Privacy policy

1. Important Information and Who We Are  

Purpose of this privacy policy  

This privacy policy aims to give you information on how Hayley Windows Design & Installation  Limited collects and processes your personal data through your use of this website and in connection  with our offline dealings when you enquire about and/or purchase goods and/or services.  

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

It is important that you read this privacy policy together with any other privacy policy or fair  processing policy we may provide on specific occasions when we are collecting or processing personal  data about you so that you are fully aware of how and why we are using your data. This privacy  policy supplements other notices and privacy policies and is not intended to override them.  

Controller  

Hayley Windows Design & Installation Limited is the controller and responsible for your personal  data (referred to as we, us or our in this privacy policy).  

We have appointed a data privacy manager who is responsible for overseeing questions in relation  to this privacy policy. If you have any questions about this privacy policy, including any requests to  exercise your legal rights (as summarised below at paragraph 9), please contact our data privacy  manager, Laura Molineux, using the details set out below:  

Email address: laura@hayleywindows.co.uk  

Postal address: Unit 19 Enterprise Trading Estate, Pedmore Road, Brierley Hill, West   Midlands, DY5 1TX  

Telephone number: 01384 89 69 89  

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO),  the UK’s regulator 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.  

Changes to the privacy policy and your duty to inform us of changes  We keep our privacy policy under regular review. This version was last updated in July 2021.  

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.  

Third-party links  

This website may include links to third-party websites, plug-ins and applications. Clicking on those  links or enabling those connections may allow third parties to collect or share data about you. We  do not control these third-party websites and are not responsible for their privacy statements. When  you leave our website, we encourage you to read the privacy policy of every website you visit.  

2. The Data We Collect About You  

Personal data means any information about an individual from which that person can be identified.  It does not include data where the identity has been removed (anonymous data).  

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

 Identity Data includes full name and title.  

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

 Financial Data includes bank account and payment card details.  

 Property Data includes photographs of your property taken by us (or photographers  appointed by us) depicting the work we have carried out at your property.  

 Transaction Data includes details about payments to and from you and other details of  goods and/or services you have purchased from us.  

 Technical Data includes internet protocol (IP) address, 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.  

 Usage Data includes information about how you use our website, goods and/or services.  

 Marketing and Communications Data includes 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 could be derived from your personal data but is not considered personal  data in law as this data will 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 policy.  

We do not collect any Special Categories of Personal Data about you (this includes details about  your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions,  trade union membership, information about your health, and genetic and biometric data). Nor do  we collect any information about criminal convictions and offences.  

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 to provide you with goods and/or services. In this case, we  may have to cancel a contract you have with us but we will notify you if this is the case at the time.  

3. How Is Your Personal Data Collected?  

We use different methods to collect data from and about you including through:  

 Direct interactions. You may give us your Identity, Contact and Financial Data by filling  in forms or by corresponding with us by post, phone, email, social media or otherwise. This  includes personal data you provide when you:  

 request a quotation for goods and/or services;  

 purchase goods and/or services;  

 instruct us to appoint a third party service provider on your behalf to provide a  quotation or services;  

 subscribe to our newsletter, blog or publications;  

 request marketing to be sent to you; or  

 complete a review form or survey; or  

 give us feedback or contact us.  

 Automated technologies or interactions. As you interact with our website, we will  automatically collect Technical Data about your equipment, browsing actions and patterns.

We collect this personal data by using cookies, server logs and other similar technologies.  We may also receive Technical Data about you if you visit other websites employing our  cookies.  

 Third parties or publicly available sources. We may receive personal data about you  from various third parties and public sources as set out below:  

 Technical Data from the following parties analytics providers such as Google  based outside the UK.  

 Contact and Transaction Data from providers of delivery services based inside the  UK.  

 Property Data from photographers appointed by us based inside the UK.  

 Identity and Contact Data from publicly available sources such as Companies  House and the Electoral Register based inside the UK.  

4. How We Use Your Personal Data  

We will only use your personal data when the law allows us to. Most commonly, we will use your  personal data in the following circumstances:  

 Where we need to perform the contract we are about to enter into or have entered into  with you. Performance of contract means processing your data where it is necessary for  the performance of a contract to which you are a party or to take steps at your request  before entering into such a contract.  

