragraph of this Section 11, we exclude all representations, warranties and conditions relating to the products.
12. General terms
    Both the SAFFRON BELLS logo and its accompanying S device are trade marks belonging to Saffron Bells Ltd.
    Images of products on our website are for illustrative purposes; actual products may differ from such images.
    We will treat all your personal information that we collect in connection with your order in accordance with the terms of our privacy policy; use of our website will be subject to our website terms of use.
    Contracts under these terms of sale may only be varied by an instrument in writing signed by both you and us. We may revise these terms of sale from time-to-time, but such revisions will not affect the terms of any contracts which we have entered into with you.
    If any provision of these terms of sale is held invalid or unenforceable by a court of competent jurisdiction, the remaining provisions will remain in full force and effect, and such invalid or unenforceable provisions or portion thereof will be deemed omitted.
    No waiver of any provision of these terms of sale, whether by conduct or otherwise, in any one or more instances, will be deemed to be, or be construed as, a further or continuing waiver of that provision or any other provision of these terms of sale.
    You may not assign, charge, sub-contract or otherwise transfer any of your rights or obligations arising under these terms of sale. Any attempt by you to do so will be null and void. We may assign, charge, sub-contract or otherwise transfer any of our rights or obligations arising under these terms of sale, at any time – providing, where you are a consumer, that such action does not serve to reduce the guarantees benefiting you under these terms of sale.
    Each contract under these terms of sale is made for the benefit of the parties to it and is not intended to benefit, or be enforceable by, any other person. The right of the parties to terminate, rescind, or agree any amendment, variation, waiver or settlement under such contracts is not subject to the consent of any person who is not a party to the relevant contract.
    Subject to the first paragraph of Section 11: these terms of sale contain the entire agreement and understanding of the parties in relation to the purchase of products from our website, and supersede all previous agreements and understandings between the parties in relation to the purchase of products from our website; and each party acknowledges that no representations not expressly contained in these terms of sale have been made by or on behalf of the other party in relation to the purchase of products from our website.
    These terms of sale will be governed by and construed in accordance with English law, and the courts of England and Wales will have exclusive jurisdiction to adjudicate any dispute arising under or in relation to these terms of sale.
13. Our details
    The full name of our company is Saffron Bells Ltd.
    We are registered in England & Wales.
    Our registered office and principal place of business is PO Box 1016, Wendover, Buckinghamshire HP22 9LW.
    You can contact us by writing to this address or by email to hello@saffronbells.com

