1. Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
2. Information About Us
Our Site is operated by Neelkanth Safe Deposit Ltd., a limited company registered in England under company number 8149644. Registered address: 335-337 Harrow Road, Wembley, HA9 6BB. Main Trading Address: 2 Beconsfield Road, Southall, UB1 1BA VAT number: 150678504. Data Protection Officer: G. Mangaroliya. Email address: firstname.lastname@example.org. Telephone number: 020 8843 9920. Postal address: 2 Beconsfield Road, Southall, UB1 1BA. We are regulated by Financial Conduct Authority. We are a member of Safety Deposit Association.
3. What Does This Policy Cover?
4. What Is Personal Data?
Personal data is defined by the UK GDPR and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’. Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
5. What Are My Rights?
Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:
- a) The right to be informed about our collection and use of your personal data. Y
- b) The right to access the personal data we hold about you.
- c) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete.
- d) The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold.
- e) The right to restrict (i.e. prevent) the processing of your personal data.
- f) The right to object to us using your personal data for a particular purpose or purposes.
- g) The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
- h) The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
- i) Rights relating to automated decision-making and profiling. For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 15. It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data. Further information about your rights can also be obtained from the Information Commissioner’s Office. If we have been unable to resolve your query or the issue and you would like to lodge a complaint, then you can do that with the Information Commissioner’s Office.
7.How Do You Use My Personal Data?
Under the Data Protection Legislation, We must always have a lawful basis for using personal data. The following table describes how We may use your personal data, and our lawful basis for doing so:
8. How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the duration of your locker rental contract with us and for 6 years after the contract ends.
9. How and Where Do You Store or Transfer My Personal Data?
We may store some or all of your personal data in countries outside of the UK. These are known as “third countries”. We will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation as follows: We ensure that your personal data is protected under binding corporate rules. Binding corporate rules are a set of common rules which all our group companies are required to follow when processing personal data. For further information, please refer to the Information Commissioner’s Office. We will use specific approved contracts which ensure the same levels of personal data protection that apply under the Data Protection Legislation. For further information, please refer to the Information Commissioner’s Office.] Please contact us using the details below in Part 15 for further information about the particular data protection safeguards used by us when transferring your personal data to a third country. The security of your personal data is essential to us, and to protect your data, We take a number of important measures, including the following: • limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality; • procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so;
10. Do You Share My Personal Data?
11. How Can I Control My Personal Data?
- 11.1 In addition to your rights under the Data Protection Legislation, set out in Part 5, when you submit personal data via Our Site, you may be given options to restrict our use of your personal data. In particular, We aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us by unsubscribing using the links provided in our emails or at the point of providing your details.
- 11.2 You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
12. Can I Withhold Information?
You may access certain areas of Our Site without providing any personal data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
13. How Can I Access My Personal Data?
If you want to know what personal data We have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). All such requests should be made in writing and sent to the email or postal addresses shown in Part 15. There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding. We will respond to your subject access request within 30 days of receiving it. Normally, We aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date We receive your request. You will be kept fully informed of our progress.
15. How Do I Contact You?
To contact us about anything to do with your personal data and data protection, please use the following details Data Protection Officer: Email address: email@example.com. Telephone number: 020 8843 9920. Postal Address: 2 Beconsfield Road, Southall, UB1 1BA.
|“Account”||means an account required to access and/or use certain areas and features of OurSite;|
|“Cookie”||means a small text file placed on your computer or device by OurSite when you visit certain parts of OurSite and/or when you use certain features of OurSite. Details of the Cookies used by OurSite are set out in Part 14, below; and|
|“Cookie Law”||means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;|
|Data Collected||How We Collect the Data|
|Identity Information including Full Name, Date of Birth, Passport/DL/Other ID details & Copy, Passport Size Photo, Nationality, Place of Residence, Place of Birth, Ethnicity, Gender, Biometric Fingerprint, Signatures.||Client entering this information during the sign up process on the oursite.|
|Contact information including Address, Email, Telephone, Mobile.||Client entering this information during the sign up process on the oursite.|
|Business information including. Business Name, Job Title, Occupation.||Client entering this information during the sign up process on the oursite.|
|Payment information including. Bank details, Debit/Credit Card details.||Client entering this information during the sign up process on the oursite.|
|Technical information including IP Address, Browser Type, Device Type, Operating System, Location.||Client entering this information during the sign up process on the oursite.|
|Data from third parties including Credit Reference, Electoral roll, Crimes & PEP data.||Contacting third party websites for ID and background checks.|
|What We Do||What Data We Use||Our Lawful Basis|
|Registering you on Our Site. Providing and managing your Account.||Full Name, Date of Birth, Address, Email, Telephone, Mobiles, Passport/DL/Other ID details & Copy, Passport Size Photo, Nationality, Place of Residence, Place of Birth, Ethnicity, Gender, Biometric Fingerprint, Signatures.||Providing our services to you. To allow you to open, manage and operate your locker and your account with us while you are renting the locker from us.|
|Providing and managing your access to Our Site.||Login ID and Password.||To allow you to login and use our site and manage your account.|
|Managing payments for our products and services.||Full Name, Address, Email,||To help process payments.|
|Communicating with you.||Full Name, Address, Email, Telephone, Mobile.||To communicate with you.|
|Supplying you with information by email AND/OR post that you have opted-in-to (you may opt-out at any time by following the given instructions).||Full Name, Address, Email, Telephone, Mobile.||To communicate information and marketing material based on your preferences.|
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email and/or telephone and/or text message and/or post with information, news, and offers on our products and/or services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out. We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time. We use the following automated systems for carrying out certain kinds of decision-making and/or profiling. If at any point you wish to query any action that We take on the basis of this or wish to request ‘human intervention’ (i.e. have someone review the action themselves, rather than relying only on the automated method), the Data Protection Legislation gives you the right to do so. Please contact us to find out more using the details in Part 15. • The following automated decision-making method(s) may be used: o Background and ID checks through third party websites as a part of our vetting process. We will only use your personal data for the purpose(s) for which it was originally collected unless We reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If We do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 15. If We need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, We will inform you and explain the legal basis which allows us to do so. In some circumstances, where permitted or required by law, We may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.