1.1. This document sets out the obligations of Storcx Limited (“Storcx”) with regard to data protection and the rights of people with whom it works in respect of their personal data under applicable data protection legislation (including the Data Protection Act 1998 and when applicable the General Data Protection Regulations the “GDPR”) ).
1.2. Storcx is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. We can be contacted by telephone on +44 (0) 2080883338, by email at info@Storcx.co.uk or by post at the registered office address 33 Wigmore Street W1U 1QX.
1.3. This policy applies between any user of this website and Storcx the owner and provider of this website.
This Policy sets out procedures that Storcx follows and where appropriate you must follow when dealing with personal data. The procedures set out herein are followed by Storcx, its employees, contractors, agents, consultants, partners or other parties working on behalf of Storcx.
1.4. Storcx views the correct and lawful handling of personal data as key to its success and dealings with third parties.
Storcx ensures that it handles all personal data correctly and lawfully.
1.5. This policy applies only to the actions of Storcx and users with respect to the Storcx website. It does not extend to any websites that can be accessed from this website including, but not limited to, any links that may be provided to social media websites.
2.1. This Policy aims to ensure compliance with current UK data protection legislation and the GDPR. That legislation sets out principles with which any party handling personal data must comply. All personal data:
2.2 must be processed fairly, lawfully and in a transparent manner (and shall not be processed unless certain conditions are met);
2.3 must be obtained only for specified and lawful purposes and shall not be processed in any manner which is incompatible with those purposes;
2.4 must be adequate, relevant and not excessive with respect to the purposes for which it is processed;
2.5 must be accurate and, where appropriate, kept up-to-date;
2.6 must be kept for no longer than is necessary in light of the purpose(s) for which it is processed;
2.7 must be processed in accordance with the rights of data subjects;
2.8 must be protected against unauthorised or unlawful processing, accidental loss, destruction or damage through appropriate technical and organisational measures; and
2.9 must not be transferred to a country or territory outside of the European Economic Area unless that country or territory ensures an adequate level of protection for the rights and freedoms of data subjects in relation to the processing of personal data.
3.1 Data subjects have the following rights:
3.2 the right to be informed that their personal data is being processed;
3.3 the right to access any of their personal data held by Storcx within one month of making a request;
3.4 the right to rectification if their personal data is inaccurate or incomplete within one month of making a request (this can be extended by two months where the request for rectification is complex);
3.5 the right to erasure which enables data subjects to request the deletion or removal of personal data where there is no compelling reason for its continued processing;
3.6 the right to restrict processing personal data;
3.7 the right to data portability allows data subjects to obtain and reuse their personal data for their own purposes across different services;
3.8 the right to objectto processing based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling); direct marketing (including profiling); and processing for purposes of scientific/historical research and statistics; and
3.9 rights in relation to automated decision making and profiling.
3.10 The rights listed in this clause 3 can be exercised by writing to Storcx Limited, 33 Wigmore Street, London W1U 1QX or by email to info@Storcx.co.uk
4.1. Personal data is defined as information relating to an identifiable person who can be directly or indirectly identified in particular by reference to that data.
4.2. The GDPR also defines “sensitive personal data” as data consisting of racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data, data concerning health or data concerning a natural person’s sex life or sexual orientation.
4.3. Storcx only holds personal data which is directly relevant to its dealings with a given data subject. That data will be held and processed in accordance with the data protection principles and with this Policy. The following data may be collected, held and processed by Storcx from time to time:
- Full Name;
- Date of birth;
- Email address;
- Telephone number;
- Personal or home address
- IP address (automatically collected);
- web browser type and version (automatically collected);
- operating system (automatically collected);
- your activity on this website, including the referring site and the pages you visit
5.1. Any and all personal data collected by Storcx (including that detailed in Section 4 of this Policy) is collected in order to ensure that Storcx can facilitate efficient transactions with third parties including, but not limited to, its customers, partners, associates and affiliates and efficiently manage its employees, contractors, agents and consultants. Personal data shall also be used by Storcx in meeting any and all relevant obligations imposed by law.
5.2.Personal data may be required by us from time to time in order to provide users with the best possible service and experience when using the website. Specifically, personal data may be used by us for the following reasons:
5.2.1. internal record keeping;
5.2.2. improvement of our products/services;
5.2.3. transmission by email of promotional materials that may be of interest to you;
5.2.4. contact for market research purposes which may be done using email, telephone, or mail. Such information may be used to customise or update the website.
5.3. Personal data may be disclosed within Storcx. Personal data may be passed from one department to another in accordance with the data protection principles and this Policy. Under no circumstances will personal data be passed to any department or any individual within Storcx that does not reasonably require access to that personal data with respect to the purpose(s) for which it was collected and is being processed.
5.4. Storcx shall ensure that:
5.4.1. all personal data collected and processed for and on behalf of Storcx by any party is collected and processed fairly and lawfully;
5.4.2. data subjects are made fully aware of the reasons for the collection of personal data and are given details of the purpose for which the data will be used;
5.4.3. personal data is only collected to the extent that is necessary to fulfil the stated purpose(s);
5.4.4. all personal data is accurate at the time of collection and kept accurate and up-to-date while it is being held and/or processed;
5.4.5. no personal data is held for any longer than necessary in light of the stated purpose(s);
5.4.6. all personal data is held in a safe and secure manner, taking all appropriate technical and organisational measures to protect the data;
5.4.7. all personal data is transferred using secure means, electronically or otherwise;
5.4.8. no personal data is transferred outside of the UK or EEA (as appropriate) without first ensuring that appropriate safeguards are in place in the destination country or territory; and
5.4.9. all data subjects can exercise their rights set out above in Section 3 and more fully in applicable legislation (including the GDPR).
