1.2 If you have any questions about how we use your personal data, please contact firstname.lastname@example.org.
2.3 Bestway Wholesale Limited is registered with company number 01207120, Bestway Northern Limited registered with company number 02675585 and MAP Trading Limited is registered with company number 01826942. Bestway Wholesale Limited is registered with the Information Commissioner's Office, or ICO, under registration number Z8416248, Bestway Northern Limited is registered under number Z8416220 and MAP Trading Limited is registered under number Z8416251.
3.2 We may need to verify your identity in order to process your request and ask you to provide valid identification documents to allow us to do so.
4.1 We will collect your name and contact details, if you have submitted an enquiry via the Contact Us page on the Website or entered a Bestway prize draw.
4.2 When you become a customer and register for an online customer account or complete hard copy application forms, we collect and use the following:
(a) full name;
(c) address, e-mail address and contact details;
(d) a copy of your passport, financial, bank and credit card information;
(e) your Bestway account passwords and customer numbers; and
(f) you may also be required to give us information about your business, business partners, beneficial owners or directors in which case you must ensure that you have permission to do this.
4.3 We collect and use the following personal data about you when you become a supplier and fill in forms on the Website or hard copy application forms:
(a) full name;
(b) address and contact details; and
(c) you may also be required to give us information about your business, business partners, beneficial owners or directors in which case you must ensure that you have permission to do this.
4.4 We also collect and use the following personal data about you indirectly:
(a) if you are a customer or supplier of Bestway, information obtained from any credit checks or other checks we are required to carry out for legal and regulatory purposes (see the section on 'Anti Money Laundering/ Sanctions' below for further information);
(b) if you are a customer of one of Bestway's suppliers, they may provide us with information such as your business name, address, as well as a relevant contact name and contact details in connection with transfer orders, or in connection with their prize draws where Bestway is supplying the prize;
(c) in order to administer the Website and understand how the Website is used, we collect technical information including your IP address, your login information, products you have viewed or searched, browser type, plug-ins you use, operating systems and platforms, URL, page response times, download errors, length of visits to certain pages, page interaction information, methods used to browse away from a page;
(d) information collected through the App, such as your purchases and account balance and geo-location data that identifies your location within the UK (you can change your settings at any time);
(e) any phone number used to contact Bestway;
(f) information collected using CCTV surveillance at our sites; and
(g) photographs of you if you are a prize winner.
5.1 We use personal data held about you for the following purposes in line with our legitimate interests to administer the Website and the App, to engage with users when they request our products and services, and provide us with products and services and to protect and exercise our rights as a business:
(a) to respond to your queries;
(b) to manage any customer trading account with us and update the records we hold about you from time to time;
(c) for customers who hold credit accounts, to carry out credit checks;
(d) to provide you with your goods and information about your goods and our services and to provide you with information via post, email, telephone or SMS about other goods and services we offer that are similar to those you have already purchased or enquired about and that may be of interest to you, to make suggestions and recommendations to you about goods or services that may interest you (for further information, see the section on 'Keeping You Up to Date' below);
(e) to administer prize draws and to communicate with you in relation to such prize draws, including where you have actively entered a Bestway prize draw or automatically qualified for entry into a prize draw due to items you have purchased;
(f) to welcome you into our depots and say goodbye to you when you leave and, if you are an App user, to tell you when you are in the vicinity of our depots;
(g) to analyse your purchases and purchase behaviour so we can provide a better service to you and to keep our website safe and secure;
(h) we may anonymise the data we hold about you or your business and share it with our suppliers for their own reporting or marketing activities;
(i) where you use EPOS or place orders directly with us using an electronic ordering system then we may automatically collect and use sales and purchase data to analyse sales of our products. We may anonymise this data and share it with selected market research agencies for the same purpose who may also share the anonymised data with third party suppliers and partners for their sales and market research purposes;
(j) if false or inaccurate information is provided and fraud is suspected or identified then this will be recorded and details will be passed to fraud prevention agencies. Law enforcement agencies may access and use this information. The information may also be used to prevent theft, fraud and money laundering for example, when checking details for customer registrations, credit applications or managing credit accounts;
(k) in relation to CCTV, for the prevention of crime and for security purposes;
(l) in relation to photographs taken of you as a prize winner, for generating business interest in Bestway customer trade press and Bestway internal communications; and
(m) to administer events and hospitality.
5.2 We will also use your personal data, for example, your name, address and contact details, to carry out our contractual obligations to provide you with products or services which you have ordered or purchased from us and to contact you in relation to such products and services.
5.3 As we are a regulated business, we are required by law to verify the identity of our customers and suppliers and carry out Anti Money Laundering and Sanctions checks.
