We take your privacy very seriously. Please read this privacy notice carefully as it contains important information on who we are and how and why we collect, store, use and share your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint.
We collect, use and are responsible for certain personal information about you. When we do so we are subject to the General Data Protection Regulation, which applies across the European Union (including in the United Kingdom) and we are responsible as ‘controller’ of that personal information for the purposes of those laws.
It would be helpful to start by explaining some key terms used in this notice:
|We, us, our||Cicli Pinarello (UK) Ltd|
|Our data protection administrator||Margaret Herety
274 Deansgate, Manchester M3 4JB
|Personal information||Any information relating to an identified or identifiable individual|
Personal information we collect about you
We may collect and use the following personal information about you:
- your name and contact information, including email address and telephone number and, where you’ve applied under the cycle to work scheme, details of the company you work for;
- your gender information (for clothing, accessories and bike details);
- address for delivery of products;
- your billing information, transaction and payment card information;
- your purchase history;
- information about how you use our website, IT, communication and other systems;
- your responses to surveys, competitions and promotions;
- details of your attendance at any of our promotional events or rides;
- CCTV footage if you visit one of our stores;
- CV’s if applying for a position;
- Any other information that may identify you that you have voluntarily provided to us.
This personal information is required to provide products and/or services to you. If you do not provide personal information we ask for, it may delay or prevent us from providing products and/or services to you
How your personal information is collected
We collect most of this personal information directly from you—in person, by telephone, or email and/or via our website. However, we may also collect information:
- your employer for the cycle to work scheme
- CCTV images when you visit our stores
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 the performance of our contract with you or to take steps at your request before entering into a contract with you;
- for our legitimate interests or those of a third party; or
- where you have given consent.
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
The table below explains what we use (process) your personal information for and our reasons for doing so:
|What we use your personal information for||Reasons and our lawful grounds|
|Where it is necessary to comply with professional, legal and regulatory obligations that apply to our business, such as tax or health and safety regulations.||We will only use your personal data to the extent that we are bound to do so by law or regulations in order that we can comply with that obligation. (legal obligation)|
|Statistical analysis to help manage our business||We have a legitimate interest in understanding statistics behind purchases of products in order to be able to provide you with products and services that best suit your needs. (legitimate interest)|
|Preventing unauthorised access and modifications to systems/websites||We have a legitimate interest in protecting our systems and our website from unauthorised access modification or other malicious activity. (legitimate interest)|
|Updating and enhancing customer records||We are required to ensure we take reasonable steps to keep your personal data up to date. (legal obligation). We ensure we can match you with products and services that you would be most interest in or best suit your needs (legitimate interest)|
|Fulfilling Orders for products or services or respond to enquiries prior to a purchase||For us to fulfil any purchases you’ve made from us or facilitate any future purchases. (necessary for contract)|
|Cycle to works scheme||To facilitate any purchases made under the cycle to work scheme (legitimate interest/necessary for contract)|
|Responding to enquiries and test rides||For us to properly respond to any other enquiries with regards our products and services or to allow you to test ride one of our bikes. (legitimate interest/necessary for contract)|
|Facilitate promotional events and rides||To let you know about exclusive Pinarello events or organised rides that are likely to be of interest to you where there is or has been some relationship or contact between us. To administrate, organise and facilitate those rides (legitimate interest)|
|Marketing our products and services to existing and former customers or potential customers who have previously expressed an interest in our products or services||To provide you with details of any of our products that are relevant to you and any promotional offers. (legitimate interests).|
|CCTV footage at our stores||We operate CCTV at our stores for the detection and prevention of crime and for the health and safety of visitors to our stores. We normally only keep CCTV footage for 30 days. For further information a copy of our CCTV policy is available upon request using our contact details below. (legitimate interest)|
|Audits of our Business||For business management and planning, including accounting and auditing, conducting performance reviews, managing performance and determining performance requirements. (legitimate interest)|
|Recruitment||In order to consider you for roles within our company we will need to discuss your application and personal information with relevant employees. Only employees involved within the recruitment process will have access to your information and will keep it secure. If you are not selected for an interview, your personal information will be deleted from our systems within 6 weeks.|
|Business contacts||In order to facilitate any business to business relationships to suppliers or other businesses we will need process personal details of persons within those businesses such as names, email addresses and job titles (legitimate interest)|
We may use your personal information to send you updates by email, post or social media communications about our products and/or services, including exclusive offers, promotions, new products and services, promotional events and organised rides.