Terms of Use

1. Introduction
   These terms of use govern your use of our website; by using our website, you accept these terms of use in full. If you disagree with these terms of use or any part of these terms of use, you must not use our website.
   If you register with our website we will ask you to expressly agree to these terms of use.
2. Licence to use website
   Unless otherwise stated, we or our licensors own the intellectual property rights in the website and material on the website. Subject to the licence below, all these intellectual property rights are reserved.
   Both the SAFFRON BELLS logo and its accompanying S device are trade marks belonging to Saffron Bells Ltd.
   You may view, download for caching purposes only, and print pages from the website for your own personal use, subject to the restrictions set out below and elsewhere in these terms of use.
   You must not:
   (a) republish material from this website (including republication on another website);
   (b) sell, rent or sub-license material from the website;
   (c) show any material from the website in public;
   (d) reproduce, duplicate, copy or otherwise exploit material on our website for a commercial purpose;
   (e) edit or otherwise modify any material on the website; or
   (f) redistribute material from this website.
3. Acceptable use
   You must not use our website in any way that causes, or may cause, damage to the website or impairment of the availability or accessibility of the website; or in any way which is unlawful, illegal, fraudulent or harmful, or in connection with any unlawful, illegal, fraudulent or harmful purpose or activity.
   You must not use our website to copy, store, host, transmit, send, use, publish or distribute any material which consists of (or is linked to) any spyware, computer virus, Trojan horse, worm, keystroke logger, rootkit or other malicious computer software.
   You must not conduct any systematic or automated data collection activities (including without limitation scraping, data mining, data extraction and data harvesting) on or in relation to our website without our express written consent.
4. Products
   The advertising of products on our website constitutes an “invitation to treat” – not a contractual offer.
   Prices stated on our website may be stated incorrectly.
   The purchase of products via our website will be subject to our terms of sale.
   We will ask you to agree to our terms of sale each time you purchase a product or products via our website.
5. Limitations of liability
   Nothing in these terms of use will: (a) limit or exclude our or your liability for death or personal injury resulting from negligence; (b) limit or exclude our or your liability for fraud or fraudulent misrepresentation; (c) limit any of our or your liabilities in any way that is not permitted under applicable law; or (d) exclude any of our or your liabilities that may not be excluded under applicable law. If you are a consumer, any statutory rights which you have, which cannot be excluded or limited, will not be affected by these terms of use.
   The limitations and exclusions of liability set out in this Section and elsewhere in these terms of use: (a) are subject to the preceding paragraph; and (b) govern all liabilities arising under the terms of use or in relation to the subject matter of the terms of use, including liabilities arising in contract, in tort (including negligence) and for breach of statutory duty.
   To the extent that the website and the information and services on the website are provided free-of-charge, we will not be liable for any loss or damage of any nature.
   We will not be liable to you in respect of any losses arising out of any event or events beyond our reasonable control.
   We will not be liable to you in respect of any business losses, including (without limitation) loss of or damage to profits, income, revenue, use, production, anticipated savings, business, contracts, commercial opportunities or goodwill.
   We will not be liable to you in respect of any loss or corruption of any data, database or software.
   We will not be liable to you in respect of any special, indirect or consequential loss or damage.
6. Breaches of these terms of use
   Without prejudice to our other rights under these terms of use, if you breach these terms of use in any way, we may take such action as we deem appropriate to deal with the breach, including suspending your access to the website, prohibiting you from accessing the website, blocking computers using your IP address from accessing the website, contacting your internet service provider to request that they block your access to the website and/or bringing court proceedings against you.
7. Variation
   We may revise these terms of use from time-to-time. Revised terms of use will apply to the use of our website from the date of the publication of the revised terms of use on our website. Please check this page regularly to ensure you are familiar with the current version.
8. Assignment
   We may transfer, sub-contract or otherwise deal with our rights and/or obligations under these terms of use without notifying you or obtaining your consent.
   You may not transfer, sub-contract or otherwise deal with your rights and/or obligations under these terms of use.
9. Severability
   If a provision of these terms of use is determined by any court or other competent authority to be unlawful and/or unenforceable, the other provisions will continue in effect. If any unlawful and/or unenforceable provision would be lawful or enforceable if part of it were deleted, that part will be deemed to be deleted, and the rest of the provision will continue in effect.
10. Exclusion of third party rights
    These terms of use are for the benefit of you and us, and are not intended to benefit any third party or be enforceable by any third party. The exercise of our and your rights in relation to these terms of use is not subject to the consent of any third party.
11. Entire agreement
    Without prejudice to the provision of our terms of sale, these terms of use constitute the entire agreement between you and us in relation to your use of our website, and supersede all previous agreements in respect of your use of this website.
12. Law and jurisdiction
    These terms of use will be governed by and construed in accordance with English law, and any disputes relating to these terms of use will be subject to the exclusive jurisdiction of the courts of England and Wales.
13. Our details
    The full name of our company is Saffron Bells Ltd.
    We are registered in England & Wales.
    Our registered office and principal place of business is PO Box 1016, Wendover, Buckinghamshire HP22 9LW.
    You can contact us by writing to this address or by email to hello@saffronbells.com

Privacy statement

Your data and privacy is respected and protected by us. We respect your rights to control your personal data. We will be clear about the data we collect and why. Your data is sacredly protected by us. We do not and will not sell your data to third parties.

Buying Saffron Bells Ltd products

Once you have decided to buy a Saffron Bells Ltd product, we offer a way for customers to buy directly from us at www.saffronbells.com. When you are asked to provide information so that we can complete your purchase.

