Privacy Notice

Hot4Tubs (“we”, “our”, ”us”) are committed to protecting and respecting any personal information our customers, suppliers, employees, workers and third parties share with us.

This statement describes the following;

• what types of personal information we collect

• how we collect it

• how we use it

• how we share it with others

• how long we keep the information

• how you can manage the information we hold

• how you can contact us

 

We will always give you the option not to receive marketing communications from us. We will never send you unsolicited “junk” email or communications, or share your data with anyone else who might. We do not sell your information to third parties, but we do work closely with selected partners who help us to provide you with the information, products and services that you request from us.

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1. What personal data do we collect?

We collect information about you directly from you. This may be collected electronically, by telephone, by post or in person. We only request information which is necessary, relevant and adequate for the purpose you are providing it. The information we collect includes some or all of the following:

• Name

• Address

• Telephone

• Email address

• The pages you visited on our website and how long you visited us for

• Your IP address

• The internet browser and device you are using

• Cookie, pixels or beacon information (for more information see our Cookie Policy)

• The website address from which you accessed our website

• Any information within correspondence you send to us

 

Special Category Data

Special category data is personal data which is more sensitive, and so needs more protection, this is similar to sensitive personal data. It includes: processing of personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation shall be prohibited.

Hot4Tubs does not collect any special category data.

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2. How is your personal data collected?

We use the following methods to collect data from and about you:

• Direct from you. You may use our website, Facebook page, email or the post to supply us with your personal details.

• Automatically. We use cookies to collect data about your computer equipment and browsing actions.

 

3. How do we use your personal data?

We use this information to provide the contractual services agreed by yourself. We may request your explicit consent for our finance partners to contact you for marketing purposes. Please be aware we are doing this on behalf of our finance partners as part of our agreement with them and the consent/non-consent you provide will not affect the way in which we process your information. A copy of their privacy statement will be available at the time of this request for consent.

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Legal basis for processing your personal data

We will only use your personal data where the law allows us to. Generally, we do not rely on consent from you as a legal basis for processing your personal data. Most commonly, we will use your personal data in the following circumstances:

Contractual Performance

We may use your personal information where this is necessary to fulfil and complete your hire, purchases and other transactions entered into with us.

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Legitate Interest

This is the interest of Hot4Tubs in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

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We may use and process your personal information as set out below where it is necessary for us to carry out activities for which it is in our legitimate interests as a business to do so.

Support customers with sales and other enquiries:

• To respond to correspondence you send to us and fulfil the requests you make to us (for example to provide a delivery quotation, hire query and information about specific hot tubs).

• To provide help & support during your hire.

 

Operate the administrative and technical aspects of our business efficiently and effectively:

• To verify the accuracy of information that we hold about you and create a better understanding of you as a customer.

• For network and information security purposes, in order for us to protect your information against loss, damage, theft or unauthorised access.

• To comply with a request from you in connection with the exercise of your rights (i.e. where you have asked us not to contact you for marketing purposes we will keep a record of this on our suppression lists in order to comply with your request).

• To inform you of updates to our terms and conditions and policies.

• To enforce or protect our contractual or other legal rights or to bring or defend legal proceedings.

• To manage your queries, complaints and claims.

 

Legal or Regulatory Obligation

We may process your information to comply with our legal requirements (e.g. to assist the police and HMRC).

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Vital Interest

Sometimes we will need to process your personal information to contact you if there is an urgent safety we need to tell you about it.

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4. How do we share your personal data?

In addition to the third parties mentioned, we may disclose your information to other third parties for legitimate interests as follows:

• to staff members in order to facilitate the provision of goods or services to you;

• to our affiliated entities to support internal administration;

• IT software providers that host our website / social media profiles and store data on our behalf;

• professional advisers including consultants, lawyers, bankers and insurers who provide us with consultancy, banking, legal, insurance and accounting services;

• HM Revenue and Customs, regulators and other authorities who require reporting of processing activities in certain circumstances; and

• third parties who we may choose to purchase, transfer or merge parts of our business or assets. Alternatively, we may seek to acquire other business or merge with them. If a change happens to our businesses then the new owners may use your personal data in the same way as set out in this privacy policy.

