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Privacy Notice

 

Introduction

 

Welcome to Rubix Group International Limited’s privacy notice.

 

Rubix Group International Limited is part of the Rubix Group of companies (the “Rubix Group”).

 

This privacy notice is issued on behalf of the Rubix Group so when we mention “Rubix”, “we”, “us” or “our” in this privacy notice, we are referring to the relevant company in the Rubix Group responsible for processing your data.

 

Rubix respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from), purchase a product or service or take part in a competition or correspond with us by post, phone, email or otherwise, and tell you about your privacy rights and how the law protects you.

 

 

Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.

 

 

Important information and who we are

 

Purpose of this privacy notice

 

This privacy notice aims to give you information on how Rubix collects and processes your personal data when you visit this website (including any data you may choose to provide through this website, for example when you sign up to our newsletter), purchase a product or service or take part in a competition, or correspond with us by post, phone, email or otherwise. 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 notice together with any other privacy notice or fair processing notice 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 notice supplements the other notices and is not intended to override them.

 

Controller

 

Rubix Group International Limited is the controller and responsible for this website.

 

We have appointed a data privacy team (“DPT”) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPT using the details set out below.

 

Contact details for the DPT

 

Our full details are: Rubix Group International Limited (Company number: 00162925), Accurist House,

 

44 Baker Street, London, England, W1U 7 AL. Email address for DPT: data-privacy@rubix-group.com

 

You have the right to make a complaint at any time to the data protection authority of your country in the EEA in respect of data privacy matters in the Rubix group of companies. We have identified some of these below. We would, however, appreciate the chance to deal with your concerns before you approach any data protection regulator so please contact us in the first instance.

 

Country	Data Protection Regulator
Austria	Austrian Data Protection Authority ('DSB')
Belgium	Data Protection Authority ('Belgian DPA')

 

Czech Republic	Office for Personal Data Protection ('UOOU')
Denmark	Danish Data Protection Agency ('Datatilsynet')
Finland	Office of the Data Protection Ombudsman ('the Ombudsman')
France	Commission Nationale de l'Informatique et des Libertés ('CNIL')
Germany	The  Federal  Commissioner  for  Data  Protection  and  Freedom  of
	Information ('BfDI')
Hungary	National Authority for Data Protection and Freedom of Information ('NAIH')
Iceland	Persónuvernd
Ireland	Data Protection Commission ('DPC')
Italy	Garante per la protezione dei dati personali ('Garante')
Luxembourg	National Commission for Data Protection ('CNPD')
Netherlands	Autoriteit Persoonsgegevens (‘AP’),
Norway	Datatilsynet
Poland	Urząd Ochrony Danych Osobowych ('UODO')
Romania	National Supervisory Authority for Personal Data Processing ('ANSPDCP')
Slovakia	Office for Personal Data Protection of the Slovak Republic ('ÚOOÚ')
Spain	Agencia Española de Protección de Datos ('AEPD')
Sweden	The Swedish Authority for Privacy Protection ('IMY')
Switzerland	Federal Data Protection and Information Commissioner ('FDPIC')
United Kingdom	Information Commissioner’s Office (‘ICO’)

 

Changes to the privacy notice and your duty to inform us of changes

 

This version was last updated on 17 May 2023.

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 notice of every website you visit.

 

The data we collect about you

 

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 as follows:

 

• Identity Data – this may include your first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.

 

• Contact Data – this may include your billing address, delivery address, email address and telephone numbers.

 

• Financial Data – this may include your bank account and payment card details.

 

• Transaction Data – this may include details about payments to and from you and other details of products and services you have purchased from us.

 

• Technical Data – this may include your internet protocol (IP) address, your login data, 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.

 

• Profile Data – this may include your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.

 

• Usage Data – this may include information about how you use our website, products and services.

 

• Marketing and Communications Data – this may include your preferences in receiving marketing from us and our third parties and your communication preferences.

 

We may 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.

 

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 (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

How is your personal data collected?

 

We use different methods to collect personal 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 or otherwise. This includes personal data you provide when you:

 

o apply for our products or services; o create an account on our website;

 

o subscribe to our service or publications; o request marketing to be sent to you;

 

o enter a competition, promotion or survey; or o give us some feedback.

 

• 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 and other similar technologies.

 

We may also receive Technical Data about you if you visit other websites employing our cookies.

 

Please see our cookie policy, which is published on our website for further details.

 

Third parties or publicly available sources. We may collect or receive personal data about you from various third parties who have your consent to pass your details to us and from publicly available sources.

 

 

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.

 

• 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.

 

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.

