The policy sets out the different areas where user privacy is concerned and outlines the obligations & requirements of the users, the website and website owners. Furthermore, the way this website processes, stores and protects user data and information will also be detailed within this policy.
Please read the following carefully to understand our practices regarding your personal data. By using our website http://torro.co.uk/website (our ‘Website’) you are accepting and consenting to the practices described in this policy.
Explaining the legal bases we rely on:
The law on data protection sets out a number of different reasons for which a company may collect and process your personal data, including:
In specific situations, we can collect and process your data with your consent.
For example, when you tick a box to receive our newsletter.
When collecting your personal data, we’ll always make clear to you which data is necessary in connection with a particular service.
In certain circumstances, we need your personal data to comply with our contractual obligations.
For example, if you order an item from us for home delivery, we’ll collect your address details to deliver your purchase, and pass them to our courier.
If the law requires us to, we may need to collect and process your data.
For example, we can pass on details of people involved in fraud or other criminal activity affecting the Partnership to law enforcement.
In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests.
For example, we will use the shopping history of many customers to identify trends and ensure we can keep up with demand or develop new products/services.
Data we may collect from you
When you visit our website, and use your account to buy products. When you make an online purchase and check out as a guest (in which case we just collect transaction-based data). When you create an account with us. When you purchase a product in store or by phone but don’t have (or don’t use) an account. When you engage with us on social media. When you join our loyalty programme. When you contact us by any means with queries, complaints etc. When you enter our competitions. When you choose to complete any surveys we send you. When you comment on or review our products and services.
What sort of personal data do we collect?
How and why do we use your personal data?
We want to give you the best possible customer experience. One way to achieve this is by combining the data we have about you. We then use this to offer you promotions, products and services that are most likely to interest you. In the case of loyalty scheme members, we’ll also offer you relevant rewards. The data privacy law allows this as part of our legitimate interest in understanding our customers and providing the highest levels of service. Of course, if you wish to change how we use your data, you’ll find details in the ‘What are my rights?’ section. Remember, if you choose not to share your personal data with us, or refuse certain contact permissions, we might not be able to provide some services you’ve asked for.
For example, if you’ve asked us to let you know when an item comes back into stock, we can’t do that if you’ve withdrawn your general consent to hear from us.
To process any orders that you make by using our website. If we don’t collect your personal data during checkout, we won’t be able to process your order and comply with our legal obligations.
How will we use your personal data and why.
For example, your details may need to be passed to a third party to supply or deliver the product or service that you ordered, and we may keep your details for a reasonable period afterwards in order to fulfil any contractual obligations such as refunds, guarantees etc.
To respond to your queries, refund requests and complaints. Handling the information you sent enables us to respond. We may also keep a record of these to inform any future communication with us and to demonstrate how we communicated with you throughout. We do this on the basis of our contractual obligations to you, our legal obligations and our legitimate interests in providing you with the best service and understanding how we can improve our service based on your experience. To protect our business and your account from fraud and other illegal activities. This includes using your personal data to maintain, update and safeguard your account. We’ll also monitor your browsing activity with us to quickly identify and resolve any problems and protect the integrity of our websites. We’ll do all of this as part of our legitimate interest.
For Example by using automated monitoring of IP addresses to identify possible fraudulent log-ins from unexpected locations.
With your consent, we will use your personal data, preferences and details of your transactions to keep you informed by email, web, text, telephone about relevant products and services including tailored special offers, discounts, promotions, events, competitions and so on.
Of course, you are free to opt out of hearing from us by any of these channels at any time.
To send you communications required by law or which are necessary to inform you about our changes to the services we provide you. For example, updates to this Privacy Notice, product recall notices, and legally required information relating to your orders. These service messages will not include any promotional content and do not require prior consent when sent by email or text message. If we do not use your personal data for these purposes, we would be unable to comply with our legal obligations.To administer any of our prize draws or competitions which you enter, based on your consent given at the time of entering.To develop, test and improve the systems, services and products we provide to you. We’ll do this on the basis of our legitimate business interests.To comply with our contractual or legal obligations to share data with law enforcement. To send you survey and feedback requests to help improve our services. These messages will not include any promotional content and do not require prior consent when sent by email or text message. We have a legitimate interest to do so as this helps make our products or services more relevant to you.
Of course, you are free to opt out of receiving these requests from us at any time by updating your preferences in your online account or by contacting us.
How we protect your personal data?
We know how much data security matters to all our customers. With this in mind our job is to take all appropriate steps to protect your data.
We secure access to all transactional areas of our websites and apps using ‘https’ technology.
