GDPR Policy

Sinclair Barr Newsagents understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of our customers and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the General Data Protection Regulation (EU Regulation 2016/679) ("GDPR").

This notice relates to all services provided by any part of Sinclair Barr Newsagents and all personal information either provided to us by an individual or company

1. Information about us
   Personal data is stored by Sinclair Barr Newsagents, whose registered address is 50 Glasgow Road, Paisley, PA1 3PW.

Under the GDPR we are the 'Data Controller'.

2. What does this Privacy Notice cover?
   This Privacy Notice explains how we use your personal data; how it is collected, how it is held, and how it is processed. It also explains your rights under the GDPR relating to your personal data.
3. What is Personal Data?
   Personal data is defined by the GDPR 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 information such as your name, contact details and customer identification numbers.

The personal data that we collect and process is set out in Part 5, below.

Generic information which does not identify an individual such as 'info@...' is not personal data and can therefore be held outside the scope of the GDPR.

4. What are your rights?
   Under the GDPR, you have the following rights, which we will always uphold:

• The right to be informed about our collection and use of your personal data.
• The right to have any errors rectified if any of your personal data held by us is inaccurate or incomplete.
• The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data held by us.
• The right to restrict (i.e. prevent) the processing of your personal data.
• The right to object to us using your personal data for a particular purpose or purposes.
• The right to data portability. This means that you can ask us for a copy of your personal data held by us to pass to another service provider.
• The right to be advised if we use automation in decision-making and profiling.

This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 13. You should also contact us at the address noted in Part 13 if you wish to exercise any of the above rights.

Further information about your rights can also be obtained from the Information Commissioner's Office or your local Citizens Advice Bureau.

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner's Office.

5. What data do we collect?
   We may collect, store and process some or all of the following personal data (this may vary according to your relationship with us):

• Name
• Business name
• Job role
• Postal/Delivery address
• Directions to a property
• Telephone number(s)
• Email address
• Web address
• Account reference identifier
• Bank account details (this information is stored separately and only referenced against an account number)

Credit or Debit Card details, if freely given, are processed securely by World Pay. We do not hold or have access to this data. Please see the World Pay privacy policy for full details on how they handle data.

We may also use automated processes to collect data when you visit our website or app to collect the IP address of the device you use to connect to the internet, the geographical location of that device, the browser you are using, the type of device you are using (tablet, mobile, desktop), the URL you came from and the web pages you access.

Our website also use Cookies. See our Cookies Policy for full details.

6. How do we use your Personal Data?
   All personal data is processed and stored securely for no longer than is necessary for the purpose it was originally collected. We will comply with our obligations and safeguard your rights under the GDPR at all times.

Our use of your personal data will always have a lawful basis, either because it is necessary for our performance of a contract with you, because you have consented to our use of your personal data (e.g. by subscribing to emails), or because it is in our legitimate interests. Specifically, we may use your data for the following purposes:

• Providing and managing your account
• To process delivery orders agreed by you
• Supplying our products and services to you (please note that we may require your personal data in order to enter into a contract with you)
• To contact you if you request communication from us
• Replying to emails from you
• Personalising and tailoring our products and services for you
• Supplying you with emails that you have opted into or for legitimate interest reasons (you may unsubscribe or opt-out at any time by following the unsubscribe link in the footer of a newsletter e-mail or by sending us an e-mail to news@sinclairbarrnewsagents.co.uk
• Market research
• Analysing your use of our services and gathering feedback to enable us to continually improve our services and your experience in dealing with us
• To maintain records required for statutory record keeping or legislative requirements

With your permission and/or where permitted by law, we may also use your data for marketing purposes which may include contacting you by email, post or by telephone with information, news, offers and services. We will not, however, send you any unsolicited personal marketing or spam and will take all reasonable steps to ensure that we fully protect your rights and comply with our obligations under the GDPR. If you do not wish to receive these offers and information please e-mail us at news@sinclairbarrnewsagents.co.uk

7. How long do we store your Personal Data?
   We only keep your personal data for as long as we need to in order to use it as described above in Part 6, and/or for as long as we have your permission to keep it.

Personal data held in connection with the management of your account will be held all the time your account remains active or is considered 'live'. If your account remains inactive after the period required to retain information for statutory record keeping, your details will be deleted.

Personal data provided in connection with direct marketing or newsletter subscriptions will be retained as long as your consent remains active and your consent is considered to be valid.

8. What steps do we take to secure and protect your Personal Data?
   Data security is very important to us, and to protect your data we have taken suitable measures to safeguard and secure data collected.

We are totally committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure we have put into place suitable physical, electronic and managerial procedures to safeguard and secure the personal data we collect against loss, theft, misuse, unauthorised access, disclosure, alteration and destruction. Access to your personal information is restricted to authorised personnel only.

9. What happens if we suffer a Personal Data breach?
   We have put in place a procedure to identify, assess and investigate any suspected personal data breach at the earliest possible time and will notify individuals or any applicable regulator where we are legally required to do so.
10. Do we share your Personal Data?
    We do not share your personal data with any other companies or entities unless required to by law or where we require third party assistance to fulfil our service to you. Such third parties will include our secure payment processing company (World Pay) and may include third party contractors, subscription providers and marketing companies. These third parties only have permission to use your data for our specific requirement, and may not use it or share it for any other purpose.

If any of your personal data is required or handled by a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party's obligations under the law.

In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

11. How you can access your 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). This is known as a "subject access request".

All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 13.

We will respond to your subject access request as quickly as possible within not more than one month 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 progress.

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.

12. Third Party links
    Our website may include links to third party websites, plug-ins and applications. Clicking on these 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 of every website you visit.
13. How to contact us
    To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details for the attention of the Data Protection Officer:

Contact details:
E-mail address:
news@sinclairbarrnewsagents.co.uk

Telephone:
0141 889 9879

Correspondence address:

Data Protection Officer

Sinclair Barr Newsagents

50 Glasgow Road

Paisley

PA1 3PW

14. Changes to this Privacy Notice
    We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.