 

We may disclose personal data to the police, regulatory bodies, legal advisors or similar third parties where we are under a legal duty to disclose or share personal data in order to comply with any legal obligation, or in order to enforce or apply our website terms and conditions and other agreements; or to protect our rights, property, or safety of our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

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We do not sell your information to third parties. However, we may from time to time share your information with our selected business partners under the following categories. Where we do share your information we take the necessary steps to ensure any third party handling this information fully complies with data protection legislation and protects your information just as we do. We will only disclose personal information that is necessary for them to provide the service.

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To provide products or services you have requested

To full fill the terms of our contracts it is necessary for us to share your personal data with a number of carefully selected suppliers

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To provide finance for the purchase of a hot tub

During the purchase of your hot tub we may broker a finance deal to assist the purchase. We will provide your information upon your agreement to the selected Finance Partners who will use this to put the finance in place. They will not use this for marketing purposes unless your explicit consent has been given.

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International Transfers

We will never share your personal data outside of the European Economic Area.

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5. How long do we keep your personal data for?

We do not retain personal information in an identifiable format for longer than is necessary.

We will retain your personal information for the period of the hire. Once the hire has ended by law we have to keep basic data about our customers including contact and transactional information for six years for tax purposes. Once the hire has ended all personal data is automatically obfuscated.

The exceptions to these retention periods are where;

• The law requires us to hold your personal information for a longer or shorter period.

• You exercise your right to have the information erased and we do not need to hold it in connection with any of the reasons permitted or required under the law.

 

6. How can you manage the personal data we hold about you?

It is important that the personal data we hold about you is accurate and current. Please keep us informed if the personal data we hold about you changes.

Data protection legislation gives you the right to object to the processing of your personal data in certain circumstances or withdraw your consent to the processing of your personal data where this has been provided. You also have the right to access information held about you and for this to be provided in an intelligible form. If you would like a copy of some or all of your personal data, please send an email to hot4tubs@gmail.com

You can also ask us to undertake the following:

• update or amend your personal data if you feel this is inaccurate;

• remove your personal data from our database entirely;

• send you copies of your personal data in a commonly used format and transfer your information to another entity where you have supplied this to us, and we process this electronically with your consent or where necessary for the performance of a contract; or

• restrict the use of your personal data

 

We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the personal data that we hold about you or make your requested changes. Data protection legislation may allow or require us to refuse to provide you with access to some or all the personal data that we hold about you or to comply with any requests made in accordance with your rights referred to above. If we cannot provide you with access to your personal data, or process any other request we receive, we will inform you of the reasons why, subject to any legal or regulatory restrictions. Except in rare cases we will respond to you within 30 days after we have received any requests.

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7. How do we secure and protect your personal information

Hot4tubs use technical and organisational security measures to protect the personal information we hold against manipulation, loss, destruction and access by third parties. These measures are continually improved in line with technological developments.

We will store all the personal information we hold on our secure servers located in specialist hosting centres and environments. These servers are accessed via a secure firewall using individual password protected logins. Where we hold personal information in hard copy/paper format this will be stored in secure archiving.

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Where we pass your information to third parties to process on our behalf we will have contracts in place which restrict the processing to that requested by us and also specify deletion of the information once processing is complete.

In certain cases where we share your information with third parties such as our manufacturer and finance partners they will become data controllers and will be bound by the same legislation as we are, you will be able to review their privacy statements and manage your information with them.

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Website Links

Our website may contain links to other websites run by organisations which we do not control. This policy does not apply to those other websites. We provide links to those websites solely for your information and convenience and we make no endorsements, representations or promises about their accuracy, content or thoroughness. Please note that if you follow a link to any of these websites, such websites will apply different terms to the collection and privacy of your personal data and we do not accept any responsibility or liability for these policies. Your disclosure of personal information to third party websites is at your own risk.

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Changes to this policy

We may review this policy from time to time and any changes will be notified to you by posting an updated version on our website, these changes will take effect 7 days after the date the modified version was posted to the website. We recommend you regularly check for changes and review this policy when you visit our website. If you do not agree with any aspect of the updated policy you must notify us on our contact details below.

This policy was last updated on 08 May 2018.

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Hot4tubs – Contact Details

We have appointed a Data Manager to oversee compliance with this privacy policy To exercise any of your rights as a Data Subject please contact us using the details below and we will, in the exception of rare cases, respond to you within 30 days:

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Email: hot4tubs@gmail.com

Telephone: 07340425137

Having contacted us if you are still unhappy, you have the right to lodge a complaint with the data protection regulator

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