TD Tom Davies Ltd. and its corporate business affiliates (“Tom Davies,” “we,” or “us”) provide this notice (“Privacy Notice”) to inform you of our personal information handling practices for personal information we collect from those who contact us and visitors to www.tdtomdavies.com and other web and mobile sites operated by us that link to this Privacy Notice (collectively, the “sites”).
This Privacy Notice (together with our Cookie Notice) sets out the basis on which any personal data, personally identifiable information, or personal information (“personal data”) that you provide to us or we collect from you through our sites will be processed by us. This Privacy Notice does not cover any personal data we collect offline.
When you use our sites, contact us, or make an inquiry via our sites, your personal data will be collected and controlled by TD Tom Davies Ltd. (a UK company organised under the laws of the United Kingdom and based at 983 Great West Road, London, TW8 9DN).
INFORMATION WE COLLECT ABOUT YOU
We collect and process the following personal data about you:
Information you give to us directly
We collect information about you when you: create an account on our sites; place an order from our sites; fill in forms on or interact with our sites; correspond with us (e.g., when you contact Tom Davies’ Customer Service team); request information about our services; book in for our services and report a problem with our sites.
The information you give us may include your name, alias, username, date of birth, gender, phone number, email address, and other information that you choose to provide. Providing such personal data is voluntary. However, without providing such personal data, we may not be able to provide you with information or services you request from us. You will know what personal data you provide because you will actively submit it to us.
Information we automatically collect about you
In addition to the personal data that you actively provide, the sites may automatically collect, process, and store certain information about you:
- Technical information, including the type and version of your web browser, device identifier, operating system and platform, IP address, and location and time zone setting.
- Information about your site visit, including the pages or products viewed on our sites, the search terms used to locate our sites from external search engines, your interactions with the sites (including the duration of visit, where you scroll on those pages, and where you click), and website performance during your visit.
- Information collected through cookies and other similar technologies.
HOW WE USE YOUR INFORMATION
To the extent permitted under applicable law, we will use personal data held about you for the purposes detailed below:
- Establish and verify your identity and the accuracy of your information.
- Manage user relationships and communicate with you, including to respond to your inquiries and fulfil your requests.
- Provide you with the information, products, and services you request from us and carry out our obligations arising from any contracts entered into between you and us, including to process, maintain, and service your accounts, provide you with service booking confirmations, provide customer support, and enable service providers to perform the services on our behalf or assist us with our provision of services to you.
- Measure and understand the effectiveness of the marketing we serve to you and others and deliver relevant communications to you.
- Provide you, or allow selected third parties to provide you, with information about goods or services we feel may interest you, to the extent permitted by applicable laws. You may opt out of receiving marketing communications from us or our affiliates by sending an email to firstname.lastname@example.org, or by unsubscribing through the unsubscribe or opt-out link in an email.
- Administer, facilitate, and improve operations of our sites, including for troubleshooting, data analysis, testing, research, statistical and survey purposes.
- Ensure that content from our sites is presented in the most effective manner for you and your device.
- Engage in research and development efforts to assess the performance of our sites and services, analyse usage, interests, and trends in connection with our sites and services, improve and personalise our sites and services, and develop new products and services.
- Send you administrative information, including information about our sites and changes to our services, terms, conditions, or policies.
- Handle and record consumer rights requests, including opt-ins and opt-outs.
- Monitor and enhance the safety and security of our sites, including to prevent fraud or other unauthorised or illegal activity.
- Conduct internal audits and investigations.
- Comply with laws and regulatory requirements, enforce our terms and conditions, respond to lawful requests, court orders, and legal processes, and protect and defend the rights, property, or safety of us, our affiliates, employees, customers, users, and others.
THE PERIODS FOR WHICH WE RETAIN YOUR INFORMATION
We will not hold your personal information in an identifiable format for any longer than is necessary for the purposes for which we collected it. For certain purposes we retain your personal information (e.g. to suppress marketing messages where you have opted out), otherwise to establish, bring or defend legal claims, we only retain your personal information in accordance with our data retention policy and relevant statutory data retention periods that apply. For example:
- We keep your personal information for no longer than necessary to fulfil the purposes for which the information is processed. We process personal information in accordance with our Data Retention Period and relevant statutory data retention period that may apply.