 Where it is necessary for our legitimate interests (or those of a third party) and your  interests and fundamental rights do not override those interests. Legitimate interest means the interest of our business in conducting and managing our business to enable us  to give you the best service and the best and most secure experience. We make sure we  consider and balance any potential impact on you (both positive and negative) and your  rights before we process your personal data for our legitimate interests. We do not use  your personal data for activities where our interests are overridden by the impact on you  (unless we have your consent or are otherwise required or permitted to by law). You can  obtain further information about how we assess our legitimate interests against any  potential impact on you in respect of specific activities by contacting us.  

 Where we need to comply with a legal obligation we are subject to.  

Generally, we do not rely on consent as a legal basis for processing your personal data. However,  there are some situations where we do rely on consent mentioned in the table below. In addition,  we will get your consent before 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  

We have set out below, in a table format, a description of all the ways we plan to use your personal  data, and which of the legal bases we rely on to do so. We have also identified what our legitimate  interests are where appropriate.  

Note that we may process your personal data for more than one lawful ground depending on the  specific purpose for which we are using your data. Please contact us if you need details about the  specific legal ground we are relying on to process your personal data where more than one ground  has been set out in the table below.

Purpose/Activity Type of data Lawful basis for processing  including basis of legitimate  

interest

To register/on-board you as a  new customer  

To process and deliver your  order including:  

(a) Manage payments, fees  and charges  

(b) Collect and recover money  owed to us  

(c) Arrange  surveys/inspections of your  property  

(d) Arrange for subcontractors  or third party suppliers to  provide quotations or services  you have ordered  

(a) Identity

(b) Contact  

(a) Identity

(b) Contact  

(c) Financial  

(d) Transaction  

(e) Marketing and  Communications  

Performance of a contract with you

(a) Performance of a contract with you

(b) Necessary for our legitimate  interests (to recover debts due to us)  

To take photographs of our  work and use those for  advertising purposes on our  website, social media and in  our marketing literature  

To display any review or  feedback you have provided on  our website, social media and  in our marketing literature  (where Identity Data is  included)  

Property Consent Identity Consent

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  

To enable you to partake in a  survey  

(a) Identity

(b) Contact  

(c) Marketing and  Communications  

(a) Identity

(b) Contact  

(c) Usage  

(e) 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  goods/services)  

(a) Performance of a contract with you

(b) Necessary for our legitimate  interests (to study how customers use  our goods/services, to develop them  and grow our business)

To administer and protect our  business and this website  (including troubleshooting,  data analysis, testing, system

(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

maintenance, support,  reporting and hosting of data)  

To deliver relevant website  content and advertisements to  you and measure or  understand the effectiveness of  the advertising we serve to you

To use data analytics to  improve our website,  goods/services, marketing,  customer relationships and  experiences  

(a) Identity

(b) Contact  

(c) Usage  

(d) Marketing and  Communications  

(e) Technical  

(a) Technical

(b) Usage  

reorganisation or group restructuring  exercise)  

(b) Necessary to comply with a legal  obligation  

Necessary for our legitimate interests  (to study how customers use our  goods/services, to develop them, to  grow our business and to inform our  marketing strategy)  

Necessary for our legitimate interests  (to define types of customers for our  goods 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 and/or services that may  be of interest to you

(a) Identity

(b) Contact  

(c) Technical  

(d) Usage  

(e) Marketing and  Communications

Necessary for our legitimate interests  (to develop our goods/services and  grow our business)

Marketing  

We strive to provide you with choices regarding certain personal data uses, particularly around  marketing and advertising.  

We may use your Identity, Contact, Technical and Usage Data to form a view on what we think you  may want or need, or what may be of interest to you. This is how we decide which goods, services  and offers may be relevant for you (we call this marketing).  

You will receive marketing communications from us if you have requested information from us or  purchased goods and/or services from us and you have not opted out of receiving that marketing.  

Third-party marketing  

We will get your express opt-in consent before we share your personal data with any third party for  marketing purposes.  