We collect: your name, phone number (optional), email address and delivery/shipping address.

Why: We use this information to complete your transaction, carry out any follow-up with you about your purchase, help with any delivery issues, handle returns, and other issues related to the purchase of Saffron Bells Ltd products. Processing your personal data for this purpose is necessary for the performance of the agreement we have with you. Please note: we do not store any payment or credit card information. We only use payment information in connection with the purchase of Saffron Bells Ltd products.

Data protection policy

Saffron Bells Ltd is committed to protecting the rights and freedoms of data subjects and safely and securely processing their data in accordance with all of our legal obligations.

This policy sets out how we seek to protect personal data and ensure that our staff understand the rules governing their use of the personal data to which they have access in the course of their work. In particular, this policy requires staff to ensure that the Data Protection Officer (DPO) be consulted before any significant new data processing activity is initiated to ensure that relevant compliance steps are addressed.

Who is responsible for this policy?

This policy applies to all staff, who must be familiar with this policy and comply with its terms.

This policy supplements our other policies relating to internet and email use. We may supplement or amend this policy by additional policies and guidelines from time to time. Any new or modified policy will be circulated to staff before being adopted.

Our data protection officer (DPO), has overall responsibility for the day-to-day implementation of this policy. You should contact the DPO for further information about this policy if necessary, at hello@saffronbells.com.

The principles

Saffron Bells Ltd shall comply with the principles of data protection (the Principles) enumerated in the EU General Data Protection Regulation. We will make every effort possible in everything we do to comply with these principles. The Principles are:

1. Lawful, fair and transparent

Data collection must be fair, for a legal purpose and we must be open and transparent as to how the data will be used.

2. Limited for its purpose

Data can only be collected for a specific purpose.

3. Data minimisation

Any data collected must be necessary and not excessive for its purpose.

4. Accurate

The data we hold must be accurate and kept up to date.

5. Retention

We cannot store data longer than necessary.

6. Integrity and confidentiality

The data we hold must be kept safe and secure.

Accountability and transparency

We must ensure accountability and transparency in all our use of personal data. We must show how we comply with each Principle.

To comply with data protection laws and the accountability and transparency Principle of GDPR, we must demonstrate compliance. We are responsible for understanding our particular responsibilities to ensure we meet the following data protection obligations:

– Fully implement all appropriate technical and organisational measures.

– Maintain up to date and relevant documentation on all processing activities.

– Conducting Data Protection Impact Assessments.

– Implement measures to ensure privacy by design and default, including:

Data minimisation
Pseudonymisation
Transparency
Allowing individuals to monitor processing
Creating and improving security and enhanced privacy procedures on an ongoing basis

Our procedures

Fair and lawful processing

We must process personal data fairly and lawfully in accordance with individuals’ rights under the first Principle. This generally means that we should not process personal data unless the individual whose details we are processing has consented to this happening.

If we cannot apply a lawful basis (explained below), our processing does not conform to the first principle and will be unlawful. Data subjects have the right to have any data unlawfully processed erased

Controlling vs. processing data

Saffron Bells Ltd is classified as a data controller and data processor. We must maintain our appropriate registration with the Information Commissioners Office in order to continue lawfully controlling and processing data.

As a data processor, we must comply with our contractual obligations and act only on the documented instructions of the data controller. If we at any point determine the purpose and means of processing out with the instructions of the controller, we shall be considered a data controller and therefore breach our contract with the controller and have the same liability as the controller. As a data processor, we must:

– Not use a sub-processor without written authorisation of the data controller.

– Co-operate fully with the ICO or other supervisory authority.

– Ensure the security of the processing.

– Keep accurate records of processing activities.

– Notify the controller of any personal data breaches.

Lawful basis for processing data

We must establish a lawful basis for processing data. Ensure that any data we are responsible for managing has a written lawful basis approved by the DPO. It is our responsibility to check the lawful basis for any data we  are working with and ensure all of our actions comply the lawful basis. At least one of the following conditions must apply whenever we process personal data:

1. Consent

We hold recent, clear, explicit, and defined consent for the individual’s data to be processed for a specific purpose.

