Privacy Policy

Registered name: Leon Harris Limited

This privacy notice tells you what to expect us to do with your personal information.

• Contact details
• What information we collect, use, and why
• Lawful bases and data protection rights
• Where we get personal information from
• How long we keep information
• Who we share information with
• How to complain

Telephone

07779201121

Email

[email protected]

We collect or use the following information to provide services and goods, including delivery:

• Names and contact details
• Addresses
• Date of birth
• Payment details (including card or bank information for transfers)
• Account information
• Website user information (including user journeys and cookie tracking)
• Identification documents
• Information relating to compliments or complaints

We collect or use the following information for the operation of customer accounts and guarantees:

• Names and contact details
• Addresses
• Payment details (including card or bank information for transfers and direct debits)
• Account information, including registration details
• Marketing preferences

We collect or use the following information for service updates or marketing purposes:

• Names and contact details
• Addresses
• Marketing preferences
• Location data
• IP addresses
• Website and app user journey information
• Records of consent, where appropriate

We collect or use the following information to comply with legal requirements:

• Name
• Contact information
• Identification documents
• Financial transaction information

We collect or use the following personal information for dealing with queries, complaints or claims:

• Names and contact details
• Address
• Payment details
• Account information
• Purchase or service history
• Correspondence

Under UK and EU data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.

Which lawful basis we rely on may affect your data protection rights which are in brief set out below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:

• Your right of access - You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for. You can read more about this right here and here for EU.
• Your right to rectification - You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. You can read more about this right here and here for EU.
• Your right to erasure - You have the right to ask us to delete your personal information. You can read more about this right here and here for EU.
• Your right to restriction of processing - You have the right to ask us to limit how we can use your personal information. You can read more about this right here and here for EU.
• Your right to object to processing - You have the right to object to the processing of your personal data. You can read more about this right here and here for EU.
• Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you. You can read more about this right here, and here for EU
• Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time. You can read more about this right here and here for EU.

If you make a request, we must respond to you without undue delay and in any event within one month.

To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.

Our lawful bases for the collection and use of your data

Our lawful bases for collecting or using personal information to provide services and goods are:

• Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
• Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

Our lawful bases for collecting or using personal information for the operation of customer accounts and guarantees are:

• Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

Our lawful bases for collecting or using personal information to prevent, detect, investigate or prosecute crimes are:

• Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
• Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

Our lawful bases for collecting or using personal information for service updates or marketing purposes are:

• Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

Our lawful bases for collecting or using personal information for legal requirements are:

• Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

Our lawful bases for collecting or using personal information for dealing with queries, complaints or claims are:

• Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
• Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

• Directly from you

Whenever we collect or process your personal data, we will only keep it for as long as is necessary for the purpose for which it was collected. We will delete your personal data from our systems unless we believe in good faith that we need to retain some information to place you on a ‘do not contact’ list or where the law or other regulation requires us to preserve it (for example, because of our obligations to tax or regulatory authorities).

Others we share personal information with

• Financial or fraud investigation authorities
• Relevant regulatory authorities
• Warranty and guarantee providers
• Emergency services
• Suppliers and service providers
• Other relevant third parties:
  • Charter Operators
  • To a third party purchaser if we sell our business, in which case business information including customer and supplier contact information may be a transferred business asset.
  • IT companies who support our website, app and other business systems and/or who host our systems and services and therefore store your personal data on our behalf.
  • Operational companies such as delivery couriers, brokers, charter operators.
  • Direct marketing companies who help us manage our electronic and printed communications with you.
  • Data insight companies to ensure your details are up to date and accurate.
  • Compliance service providers that perform checks on our behalf.

If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice.

If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.

The ICO’s address:           

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Helpline number: 0303 123 1113

Website: https://www.ico.org.uk/make-a-complaint

Where this privacy policy is available in a language other than English, then in case of any dispute about its meaning, the English version will take precedence.

By using our services or providing your personal data to us, you expressly consent to the processing of your personal data by us or on our behalf. Of course, you still have the right to ask us not to process your data in certain ways, and if you do so, we will respect your wishes.

Sometimes we will need to transfer your personal data between countries to enable us to supply services you have requested. In the ordinary course of business, we may transfer your personal data from your country of residence to ourselves and to third parties located in the UK, EU or elsewhere.