The only exceptions to this are where:
- The law requires us to hold your personal information for a longer period, or delete it sooner;
- You exercise your right to have the information erased (where it applies) and we do not need to hold it in connection with any of the reasons permitted or required under the law (see further Your Rights In Relation To Your Personal Information below);
- We bring or defend a legal claim or other proceedings during the period we retain your personal information, in which case we will retain your personal information until those proceedings have concluded and no further appeals are possible;
- We archive the information, in which case we will delete it in accordance with our deletion cycles which are based on good industry practice; or
- You exercise your right to require us to retain your personal information for a period longer than our stated retention period (see further Your Rights In Relation To Your Personal Information below).
DISCLOSURE OF YOUR INFORMATION
To the extent permitted under applicable data protection law, we may share your personal data with:
- Any member of our group. For example, we may share your personal data with Tom Davies’ group companies to provide you with products and services, provide you with customer support, understand your preferences, offer targeted marketing, send you information about products and services that may be of interest to you, and conduct other activities described in this Privacy Notice.
- Selected third parties including:
- Service providers who act as our data processor. These service providers perform services on our behalf and assist us with the provision of our sites and services. For example, they may assist us with powering our sites, payment processing, processing and fulfilling orders placed by customers, fraud prevention, marketing, purchase financing, and customer support services.
- Analytics and search engine providers that assist us in the improvement and optimisation of our sites.
- Business partners that enhance our advertising efforts.
- Other third parties in the following circumstances:
- If we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
- If we or our affiliates, or substantially all of the assets of any of the foregoing, is acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
- To comply with any legal obligation or request from law enforcement, enforce or apply our agreements, or to protect the rights, property, or safety of us or our affiliates, employees, customers, users, or others.
We have put in place technical and organisational security measures, to reduce the risk of your personal data being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed.
INTERNATIONAL DATA TRANSFERS
Your personal data may be disclosed to employees, representatives, or other third parties including our service providers operating outside of the country you are based and who work for, or are engaged by us or our affiliates in other countries, including the UK and in other countries that we operate. We note that these persons and third parties may also store, transfer, or access personal data outside of the country you are based. In disclosing your personal data overseas, we will take such steps as are reasonable in the circumstances to require that overseas recipients protect your personal data in accordance with applicable laws.
YOUR RIGHTS AND CHOICES
Individuals in certain jurisdictions have legal rights to obtain confirmation of whether we hold personal data about them, to access personal data we hold about them (including, in some cases, in portable form), and to obtain its source, correction, purpose of collection, update, amendment or deletion in appropriate circumstances. They may also object to our uses or disclosures of personal data, request a restriction on its processing, or withdraw any consent, though such actions typically will not have retroactive effect. They also will not affect our ability to continue processing data in lawful ways. To exercise any of the rights or choices described above (or any other rights under applicable law), please contact us as described at the end of this Privacy Notice.
The rights and options described above are subject to limitations and exceptions under applicable law. We will respond to your requests to exercise your privacy rights in accordance with applicable law. We may request additional information from you to verify your identity and complete your request. If we deny your request, we will explain why.
Questions, comments, or requests regarding this Privacy Notice and any other supplemental documents are welcomed and should be addressed to:
Attn: Operations Department
TD Tom Davies Ltd.
983 Great West Road,
Telephone: +44 (0) 20 8392 0555
Similarly, if you have any complaints about our privacy management practices, you can contact us using the same details. You may also have a right to raise your complaint with the relevant privacy regulator in your jurisdiction.
CHANGES TO OUR PRIVACY NOTICE
We may make changes to this Privacy Notice, including material changes, from time to time. We will inform you of any changes to the processing activities described in this Privacy Notice before we start that new processing.