Privacy and Cookies Policy

Welcome to Lockabox’s privacy policy.

Lockabox Limited respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to 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 policy

This privacy policy aims to give you information on how Lockabox Limited collects and processes your personal data through your use of this website and through direct interactions with us including by telephone and email, including any data you may provide through this website when you purchase a product or service.

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 policy together with any other privacy policy or fair processing policy 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 policy supplements other notices and privacy policies and is not intended to override them.

Controller

Lockabox Limited is the controller and responsible for your personal data (referred to as “we”, “us” or “our” in this privacy policy).

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

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact our data privacy manager in the following ways:

Full name of legal entity: Peter Morris

Email address: [email protected]

Postal address: Unit 1 Duke Street Chambers, Bridge Street, Kingsbridge, Devon, UK, TQ7 1HX

Telephone number: 01548 856574

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.

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

We keep our privacy policy under regular review.

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 policy of every website you visit.

2. 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 includes first name, last name, username or similar identifier, title.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data includes 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 includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our website, products and services.
• 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 could be derived from your personal data but is not considered personal data in law as this data will 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 policy.

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.

3. How is your personal data collected?

We use different methods to collect 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:
• apply for our products;
• create an account on our website;
• request marketing to be sent to you;
• enter a competition, promotion or survey; or
• give us feedback or contact us.
• Automated technologies or interactions. As you interact with our website, we will 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 for further details.
• Third parties or publicly available sources. We will receive personal data about you from various third parties as set out below:
• Technical Data from the following parties:
  • analytics providers such as Google based outside the EU;
  • advertising networks such as Active Campaign, Trust Pilot, Instagram, Facebook, Twitter, LinkedIn, based inside outside the EU; and
  • search information providers such as Google, Bing and Yahoo based outside the EU.
• Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Xero, Trade Gecko, Amazon, PayPal, Stripe Payment, WooCommerce based inside OR outside the EU.
• Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.

4.  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 obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before 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 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) 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 or privacy policy (b) Asking you to leave a review or take a survey	(a) Identity(b) Contact (c) Profile (d) 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 study how customers use our products/services)
To enable you to partake in a prize draw, competition or complete a survey	(a) Identity(b) Contact (c) Profile (d) Usage (e) Marketing and Communications	(a) Performance of a contract with you(b) Necessary for our legitimate interests (to study how customers use our products/services, 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	(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 the advertising we serve to you	(a) Identity(b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	(a) Technical(b) Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you	(a) Identity(b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications	Necessary for our legitimate interests (to develop our products/services and grow our business)

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

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 products from us and 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 third party for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time 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/service purchase or warranty registration 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.

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.

5. Disclosures of your personal data

We may share your personal data with the following parties WooCommerce 20i Limited,  Xero, Trade Gecko, Amazon, PayPal, Stripe Payment, Active Campaign, Trust Pilot, Instagram, Facebook, Twitter, LinkedIn for the purposes set out in the table above.

We may share your personal data with 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 policy.

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

Many of our external third parties are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, 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. 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 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.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the 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.

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 reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

Details of retention periods for different aspects of your personal data can be request from us.

In some circumstances you can ask us to delete your data: see ‘your legal rights’ below for further information.

In some circumstances we will anonymise your personal data (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.

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data.   These are as follows:

• 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:
  • If you want us to establish the data’s accuracy.
  • Where our use of the data is unlawful but you do not want us to erase it.
  • 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.
  • 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 us.

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 could 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 could 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.

Cookies

About cookies

A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

Cookies that we use

We use cookies for the following purposes:

(a)      authentication – we use cookies to identify you when you visit our website and as you navigate our website,

(b)      status – we use cookies to help us to determine if you are logged into our website

(c)      shopping cart – we use cookies to maintain the state of your shopping cart as you navigate our website

(d)      personalisation – we use cookies to store information about your preferences and to personalise our website for you

(e)      security – we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally ;

(f)       analysis – we use cookies to help us to analyse the use and performance of our website and services ; and

(g)      cookie consent – we use cookies to store your preferences in relation to the use of cookies more generally.

Cookies used by our service providers

Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Please see Google’s Privacy Policy for more information.

Managing cookies

Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

(a)     For Google Chrome browsers;

(b)     For Mozilla Firefox browsers;

(c)     For Opera browsers;

(d)     For Microsoft Edge browsers; and

(e)     For Safari browsers;

Blocking all cookies will have a negative impact upon the usability of many websites.

If you block cookies, you will not be able to use all the features on our website.

Cookies that we use:

Cookies Necessary for the Functioning of the Site

Name	Function
_Brochure_session	Used in connection with browsing through site.

 Reporting and Analytics

Store front end:

COOKIE NAME	DURATION	PURPOSE
woocommerce_cart_hash	session	Helps WooCommerce determine when cart contents/data changes.
woocommerce_items_in_cart	session	Helps WooCommerce determine when cart contents/data changes.
wp_woocommerce_session_	2 days	Contains a unique code for each customer so that it knows where to find the cart data in the database for each customer.
woocommerce_recently_viewed	session	Powers the Recent Viewed Products widget.
store_notice[notice id]	session	Allows customers to dismiss the Store Notice.

