Privacy Notice

Version 3 – (August 2018 - A L Younger Limited, Trading as Wessex Pictures (‘we/us’)).

Welcome to A L Younger’s privacy notice.

We respect your privacy and are committed to protecting your personal data. We collect data from visitors throughout the website experience. This is largely to provide interactive functionality that would otherwise be impossible without collecting the minimum amount of data. Some data is also used to analyse your experience anonymously to improve the website experience.

We will not sell your data to third parties, allow any access to the data that isn’t necessary to honour any other contracts we have in place or store excessive amounts of data we no longer need.

This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

We comply with the General Data Protection Regulation (GDPR) (EU May 25^th 2018).

Definitions

Data Subject – any living person.

Third Party – another company who we work with to provide services to the Data Subject.

Personal Data – data belonging to the Data Subject that can be used to uniquely identify them. This does not include data where the identity has been removed (anonymous data).

Data Controller – any organisation that stores Personal Data, E.g. A L Younger Limited, Trading as Wessex Pictures.

Data Processor – any organisation that works on (processes) Personal Data.

The data we collect about you

We may collect, use, store and transfer different kinds of Personal Data about you which we have grouped together follows:

Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.

Contact Data includes billing address, delivery address, email address and telephone numbers.

Financial Data includes bank account and payment card details.

Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.

Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.

Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses. 

Usage Data includes information about how you use our website, products and services.

Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

If you fail to provide Personal Data

Where we need to collect Personal Data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service, you have with us but we will notify you if this is the case at any time.

How we obtain your data

We collect data from the Data Subject during the usage of this website. Some of that data may be Personal Data. This may be entered into web forms or provided to the website by the browser (such as IP address).

We may also obtain Personal Data about the Data Subject from a Third Party as part of a contract to work with that data.

How we use your data

We will only use your Personal Data when the law allows us to.

We primarily use data from the Data Subject either to serve a contract between us and the Data Subject, or to provide necessary functionality on our website.

We may also collect additional data to satisfy other legal requirements, such as is required for e-commerce.

Generally we do not rely on consent as a legal basis for processing your Personal Data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your Personal Data

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new customer	(a) Identity (b) Contact	Performance of a contract with you
To process and deliver your order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to partake in a prize draw, competition or complete a survey	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	(a) Technical (b) Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile	Necessary for our legitimate interests (to develop our products/services and grow our business)

Third Parties which have access to the data collected

We work with several Third Parties to provide the service the Data Subject receives.

In all cases there is either an explicit contract in place between us and the Third Party, terms and conditions or another legally binding relationship.

The data will likely be shared with:

Alphabet Inc (Google) – a suite of Google Tools is used by us.

Intergage Ltd – website host/provider.

Pegasus Opera 3 – In House Invoicing /Ordering System

The data may be shared with:

Sage (Accounts) – accounting tool used for tracking and invoicing customers.

The data is also rarely shared with the following:

Mobile phones – our staff may enter your contact number into their phones for the purpose of a meeting and will then erase the number after the meeting.

Tuffnells Parcels Express - parcel/package delivery supplier.

Euler Hermes – Credit Insurance

Marketing

We strive to provide you with choices regarding certain Personal Data uses, particularly around marketing and advertising. We do not share your data with any Third Parties for marketing purposes unless the Data Subject has explicitly opted in.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to Personal Data provided to us as a result of a product/service purchase, product/service experience or other transactions.

Third Party Cookies

We can largely operate without the use of third party cookies. However, in many cases third party cookies improve the website experience.

We will not add social sharing buttons to the page unless the Data Subject has explicitly opted in to social cookies.

We will not include any tracking systems unless the Data Subject has explicitly opted in to tracking cookies.

We will allow Google Analytics to operate on this website in order to provide necessary anonymous analytical data. This may result in a small amount of personally identifiable information being collected but this is only used as statistics and not for identification purposes.

Change of purpose

We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

International Transfers

We do not transfer your Personal Data outside the European Economic Area (EEA).

Data Security and Storage

We take security seriously and make use of technology where feasible to secure data and protect against breaches.

We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality.

We will store data for only as long as necessary to fulfil the purpose for which it was obtained. Some data may be held for longer if it is either held on other systems that have not been updated, in backup data that has not expired or because of another lawful basis.

We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

We will only retain your Personal Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your Personal Data: see Request erasure 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.

Data Subject's legal rights and requests

Under certain circumstances, Data Subjects have rights under data protection laws when it comes to how we handle their Personal Data. These include rights to:

1. Right to withdraw consent where we are relying on consent to process your Personal Data . However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
2. Request access to your Personal Data (commonly known as a "data subject access request"). This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.
3. Request restriction of processing of your Personal Data . This enables you to ask us to suspend the processing of your Personal Data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
4. Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
5. Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your Personal Data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
6. Object to processing of your Personal Data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
7. Request the transfer of your Personal Data to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

If you wish to exercise any of the rights set out above, please contact the DPO (details set out 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 may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Personal Data protection principles

We adhere to the principles relating to processing of Personal Data set out in the GDPR (as follows) which require Personal Data to be:

1. Processed lawfully, fairly and in a transparent manner (Lawfulness, Fairness and Transparency).
2. Collected only for specified, explicit and legitimate purposes (Purpose Limitation).
3. Adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed (Data Minimisation).
4. Accurate and where necessary kept up to date (Accuracy).
5. Not kept in a form which permits identification of Data Subjects for longer than is necessary for the purposes for which the data is processed (Storage Limitation).
6. Processed in a manner that ensures its security using appropriate technical and organisational measures to protect against unauthorised or unlawful processing and against accidental loss, destruction or damage (Security, Integrity and Confidentiality).
7. Not transferred to another country without appropriate safeguards being in place (Transfer Limitation).
8. Made available to Data Subjects and Data Subjects allowed to exercise certain rights in relation to their Personal Data (Data Subject's Rights and Requests).

Updates to our Privacy Notice and your duty to inform us of changes

This Privacy Notice will be reviewed regularly and this page will be updated with changes.

It is important that the Personal Data we hold about you is accurate and current. Please keep us informed if your Personal Data changes during your relationship with us.

Contacting the Data Protection Officer (DPO)

We have appointed a DPO who is responsible for overseeing questions in relation to this privacy notice. If you have any question about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

Contact Details

Our full details are:

Full name of legal entity: A L Younger Limited, trading as Wessex Pictures

Name of DPO: Daren Hills

Postal address: Wessex Pictures, Gordleton Industrial Park, Sway Road, Lymington, Hampshire, SO41 8JD

Telephone number: 01590 681681

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.