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Privacy Policy


Summary

This Privacy Policy is applicable to Blackcircles.com

Blackcircles.com Limited ("Blackcircles.com") is committed to protecting your personal information and being clear and transparent about what information we collect and how we will use it. This policy explains how any personal information we collect when you use our website or digital services, or that you provide to us, will be processed by us.

Please read the following policy carefully to understand our views and practices regarding your personal information and how we will treat it.

1. Who we are and how we can be contacted
2. About our Data Protection Officer
3. Other policies and information we encourage you to read
4. Information we may collect from you
5. Marketing Communications
6. Information we collect about you from other places
7. Where we store your personal information
8. Sharing your personal information
9. How long will personal information be kept by us
10. Your rights under data protection legislation
11. What can you do if you’re not happy
12. About Data Security
13. Changes to our Privacy Policy

1. Who we are and how we can be contacted

Our full legal name is Blackcircles.com Limited (Company House Registration Number: SC224310) and we are the Data Controller. If you need to contact us you have a number of options:

• You can email us at info@blackcircles.com
• You can send us a letter addressed to the Blackcircles.com Limited, 15 Alva Street, Edinburgh, EH2 4PH
• You can also contact us using our contact form on our website here.
• You can also contact us by telephone on 01721 725050.

2. About our Data Protection Officer

While everyone at Blackcircles.com is committed to protecting and respecting your privacy, we have a Data Protection Officer who deals with all aspect of personal data at Blackcircles.com. You can contact our Data Protection Officer by sending an email to dataprotectionofficer@blackcircles.com.

3. Other policies and information we encourage you to read

While this Privacy Policy contains all the information you need on how we collect and use your personal information on our websites, there is information in some other places which we encourage you to read.

(a) Additional privacy policies
(b) Our Cookie Policy
(c) Our Terms of Website Use
(d) Linked Platforms

(a) Additional privacy policies

This is our main privacy policy for your use of website and digital services and products offered by Blackcircles.com. However, there may be additional information in privacy policy for specific digital products and services. Please read these policies when you register or subscribe to these products and services.

(b) Our cookie policy

When you use our website and other digital products and services provided by us, information can be collected through cookies to distinguish you from other users of our website and other digital products and services. We have a separate Cookie Policy which explains our use of cookies and the purposes for which we use them. We encourage you to read our Cookie Policy here.

(c) Our Terms of Website use

Our Terms of Website Use tells you the terms on which you may make use of our websites and should be read alongside this Privacy Policy. You can read our Terms of Website Use here.

(d) Linked platforms

Our site may, from time to time, contain links to and from our websites and digital platforms of our partner networks, advertisers, affiliates and social media pages. 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 information to these websites.

4. Information we may collect from you

This section sets out:

• how we collect your personal information;
• the categories of data that we collect;
• a description of how we plan to use the information we collect;
• the legal basis that we will rely on to process information collected; and
• where applicable, how long we hold the information collected.

We may collect and hold the following information about you:

Data Collected Purpose/Activity Type of data Lawful basis for processing Retention period
Information you give us when you make a purchase on our website and where applicable book a service (“Purchase Data”) We may use Purchase Data to enable us to: -
1. complete the sale of the products and services purchased from us;
2. provide you with information about your purchases e.g. confirmation emails;
3. to request a review or feedback on the products or service you purchased; and
4. to fulfill any warranty in respect of the products purchased
Information gathered to complete sale include name, contact information, vehicle registration number, payment information (note that payment information is not stored by us and only captured to pass to the payment provider selected) The performance of the contractual agreement between you and us to enable us to fulfil the sale of the products and services purchased. It is also in our legitimate interest to request a review or feedback from you to help us better understand our customers’ needs. This data is held for a period of 10 years for warranty purposes
Information you give to us when you enter a competition or promotion (“Promotion Data”). To enable us to send you further information about the competition or a prize if you are the competition winner. Unless we state otherwise when we collect your information, we will only use this information for managing and administer the competitions or promotions. Promotion Data might include, for example, your name and your contact details The performance of an agreement between you and us to enter the competition or promotion. Unless otherwise specified at the time of the competition or promotion, Promotion Data, is stored for 3 years following the end of the competition or promotion for Aaudit purposes.
Information you provide to us when you complete a survey, respond to a questionnaire or submit a review or feedback (“Review Data”). To collect information about a specific matter, for example, our services to you. In many cases surveys and questionnaires are anonymous and we only collect personal information for statistical data. If this is not the case, we will let you know at the time of collecting the information. Information may include your full name, your email address and other personal data requested. We will use our legitimate interests in the monitoring and improvement of our products and services to our customers and users as the legal basis for processing Review Data. While we like to retain reviews and feedback from you to help other website users, we will anonymise or delete your reviews and feedback after 6 years. Any information collected pursuant to a survey or questionnaire will be deleted within 3 years of you submitting your responses. Any information retained will be anonymous data only.
If you register for any of our digital products or services via an account we will request information to enable us to identify you and provide the products and services to you (“Account Data”). Account Data will be processed for the purpose of operating our websites, providing digital services you sign up for, communicating with you about those digital products and services and maintaining back-ups of our services. Account Data will include your full name and email address. We may also ask you to set a password so you can securely log back on to your account at a later date. The performance of the agreement between you and us for the provision of the digital product and services is the legal basis for processing Account Data. This data is retained for as long as the customer continues to have an active account with Blackcircles.com. If you do not access your account for 24 months, we will delete your account data so that we do not keep information for longer than is necessary. You can of course, create a new account if you like.
If you request further information from us by signing up to receive any of our newsletters or marketing communications (“Marketing Data”).