By dealing with us, you are giving your consent to this overseas use, transfer and disclosure of your personal data outside your country of residence for our ordinary business purposes.

This may occur because our information technology storage facilities and servers are located outside your country of residence and could include storage of your personal data on servers in the UK, EU or elsewhere.

We will ensure that reasonable steps are taken to prevent third parties outside your country of residence using your personal data in any way that is not set out in this privacy policy. We will also make sure we adequately protect the confidentiality and privacy of your personal data.

We will ensure that any third parties process your personal data only in accordance with their legitimate interests. These third parties may be subject to different laws from those which apply in your country of residence. Please note that we do not take active steps to ensure that any overseas recipient of your personal data complies with the laws which apply in your country.

Where applicable, we will comply with the requirements of the Personal Information Protection Law of the People’s Republic of China (“PIPL”) and other relevant Chinese laws and regulations.

We will process your personal data in accordance with the principles of legality, legitimacy, necessity, and good faith. We will obtain your consent before processing your personal data, where required, including for direct marketing purposes and where processing sensitive personal data.

If we process your personal information beyond the scope described in this privacy policy, we will separately explain the purpose, method, and scope of such processing to you, and obtain your consent again if required.

You agree that we may process your personal data outside the need to obtain your authority or consent where (i) it is necessary for the conclusion or performance of a contract to which you are a party, or for the implementation of human resources management in accordance with applicable labour rules and regulations; (ii) it is necessary for the performance of statutory duties or obligations; (iii) it is necessary for the response to a public health emergency or for the protection of the life, health and property safety of a natural person; (iv) it is necessary to process such personal data or other personal data that has been legally disclosed within a reasonable scope in accordance with the law; and/or (v) other circumstances prescribed by law and administrative regulations apply.

Our sharing of personal data with third parties is as set out above in our privacy policy.

Your personal data will be stored outside of the People’s Republic of China, and may be transferred to different entities and territories as described above. We will take necessary measures required by applicable law to ensure that your personal data is adequately protected at all times.

Under the PIPL, you have the following rights:

• Right to be informed: You have the right to know the processing of your personal data. In addition, you have the right to ask us to explain this privacy policy and the rules governing our processing of personal information.
• Right to access and copy: You can request access to your personal data or obtain a copy of your personal data.
• Right to correct and supplement: You can request that we to make corrections or supplements where you find that your personal data is inaccurate or incomplete.
• Right to delete: You can request the deletion of your personal data in certain circumstances (for example if you withdraw your consent, or the purpose of personal data processing has been achieved, it is impossible to achieve such purpose, or it is no longer necessary to achieve such purpose;)
• Right to transfer: You can transfer your personal data to another processor designated by you when it meets the conditions stipulated by the authorities.
• Right to make decisions, restrict and refuse: You can make decisions on the processing of your personal data and restrict or refuse that we process your personal data.
• Right to withdraw your consent: Where our processing of your personal data relies on your consent, you can withdraw your consent at any time. After you withdraw your consent, we will not process the relevant personal data, and cannot provide you with the corresponding services as a result. Withdrawal of consent will not affect the previous personal data processing whilst your consent was valid.

You can exercise these rights by contacting us via the details provided above. We may require you to provide information to enable us to verify your identity before we respond to your request. There are exemptions to the exercise of these rights and we will let you know if we intend to rely on any exemptions.

For the purposes of the California Consumer Privacy Act (“CCPA”), the types of personal data that we collect are as described in the other sections of this privacy policy. In the twelve months preceding the effective date of this privacy policy, we have not sold your personal data to any third party, though we do use standard analytics and tracking tools provided by third parties (see the ‘Cookies’ section for more information).

Subject to certain limitations, you have the right to (i) request more information about the categories and specific pieces of personal data that we collect, use and disclose; (ii) request deletion of your personal data; (iii) opt out of any “sales” of your personal data that may be occurring; and (iv) not be discriminated against for exercising any of these rights.

You can exercise these rights by contacting us via the details provided above. We may require you to provide information to enable us to verify your identity before we respond to your request.

23 October 2024