Privacy Notice

This is the privacy notice of Holmes Cycling Limited (‘we’, ‘our’, or ‘us’).

Holmes Cycling Limited is a private limited company registered in the UK – Company registration no 11835706 – with the registered address at 19 Bennett Drive, Orrell, WIGAN, WN5 7AR

Introduction

This notice describes how we collect, store, transfer and use personal data. It tells you about your privacy rights and how the law protects you.

In the context of the law and this notice, ‘personal data’ is information that clearly identifies you as an individual or which could be used to identify you if combined with other information. Acting in any way on personal data is referred to as ‘processing’.

Except as set out below, we do not share, or sell, or disclose to a third party, any information collected through our website.

Personal data we process

  1. How we obtain personal data

The information we process about you includes information:

  • you have directly provided to us
  • that we gather from third party databases and service providers
  • as a result of monitoring how you use our website or our services
  1. Types of personal data we collect directly

When you use our website, our services or buy from us, [for example, when you create an account on our website,] we ask you to provide personal data. This can be categorised into the following groups:

  • personal identifiers, such as your first and last names, your title and your date of birth
  • contact information, such as your email address, your telephone number and your postal addresses for billing, delivery and communication
  • account information, including your username and password
  • payment information, such as a debit or credit card number and expiry date and bank account details
  • records of communication between us including messages sent through our website, email messages and telephone conversations
  • marketing preferences that tell us what types of marketing you would like to receive
  1. Types of personal data we collect from your use of our services

By using our website and our services, we process:

  • your username and password and other information used to access our website and our services
  • information you contribute to our community, including reviews
  • your replies to polls and surveys
  • technical information about the hardware and the software you use to access our website and use our services, including your Internet Protocol (IP) address, your browser type and version and your device’s operating system
  • usage information, including the frequency you use our services, the pages of our website that you visit, whether you receive messages from us and whether you reply to those messages
  • transaction information that includes the details of the products services you have bought from us and payments made to us for those services
  • your preferences to receive marketing from us; how you wish to communicate with us; and responses and actions in relation to your use of our services.
  1. Our use of aggregated information

We may aggregate anonymous information such as statistical or demographic data for any purpose. Anonymous information is that which does not identify you as an individual. Aggregated information may be derived from your personal data but is not considered as such in law because it does not reveal your identity.

For example, we may aggregate usage information to assess whether a feature of our website is useful.

However, if we combine or connect aggregated information with your personal data so that it can identify you in any way, we treat the combined information as personal data, and it will be used in accordance with this privacy notice.

  1. Information we process because we have a contractual obligation with you

When you create an account on our website, buy a product or service from us, or otherwise agree to our terms and conditions, a contract is formed between you and us.

In order to carry out our obligations under that contract we must process the information you give us. Some of this information may be personal data.

We may use it in order to:

  • verify your identity for security purposes when you use our services
  • sell products to you
  • provide you with our services
  • provide you with suggestions and advice on products, services and how to obtain the most from using our website

We process this information on the basis there is a contract between us, or that you have requested we use the information before we enter into a legal contract.

We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.

  1. Information we process because we have a legal obligation

Sometimes, we must process your information in order to comply with a statutory obligation.

For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order.

This may include your personal data.

  1. Information we process to protect vital interests

In situations where processing personal information is necessary to protect someone’s life, where consent is unable to be given and where other lawful bases are not appropriate, we may process personal information on the basis of vital interests.

For example, we may inform relevant organisations if we have a safeguarding concern about a vulnerable person.

  1. Your personal data is not shared

We do not share or disclose to a third party, any information collected through our website.

  1. Information you provide

Our website allows you to post information with a view to that information being read, copied, downloaded, or used by other people.

For example, when you leave a review or post a message on our website, we reasonably assume that you consent for the message to be seen by others. We may include your username with your message, and your message may contain information that is personal data.

Other examples include:

  • tagging an image
  • clicking on an icon next to another visitor’s message to convey your agreement, disagreement or thanks

In posting personal data, it is up to you to satisfy yourself about the privacy level of every person who might use it.

We do not specifically use this information except to allow it to be displayed or shared.

We do store it, and we reserve a right to use it in the future in any way we decide.

Once your information enters the public domain, we have no control over what any individual third party may do with it. We accept no responsibility for their actions at any time.

  1. Payment information

Payment information is never taken by us or transferred to us either through our website or otherwise. Our employees and contractors never have access to it.

At the point of payment, you are transferred to a secure page on the website of Stripe. That page may be branded to look like a page on our website, but it is not controlled by us.

  1. Third party advertising on our website

Third parties may advertise on our website. In doing so, those parties, their agents or other companies working for them may use technology that automatically collects information about you when their advertisement is displayed on our website.

They may also use other technology such as cookies or JavaScript to personalise the content of, and to measure the performance of their adverts.