No personal information is stored within these cookies.

Store dashboard:

COOKIE NAME	DURATION	PURPOSE
woocommerce_snooze_suggestions__[suggestion]	2 days	Allows dashboard users to dismiss Marketplace suggestions, if enabled.
woocommerce_dismissed_suggestions__[context]	1 month	Count of suggestion dismissals, if enabled.
tk_ai	session	Stores a randomly-generated anonymous ID. This is only used within the dashboard (/wp-admin) area and is used for usage tracking, if enabled.

Additionally, we use pixels and tags from the following third parties, which may in turn place cookies:

Reporting & Analytics:

Third Party	Description	Privacy Policy
Alexa Metrics	We use Alexa Metrics to help measure how users interact with our websites.	Alexa Privacy Policy
Bugsnag	We use Bugsnag to help us troubleshoot and fix issues with our websites.	Bugsnag Privacy Policy
Chartbeat	We use Chartbeat to help measure how users interact with our websites.	Chartbeat Privacy Policy
Crazy Egg	We use Crazy Egg to help measure how users interact with our websites.	Crazy Egg Privacy Policy
Fullstory	We use Fullstory to help measure how users interact with our websites.	FullStory Privacy Policy
Google Analytics	We use Google Analytics to help measure how users interact with our websites.	Google Privacy Policy
Hotjar	We use Hotjar to help measure how users interact with our websites.	Hotjar Privacy Policy
KissInsights	We use KissInsights to help measure how users interact with our websites.	Kissmetrics Privacy Policy
LinkedIn Analytics	We use LinkedIn Analytics to help measure how users interact with our websites.	LinkedIn Privacy Policy
New Relic	We use New Relic to help measure how users interact with our websites.	New Relic Privacy Policy
Optimizely	We use Optimizely to help us test improvements or changes to our websites.	Optimizely Privacy Policy

 

Social Media & Content:

Third Party	Description	Privacy Policy
Disqus	We use Disqus to provide commenting capabilities on posts on our websites.	Disqus Privacy Policy
Facebook Connect	We use Facebook Connect to allow visitors to our website to interact with and share content via Facebook’s social media platform.	Facebook Privacy Policy
Automattic	We use Automattic to allow visitors to our websites to create avatars.	Automattic Privacy Policy
Pinterest	We use Pinterest to allow visitors to our website to interact with and share content via Pinterest’s social media platform.	Pinterest Privacy Policy
Twitter	We use Twitter to allow visitors to our website to interact with and share content via Twitter’s social media platform.	Twitter Privacy Policy
Wistia	We use Wistia to display video content.	Wistia Privacy Policy

 

Our details

This website is owned and operated by Lockabox Limited.

Our principal place of business is at:

Lockabox Limited, Unit 1, Duke St Chambers, Bridge Street, Kingsbridge, TQ7 1HX, United Kingdom.

 You can contact us:

(a)      by post, to the postal address given above;

(b)      using our website contact form;

(c)      by telephone, on the contact number published on our website from time to time; or

(d)      by email, using the email address published on our website from time to time.

Voluntary slavery and human trafficking statement

Lockabox Limited is making a voluntary modern slavery and human trafficking statement relating to section 54 of the Modern Slavery Act 2015.

We oppose slavery and human trafficking in all its forms and make this statement to set out the steps we have taken to ensure that there is no slavery or human trafficking in our business or in our supply chains.

About us

We are a small business providing compact and hygienic lockable storage boxes in the hospital, care and education sectors, together with thousands of homes around the World.

Our annual turnover is under £36 million. Although we are not required to make a modern slavery statement under section 54 of the Modern Slavery Act.2015, we are making this voluntary statement to show our commitment to ethical trading principles and to set out the steps we are taking to tackle modern slavery and human trafficking in our business and in our supply chains.

Policies

Our Anti-slavery Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking are not taking place anywhere in our supply chains.

Due diligence and risk assessment

To help identify and monitor the risk of slavery and human trafficking in our supply chain we vet suppliers and sub-contractors to ensure that they are committed to ethical labour practices. In addition, since 28/02/2020 we include anti-slavery and human tracking provisions in all our contracts with suppliers.

Effectiveness in combating slavery and human trafficking

We use the following key performance indicators (KPIs) to measure how effective we have been at ensuring that slavery and human trafficking is not taking place in any part of our business or supply chains:

• The percentage of suppliers and sub-contractors vetted for ethical labour practices.
• The number of reported breaches in the past year.
• Percentage of staff receiving training on identifying and addressing the risk of slavery and human trafficking in our business and supply chains.

Training

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to our staff.

Thank you, if you have any queries or questions please email us at [email protected]