We have a legitimate interest in processing your personal information for promotional purposes (see above ‘How and why we use your personal information’). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.
We will always treat your personal information with the utmost respect and never sell it to other organisations outside the Cicli Pinarello group for marketing purposes.
We may share your personal information for marketing purposes with third parties but only where we have engaged such third parties to market on our behalf and only our products. They will only act upon our strict instructions and we will only allow them to handle your personal information if we are satisfied they take appropriate measures to protect your personal information.
You have the right to opt out of receiving promotional communications at any time by:
- contacting us at firstname.lastname@example.org
- using the ‘unsubscribe’ link in emails
Who we share your personal information with
We routinely share personal information with:
- companies within the Pinarello group;
- third parties we use to help deliver our products, services, events or rides to you, for example, payment service providers, delivery companies, event or ride organisers/suppliers;
- providers of cycle to work scheme;
- other third parties we use to help us run our business, for example, marketing agencies, website hosts or administrative functions;
- our insurers and brokers (if applicable);
- our bank, (if applicable);
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 relating to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors, accreditation and the audit of our accounts.
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, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
Where your personal information is held
Information may be held at our offices and stores and those of our group companies, third party agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal information with’).
Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below: ‘Transferring your personal information out of the EEA’.
How long your personal information will be kept
We will keep your personal information while we are providing products and services to you. Thereafter, we will keep your personal information for as long as is necessary:
- to respond to any questions, complaints or claims made by you or on your behalf;
- to show that we treated you fairly;
- to keep records required by law.
We will not retain your personal information for longer than necessary for the purposes set out in this notice. Different retention periods apply for different types of personal information. Further details on this are available in our retention schedule which is available upon request by contacting us using our details below.
When it is no longer necessary to retain your personal information, we will delete or anonymise it.
Transferring your personal information out of the EEA
To deliver services to you, it is sometimes necessary for us to share your personal information outside the European Economic Area (EEA):
These transfers are subject to special rules under European and UK data protection law. We currently use a marketing platform based in the US, this may involve transfer of your email address to their servers based outside of the EEA. The US has different laws surrounding data protection than we do in this country, these laws may not offer the same level of protection as our laws. We therefore only use a marketing platform that has signed up to the Privacy Shield framework offering you the same level of protection as you can expect from us. Further details of this framework can be found at www.privacyshield.gov. If we use any provider who has not signed up to the Privacy Shield framework, we will ensure the transfer of any personal information complies with data protection law and all personal information will be secure. We will do this by using standard data protection contract clauses that have been approved by the European Commission. For further information on whether we have in place any of these clauses and to obtain a copy if we have please contact us using our contact details below.
You have the following rights, which you can exercise free of charge:
|Access||The right to be provided with a copy of your personal information (the right of access)|
|Rectification||The right to require us to correct any mistakes in your personal information|
|To be forgotten||The right to require us to delete your personal information—in certain situations|
|Restriction of processing||The right to require us to restrict processing of your personal information—in certain circumstances, for example if you contest the accuracy of the data|
|Data portability||The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations|
|To object||The right to object:
—at any time to your personal information being processed for direct marketing (including profiling);
—in certain other situations to our continued processing of your personal information, for example processing carried out for the purpose of our legitimate interests.
|Not to be subject to automated individual decision making||The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you|
If you would like to exercise any of those rights, please:
- email, call or write to us using our details below;
- complete the form we will then provide to you;
- let us have enough information to identify you (for example your full name, address and any customer or matter reference number);
- let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
- let us know what right you want to exercise and the information to which your request relates.
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is manifestly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
Keeping your personal information secure
We have appropriate security measures to prevent personal information from being accidentally lost or used or accessed unlawfully. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
How to complain
We hope that can resolve any query or concern you may raise about our use of your information.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns or telephone: 0303 123 1113.
Changes to this privacy notice
We may change this privacy notice from time to time and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.
How to contact us
Please contact us by post, email or telephone if you have any questions about this privacy notice or the information we hold about you.
Our contact details are shown below:
|Data Protection Administrator:||Margaret Herety|
|Postal Address:||Cicli Pinarello (UK) Ltd, 274 Deansgate, Manchester, M3 4JB|
|Telephone:||0161 870 8195|