2. Contract

 The processing is necessary to fulfil or prepare a contract for the individual.

3. Legal obligation

 We have a legal obligation to process the data (excluding a contract).

4. Vital interests

 Processing the data is necessary to protect a person’s life or in a medical situation.

5. Public function

 Processing necessary to carry out a public function, a task of public interest or the function has a clear basis in law.

6. Legitimate interest

 The processing is necessary for our legitimate interests. This condition does not apply if there is a good reason to protect the individual’s personal data which overrides the legitimate interest.

Deciding which condition to rely on

If we  are making an assessment of the lawful basis, we must first establish that the processing is necessary. This means the processing must be a targeted, appropriate way of achieving the stated purpose. We cannot rely on a lawful basis if we can reasonably achieve the same purpose by some other means.

More than one basis may apply, and we should rely on what will best fit the purpose, not what is easiest.

We consider the following factors and docment our answers:

– What is the purpose for processing the data?

– Can it reasonably be done in a different way?

– Is there a choice as to whether or not to process the data?

– Who does the processing benefit?

– After selecting the lawful basis, is this the same as the lawful basis the data subject would expect?

– What is the impact of the processing on the individual?

– Are we in a position of power over them?

– Are they a vulnerable person?

– Would they be likely to object to the processing?

– Are we able to stop the processing at any time on request, and have we factored in how to do this?

Our commitment to the first Principle requires us to document this process and show that we have considered which lawful basis best applies to each processing purpose, and fully justify these decisions.

We must also ensure that individuals whose data is being processed by us are informed of the lawful basis for processing their data, as well as the intended purpose. This should occur via a privacy notice. This applies whether we have collected the data directly from the individual, or from another source.

Special categories of personal data

What are special categories of personal data?

Previously known as sensitive personal data, this means data about an individual which is more sensitive, so requires more protection. This type of data could create more significant risks to a person’s fundamental rights and freedoms, for example by putting them at risk of unlawful discrimination. The special categories include information about an individual, as listed below. Saffron Bells Ltd does not ask for, know, or hold any of these special categories of personal data:

Race, ethnic origin, politics, religion, trade union membership, genetics, biometrics (where used for ID purposes), health, sexual orientation.

Responsibilities

Our responsibilities:

– Analysing and documenting the type of personal data we hold.

– Checking procedures to ensure they cover all the rights of the individual.

– Identify the lawful basis for processing data.

– Ensuring consent procedures are lawful.

– Implementing and reviewing procedures to detect, report and investigate personal data breaches.

– Store data in safe and secure ways.

– Assess the risk that could be posed to individual rights and freedoms should data be compromised.

Your responsibilities:

– Fully understand your data protection obligations.

– Check that any data processing activities you are dealing with comply with our policy and are justified.

– Do not use data in any unlawful way.

– Do not store data incorrectly, be careless with it or otherwise cause us to breach data protection laws and our policies through your actions.

Comply with this policy at all times.

– Raise any concerns, notify any breaches or errors, and report anything suspicious or contradictory to this policy or our legal obligations without delay.

Responsibilities of the Data Protection Officer:

– Keeping the board updated about data protection responsibilities, risks and issues.

– Reviewing all data protection procedures and policies on a regular basis.

– Arranging data protection training and advice for all staff members and those included in this policy.

– Answering questions on data protection from staff, board members and other stakeholders.

– Responding to individuals such as clients and employees who wish to know which data is being held on them by us.

– Checking and approving with third parties that handle the company’s data any contracts or agreement regarding data processing.

Responsibilities of the IT Manager:

– Ensure all systems, services, software and equipment meet acceptable security standards.

– Checking and scanning security hardware and software regularly to ensure it is functioning properly.

– Researching third-party services, such as cloud services the company is considering using to store or process data.

Responsibilities of the Marketing Manager:

– Approving data protection statements attached to emails and other marketing copy.

– Addressing data protection queries from clients, target audiences or media outlets.