We do not have control over these technologies or the data that these parties obtain. Accordingly, this privacy notice does not cover the information practices of these third parties.

  1. Disputes between users

In the event of a dispute between you and another user, provided that you consent, we may share your basic personal data, business information and contact information with the other user.

At our discretion, we may share other information to enable the dispute to be resolved through litigation or alternative dispute resolution methods.

  1. Service providers and business partners

We may share your personal data with businesses that provide services to us, or with business partners.

As examples:

  • we may pass your payment information to our payment service provider to take payments from you
  • we may use fraud prevention agencies and credit reference agencies to verify your identity and we may pass your information to those agencies if we strongly suspect fraud on our website
  • we may pass your contact information to advertising agencies to use to promote our services to you
  1. Cookies

Cookies are small text files that are placed on your computer’s hard drive by your web browser when you visit a website that uses them. They allow information gathered on one web page to be stored until it is needed for use at a later date.

They are commonly used to provide you with a personalised experience while you browse a website, for example, allowing your preferences to be remembered.

They can also provide core functionality such as security, network management, and accessibility; record how you interact with the website so that the owner can understand how to improve the experience of other visitors; and serve you advertisements that are relevant to your browsing history.

Some cookies may last for a defined period of time, such as one visit (known as a session), one day or until you close your browser. Others last indefinitely until you delete them.

Your web browser should allow you to delete any cookie you choose. It should also allow you to prevent or limit their use. Your web browser may support a plug-in or add-on that helps you manage which cookies you wish to allow to operate.

The law requires you to give explicit consent for use of any cookies that are not strictly necessary for the operation of a website.

We use cookies in the following ways:

  • to track how you use our website
  • to record whether you have seen specific messages we display on our website
  • to keep you signed in to our website
  • to record your answers to surveys and questionnaires on our site while you complete them
  • to record the conversation thread during a live chat with our support team

[We provide more information about the cookies we use in our cookie policy].

  1. Personal identifiers from your browsing activity

Requests by your web browser to our servers for web pages and other content on our website are recorded.

We record information such as your geographical location, your Internet service provider and your IP address. We also record information about the software you are using to browse our website, such as the type of computer or device and the screen resolution.

We use this information in aggregate to assess the popularity of the webpages on our website and how we perform in providing content to you.

If combined with other information we know about you from previous visits, the data possibly could be used to identify you personally, even if you are not signed in to our website.                     

  1. Your rights

The law requires us to tell you about your rights and our obligations to you in regard to the processing and control of your personal data.

We do this now, by requesting that you read the information provided at http://www.knowyourprivacyrights.org

  1. Use of our services by children

We do not sell products or provide services for purchase by children, nor do we market to children.

  1. Encryption of data sent between us

We use Secure Sockets Layer (SSL) certificates to verify our identity to your browser and to encrypt any data you give us.

Whenever information is transferred between us, you can check that it is done so using SSL by looking for a closed padlock symbol or other trust mark in your browser’s URL bar or toolbar.

  1. Control over your own information

It is important that the personal data we hold about you is accurate and up to date. Please inform us if your personal data changes.

At any time, you may contact us to request that we provide you with the personal data we hold about you.

At any time you may review or update personally identifiable information that we hold about you, by signing in to your account on our website.

To obtain a copy of any information that is not provided on our website you should contact us to make that request.

When we receive any request to access, edit or delete personal data we first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.

Please be aware that we are not obliged by law to provide you with all personal data we hold about you, and that if we do provide you with information, the law allows us to charge for such provision if doing so incurs costs for us. After receiving your request, we will tell you when we expect to provide you with the information, and whether we require any fee for providing it to you.

If you wish us to remove personally identifiable information from our website, you should contact us to make your request.

This may limit the service we can provide to you.

We remind you that we are not obliged by law to delete your personal data or to stop processing it simply because you do not consent to us doing so. While having your consent is an important consideration as to whether to process it, if there is another legitimate basis on which we may process it, we may do so on that basis.

  1. Communicating with us

When you contact us, whether by telephone, through our website or by email, we collect the data you have given to us in order to reply with the information you need.

We may keep personally identifiable information associated with your message, such as your name and email address so as to be able to track our communications with you to provide a high quality service.

  1. Retention period

Except as otherwise mentioned in this privacy notice, we keep your personal data only for as long as required by us:

  • to provide you with the services you have requested
  • to comply with other law, including for the period demanded by our tax authorities
  • to support a claim or defence in court
  1. Compliance with the law

Our privacy policy complies with the law in the United Kingdom, specifically with the Data Protection Act 2018 (the ‘Act’) accordingly incorporating the EU General Data Protection Regulation (‘GDPR’) and the Privacy and Electronic Communications Regulations (‘PECR’).

  1. Review of this privacy policy

We shall update this privacy notice from time to time as necessary.

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