Access to your personal data is password-protected, and sensitive data (such as payment card information) is secured by Stripe Payments Europe ltd. We agree that at all times you shall be compliant with applicable Payment Card Industry Data Security Standards (“PCI-DSS”) and the Payment Application Data Security Standards (“PA-DSS”).
We regularly monitor our system for possible vulnerabilities and attacks.
How long will we keep your personal data?
Whenever we collect or process your personal data, we’ll only keep it for as long as is necessary for the purpose for which it was collected.
At the end of that retention period, your data will either be deleted completely or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning.
Who do we share your personal data with?
We sometimes share your personal data with trusted third parties.
For example, delivery couriers, for fraud management, to help us personalise our offers to you and so on.
Here’s the policy we apply to those organisations to keep your data safe and protect your privacy:
We provide only the information they need to perform their specific services. They may only use your data for the exact purposes we specify in our contract with them. We work closely with them to ensure that your privacy is respected and protected at all times. If we stop using their services, any of your data held by them will either be deleted or rendered anonymous.
Examples of the kind of third parties we work with are:
IT companies who support our website and other business systems. Operational companies such as delivery couriers. Direct marketing companies who help us manage our electronic communications with you. Google/Facebook to show you products that might interest you while you’re browsing the internet. This is based on either your marketing consent or your acceptance of cookies on our websites. Please refer to our Cookies Policy for details. Data insight companies to ensure your details are up to date and accurate. Service monitoring agents to assist us in collating feedback regarding our performance in order to improve our service and products.
Sharing your data with third parties for their own purposes
We will only do this in very specific circumstances, for example:
For fraud management, we may share information about fraudulent or potentially fraudulent activity in our premises or systems. This may include sharing data about individuals with law enforcement bodies. We may also be required to disclose your personal data to the police or other enforcement, regulatory or Government body, in your country of origin or elsewhere, upon a valid request to do so. These requests are assessed on a case-by-case basis and take the privacy of our customers into consideration.We may, from time to time, expand, reduce or sell the limited company and this may involve the transfer of divisions or the whole business to new owners. If this happens, your personal data will, where relevant, be transferred to the new owner or controlling party, under the terms of this Privacy Notice.
To help personalise your journey through our website we currently use the following companies, who will process your personal data as part of their contracts with us:
Where your personal data may be processed?
Protecting your data outside the EEA
The EEA includes all EU Member countries as well as Iceland, Liechtenstein and Norway. We may transfer personal data that we collect from you to third-party data processors in countries that are outside the EEA.
For example, this might be required in order to fulfil your order, process your payment details or provide support services.
If we do this, we have procedures in place to ensure your data receives the same protection as if it were being processed inside the EEA. For example, our contracts with third parties stipulate the standards they must follow at all times.
Any transfer of your personal data will follow applicable laws and we will treat the information under the guiding principles of this Privacy Notice.
What are your rights over your personal data?
You have the right to request: Access to the personal data we hold about you, free of charge in most cases.The correction of your personal data when incorrect, out of date or incomplete. For example, when you withdraw consent, or object and we have no legitimate overriding interest, or once the purpose for which we hold the data has come to an end (such as the end of a warranty). That we stop using your personal data for direct marketing (either through specific channels, or all channels). That we stop any consent-based processing of your personal data after you withdraw that consent. You have the right to request a copy of any information about you that the limited company holds at any time, and also to have that information corrected if it is inaccurate.
To ask for your information to be amended, please update your online account, or contact our Customer Services team. If we choose not to action your request we will explain to you the reasons for our refusal.
To request for your information please put your request in writing to:
B.A.M Worldwide ltd, Unit 4b, New York Way, New York Industrial Park, Newcastle Upon Tyne, NE27 0QF.
To ask for your information to be amended, please update your online account, or contact our Customer Services team. If we choose not to action your request, we will explain to you the reasons for our refusal.
Your right to withdraw consent
Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent.
Where we rely on our legitimate interest
In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.
You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We must always comply with your request.
Checking your identity
To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Notice. If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.
How can you stop the use of your personal data for direct marketing?
There are several ways you can stop direct marketing communications from us:
Click the ‘unsubscribe’ link in any email communication that we send you. We will then stop any further emails from that particular division.
Write to B.A.M Worldwide ltd, Unit 4B, New York Way, New York Industrial Estate, Shiremoor, Newcastle Upon Tyne NE27 0QF.
Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated.
We hope this Privacy Notice has been helpful in setting out the way we handle your personal data and your rights to control it.
If you have any questions that haven’t been covered, please contact our Customer Care team who will be pleased to help you:
Write to us at B.A.M Worldwide ltd, Unit 4B, New York Way, New York Industrial Estate, Shiremoor, Newcastle Upon Tyne NE27 0QF.
This notice was last updated on 15/08/2019