We understand that your privacy is important and that you care about how your personal data is used and shared. We respect the privacy of everyone who visits our website and uses our online services.
We are committed to respecting, securing, and protecting your privacy and private data. We are also committed to being transparent about what we collect from you and how we use it.
This privacy notice provides you with information about what personal data we collect, how we use your data, how we ensure your privacy is maintained, and your legal rights relating to your personal data.
1. Who We Are
We are William Serfaty & Co Limited, trading as The Red House.
You can contact our head office by:
• Telephone +350 200 75960
• Email – email@example.com
• Post – 68 Main Street, Gibraltar GX11 1 AA
2. Your Rights
2.1 Under the General Data Protection Regulation (GDPR) and The Data Protection Act 2018 (DPA) you have a number of rights with regard to your personal data; which this policy and our use of your data has been designed to uphold:
• Right to be informed – you have the right to be informed about our collection and use of your personal data.
• Right of access – you have the right to request a copy of the information that we hold about you. You can do this by contacting us using the above details.
• Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
• Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
• Right to restriction of processing – where certain conditions apply, you have a right to restrict our processing.
• Right of portability – you have the right to have the data we hold about you transferred to another organisation.
• Right to object – you have the right to object to certain types of processing (such as direct marketing).
2.2 If you have cause for complaint about our use of your data, or you would like to exercise any of your rights, then please contact us using the details provided in Section 1 and we will do our best to solve the problem for you.
3. What Data Do We Collect from You?
3.1 If you use our websites, we will collect some data automatically from you when you user our website. Generally, that information is aggregated but it may contain your IP address. That information is:
• Your IP address, login information, browser type and version, time zone setting, browser plug-in types, geolocation information about where you might be, operating system and version.
• Your URL clickstreams (the path you take through our site), products/services viewed, page response times, download errors, how long you stay on our pages, what you do on those pages, how often, and other actions.
3.2 If you are a customer we will collect additional information which you provide to us:
• Contact Details – Your name, address, phone numbers, email address.
• Purchase & Quote Details – Information about products and services you have purchased or enquired about.
• Payment Details – We will collect payment card and/or bank details from you.
3.3 If you are a subscriber to our marketing content:
• Contact Details – Your name and email address.
4. How We Use Your Data
4.1 Data protection law means that we can only use your data for certain reasons and where we have a legal basis to do so. Here are the reasons for which we process your data:
• Products, Services & Warranty – We’ll use the details you provide to provide our products & services to you. If we don’t collect this information, we won’t be able to provide our services and comply with our legal obligations. Our legal basis for this is contractual obligation (explained below).
• Keeping Our Website Running: providing and managing your access to our website and services, personalising and tailoring your experience on our website and services. Our legal basis for this is legitimate interest (see below).
• Marketing Purposes: We may send you emails and messages about new features, products and services, and content. You will always be able to unsubscribe from these. Our legal basis for doing that is either consent or legitimate interest (see below).
• Answering Your Queries & Customer Support: We will use your data to answer your contact requests and queries. Our legal basis for doing so is contractual obligation where you are a customer, or legitimate interest where you are not.
5. Legal Basis
5.1 We have identified a legal basis for each of our purposes in paragraph 4. This is what they mean:
5.2 Legitimate Interest:
• Processing your data is necessary for our legitimate interests, provided those interests are not outweighed by your rights and interests. These legitimate interests are:
o gaining insights from your behaviour on our website
o delivering, developing and improving our service
o enabling us to enhance, customise or modify our services and comms
o enhancing data and physical security
o promoting our products, services and business.
o responding to customer enquiries, contact requests and promoting our services.
• In each case, these legitimate interests are only valid if they are not outweighed by your rights and interests.
• You can always object to our processing of your data based on legitimate interest. If you do so and we have no other legal basis for processing your data we will stop. If we do have another legal basis we will continue to do so, subject to your legal rights.
• You have given clear consent for you to process your personal data for a specific purpose.
• You can always withdraw your consent. You can do this by clicking on unsubscribe in any marketing email we send, or by getting in touch via the contact details in paragraph 1.
• If you withdraw your consent and we have no other legal basis for processing your data we will stop. If we do have another legal basis we will continue to do so, subject to your legal rights.
5.4 Contractual Obligation:
• Processing your data is necessary for a contract you have with us, or because we have asked you to take specific steps before entering into that contract.
6. Storing and Sharing Your Data
6.1 Data security is very important to us and we take appropriate security measures to safeguard and secure your data which is collected via our website and services.
6.2 We endeavour to keep all of your personal information in the European Economic Area (EEA). The EEA includes all EU Member States plus Norway, Iceland and Liechtenstein.
6.3 In limited, and necessary, circumstances your information may be transferred outside of the EEA. Where this does happen, we will put special protections in place. We will only move data to countries or organisations:
• Where the EU Commission has deemed their data protection measures to be adequate;
• Or under a contract which enforces the EU Commission approved “standard data protection clauses” which can be viewed at http://ec.europa.eu/justice/data-protection/international-transfers/transfer/index_en.htm.
6.4 We will never sell your personal data to a third party.
6.5 We will not transfer or disclose your personal data to any third party except:
• We may sometimes contract with trusted service providers to provide goods and services on our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising, marketing, IT systems and support with book-keeping. This will sometimes necessitate the transfer of your personal data to those trusted service providers.
• Where we transfer your data to our trusted service providers we will have confirmed that they will apply data protection and security measures to the same standard we would. We will always impose contractual terms on all of our providers to ensure your data remains secure.
• Where you have given consent we may release your information to third parties – for example if you ask us to put you in touch with professional advisors.
• We may disclose your personal data to third parties in the event that we sell any part of our business, in which case we may disclose your personal data to the prospective buyer of such business or assets and our advisors. If any part of our business is acquired by a third party, personal data held by us may be transferred.
6.6 In certain limited circumstances we may be legally required to share your personal data – for example where we are involved in legal proceedings, or where we are complying with a court order, regulatory requirement, or government department with appropriate legal authority to compel us to do so.
7. How Long We Keep Your Data
7.1 We do not keep your personal data for any longer than it is necessary in light of the reason(s) for which it was first collected and for our obligation under other laws. There is no fixed period after which all record of your personal data will be deleted as this will depend on the circumstances and the purposes of the processing but we will take steps and maintain policies to keep retention under proper review.
7.2 We will keep your personal data for at least the length of any warranty on products and services which you have bought from us.
7.3 We may need to keep your information to establish, bring or defend legal claims. We’ll therefore always keep your personal data for 7 years after the date it is no longer necessary for us to hold it.
7.4 At the end of that period your data will be either deleted completely or anonymised.
7.5 Exceptions to the above will be:
• Where you have exercised your right to have the information where it applies.
• Where the law requires us to keep your data for longer or delete it sooner.
• Where a legal claim is in progress – we’ll keep your data until that claim is concluded.
8. Changes to Our Privacy Notice
8.1 We may change this privacy notice from time to time (for example, if the law changes). Any changes will be immediately posted on our site. We recommend you check the privacy notice regularly to remain up to date.
8.2 This privacy notice was last updated in May 2019.