 

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 may 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 basis depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal basis we are relying on to process your personal data where more than one basis 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

(a)

Identity

(b)

Performance of a contract with you

customer or supplier

Contact

To process and deliver your /

our

order

including:

(a)

Manage

payments,

fees

and

charges (b) perform credit risk

(a)

Identity

(b)

assessments (including but not

Contact (c) Financial

(a) Performance of a contract with you

limited  to  referral  to  Credit

(d)   Transaction

(e)

(b)   Necessary   for   our   legitimate

Reference Agencies

to

assess

Marketing

and

interests (to recover debts due to us)

creditworthiness,

check  your

Communications

identity and prevent criminal

activity)

(c)

Collect

and

recover money owed to us

To

manage

our

relationship

(a) Performance of a contract with you

with

you

which

will

include:

(a)

Identity

(b)

(b) Necessary to comply with a legal

(a)

Notifying

you

about

Contact (c) Profile (d)

obligation

(c)

Necessary

for

our

changes

to

our

terms

or

Marketing

and

legitimate

interests

(to

keep

our

privacy policy

(b)

Asking you

Communications

records

updated

and

to  study

how

to

leave

a  review  or

take

a

customers use our products/services)

survey

(a)

Identity

(b)

(a) Performance of a contract with you

To enable you to partake in a

(b)

Necessary

for

our

legitimate

Contact (c) Profile (d)

prize

draw,

competition

or

interests (to study how customers use

Usage

(e)

Marketing

complete a survey

our

products/services,

to   develop

and Communications

them and grow our business)

(a)   Necessary   for   our   legitimate

To administer and protect our

interests  (for  running  our  business,

business

and

this

website

provision  of  administration  and  IT

(including

troubleshooting,

(a)

Identity

(b)

services, network security, to prevent

data analysis, testing, system

Contact(c) Technical

fraud and in the context of a business

maintenance,

support,

reorganisation  or

group

restructuring

reporting and hosting of data)

exercise) (b) Necessary to comply with

a legal obligation

To

deliver

any

relevant

(a)

Identity(b)

website

content

and

Necessary for our legitimate interests

Contact(c)

Profile(d)

advertisements

to

you

and

(to

study

how

customers

use

our

Usage(e)

Marketing

measure

or

understand

the

products/services,

to

develop  them,

and

effectiveness

of

the

to grow our business and to inform our

Communications(f)

advertising  we

may

serve

to

marketing strategy)

Technical

you

To

use

data

analytics

to

Necessary for our legitimate interests

(a)

Technical(b)

(to define types of customers for our

improve

our

website,

Usage

products

and  services,

to

keep

our

products/services,

marketing,

website

updated

and

relevant,

to

 

	customer   relationships				and			develop our business and to inform our
	experiences							marketing strategy)
	To	make	suggestions		and	(a)	Identity(b)	Necessary for our legitimate interests
	recommendations			to	you	Contact(c)
								(to develop our products/services and
	about  goods		or  services		that	Technical(d) Usage(e)
								grow our business)
	may be of interest to you					Profile
	To	register	you	as  a	job	(a)	Identity
	applicant (as described in our							Performance of a contract with you
						(b)	(b) contact
	job applicant privacy notice)
Marketing

 

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

 

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, 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 or services 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 direct marketing

 

We will get your express opt-in consent before we share your personal data with any company outside the Rubix Group for third-party direct marketing purposes. Note that we may, however, share your personal data with our external marketing agencies for the purpose of conducting Rubix Group surveys or promotions administered on our behalf by our external marketing agencies provided that, in each case, you have not opted out of receiving such marketing.

 

Opting out

 

You can ask us or third parties to stop sending you marketing messages at any time by contacti ng 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/service purchase, warranty registration, product/service experience or other transactions.

 

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. For more information about the cookies we use, please see our cookie policy, which is published on our website.

 

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.

We may share your personal data with Credit Reference Agencies for the purposes of credit risk assessment and they will give us information about you, such as your financial history. We do this to assess creditworthiness, check your identity, manage your account, trace and recover debts and prevent criminal activity. We may also continue to exchange information about you with Credit Reference Agencies on an ongoing basis, including about your settled accounts and any debts not fully paid on time. Credit Reference Agencies may share the data with other organisations for the purposes of credit risk assessment and to prevent criminal activity.

International transfers

We may need to share your personal data within the Rubix Group. As we are outside the European Economic Area (EEA) this involves transferring your data into as well as outside the EEA.

We ensure your personal data is protected by requiring all our group companies to which we will share your personal data to follow the same rules when processing your personal data.

As we and some of our external third parties are based outside the EEA processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

 

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission and/or UK authorities. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.

• Where we use certain service providers, we may use specific contracts approved by the European Commission and/or UK authorities which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.

 

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

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.

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 are available in our retention policy which you can request from us by contacting us.

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: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) 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 products 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 our DPT, using the contact details at paragraph 4 above.

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.

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 one month. Occasionally it may 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.

Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/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 personal 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

Internal Third Parties

Other companies in the Rubix Group acting as joint controllers or processors.

External Third Parties

Third parties other than our Internal Third Parties. For example, our IT service providers; professional advisors (including lawyers, bankers, auditors and insurers); credit reference agencies; regulators and other authorities; and our marketing agencies.