Your personal information
Changes to data protection law
The law in relation to data protection is changing on the 25 May 2018 when the General Data Protection Regulation comes into force in the United Kingdom and across Europe.
1. Who we are and how you can contact us
We are Wintec Saddles, a world-wide brand owned by Hammersmith Nominees Pty Ltd (ABN 41 008 829 392), PO Box 153, Perth, WA 6858, an Australian company.
You can contact us by email at email@example.com or by calling us on +61 8 9492 6454. If you need to you can write to us at Wintec Saddles, 430 Newcastle Street, West Perth, WA, 6005.
If you are in the EU, our representative for all queries in relation to this policy and your data protection rights is Ellen Bates.
When we refer to our website, we mean our website at wintec-saddles.com.
2. Where we collect your personal information from
We may collect personal information about you in the following ways:
Data you give to us:
- When you use one of our websites (including when you sign up to receive one of our newsletters or to book a test ride for one of our saddles)
- When you provide your details to us at an event we are attending (for example, at a trade show or equestrian event)
- When you register a saddle, a guarantee or a warranty with us
- In emails or letters to us
- If you take part in our competitions or promotions
- When you give us feedback
- When you become a retailer/stockist of our products and/or services
Data we collect when you use our services:
- Payment and transaction data
- Profile and usage data, including data we gather from the devices you use to connect to those services such as computers and mobile phones, using cookies (please see our separate cookies policy) and other internet tracking software
Data from third parties we work with:
- Our retailers and stockists
- Social networks (including Facebook, Twitter and Instagram)
- Agents working on our behalf
- Other customers who may provide information about you
3. Data we collect about you
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity data – name, date of birth, gender, photograph or video
- Contact data – billing address, delivery address, email address or telephone numbers
- Financial data – bank account and payment card details and corporate details
- Transaction data – details about payments to and from you and other details of products and services you have purchased from us
- Technical data – internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website
- Profile data – [your username and password], purchases or orders made by you, your interests and hobbies, preferences, feedback and survey responses
- Usage data – information about how you use our website, products and services
- Marketing and communications data – your preferences in receiving marketing from us and our third parties and your communication preferences
We may also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any special categories of personal data about you. This includes details about race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
4. How we use your personal information
Your privacy is protected by law.
We are only allowed to use personal information about you if we have a legal basis to do so, and we are required to tell you what that legal basis is. We have set out in the table below: the personal information which we collect from you, how we use it, and the legal ground on which we rely when we use the personal information.
In some circumstances, we can use your personal information if it is in our legitimate interest to do so, provided that we have told you what that legitimate interest is. A legitimate interest is when we have a business or commercial reason to use your information which, when balanced against your rights, is justifiable. If we are relying on our legitimate interests, we have set that out in the table below.
5. Who we share your personal information with
We may share your personal information with any of the following organisations, for the purposes of providing the products and services which you have requested from us:
- Our group companies, including:
- Hammersmith Nominees Pty Ltd T/as Bates Australia (ABN 41 008 829 392), PO Box 153, Perth, WA 6858 (AUSTRALIA)
- Saddlery Brands International USA LLC (USA)
- Saddlery Brands International UK Limited (UK)
- Our retailers and stockists (for example when you book a test ride of one of our saddles your local retailer or stockist)
- Courier and shipping/haulage companies
- Public regulators or authorities
- Companies that we have a joint venture or cooperation agreement with
Third party organisations that provide applications/functionality, data processing or IT services to us. For example, we use third parties to help provide, run and manage our internal IT systems, manage payments on our behalf, email marketing campaigns and customer analytics. These include providers of IT services, cloud-based software as services providers, data analysis, security and storage service
You can find details of how these third parties use your personal information by looking at their privacy policies, all of which should be available on the relevant websites, or on request.
We require all organisations who we share your data with to respect the security of your personal data and to treat it in accordance with the law. We do not allow any of our service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. Failing to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
7. Third party links
Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice or policy of every website you visit.
8. Transferring your personal information outside the EEA
The EEA is the European Economic Area, which consists of the EU Members States, Iceland, Liechtenstein and Norway. If we transfer your personal information outside the EEA we have to tell you.
If you are outside Australia, please be aware that you are sending information (including personal information) to Australia where our business is based and our servers are located. That information could then be transferred within Australia or to other countries outside your country of residence, depending on the type of information and how it is stored by us.
These countries (including Australia) may not necessarily have data protection laws as comprehensive or protective as those in your country of residence (especially if you live in the EEA); however, our collection, storage and use of your personal information will at all times continue to be governed by this policy.
9. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator (in the UK, this would be the ICO) of a breach where we are legally required to do so.
10. How long do we keep your personal information
We will keep your personal information for as long as you are our customer.
After you stop being a customer, because you have stopped regularly purchasing our products, we may keep your personal information for so long as necessary to fulfil the purposes we collected it for, including, for one of the following reasons:
- To respond to any questions or complaints from you
- To ensure our lifetime guarantee can be fulfilled
- To maintain our records
- To comply with laws applicable to us
We may use your personal information to tell you about relevant products or services [and any upcoming offers].
We can only use your personal information to send you marketing messages if we have either your consent or a legitimate interest to do so.
You can ask us to stop sending you marketing messages at any time – you just need to contact us, or use the opt-out links on any marketing message sent to you.
We will get your express opt-in consent before we share your personal data with any company outside our group of companies for marketing purposes. You can ask a third party company to stop sending you marketing messages at any time, by adjusting your marketing preferences in relation to that company or by using the opt-out links on any marketing message sent to you.
Where you opt out of receiving marketing messages, this will not apply to personal data provided to us as a result of purchasing our products or services or any other transaction between you and us.
12. Your rights
You have certain rights which are set out in the law relating to your personal information. The most important rights are set out below.
Getting a copy of the information we hold
You can ask us for a copy of the personal information which we hold about you, by writing to us at firstname.lastname@example.org. This is known as a data subject access request.
You will not have to pay a fee to access your personal data unless we believe that your request is clearly unfounded, repetitive or excessive. In such circumstances, we can charge a reasonable fee or refuse to comply with your request.
We will try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month and in that case, we will notify you and keep you updated.
Telling us if the information we hold is incorrect
You have the right to question any information we hold about you that you think is wrong or incomplete. Please contact us at email@example.com if you want to do this and we will take reasonable steps to check its accuracy and, if necessary, correct it.
Telling us if you want us to stop using your personal information
You have the right to:
- object to our use of your personal information (known as the right to object); or
- ask us to delete the personal information (known as the right to erasure); or
- request the restriction of processing; or
- ask us to stop using it if there is no need for us to use it (known as the right to be forgotten).
There may be legal reasons why we need to keep or use your data, which we will tell you if you exercise one of the above rights.
Where we rely on our legitimate interest
In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.
You can withdraw your consent to us using your personal information at any time. Please contact us at firstname.lastname@example.org if you want to withdraw your consent. If you withdraw your consent, we may not be able to provide you with certain products or services.
Request a transfer of data
You may ask us to transfer your personal information to a third party. This right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Making a complaint
Please let us know if you are unhappy with how we have used your personal information by contacting us at email@example.com.
If you are in the EU, you also have a right to complain to the local data protection regulator in your country of residence (in the UK, this is the Information Commissioner’s Office whose contact details you can find at www.ico.org.uk). We would be grateful for the chance to deal with your concerns before you approach the relevant EU regulator so please contact us in the first instance.