– Coordinating with the DPO to ensure all marketing initiatives adhere to data protection laws and the company’s Data Protection Policy.

– Accuracy and relevance.

We will ensure that any personal data we process is accurate, adequate, relevant and not excessive, given the purpose for which it was obtained. We will not process personal data obtained for one purpose for any unconnected purpose unless the individual concerned has agreed to this or would otherwise reasonably expect this.

Individuals may ask that we correct inaccurate personal data relating to them. If you believe that information is inaccurate you should record the fact that the accuracy of the information is disputed and inform the DPO

Data security

We must keep personal data secure against loss or misuse. Where other organisations process personal data as a service on our behalf, the DPO will establish what, if any, additional specific data security arrangements need to be implemented in contracts with those third party organisations.

– Storing data securelyIn cases when data is stored on printed paper, it should be kept in a secure place where unauthorised personnel cannot access it.

– Printed data should be shredded when it is no longer needed.

– Data stored on a computer should be protected by strong passwords that are changed regularly. We encourage all staff to use a password manager to create and store their passwords.

– Data stored on CDs or memory sticks must be encrypted or password protected and locked away securely when they are not being used.

– The DPO must approve any cloud used to store data.

– Servers containing personal data must be kept in a secure location, away from general office space.

– Data should be regularly backed up in line with the company’s backup procedures.

– Data should never be saved directly to mobile devices such as laptops, tablets or smartphones.

– All servers containing sensitive data must be approved and protected by security software.

– All possible technical measures must be put in place to keep data secure.

Data retention

We must retain personal data for no longer than is necessary. What is necessary will depend on the circumstances of each case, taking into account the reasons that the personal data was obtained, but should be determined in a manner consistent with our data retention guidelines

Transferring data internationally

There are restrictions on international transfers of personal data. We must not transfer personal data abroad, or anywhere else outside of normal rules and procedures without express permission from the DPO.

Rights of individuals

Individuals have rights to their data which we must respect and comply with to the best of our ability. We must ensure individuals can exercise their rights in the following ways:

1. Right to be informed

Providing privacy notices which are concise, transparent, intelligible and easily accessible, free of charge, that are written in clear and plain language, particularly if aimed at children.

Keeping a record of how we use personal data to demonstrate compliance with the need for accountability and transparency.

2. Right of access

Enabling individuals to access their personal data and supplementary information

Allowing individuals to be aware of and verify the lawfulness of the processing activities

3. Right to rectification

We must rectify or amend the personal data of the individual if requested because it is inaccurate or incomplete.

This must be done without delay, and no later than one month. This can be extended to two months with permission from the DPO.

4. Right to erasure

We must delete or remove an individual’s data if requested and there is no compelling reason for its continued processing.

5. Right to restrict processing

We must comply with any request to restrict, block, or otherwise suppress the processing of personal data.

We are permitted to store personal data if it has been restricted, but not process it further. We must retain enough data to ensure the right to restriction is respected in the future.

6. Right to data portability

We must provide individuals with their data so that they can reuse it for their own purposes or across different services.

We must provide it in a commonly used, machine-readable format, and send it directly to another controller if requested.

7. Right to object

We must respect the right of an individual to object to data processing based on legitimate interest or the performance of a public interest task.

We must respect the right of an individual to object to direct marketing, including profiling.

We must respect the right of an individual to object to processing their data for scientific and historical research and statistics.

8. Rights in relation to automated decision making and profiling

We must respect the rights of individuals in relation to automated decision making and profiling.

Individuals retain their right to object to such automated processing, have the rationale explained to them, and request human intervention.

Privacy notices

When to supply a privacy notice

A privacy notice must be supplied at the time the data is obtained if obtained directly from the data subject. If the data is not obtained directly from the data subject, the privacy notice must be provided within a reasonable period of having obtained the data, which mean within one month.

If the data is being used to communicate with the individual, then the privacy notice must be supplied at the latest when the first communication takes place.

If disclosure to another recipient is envisaged, then the privacy notice must be supplied prior to the data being disclosed.