See section 5 below for further information.
Marketing Data is processed for the purposes of sending you the relevant notifications and/or newsletters you have requested. We will ask you for your name and email address so we can send you the information requested The legal basis for this processing is consent. We will generally send you marketing communications until you choose to unsubscribe from receiving them. However, if we have not heard from you for a while or notice that you have not opened our emails in a period of 36 months, we will remove your details from our database. There’s nothing stopping you from subscribing again at any time.
Information you provide us when using location services, for example our Garage Search facility (“Location Data”). Location Data is used to identify Fitting Partners in the surrounding location and to perform postcode based address lookup at checkout. To use some of our services we request a postcode. The performance of the agreement between you and us for the provision of the digital product and services is the legal basis for processing Location Data. Location Data is not retained except when a sale is successfully completed when the data becomes part of the Purchase Data.
Information you provide us when using Vehicle Registration Lookup services, for example our Tyre search (“Vehicle Data”). Vehicle Data is used to identify tyres which may be relevant for your vehicle. To use some of our services we request a vehicle registration. The performance of the agreement between you and us for the provision of the digital product and services is the legal basis for processing Vehicle Data. Vehicle Data is not retained except when a sale is successfully completed when the data becomes part of the Purchase Data.
Information you provide us when you communicate with us, e.g. by email or contact us form via our websites or through the live chat function on our website (“Communication Data”). This information is used to enable us to respond to or following up on your comments, queries or questions. Information may include your full name, your email address and other personal data you provide us to enable us to deal with your communication. We will use our legitimate interests in the assisting you and answering your communications as the legal basis for processing Communication Data. We will hold on to Communication Data for as long as it is necessary to enable us to deal with the matter relating to that communication. Once your matter has been dealt with, unless we inform you otherwise, we will delete Communication Data within 36 months.

Voluntary Information

When you provide us information (for example, the information set out in the scenarios above), in some cases we will also ask you for additional, voluntary information. This information will be identified as optional and is used to help us better understand our customers and tailor our services to them.

Statistical Information

We also collect and use aggregated data such as statistical or demographic data (“Aggregated Data”). Aggregated Data may be derived from your personal information but does not reveal your identity in any way. For example, we may aggregate your Usage and Device Data to calculate the percentage of our website users accessing a specific feature or product on our website. We may disclose Aggregated Data to third parties. No personal information is shared

Sensitive Personal Information

While we do not request sensitive personal data, we do have sections on our websites where you can submit additional information, for example, when you submit a review. If you submit information on these free text sections, only submit information you are comfortable providing and always bear in mind that it may be sensitive information. If you submit reviews or feedback for our website, please remember that this information will be visible to others users of our website.

5. Marketing Communications

When you sign up to receive any of our newsletters or marketing communications we will use the information you provide us, usually just your name and email address, to enable us to send you our newsletters, promotions and other communications you’ve requested.

You are given the option to 'opt int' to receiving marketing communications from Blackcircles.com on the checkout page of the order process by ticking the box at the bottom of the aforementioned page.