6.1. Storcx shall ensure that all of its employees, contractors, agents, consultants, partners or other parties working on behalf of Storcx comply with the following when processing and / or transmitting personal data:
6.1.1. all emails containing personal data must be encrypted;
6.1.2. personal data may be transmitted over secure networks only – transmission over unsecured networks is not permitted in any circumstances;
6.1.3. personal data may not be transmitted over a wireless network if there is a wired alternative that is reasonably practicable;
6.1.4. personal data contained in the body of an email, whether sent or received, should be copied from the body of that email and stored securely. The email itself should be deleted. All temporary files associated therewith should also be deleted;
6.1.5. where Personal data is to be sent by facsimile transmission the recipient should be informed in advance of the transmission and should be waiting by the fax machine to receive the data;
6.1.6. where Personal data is to be transferred in hardcopy form it should be passed directly to the recipient. Using an intermediary is not permitted;
6.1.7. all hardcopies of personal data should be stored securely in a locked box, drawer, cabinet or similar;
6.1.8. all electronic copies of personal data should be stored securely using passwords and suitable data encryption, where possible on a drive or server which cannot be accessed via the internet; and
6.1.9. all passwords used to protect personal data should be changed regularly and should not use words or phrases which can be easily guessed or otherwise compromised.
6.2. Any personal data you submit will be retained by Storcx for a period of up to three years after your account registration has been made inactive.
6.3. Unless we are obliged or permitted by law to do so, and subject to Section 10, your personal data will not be disclosed to third parties.
7.1. Storcx shall ensure that the following measures are taken with respect to the collection, holding and processing of personal data:
7.1.1. Storcx will have responsibility of overseeing data protection and ensuring compliance with the GDPR;
7.1.2. all employees, contractors, agents, consultants, partners or other parties working on behalf of Storcx are made fully aware of both their individual responsibilities and Storcx’ responsibilities under the GDPR and shall be furnished with a copy of this Policy;
7.1.3. all employees, contractors, agents, consultants, partners or other parties working on behalf of Storcx handling personal data will be appropriately trained to do so;
7.1.4. all employees, contractors, agents, consultants, partners or other parties working on behalf of Storcx handling personal data will be appropriately supervised;
7.1.5. methods of collecting, holding and processing personal data shall be regularly evaluated and reviewed;
7.1.6. the Performance of those employees, contractors, agents, consultants, partners or other parties working on behalf of Storcx handling personal data shall be regularly evaluated and reviewed;
7.1.7. all employees, contractors, agents, consultants, partners or other parties working on behalf of Storcx handling personal data will be bound to do so in accordance with the principles of the GDPR and this Policy by contract. Failure by any employee to comply with the principles or this Policy shall constitute a disciplinary offence. Failure by any contractor, agent, consultant, partner or other party to comply with the principles or this Policy shall constitute a breach of contract. In all cases, failure to comply with the principles or this Policy may also constitute a criminal offence under the GDPR;
7.1.8. all contractors, agents, consultants, partners or other parties working on behalf of Storcx handling personal data must ensure that any and all of their employees who are involved in the processing of personal data are held to the same conditions as those relevant employees of Storcx arising out of this Policy and the GDPR;
7.1.9. where any contractor, agent, consultant, partner or other party working on behalf of Storcx handling personal data fails in their obligations under this Policy that party shall indemnify and hold harmless Storcx against any costs, liability, damages, loss, claims or proceedings which may arise out of that failure.
8.1. A data subject may make a subject access request (“SAR“) at any time to see the information which Storcx holds about them:
8.1.1. SARs must be made in writing, and if applicable, accompanied by the correct fee;
8.1.2. Storcx shall provide a copy of the information free of charge, unless the request is manifestly unfounded or excessive, particularly if it is repetitive, in which case Storcx shall charge a reasonable fee based on the administrative cost of providing the information.
8.2. Upon receipt of a SAR Storcx shall have a maximum period of 30
days within which to respond. The following information will be provided to the data subject:
8.2.1. whether or not Storcx holds any personal data on the data subject;
8.2.2. a description of any personal data held on the data subject;
8.2.3. details of what that personal data is used for;
8.2.4. details of any third-party organisations that personal data is passed to; and
8.2.5. details of any technical terminology or codes.
9.1. Storcx may, from time to time, employ the services of other parties for dealing with payment processing and delivery of purchased items. The providers of such services do have access to certain personal data provided by users of the website.
9.2. Any personal data used by such parties is used only to the extent required by them to perform the service that Storcx requests. Any use for other purposes is strictly prohibited. Furthermore, any personal data that is processed by third parties shall be processed within the terms of this policy and in accordance with the GDPR.
11.1. Storcx may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of Storcx. Personal data provided by users will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this policy, be permitted to use the personal data for the purposes for which it was originally supplied to us.
12.1. You may access certain areas of the website without providing any personal data at all. However, to use all features and functions available on the website you may be required to submit certain personal data.
13.1. This Policy shall be deemed effective as of 17th May 2018
No part of this Policy shall have retroactive effect and shall thus apply only to matters occurring on or after this date.
This Policy has been approved & authorised by:
Name: Elizabeth Rafferty
Date: 6th June 2018