What to include in a privacy notice

Privacy notices must be concise, transparent, intelligible and easily accessible. They are provided free of charge and must be written in clear and plain language, particularly if aimed at children

The following information must be included in a privacy notice to all data subjects:

– Identification and contact information of the data controller and the data protection officer.

– The purpose of processing the data and the lawful basis for doing so.

– The legitimate interests of the controller or third party, if applicable.

– The right to withdraw consent at any time, if applicable.

– The category of the personal data (only for data not obtained directly from the data subject).

– Any recipient or categories of recipients of the personal data.

– Detailed information of any transfers to third countries and safeguards in place.

– The retention period of the data or the criteria used to determine the retention period, including details for the data disposal after the retention period.

– The right to lodge a complaint with the ICO, and internal complaint procedures.

– The source of the personal data, and whether it came from publicly available sources (only for data not obtained directly from the data subject).

– Any existence of automated decision making, including profiling and information about how those decisions are made, their significances and consequences to the data subject.

– Whether the provision of personal data is part of a statutory of contractual requirement or obligation and possible consequences for any failure to provide the data (only for data obtained directly from the data subject).

Subject Access Requests

What is a subject access request?

An individual has the right to receive confirmation that their data is being processed, access to their personal data and supplementary information which means the information which should be provided in a privacy notice.

How we deal with subject access requests

We must provide an individual with a copy of the information the request, free of charge. This must occur without delay, and within one month of receipt. We endeavour to provide data subjects access to their information in commonly used electronic formats, and where possible, provide direct access to the information through a remote accessed secure system.

If complying with the request is complex or numerous, the deadline can be extended by two months, but the individual must be informed within one month. You must obtain approval from the DPO before extending the deadline.

We can refuse to respond to certain requests, and can, in circumstances of the request being manifestly unfounded or excessive, charge a fee. If the request is for a large quantity of data, we can request the individual specify the information they are requesting. This can only be done with express permission from the DPO.

Once a subject access request has been made, you must not change or amend any of the data that has been requested. Doing so is a criminal offence.

Data portability requests

We must provide the data requested in a structured, commonly used and machine-readable format. This would normally be a CSV file, although other formats are acceptable. We must provide this data either to the individual who has requested it, or to the data controller they have requested it be sent to. This must be done free of charge and without delay, and no later than one month. This can be extended to two months for complex or numerous requests, but the individual must be informed of the extension within one month and you must receive express permission from the DPO first.

Right to erasure

What is the right to erasure?

Individuals have a right to have their data erased and for processing to cease in the following circumstances:

– Where the personal data is no longer necessary in relation to the purpose for which it was originally collected and / or processed.

– Where consent is withdrawn.

– Where the individual objects to processing and there is no overriding legitimate interest for continuing the processing.

– The personal data was unlawfully processed or otherwise breached data protection laws.

– To comply with a legal obligation.

– The processing relates to a child.

How we deal with the right to erasure

We can only refuse to comply with a right to erasure in the following circumstances:

– To exercise the right of freedom of expression and information.

– To comply with a legal obligation for the performance of a public interest task or exercise of official authority.

– For public health purposes in the public interest.

– For archiving purposes in the public interest, scientific research, historical research or statistical purposes.

– The exercise or defence of legal claims.

If personal data that needs to be erased has been passed onto other parties or recipients, they must be contacted and informed of their obligation to erase the data. If the individual asks, we must inform them of those recipients.

The right to object

Individuals have the right to object to their data being used on grounds relating to their particular situation. We must cease processing unless:

– We have legitimate grounds for processing which override the interests, rights and freedoms of the individual.

– The processing relates to the establishment, exercise or defence of legal claims.

We must always inform the individual of their right to object at the first point of communication, i.e. in the privacy notice. We must offer a way for individuals to object online.

Reporting breaches

Any breach of this policy or of data protection laws must be reported as soon as practically possible. This means as soon as we have become aware of a breach. Saffron Bells Ltd has a legal obligation to report any data breaches to the supervisory authority within 72 hours.