If at any stage you wish to unsubscribe from receiving marketing communications, you can use the unsubscribe link at the bottom of any communications received. Alternatively send an email to info@blackcircles.com or write to us to let us know you would like to opt out of receiving any further emails from Blackcircles.com.

Existing customers who have signed up for an account can log in to the My Account section on our website to change their marketing preferences.

Should we wish to use your personal information for a purpose not permitted under this Privacy Policy, we will contact you to seek your consent.

6. Information we collect about you from other places

To enable us to provide you with our products and services, we may receive personal information about you from other sources, including:

• third party business partners, sub-contractors, for example technical providers, payment service providers, analytics providers, such as Google Analytics, search information providers and credit reference agencies) and may receive information about you or your vehicle from them.

The legal basis fort this processing is our legitimate interests , namely monitoring and improving our website , products and services.

• Information from our web servers’ logs, for example information about your computer, such as your IP address, operating system and browser type. We may also collect information on the searches you carry out on our website and you interaction with communications we send you, for example if you open email communications from us (“Usage and Device Data”). This information is used by us for system administration and to analyse how people are using our websites and platforms. It also helps us to provide the best online experience.

The legal basis for this processing is our legitimate interests, namely monitoring and improving our website, products and services.

• As mentioned above, we collect information using cookies [or other similar technologies] stored on your device about how you use our website, digital products and services. Cookies contain information that is transferred to your computer's hard drive. They help us to improve our websites and deliver a better and more personalised service to you. You can read our Cookie Policy here.

• We also collect information from our social media sites, including likes, shares and tweets, and about the content on social networking sites.

• Information we find about you from other reputable information sources. This information will be collected from publically available records, such as the DVLA and vehicle registration lookup services where we may gather additional information about your vehicle to help improve the services we provide to our customers.

• We also use location services based on the postcode or location you may enter to determine location information for the purposes of identifying our nearest fitting centres.

7. Where we store your personal information

All information you provide to us is stored on secure servers within the EU except for information collected as part of website session recording. Session recording is provided by SessionCam Ltd. SessionCam Ltd stores information on secure servers based in the United States and conforms to EU-US Privacy Shield providing adequate protection to allow personal data to be transferred to the US. Blackcircles.com's website servers are situated in the UK.

8. Sharing your personal information

The recipients of your personal data are limited exclusively to the people who have a need to know such information to perform their responsibilities. We may share your personal information with the following:

Service Providers - Blackcircles.com work with a number of trusted service providers who supply services on our behalf and we may share your personal data with these service providers to process your request or provide the services, for example a customer service ticketing. These service providers are contractually obligated to keep the personal data they may have received confidential and secure and to use your personal data only based on our instructions.
Delivery Partners – In order for you to receive the goods you have purchased we work with a number of delivery partners. Where necessary we will provide your delivery contact details to enable the delivery of your goods purchased.
Fitting Partners – In order to facilitate any fitting service requested by you, we will share your contact and vehicle details in order to complete your order. We also use location services to identify fitting centre based on the location you provide on our website.
IT Partners – Blackcircles.com work with a number of IT companies to support our website and IT infrastructure, such as hosting and email services.
Payment Processing – Blackcircles.com integrates with trusted third-party payment processing providers to facilitate the processing of your payments. We fully comply with the PCI & DSS standards in respect of processing credit/debit card payments
Finance Providers – Where a customer decides to take a finance option during the payment process Blackcircles.com will introduce you to our Finance Provider. Please note that, any finance agreement entered into is with the Finance Provider and not Blackcircles.com. As such, Blackcircles.com is not in control of the information you provide to a Finance Provider and the privacy policies of those Finance Providers will apply when using their services.
• Our website uses third parties to collect session data which may record mouse clicks, mouse movements, page scrolling and any text keyed into some of the website forms ("Session Data"). Session Data does not include bank details or any sensitive personal data and is limited to the minimum identification data required to identify website users. Data collected from the Blackcircles.com website is for Blackcircles.com Limited internal use only. Session Data is used to improve our website usability and to aid with investigation of any issues experienced by our customers on our website. The information is stored for 12 months and used for aggregated and statistical reporting.
• In the event that we sell or transfer any business or assets, in which case we may disclose your personal information to the prospective purchaser or recipient of such business or assets.
• If we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or in order to enforce or apply our terms and conditions and other agreements; or to protect the rights, property, or safety of Blackcircles.com, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
• In order to obtain insurance cover, managing risks and legal dispute and obtaining professional legal advice. This disclosure will be on a confidential basis and only to our insurers or professional advisors.

