As a data controller, we are responsible for ensuring that when we process Personal Information we comply with UK data protection law.
If you have any questions about this policy, please get in touch with No Label Required.
Personal Information; Some of that information will identify the individual directly, for example by giving their name and email address. It may also be possible to identify someone indirectly, from information in which their name is not given, such as their IP address. See below in “what Personal Information do we collect and use?” for examples of the type of information which would fall within this definition.
Special Category Personal Information: Personal information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership. Genetic and biometric data. Data concerning health, sex life or sexual orientation.
Website: The website at this address: www.nolabelrequired.net
What Personal Information do we collect and use?
The type of Personal Information we collect and process depends on our relationship with you and the context in which we obtain and use it. The list below sets out the Personal Information we will or may collect depending on the circumstances.
Personal Information we may collect from our customers;
- Your title;
- Your first name;
- Your last name;
- Your age;
- Your postal address;
- Your email address;
- Telephone number;
- Mobile Number (so we may send you a free delivery text message the night before your order is delivered, if the service is available).
Personal Information we collect from our employees;
- Full name and title;
- Date of Birth;
- National Insurance number;
- Proof of identification and address documentation;
- Medical history;
- Next of kin;
- Bank details;
- Ethnic Group;
- Other employment-related information, (including CV’s, references, etc.).
How Personal Information is collected and your responsibilities:
We may collect Personal Information from you in person, via telephone, our Website or email communication.
The sources we may also collect Personal Information from include:
- our information technology systems, e.g., our Website or other relevant websites and applications;
- automated monitoring of our Website and other technical systems, such as our computer networks and connections, CCTV and access control systems, communications systems, email, voicemail and instant messaging systems.
When you provide Personal Information to us relating to a third party, you confirm that you have any necessary permission or authority to do so. You are also responsible for ensuring that the provision of that Personal Information complies with data protection and other applicable law. You must have the authority to disclose personal data if it relates to someone else and all data disclosed should be complete, accurate and up to date.
No Label Required Portal
Usernames and passwords are provided to you only, as a customer of No Label Required. This allows you to access Personal Information that we are holding on your account. You are able to update, delete and amend this information. The account allows you to access this feature.
Personal data of children
Visitors to our website
We use technology to track the patterns of behaviour of visitors to our Website. This can include using a “cookie” which would be stored on your browser or the hard drive of your computing device. Cookies are small pieces of information which track what items you have looked at previously, so we can bring them to your attention at a later date and also allow us to keep items in your shopping cart which you can select and then return to purchase at a later date. The cookies are stored on your hard drive and will not harm to your computer. If you wish you can change your own computer’s settings or firewall to disable cookies. You will be able to use most of the features when these are disabled such as the shopping cart and purchasing items.
How and why we use your personal information
Under data protection law, we can only use your Personal Information if we have a proper reason for doing so, for example:
- to comply with our legal and regulatory obligations;
- for our legitimate interests (see below) or those of a third party;
- for the performance of our contract with you or to take steps at your request;
- you have given consent.
A legitimate interest is when we have a business or commercial reason to use your Personal Information, so long as this is not overridden by your own rights and interests. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Information for our legitimate interests. We do not use your Personal Information 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).
In general terms, we will collect Personal Information to:
- provide our services to you, to manage our relationship and comply with our legal obligations arising from it;
- provide you with information about our business and the services we offer including relevant communications;
- help us improve our business and the services we offer.
Change of purpose
We will only use your Personal Information 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 we need to use your Personal Information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
We may process your Personal Information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Where you have requested that we do so, we may use your Personal Information to send you updates and newsletters (telephone, post, email, SMS or other electronic means) about our products and services, including new products and services.
We will always treat your Personal Information with the utmost respect and we will never sell or share it with other organisations for marketing purposes.
By registering with No Label Required and providing us with your email address, phone number and postal address and consenting to receive communication from No Label Required, you acknowledge that you will receive email notifications in relation to our products, services and special offers that you may be interested in. This will usually be in the form of a newsletter.
You have the right to opt out of receiving marketing communications at any time by:
- contacting us in writing at our address above
- By logging into your No Label Required account and making the necessary changes.
We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.
Who we share your Personal Information with
We may share Personal Information with:
- Our professional advisers; e.g. lawyers, accountants, etc.;
- Other third parties where necessary to carry out your instructions e.g. our Courier and delivery services or any outsourced warehousing and distribution facilities.;
- our bank/s, insurers, brokers;
- external service suppliers, representatives and agents that we use to make our business more efficient.
