Privacy Policy BHID GROUP LTD (BHID GROUP LTD HAS THREE MAIN SUBSIDIARIES TOM HOWLEY LTD, NEVILLE JOHNSON LTD, LONDON DOOR COMPANY LTD) TOM HOWLEY LIMITED (“WE”) ARE COMMITTED TO PROTECTING AND RESPECTING YOUR PRIVACY. This policy (together with our terms of use and any other documents referred to in it) explains what personal data we hold about you and sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read it carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting tomhowley.co.uk you are accepting and consenting to the practices described in this policy. For the purpose of the General Data Protection Regulations 2018 (“GDPR”), the Data Controller is Tom Howley Limited, registered in England with company number 7482731 at address Broadoak Business Park, Ashburton Road West, Trafford Park, Manchester, M17 1RW. We are registered with the Information Commissioner’s Office as a data controller under number Z5366814. Our Data Protection Officers are Sharon Rawsterne and Emma Roscoe who can be contacted by email at dpofficer@bhid.co.uk. INFORMATION WE MAY COLLECT FROM YOU We may collect and process the following data about you: Information you give us. You may give us information about you by filling in forms, on our site tomhowley.co.uk (our site) or by corresponding with us by phone, e-mail, post or in person. This includes information you provide when you request a brochure, request a consultation, attend a consultation and enter a competition, promotion or survey. The information you give us may include your name, mailer address, e-mail address and phone number, financial and credit card information and mobility description and requirements. Information we collect about you. With regard to each of your visits to our site we may automatically collect the following information: technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number. information we receive from other sources. We may receive information about you if you use any of the other websites we operate or the other services we provide. In this case we will have informed you when we collected that data that it may be shared internally and combined with data collected on this site. We also work closely with third parties (including, for example, agents, business partners, sub-contractors in sales, technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them. These companies only have access to personal information needed to perform their functions and may not use it for other purposes. An example of this is other members of the BHID Group (Tom Howley, Neville Johnson and London Door Company). COOKIES In common with many other website operators, we use standard technology called ‘cookies’ on our website. Cookies are small pieces of information that are stored by the browser on your computer’s hard drive and they are used to record how you navigate websites on each visit. They help distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. For further information on how we use cookies you can access a copy of our Cookie Policy by visiting https://www.tomhowley.co.uk/cookie-policy/ E-newsletter – we use a third party supplier Dotmailer to send regular updates to our database to update you on all our new products, competitions, product information and marketing updates. We gather statistics and results from our emails to help improve and monitor our e-newsletter feedback. You can control your marketing communication via email by simply selecting the ‘unsubscribe’ link in an email. Please see their privacy policy here https://www.dotmailer.com/terms/privacy-policy/ WordPress (Automattic Inc) – we use a third party service, WordPress.com, to publish our blogs and host all BHID Group websites. We collect user information from the website to monitor and improve user activity of the websites. Please see their privacy policy here https://automattic.com/privacy/ Social Media – we use third party advertising via social media channels Facebook, Pinterest and Instagram. All data collected through these channels will follow that specific channels privacy policy found here: Houzz https://www.houzz.com/privacyPolicy , Facebook https://www.facebook.com/full_data_use_policy , Instagram https://help.instagram.com/155833707900388 , Pinterest https://policy.pinterest.com/en-gb/privacy-policy Children Our website and services are not aimed at children because in relation to our products and services children would need to be represented by their parent or guardians. If you are a child and need further advice or explanation about how we would use your data, please email dpofficer@bhid.co.uk. How we use this data. We use information held about you in the following ways: Information you give to us. We will use this information: to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us; to provide you with information about other products and services we offer that are similar to those that you have already purchased or enquired about; to provide you, or permit selected third parties, including BHID Group members to provide you, with information about products or services we feel may interest you. If you are an existing client, we will only contact you (either via post, or by e-mail or SMS, or telephone) with information about products and services similar to those which were the subject of a previous sale or negotiations of a sale to you. If you are a new client, we will only contact you (either via post, or by e-mail or SMS, or telephone) as you will have selected via our online form. If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, you are free to withdraw your consent at any time by emailing dpofficer@bhid.co.uk. to notify you about changes to our services; to ensure that content from our site is presented in the most effective manner for you and for your computer. Information we collect about you. We will use this information: to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes; to improve our site to ensure that content is presented in the most effective manner for you and for your computer; as part of our efforts to keep our site safe and secure; to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you; to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them. Information we receive from other sources. We may combine this information with information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive). DISCLOSURE OF YOUR INFORMATION We may share your personal information with any member of the BHID group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006. We may share your information with selected third parties including: Agents, business partners, suppliers and sub-contractors for the performance of any contract we enter into with you. Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers, but we may provide them with aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in M1). We may make use of the personal data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience. Analytics and search engine providers that assist us in the improvement and optimisation of our site. Credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you. Suppliers of some appliances purchased by you to ensure warranty cover. We may disclose your personal information to third parties: In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets. If Tom Howley Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its clients will be one of the transferred assets. If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use or terms and conditions of supply and other agreements; or to protect the rights, property, or safety of the BHID Group and subsidiaries, our clients, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction. WHERE WE STORE AND PROTECT YOUR PERSONAL DATA The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. In the event that we do transfer your personal data outside of the EEA, we will ensure there is an adequate level of protection for your rights and freedoms in relation to that data. All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. How long will we keep it for Your personal data will be retained electronically only for as long as necessary to fulfil the purposes for which the information was collected or as required by law. YOUR RIGHTS Under GDPR, you are entitled to access your Personal Data (this is known as a “right to access”). If you wish to make a request, please do so in writing addressed to our Data Protection Officer. A right to access your Personal Data means that you are entitled to a copy of the data we hold on you – such as your name, address, contact details, date of birth, etc.- but it does not mean you are entitled to the documents that contain this data. Under certain circumstances, in addition to your right to access, you have these rights: The right to be informed: which is fulfilled by our making this Policy available and our transparent explanation as to how we use your Personal Data; The right to rectification: you are entitled to have Personal Data rectified if it is inaccurate or incomplete; The right to erasure / ‘right to be forgotten’: you have the right to request the deletion or removal of your Personal Data where there is no compelling reason for its continued processing. This right only applies in these circumstances: where the Personal Data is no longer necessary as regards the purpose for which it was originally collected; where consent is relied upon as the lawful basis for holding your data, and you withdraw your consent; where you object to the processing, and there is no overriding legitimate interest for continuing the processing; that the personal data was unlawfully processed; where you object to the processing for direct marketing purposes. The right to object: you have the right to object to processing based on legitimate interests, and direct marketing. This right only applies in these circumstances: an objection to stop processing personal data for direct marketing purposes is absolute; there are no exemptions or grounds to refuse and we must stop processing for such purposes; where you have an objection based on grounds relating to your particular situation; We must stop processing your Personal Data unless: we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms; or the processing is for the establishment, exercise or defence of legal claims. The right to restrict processing: you have the right to request the restriction or suppression of your Personal Data. When processing is restricted, we can store the data but not use it. This right only applies in these circumstances: where you contest the accuracy of the Personal Data, we should restrict the processing until we have verified the accuracy of that data; where you object to data processing which was necessary for the performance of a public interest or purpose of legitimate interests, and we are considering whether our legitimate grounds override your right; where the processing is unlawful and you request restriction; if we no longer need the data, but you require it to establish, exercise or defend a legal claim. When contacting us please ensure that you provide relevant information to allow us to identify you and state the right or rights that you wish to exercise. We may need to contact you to request further information to verify your identity. We will respond to you within one month of receipt of a valid request. Complaints about the use of Personal Data If you wish to make a complaint about our handling of your Personal Data, you can contact our Data Protection Officer who will investigate further. Our Data Protection Officers are Sharon Rawsterne and Emma Roscoe who can be contacted by email at dpofficer@bhid.co.uk. If you are not satisfied with our response or believe we are not processing your Personal Data in accordance with the law, you can complain to the Information Commissioner’s Office (ICO): Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. You can also contact the Information Commissioner’s Office by visiting their website https://www.ico.org.uk Any questions regarding the Policy and our privacy practices should be sent by email to dpofficer@bhid.co.uk. Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites. CHANGES TO OUR PRIVACY POLICY Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy. CONTACT Questions, comments and requests regarding this privacy policy, or removal from our database are welcomed and should be addressed to dpofficer@bhid.co.uk.