Opting out  

You can ask us or third parties to stop sending you marketing messages at any time by contacting  us (or the relevant third party) 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 your purchase goods and/or services.  

Cookies  

You can set your browser to refuse all or some browser cookies, or to alert you when websites set  or access cookies. If you disable or refuse cookies, please note that some parts of this website may  become inaccessible or not function properly.  

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.  

5. Disclosures of Your Personal Data  

We may share your personal data with the parties set out below:  

 Our website provider, WIX, based in Israel. Privacy information relating to WIX can be  found here: https://www.wix.com/about/privacy. Our website is hosted on the Wix.com  platform. Your data may be stored through Wix.com’s data storage, databases and the  general Wix.com applications. Wix store your data on secure servers behind a firewall.  

 Software providers such as Intuit Inc. (who provide the Quickbooks software) based in the  USA. Privacy information relating to Intuit Inc. can be found here:  https://www.intuit.com/privacy/statement/.  

 Software providers such as Microsoft. Privacy information relating to Microsoft can be found  here: https://privacy.microsoft.com/en-GB/.  

 Service providers based in the UK such as Fix It PC Services who provide IT and system  administration services.  

 Subcontractors and third party suppliers based in the UK who we use to provide quotations  you have requested and/or certain elements of the services you have ordered.  

 Couriers based in the UK who we (or our suppliers) use to provide delivery services in  relation to goods you have ordered.  

 Professional advisers including lawyers, bankers, auditors and insurers based in the UK  who provide consultancy, banking, legal, insurance and accounting services.  

 HM Revenue & Customs, regulators and other authorities based in the UK who require  reporting of processing activities in certain circumstances.  

 Third parties to whom we may choose to sell, transfer or merge parts of our business or  our assets. Alternatively, we may seek to acquire other businesses or merge with them. If  a change happens to our business, then the new owners may use your personal data in  the same way as set out in this privacy policy.  

We require all third parties to respect the security of your personal data and to treat it in accordance  with the law. We do not allow our third-party service providers to use your personal data for their  own purposes and only permit them to process your personal data for specified purposes and in  accordance with our instructions.  

6. International Transfers  

Many of the external third parties we use as mentioned in paragraph 5 are based outside or transfer  personal data outside the UK so their processing of your personal data will involve a transfer of data  outside the UK.  

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is  afforded to it, for example, by ensuring that:

 Your personal data is being transferred to countries that have been deemed to provide an  adequate level of protection for personal data;  

 Where we use certain service providers, we may use specific contracts approved for use in  the UK which give personal data the same protection it has in the UK.  

There have been recent (and there are ongoing) developments relating to international transfers of  personal data, both in the EU and, following the end of the Brexit transition period on 31 December  2020, in the UK. We will therefore keep this aspect under regular review and update it in due course.  

Please contact us if you want further information on the specific mechanism used by us when  transferring your personal data out of the UK.  

7. Data Security  

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 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.  

8. Data Retention  

How long will you use my personal data for?  

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we  collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or  reporting requirements. We may retain your personal data for a longer period in the event of a  complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship  with you.  

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, regulatory, tax, accounting  or other requirements.  

By law we have to keep basic information about our customers (including Contact, Identity, Financial  and Transaction Data) for 6 years after they cease being customers for tax purposes.  

In some circumstances you can ask us to delete your data: see “your legal rights” (paragraph 9)  below for further information.  

In some circumstances we will 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.  

9. Your Legal Rights  

Under certain circumstances, you have rights under data protection laws in relation to your personal  data.  

You have the right to:  

 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.

 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.  

 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.  

 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.  

 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:  

 If you want us to establish the data’s accuracy.  

 Where our use of the data is unlawful but you do not want us to erase it.  

 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.  

 You have objected to our use of your data but we need to verify whether we have  overriding legitimate grounds to use it.  

 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.  

 Withdraw consent at any time 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 goods and/or services to you. We will advise you if this is the case at the  time you withdraw your consent.  

If you wish to exercise any of the rights set out above, please contact us.  

No fee usually required  

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.  

What we may need from you

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.  

Time limit to respond  

We try to respond to all legitimate requests within 1 month. Occasionally it could 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.

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