Philip Harris Privacy Policy

We are Findel Education Limited (collectively referred to as “Findel”, “we”, “us” and “our” in this privacy policy). Findel is the data controller and responsible for your personal data collected through Our Site.

Findel is owned by Manutan who shall act as a data controller of any Findel data that is provided in connection with their investment and ongoing relationship with Findel. Personal data will be processed by Manutan in accordance with the Manutan Privacy statement, accessible here: Cookies and personal data | Manutan Group. Manutan is a company incorporated in France with Company Reg. No. 920 350 477.

We will only collect and use your personal data for the following purposes: to

• fulfil your order(s) and carry out our obligations arising from any contracts entered into between you and us;
• keep you up to date with the latest offers and trends and notify you of any changes to our service;
• give you a better shopping experience to ensure that content from our site is presented in the most effective manner for you and for your computer;
• help us to make our marketing more relevant to you and your interests;
• meet our legal responsibilities;
• to allow you to participate in interactive features of our service, when you choose to do so.

Information that you provide by filling in forms on Our Site.

We may also invite you to complete surveys that we use for research purposes, although you do not have to respond to them.

We may also ask you for information when you register for offers, enter a competition or promotion, and when you report a problem with our site. If you contact us, we may keep a record of that correspondence.

Payments and Financial Data

We do not collect Financial Data such as payment card details or bank account numbers. In line with best practice, when you make a purchase from Our Site we use separate, trusted and secure 3^rd party services to collect payment and card details on our behalf, and to carry out all the security checks required by your bank or financial institution.

This website is not intended for children and we do not knowingly collect data relating to children.

The following groups of personal data are collected:

• Identity Data includes information such as first name, last name, title and role.
• Contact Data includes information such as email address, delivery address, location, country, and contact telephone number.
• Transaction Data includes details of your order (such as your Purchase Order number, the items and quantities you are ordering, and any discounts, shipping costs, tax etc.), payments to and from you and details of other products and services you have obtained from us, correspondence or communications with you in respect of your orders, and details of any rewards and bonuses awarded.
• Technical Data includes information such as details of the device(s) you use to access our services, your username and password, your browser type and version, your time zone setting and location, and the type of computer or device you are using, and how long it takes pages to load for you.
• Profile Data includes information such as the purchases or orders made by you, your product interests, your settings or preferences, and your feedback and survey responses.
• Usage Data includes information such as when you used Our Site and which pages you viewed.
• Marketing and Communications Data includes information such as your preferences in receiving marketing from us and our third parties. and your communication preferences.

We 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 as it 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 sell your data, nor do we share it with and any third-party organisations not directly relevant to fulfilling your order.  We share limited amounts of your data with chosen third party partners in order to deliver the products and services you have ordered to you - for example, your name, address, email addresses and phone number are shared with our delivery partners in order to fulfil your parcel delivery. Where we do share such data, we ensure the chosen third parties are also compliant with the General Data Protection Regulations, we only share the minimum amount of data needed for the third party to fulfil your order, and they will contact you by electronic means only if you have consented to this.

Our legal basis for the processing activities described above depends on the personal information concerned and the specific context in which we process it. The most common legal bases we have for processing your data are:

• processing is necessary in order for us to fulful the order you have placed with us;
• where relevant, processing is necessary for the performance of our obligations under a contract between you and us, or to take steps prior to entering into a contract with you;
• processing is necessary for the purposes of our legitimate interests, such as keeping your data secured, accurate and up to date. A legitimate interest in this context means a valid interest we have which is not overridden by your interests in data privacy and security;
• processing is necessary to comply with a legal obligation; or
• you have consented to such processing of your personal information.

Where we ask for your consent to process certain personal information, you are free to refuse our use of your personal data for those purposes and you may withdraw your consent at any time by contacting us on the details below. This won't affect the lawfulness of any processing of your personal information that was based on your consent before you withdrew it.

We do not use your data to carry out automated decision-making.

We may obtain information about your general internet usage by using a cookie file which is stored on the hard drive of your computer. Cookies contain information that is transferred to your computer’s hard drive. They help us to improve our site and to deliver a better and more personalised service. They enable us:

• to speed up your searches and make Our Site faster to load on your device,
• to store information about your preferences, so we can customise our site according to your individual interests or choices, and
• to recognise you when you return to our site.

You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. However, if you select this setting, you may be unable to access certain parts of our site. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you log on to our site.

For full details as to how we use cookies please see our cookie policy.

The data that we collect from you may be transferred to, and stored at, a destination outside the UK or the European Economic Area ("EEA"). It may also be processed by staff operating outside the UK of the EEA who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. Where the recipient of your personal data is based in a jurisdiction that has not been deemed to provide adequate protection of your data, then we put in place specific contractual protections approved for use by the ICO in order to ensure that your data is adequately protected. If you'd like to know more about those protections then please contact us using the information provided below. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

All information you provide to us is stored securely. Any payment transactions are encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the internet cannot be guaranteed to be completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of data transmitted between us over the internet; any transmission is at your own risk. Once we have received your information, we use strict procedures and security features to prevent unauthorised access.

We will retain your personal data only for as long as is reasonably necessary for the purpose for which it was obtained and in accordance with our legal obligations, and follow our data destruction policy and processes thereafter.

We may disclose your personal information to any member of our 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 disclose your personal information to third parties:

• 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 Findel, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
• 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 Findel or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.

You have the right to:

• request access to your personal data
• request correction of your personal data
• request erasure of your personal data
• request restriction of processing of your personal data
• request the transfer of your personal data
• object to processing of your personal data

Our site may, from time to time, contain links to and from the websites of other businesses. 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.

These rights are limited in some situations; for example, if we have a legal requirement or a compelling legitimate ground we may continue to process your data even where you request its deletion.

If you would like to exercise any of these rights, please contact us using the details in the Contact section below.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

You also have the right to make a complaint if you feel your personal data has been mishandled. We encourage you to come to us in the first instance, but you are also entitled to complain directly to the Information Commissioner’s Office (ICO) (if you are in the UK), or to your local data protection authority (if you are outside the UK).

You can contact us at the addresses below.

General enquiries

Email: enquiries@philipharris.co.uk

Post: Findel, 2 Gregory Street, Hyde, Cheshire SK14 4TH

Data Protection enquiries

Email: dpo@findel-education.co.uk

Post: Attn DPO, Findel, 2 Gregory Street, Hyde, Cheshire SK14 4TH

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 email.