5.4 We will process your personal data, including your name, address and identity verification documents, for the purposes of preventing money laundering or terrorist financing, as it is necessary in order to prevent unlawful acts and for the purposes of meeting regulatory requirements.
5.5 We are legally permitted to hold this information for no more than five years from the end of your business relationship with Bestway.
6.1 Special protection is given to certain kinds of personal data that is particularly sensitive. This is information about your health status, racial or ethnic origin, political views, religious or similar beliefs, sex life or sexual orientation, genetic or biometric identifiers, trade union membership ('special categories of personal data') or about your criminal convictions or offences.
6.2 Where we collect any special categories of personal data, we will take appropriate steps to ensure that we have explicit consent or another legal basis to hold, use and retain the information. In particular, we collect special category personal data in relation to Anti Money Laundering and Sanctions checks and our legal basis for using this personal data is as set out at 5 above.
7.1 We may share your personal data in the following scenarios. Unless stated otherwise, we either do this in our in line with our legitimate interests to provide you with and engage with you in relation to our goods and services, the commercial interests of our suppliers, to generate legitimate business interest or for contractual purposes:
(a) with other members of the Bestway group – for example, for administration or reporting purposes, or for marketing purposes where you have indicated that you wish to receive marketing from other group companies;
(b) selected third parties for the performance of our contractual obligations with you such as Drop Shipment suppliers;
(c) with Bestway's suppliers for their supply chain management purposes (for example, your business name, address and purchase history), but not for their own marketing purposes unless you have indicated that you wish to receive such marketing;
(d) sub-contractors we may use in technical, payment and delivery services, events and hospitality;
(e) where you have agreed to receive marketing emails from us, we need to pass your personal data on to our service providers who help us with these marketing activities;
(f) analytics and search engine providers that assist us with improvement and optimisation of our site who may anonymise the information and send on to third parties for statistical purposes;
(g) where you enter (or have been entered into) a prize draw, with any third parties who help to administer the prize draw as set out in the prize draw terms;
(h) credit reference agencies and other background check providers for Anti Money Laundering/ Sanctions purposes (see the section on 'Anti Money Laundering/ Sanctions' above for further information); and
(i) photographs of prize winners to generate legitimate business interest with Bestway customers and internally within Bestway.
7.2 Occasionally, we may also share personal data with relevant third parties:
(a) where you have given us your consent to do so;
(b) where we sell or buy any business or assets;
(c) if we are under a duty to disclose or share your personal data to comply with a legal obligation;
(d) for law enforcement purposes, including the prevention or detection of crime (for example, we may need to share CCTV footage of you with the police);
(f) where it is fair and reasonable for us to do so in the circumstances.
8.1 We may need to transfer your information outside the UK to service providers, agents, subcontractors and regulatory authorities in countries where data protection laws may not provide the same level of protection as those in the European Economic Area ("EEA"), such as the USA.
8.2 We will only transfer your personal data outside the EEA where either:
(a) the transfer is to a country which the EU Commission has decided ensures an adequate level of protection for your personal data; or
(b) we have put in place our own measures to ensure adequate security as required by data protection law. These measures include ensuring that your personal data is kept safe by carrying out strict security checks on our overseas partners and suppliers, backed by strong contractual undertakings approved by the relevant regulators such as the EU style model clauses. Some US providers may also be certified under the EU-US Privacy Shield which confirms they have appropriate measures in place to ensure the protection of your data.
8.3 If you would like further information, please contact email@example.com.
9.1 If you are a customer, we will send you our catalogues and communicate relevant news and information about products and services similar to those you have purchased or enquired about by post, email, telephone, SMS or other electronic messages, unless you tell us that you do not wish to receive them.
9.2 You can unsubscribe at any time by clicking the "unsubscribe" link in any marketing email which you receive, by emailing us at firstname.lastname@example.org, writing to us at Bestway Data Officer, Marketing Department, Bestway Wholesale, 2 Abbey Road, London NW10 7BW or, if you are registered to shop online you can manage your preferences on the manage my data tab or unsubscribe using any of the other methods above.
10.1 We will not retain your personal data for any longer than is necessary for our purposes, including for the purposes of satisfying any legal, accounting or reporting requirements. If you have any questions about data retention then please email email@example.com.
10.2 Where we have been using your personal data to provide you with marketing, we will remove you from our marketing list if you ask us to do so, but we may still need to keep your information for ongoing contractual purposes if you continue to be our customer and for legal, accounting and regulatory reporting reasons.
You can make a complaint to us by contacting us via firstname.lastname@example.org or to the data protection supervisory authority – in the UK, this is the Information Commissioner's Office, at https://ico.org.uk.