9. How long will personal information be kept by us

As a rule, we will not hold your personal information for any purpose or purposes for longer than is necessary to fulfil the purposes we collect it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. For more specific retention periods, please see section 4 above. While we do everything we can to comply with these retention periods, if there is a legal, accounting or tax reason why the information is to be held for longer, we will only retain the information for as long as necessary to satisfy that legal, accounting or tax reason.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances you can ask us to delete your data: see your right to be deleted below for further information. In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

10. Your rights under data protection legislation

Data protection legislation provides you with certain rights when it comes to the processing of your information. These are the right to:

(a) be informed
(b) access your information
(c) correct your information
(d) delete your information
(e) restrict processing
(f) transfer information
(g) object to processing

(a) The right to be informed

You have the right to be informed about how we collect and process your personal information, including who we are, how we use your personal information and your rights in relation to your personal information. We have gathered all the information you need in this privacy notice.

(b) The right of access your information

You have the right to access the personal information we have on you. We can confirm whether or not your information is being processed and provide you with access to your personal information.

(c) The right to correct your information

If your personal information is inaccurate or incomplete, you are entitled to have that information corrected and updated. If we have disclosed your information to any third parties, where possible, we will inform them of any updates you provide to us. You can update the personal information we hold about you by contacting us using any of the contact methods details in this Privacy Policy.

(d) The right to delete your information

You have the right to request the deletion or removal of your personal. There are limited circumstances in which you can request deletion of you information, these include, where the information is no longer necessary for the purpose for which we originally collected or processed it and where you have withdrawn your consent to the processing by us.

If you would like further information on your right to deletion, please just ask.

(e) The right to restrict processing

In some circumstances, you also have the right to restrict or suppress the processing of your personal information. If you request us to suppress your personal information, we will suspend any further processing of it.

(f) The right to transfer information

If you want to move or transfer your personal information to a different service provider or copy your information for your own purposes, you have the right to have your information transferred to another person.

(g) The right to object

You have the right to ask us not to process your personal information where we are relying on a legitimate interest and there is something which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes. You can exercise the right at any time by accessing your MyAccount area or contacting us at dataprotectionofficer@blackcircles.com.

You can find further information on your data protection rights from the Information Commissioners Office (ICO) at https://www.ico.org.uk

11. What can you do if you’re not happy

We are committed to protecting and respecting your privacy. However, if you’re not happy with how we collect or process your information or just want some further information on your rights, you can contact us in the following ways:

• You can email us at dataprotectionofficer@blackcircles.com
• You can send us a letter addressed to Blackcircles.com Limited, 15 Alva Street, Edinburgh, EH2 4PH
• You can also contact us using our contact form on our website (https://www.blackcircles.com/helpcentre/customer_service/how-do-i-contact-you)

We will work with you to resolve any issues you may have and aim to answer any question raised by you as soon as possible.

You can also make a complaint to ICO – further information can be found at https://www.ico.org.uk/concerns/

12. About Data Security

Blackcircles.com has implemented measures to protect the privacy, security and integrity of your personal data. Access to personal data is restricted to those employees and service providers who need to know this information and who have been trained to comply with rules on confidentiality.

Blackcircles.com does not store payment information and securely transfers this information to the payment provider who will process the payment transaction. Blackcircles.com fully complies with PCI & DSS standards in respect of processing credit/debit card payment – please see following website for information regarding compliance - https://www.pcisecuritystandards.org/security_standards/index.php

Blackcircles.com ensures that your personal data are not altered, damaged or accessed by unauthorised third parties.

Please note that the Internet is not a secure medium. When submitting personal information to us using the Internet, your details may not be secure from access by third parties. The submission of personal information to us using the Internet is therefore made at your own risk. Once in receipt of your information Blackcircles.com uses procedures and security measures to ensure only authorised access is permitted.

13. Changes to our Privacy Policy

We may change our policy from time to time. Any changes we make to this policy in the future will be posted on this page. If you have an online account with us, we may notify you of any changes by email or through your account the next time you log on.

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