Our IT support and service providers may also access your Personal Information as a consequence of them providing support to us.
We only allow our service providers to handle your Personal Information if we are satisfied they take appropriate measures to protect your Personal Information. We also impose contractual obligations on service providers to ensure they can only use your Personal Information to provide services to us and to you.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
We may also need to share some Personal Information with other parties. For example, if we, in the course of our own business operations, sell or buy any business or assets we may disclose Personal Information held by us to the prospective seller or buyer of those businesses or assets.
Where possible, information will be anonymised, but the recipient of the information will be bound by confidentiality obligations. If we are acquired, or substantially all of our assets are acquired, by a third party (or are subject to a reorganisation), Personal Information held by us will be one of the assets which is transferred.
Where your Personal Information is held
Personal Information will be held on the secure server at our offices, third-party agencies, service providers, representatives and agents as described above (see Who we share your Personal Information with).
We also hold your Personal Information in secure data centres in the UK (and in relation to personal data held in our customer relationship management system only, this may be held in secure data centres in the UK, EU and USA) with all reasonable technological and operational measures put in place to safeguard it from unauthorised access.
Transferring your Personal Information out of the EEA
To deliver services to you, it may be necessary for us to share your Personal Information outside the European Economic Area (EEA) i.e. the USA, e.g.:
- with our data centres in the USA;
- with your and our service providers located in the USA;
- if you are based in the USA;
- if one of our staff or contractors needs to access it remotely while they are travelling in the USA.
These transfers are subject to special rules under European and UK data protection law. In those circumstances, we undertake an assessment of the level of protection in light of the circumstances surrounding the transfer. We will make sure that any transfers are not repetitive and only limited to the minimum amount of information possible and will always take steps to ensure that your Personal Information is adequately protected. In certain circumstances, we may need to seek your consent unless there is an overriding legal need to transfer the Personal Information.
The United States has been assessed by the European Commission as providing an adequate level of protection for Personal Information.
How long your Personal Information will be kept
We will only retain your Personal Information 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.
When it is no longer necessary to retain your Personal Information, we will delete or anonymize it. In some circumstances, we may anonymize your Personal Information (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.
To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorised use or disclosure of it, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances you can ask us to delete your data: see Your rights with respect to your Personal Information.
We only keep your Personal Information for as long as is necessary to:
- provide you with our products and services;
- respond to any questions, complaints or claims made by you or on your behalf;
- keep records required by law to comply with our legal obligations and our duties.
Complaints or requests
If you are not a customer of ours but you complain to us about how we have processed your Personal Information or you seek to exercise a data protection right such as a data subject access request, we will retain details of your complaint or request. We will only use the Personal Information we collect to process the complaint or request, to audit the level of service we have provided and to provide information to our insurers or regulator.
We will keep information in connection with the complaint or request in line with our retention policy. In most cases, this means we will retain the information for six years.
How we protect your Personal Information
Keeping information secure is a key part of data protection compliance. We have put in place appropriate security measures to prevent your Personal Information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your Personal Information to those employees, agents, contractors and other third parties who have a business need to know 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 or where we have otherwise agreed with you that we will.
We also maintain our own internal audit programme to verify that our staff are familiar with and adhere to our policies and procedures.
If we have given you a username and password which allows you to access via our systems, you are responsible for keeping it confidential.
Your rights with respect to your Personal Information
You are entitled at any time to ask us for a copy of Personal Information we hold about you, known as a data subject access request. You are also entitled to ask that any information we hold about you is supplemented, updated or rectified. You can make any of these requests free of charge by contacting us – see Contact Information.
In certain circumstances, you can also ask us to restrict our processing of your Personal Information, e.g. if you contest the accuracy of it. We will always review your request and will inform you if we decide we are not required to action it. If you require us to restrict or stop processing your Personal Information in any way, this may impact on our ability to provide our services to you.
How to complain
We hope that we can resolve any query or concern you may raise about our use of your information. If you want to complain about how we have handled your Personal Information, please contact our Data Protection Officer. We will investigate your complaint but if you are not satisfied with our response or believe we are processing your Personal Information unlawfully, you can complain to the UK Information Commissioner’s Office. Further information is available on the ICO website or telephone 0303 123 1113.
The EU General Data Protection Regulation also gives you the right to lodge a complaint with a supervisory authority, in particular in the European Union (or EEA) State where you work, normally live or where any alleged infringement of data protection laws occurred. The UK supervisory authority is the Information Commissioner.
- Data Protection Officer: John Budgen
- Address: (enter address)
- Email to – email@example.com
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