101 Limited (“we” “us” “our”) are committed to protecting and respecting your privacy. For the purposes of data protection legislation, we are the data controller and we will process your personal data in accordance with the General Data Protection Regulation (EU) 2016/679 and national laws which relate to the processing of personal data. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
2.Visitors to our website
We may collect and process personal data about you in the following circumstances:
1. when you contact us through our website at www.101gibraltar.com (“Website”). We will collect details such as your name, address, email address and telephone number so we can contact you about the services you have requested and respond to your enquiry;
2. whenever you provide information to us when reporting a problem with our Website, making a complaint, making an enquiry or contacting us for any other reason. If you contact us, we may keep a record of that correspondence;
4. whenever you disclose your information to us, or we collect information from you in any other way, through our Website.
5. whenever you recommend a friend or accept a recommendation as part of our referral scheme
6. We may also collect data in the following ways:
A). IP Address
We may collect information about your device, including where available your Internet Protocol address, for reasons of fraud protection. We may also collect information about your device’s operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users' browsing actions and patterns, and does not identify any individual.
7. provide you with information, or services that you requested from us;
a). allow you to participate in interactive features of our Website, when you choose to do so;
b). ensure that content from our Website is presented in the most effective manner for you and for your device;
c). improve our Website and services;
d). process and deal with any complaints or enquiries made by you; and
e). contact you for marketing purposes where you have signed up for these (see section 7 for further details).
Our Website may, from time to time, contain links to and from the websites of third parties. Please note that if you follow a link to any of these websites, such websites will apply different terms to the collection and privacy of your personal data and we do not accept any responsibility or liability for these policies. When you leave our Website, we encourage you to read the privacy notice/policy of every website you visit.
1. We will collect details such as your name, address, telephone number and email address when you order goods or services from us in one of our showrooms or over the phone. We will use this information to process your order, comply with our contractual obligations. We may also collect contact details from you relating to a third party we may contact (with your consent) to discuss an order which you have placed. We may also use your information including your address and the type of product purchased from us to help inform the sale of our products to future customers.
2. In order to perform our contract with you, we may also need to share personal data with third parties such as payment providers, suppliers, postal service or other delivery organisations and installers, in order to assist in the supply, delivery and performance of the goods and services you have ordered.
3. We may also instruct third parties to conduct customer experience surveys on our behalf.
4. We may also publish your feedback on our Website and in other marketing materials (subject to obtaining your prior consent where necessary).
5. We will also use your personal data in the ways described in sections 6, 7 and 9 of this policy.
4 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 the 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 our goods or services). In this case, we may have to cancel the order you have placed with us, and we will notify you if this is the case at that time.
1. In addition to the uses described in sections 2-3 above, where you have purchased our products or services, indicated that you would like to receive marketing correspondence from us, subscribed to our mailing lists or newsletters, entered into any of our competitions or provided us with your details at networking events, we may use your personal data for our legitimate interests in order to provide you with details about our goods and services which we think may be of interest.
2. You have the right to opt-out of receiving marketing correspondence from us at any time. To opt-out of receiving such information you can:
a). log onto your online account and amend your preferences;
b). click the unsubscribe button contained in any marketing email which we send you; or
d). We may contact you in order to obtain third party contact details for third parties who have provided you with installation or other related services.
e). If you are a third party which has provided a related service to our customer, you may be contacted by 101Ltd.
6 Monitoring and recording
We may monitor and record communications with you (such as telephone communications) for the purpose of quality assurance, training, fraud prevention and compliance. We have CCTV cameras installed in our premises and in our delivery vehicles for the purpose of crime prevention and for health and safety reasons. We may also take photos of the products delivered and/or installed at your property in order to demonstrate the delivery and performance of products and services to you.
7 Anti-money laundering/combatting the financing of terrorism legislation
1. Where customers want to pay for goods and services in cash of £8,000.00 or more, 101Ltd will keep a register of the payment and submit an annual return to the Office of Fair Trading. This does not apply to payments below this amount, or the equivalent or more amounts if paid by cheque, bank transfer, credit or debit card.
8 Legal basis for processing your personal data
We will only use your personal data where the law allows us to. Most commonly, we will use your personal data in the following circumstances:
1. for performance of a contract we enter into with you;
2. where necessary for compliance with a legal or regulatory obligation we are subject to; and
3. for our legitimate interests (as described within this policy) (but only if your interests and fundamental rights do not override these interests).
9 Disclosure of personal data to third parties
As well as set out elsewhere in this policy, we may disclose your information to the following parties, because we have a legitimate interest in doing so:
1. our group companies (including our subsidiaries, our holding companies and any subsidiaries of our holding companies as defined in Section 1159 of the Companies Act 2006);
2. staff members and third party suppliers in order to facilitate the provision of goods or services to you;
3. our affiliated entities to support internal administration;
4. IT software providers that host our Website and store data on our behalf;
5. our professional advisers including consultants, legal advisors, bankers and insurers; and
6. Gibraltar Income Tax Dept, regulators and other authorities who require reporting of processing activities in certain circumstances;
7. to third party organisations who provide us with information on an anonymised basis about customer demographics and expenditure; and
8. to third parties with whom we may in the future negotiate a sale, transfer or merger of our business.
9. We may also disclose personal data to the police, regulatory bodies, legal advisors or similar third parties where we are under a legal duty to disclose or share personal data in order to comply with any legal obligation, or in order to enforce or apply our website terms and conditions and other agreements; or to protect our rights, property, or safety of our customers, or others.
10. We will not sell or distribute personal data to other organisations without your approval.
10 Cross-border data transfers
1. Our IT software providers and developers may process your personal data to the United States and other jurisdictions outside the European Economic Area (‘EEA’). We will ensure that adequate levels of protection approved by the European Commission are in place for the security of the processing of your personal data outside the EEA.
11 Data security
1. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
2. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your information transmitted to our Website; any transmission is at your own risk.
3. Information you provide to us is shared on our secure servers. We have implemented appropriate physical, technical and organisational measures designed to secure your information against accidental loss and unauthorised access, use, alteration or disclosure. In addition, we limit access to personal data to those employees, agents, contractors and other third parties that have a legitimate business need for such access.
12 Access to, updating, deleting and restricting use of personal data
1. It is important that the personal data we hold about you is accurate and current. Please keep us informed if the personal data we hold about you changes.
3. You can also ask us to do the following (although please see section 12.4, which might apply to your request):
a). update or amend your personal data if you feel this is inaccurate;
b). remove your personal data from our records entirely;
c). send you copies of your personal data in a commonly used format, and transfer your information to another entity; or
d). restrict the use of your personal data.
4. If you make this type of request we may request specific information from you to help us confirm your identity and verify your request. Data protection legislation may allow or require us to refuse your request. If we refuse your request we will inform you of the reasons why, subject to any legal or regulatory restrictions.
13 Retention of personal data
1. 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
2. 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.
14 Right to withdraw consent
16 Contact us
Last updated: 28th April 2019