Grand Passion Pianos Limited respects your privacy and is committed to protecting your personal data. This privacy notice provides information on 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.
1. IMPORTANT INFORMATION AND WHO WE ARE
PURPOSE OF THIS PRIVACY NOTICE
This privacy notice aims to give you information on how Grand Passion Pianos Limited collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up using the button on our homepage or send us a message from the contact page.
Grand Passion Pianos Limited is the controller and responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).
If you have any questions about our use of your personal data please contact us using the details below:
Grand Passion Pianos Limited (company number 08152753)
Email address: firstname.lastname@example.org
Postal address: Grand Passion Pianos Limited, Kemp House, 152 – 160 City Road, London EC1V 2NX
Telephone: 0800 233 5213 (you will not be charged for your call).
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 notice of every website you visit.
2. THE DATA WE COLLECT ABOUT YOU
We may receive or obtain your personal data in the following ways:
through direct interaction with one of our directors, employees or contractors;
by sending us an email;
by completing the form on the “contact us“ page of our website.
The categories of personal data which we routinely collect from the sources described above are some or all of the following:
address (for example, where we need to deliver a piano to you);
name of business or employer (where you provide us with a business card or otherwise include this information in a communication with us such as an email);
information about the types of products which you are interested in.
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.
We do not knowingly 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. Please do not provide any of the types of personal data described in this paragraph to us.
4. PURPOSES FOR THE USE OF 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:
to contact you about our products;
to promote or market our products and services;
to perform a contract which we have entered into with you;
to maintain a record of our past sales and servicing history;
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; and
where we need to comply with a legal or regulatory obligation.
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 using the details set out in paragraph 1 above.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We will only send you a marketing communication if you have opted in to receiving that communication or the communication is of a type that does not require prior opt-in consent. We provide you with an option to opt out of receiving further marketing communications from us in each marketing communication that we send to you by email. Alternatively, you can write to us at any time to request removal from our marketing database by contacting us using the details set out in paragraph 1 above.
5. LEGAL BASIS FOR THE PROCESSING OF YOUR PERSONAL DATA
The General Data Protection Regulation permits us to use your personal data where one or more bases set out in that Regulation applies to such usage. One of these bases is called the “legitimate interests” base, and it is this one which we rely upon. This permits us to use your personal data for legitimate business interests, but only where such interests are not overridden by your interests, rights or freedoms.
Our relevant legitimate business interests are:
- the operation of a piano supply business;
- the promotion of our products and services;
- the maintenance of internal records;
- the prevention of crime and fraud; and
- compliance with the law.
Where we market to you by email, we will have obtained prior consent from you unless you are a business and the product or service which is the subject of the marketing communication is aimed at that business and not an individual consumer.
DISCLOSURES OF YOUR PERSONAL DATA
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
We do not transfer your personal data outside the European Economic Area (EEA).
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 for the purposes set out in this policy.
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 necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Accordingly, except in respect of provenance data, we use the following criteria to determine the period for which we retain your personal data:
any statutory limitation period relevant to the personal information; or
any statutory or regulatory retention period applicable to the personal information.
Where you have purchased a piano from us, we maintain a record of that purchase, together with identifying information about the relevant piano and the works undertaken to the piano, for up to 20 years. This is because:
we are often the sole source of provenance of a particular piano;
pianos are rarely sold within a few years of purchase and therefore the issue of provenance is very rarely relevant for a number of years post-purchase – typically no less than 10 – 15 years (meaning a short retention period will not provide any benefit to the purchaser); and
provenance tracing, together with details of the works undertaken to a piano (which only we can often provide) ensure that the value of your instrument is maximised.
It follows that, after careful consideration, we have concluded that there is a clear purpose for the retention of provenance data for the period set out in this policy and that this is primarily for the benefit of our customers or a future purchaser upon a subsequent sale. In all instances, we only maintain a small amount of personal data for provenance purposes (name and address), with the majority of the relevant data relating to the piano and the works undertaken to it. You may elect that we keep your personal data only for the standard retention periods set out above by notifying us using the contact details set out in section 1 above or by notifying us at the time that you purchase a piano from us.
9. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These rights are:
access to your personal data;
rectification of your its personal data;
restricting the use of your personal data;
erasure of your personal data; and/or
objecting to the processing of your personal data.
You also have the right to lodge a complaint with a supervisory authority and, where we request your consent to process your personal data, to withdraw consent at any time by contacting us using the details set out in section 1 above.
If you wish to exercise any of the rights set out above, please contact us using the details set out in paragraph 1 above.
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 and we will do all that we can to resolve the issue.
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 may refuse to comply with your request in these circumstances.
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