Privacy Policy
Introduction
Sprockets respects your privacy and is committed to protecting your personal data. We will only use the information that we collect about you lawfully (in accordance with the Data Protection Act 1998 and General Data Protection Regulations 2018). Sprockets Limited shall be referred to as "SprocketsUK", "Sprockets", "we", "us", "our" throughout this privacy notice.
This privacy notice will inform you as to how we look after your personal data when you visit and use our website (regardless of where you visit it from), subscribe to our newsletter, purchase a product, track your order or take part in a competition. In addition, it will tell you about your privacy rights and how the law protects you.
Please use the Glossary at the end of this Privacy Notice to understand the meaning of some of the terms used.
What Data do we collect?
Personal data, or personal information, 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 follows:
- Identity Data includes first name, last name, middle name or initial, and username or similar identifier.
- Contact Data includes billing address, delivery address, email address and telephone number.
- Financial Data includes PayPal details (specifically, the Transaction ID) and payment card details (note: only the last four digits of the card number are stored).
- Transaction Data includes details about payments to and from you and other details of products you have purchased from us.
- Technical Data includes internet protocol (IP) address, your log-in data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, technologies to track website users, advertisements you have clicked on and other technology on the devices you use to access this website.
- Account Data includes your username and password (which is encrypted by us), purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our website and products.
- 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 may be derived from your personal data but is not considered personal data in law as this data does 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 notice.
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.
This website is not intended for children and we do not knowingly collect data relating to children.
How do we collect your data?
We use different methods to collect data from and about you through;
- Direct interactions. You may give us your Identity, Contact, and Financial Data by filling in forms, ordering products from us or by corresponding with us by post, phone, e-mail or otherwise. This includes personal data you provide when you:
- order our products;
- create an account on our website;
- signing up for our rewards scheme;
- subscribe to our newsletter;
- request marketing to be sent to you;
- enter a competition, promotion or survey; or
- give us some feedback or leave a review.
- Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs, website user tracking, session replay and other similar technologies.
- 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:
(a) analytics providers;
(b) advertising networks; and
(c) search information providers.
- Contact, Financial and Transaction Data from providers of technical, payment, consumer credit and delivery services.
- Identity and Contact Data from data brokers or aggregators.
- Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.
- Identity, Contact and Transaction Data from customer service software providers.
If you don’t provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you (for example, to provide the products you have ordered), 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. In this case we may not be able to complete the order, but we will notify you if this is the case.
Inform us of 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.
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. For example, to administer your order and deliver the products to you.
- 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.
- Where we need to comply with a legal or regulatory obligation.
See below to find out more about the types of lawful basis that we will rely on to process your personal data.
Consent
By submitting information to Sprockets you consent to the collection and use of this information by Sprockets and it's Service Provider (if any). If we make any changes our privacy policy, we will post those changes on this page so that you are aware of what information we collect, how we use it and under what circumstances we disclose it.
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established a system where you can view and make certain decisions about your personal data use, such as by setting preferences as to the specific types of marketing you may be interested in:
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile 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 products and offers may be relevant for you.
You will receive marketing communications from us if you have requested information from us or purchased products from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, 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 company outside of SprocketsUK or our group companies for marketing purposes.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or 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 purchase, warranty registration, product experience or other transaction.
What are your data protection rights?
Our Company would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:
The right to access – You have the right to request Sprockets for copies of your personal data. We may charge you a small fee for this service.
The right to rectification – You have the right to request that Sprockets correct any information you believe is inaccurate. You also have the right to request Our Company to complete the information you believe is incomplete.
The right to erasure – You have the right to request that Sprockets erase your personal data, under certain conditions.
The right to restrict processing – You have the right to request that Sprockets restrict the processing of your personal data, under certain conditions.
The right to object to processing – You have the right to object to Sprockets processing of your personal data, under certain conditions.
The right to data portability – You have the right to request that Sprockets transfer the data that we have collected to another organization, or directly to you, under certain conditions.
The right to Withdraw – You have the right to request that Sprockets withdraw 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 to you. We will advise you if this is the case at the time you withdraw your consent.
If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us at our email: paul@sprockets.uk.com
Cookies
Cookies are text files placed on your computer to collect standard Internet log information and visitor behaviour information. When you visit our websites, we may collect information from you automatically through cookies
How do we use cookies?
Sprockets website uses cookies in a range of ways to improve your experience on our website, such as:
- Keeping you signed in
- Understanding how you use our website
For instance, if you block or reject our website cookies, you will not be able to add items to your Shopping Cart, proceed to Checkout, or use any sprockets.uk.com features that require you to Sign in. If you use a shared computer, please be sure to sign out of Sprockets.uk.com when you finish.
For further information, see our Cookie Policy
How to manage cookies
You can set your browser not to accept cookies, and the above website tells you how to remove cookies from your browser. However, in a few cases, some of our website features may not function as a result.
Privacy policies of other websites
The Sprockets website contains links to other websites, plug-ins and applications. For example, we may include links to the manufacturer of the products on our website. 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 notice of every website you visit.
Changes to our privacy policy
Our Company keeps its privacy policy under regular review and places any updates on this web page. This privacy policy was last updated on 27 November 2020
How to contact us
If you have any questions about Our Company’s privacy policy, the data we hold on you, or you would like to exercise one of your data protection rights, please do not hesitate to contact us.
Email us at: paul@sprockets.uk.com
Call us: 01304 840673
Or write to us at: SprocketsUK, Ratling Road, Aylesham, Kent CT3 3HL
Name of data compliance manager: Paul Hudson
How to contact the appropriate authority
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
Purposes for which we will use your personal data
In the table below we have set out a description of 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 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) Account (f) 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 of sale or privacy policy (b) Asking you to leave a product review or take a survey (c) Providing support services in relation to our products |
(a) Identity (b) Contact (c) Account (d) Transaction (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 analyse how customers use our products) |
To enable you to partake in a prize draw, competition or complete a survey |
(a) Identity (b) Contact (c) Account (d) Usage (e) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to analyse how customers use our products, 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 (d) Usage |
(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 our advertising |
(a) Identity (b) Contact (c) Transaction (d) Account (e) Usage (f) Marketing and Communications (e) Technical |
Necessary for our legitimate interests (to analyse how customers use our products, to develop them, to grow our business and to inform our marketing strategy) |
To use data analytics to improve our website, products, marketing, customer relationships and experiences |
(a) Transaction (b) Technical (c) Usage |
Necessary for our legitimate interests (to define types of customers for our products, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
To make available consumer credit finance in relation to the products that you have ordered |
(a) Identity (b) Contact (c) Financial (d) Transaction (e) Account Data |
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to supply your details to the consumer credit provider for assessment about your suitability for credit finance) |
To make suggestions and recommendations to you about products that may be of interest to you |
(a) Identity (b) Contact (c) Transaction (d) Technical (e) Usage (f) Account |
Necessary for our legitimate interests (to develop our products and grow our business) |
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.
Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
- Internal Third Parties as set out in the Glossary.
- External Third Parties as set out in the Glossary.
- 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 notice.
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.
International transfers
We do not transfer your personal data outside the European Economic Area (EEA).
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.
Data retention
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.
Details of retention periods for different aspects of your personal data can be requested by contacting us.
Glossary of Terms
Legitimate interest means the interest of our business in conducting and managing our business to enable us to give you the best product 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
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.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
THIRD PARTIES
- Service providers acting as processors who provide IT, marketing, system administration services and other services from time to time.
- Credit finance providers acting as processors or joint controllers who provide, or may provide, credit finance in relation to the purchase of a product.
- Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.