BACKGROUND:

UK WHISTL LTD. understands that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who visits this website, www.whistl.co.uk (“Our Site”) and (subject to the limited exceptions in section 6, below) We do not collect personal data about you unless you contact us (see section 5, below). Any personal data we do collect will only be used as permitted by law.

Please read this Privacy Policy carefully and ensure that you understand it.    By using this site you are accepting the practices described in this policy.

  1. Definitions and Interpretation

In this Policy, the following terms shall have the following meanings:

“Customer”   a customer (sometimes known as a client, buyer, or purchaser) is the recipient of a good, service, product or an idea

“personal data”       means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site. This definition shall, where applicable, incorporate the definitions provided in the EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”); and

“We/Us/Our”    means WHISTL UK LTD. , a limited company registered in England under company number 04417047, whose registered address is Meridian House, Fieldhouse Lane, Marlow, Buckinghamshire, England, SL7 1TB.

2. Information About Us

2.1         Our Site is owned and operated by WHISTL UK LTD. a limited company registered in England under company number 04417047, whose registered address is Meridian House, Fieldhouse Lane, Marlow, Buckinghamshire, England, SL7 1TB.

2.2         Our VAT number is GB991 2657 87

2.3         For any enquiries please contact Stephen A Betts at steve.betts@whistl.co.uk, by telephone on 01628  891644, or by post at Meridian House, Fieldhouse Lane, Marlow, Buckinghamshire, England, SL7 1TB.

2.4         We are regulated by OFCOM

2.5         We are a member of the DMA, IPM, Print Power, ELMA, RHA and MCF

2.6        ICO Registration number is: Z692857X

3. What Does This Policy Cover?

This Privacy Policy applies only to your use of Our Site. Our Site may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.

Please refer to our Compliance Statement for additional information about our approach to Data Protection: https://www.whistl.co.uk/news/whistl-gdpr-compliance-statement/ 

4. Your Rights

As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:

4.1  Right to be informed – When we collect your data we have to tell you what we are going to do with it primarily through this Privacy Policy and consent statement.

4.2  Right of access – You have the right to contact us in writing to request details of the information we hold about you.

4.3  Right of rectification – You have the right to ask us to rectify information that we hold about you if this is inaccurate or incomplete.

4.4  Right to erasure- This is also known as the right to be forgotten and gives you the right to request your information to be removed if there is no compelling reason for its continued processing. A word of warning though, we keep a list of people who have asked not to be contacted which is used to ensure that you receive no further marketing information from the Lifecycle Group or client from the result of our activity. Without this list your data could enter our system again from another source and we would have no record of the fact that you asked us not to contact you.

4.5  Right to restrict processing – this is the alternative to erasure and gives you the right to tell us to stop processing your data but allowing us to keep enough information about you to ensure that you’re wishes are respected in the future.

4.6  Right to data portability – this gives you the right to ask the holder of your information to transfer that information to another business. This right would be most commonly used if you were switching banks, insurance companies, utility companies or mobile phone companies.

4.7  Right to object – you have the right to object to the processing of your data for marketing purposes and profiling for marketing purposes. Your rights and freedoms override our interests.

4.8  Rights related to automated decision making including profiling – we do not use automated decision making processes which would have a potentially damaging effect on the information we hold about you. But if we did you have the right to obtain human intervention, express your point of view and obtain an explanation of the decision and challenge it.

4.9   Rights to withdrawn consent at any time where relevant – you have the right to withdraw your consent to the processing of your information at any time and we must provide you with the information to need to do so at the time we collect your data and each time we contact you.

4.10 If you have any cause for complaint about our use of your personal data, please contact us using the details provided in section 9 and we will do Our best to solve the problem for you. If we are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.

4.11 For further information about your rights please contact the Information Commissioner Office or your local Citizens Advice Bureau

5. What Data Do We Collect?

5.1         Subject to section 5.2, we do not collect any personal data from you. We do not place cookies on your computer or device, nor do we use any other means of data collection.

5.2         If you send us an email, we may collect your name, your email address, and any other information which you choose to give Us.

6. How Do We Use Your Data?

6.1         If we do collect any personal data, it will be processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with our obligations and safeguard your rights underGDPR at all times.

6.2         As noted above, we do not generally collect any personal data. If you contact Us and We obtain your personal details from your email or we retain your address in order to deliver your mail , We may use them as follows:

6.2.1      To reply to your email

6.2.2      To do address verification

6.3         You have the right to withdraw your consent to us using your personal data at any time, and to request that we delete it.

6.4         We may share your data with selected associated partners in order to provide the service required. We  will ensure your data is only provided to third parties with appropriate and commensurate controls in place

7. How and Where Do We Store Your Data?

7.1         We only keep your personal data for as long as we need to in order to use it as described above in section 6, Some or all of your data may be stored outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). If We do store data outside the EEA (this may be the case, for example, if Our email server is located in a country outside the EEA), We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the Data Protection Act 1998or GDPR.

7.2         Data security is very important to us, and to protect your data We have taken suitable measures to safeguard and secure any data We hold about you.

7.3         Whistl secures your personal information from unauthorised access, use or disclosure. Whistl secures the personally identifiable information you provide on computer servers in a controlled, secure environment, protected from unauthorised access, use or disclosure. When personal information (such as a credit card number) is transmitted to other Web sites, it is protected through the use of encryption, such as the Secure Socket Layer (SSL) protocol.

8. Data Sharing

relation to the provision of delivery services:

Party

Personal Data

Activity

Purpose

Carriers and national postal service providers

Name, address, email address and telephone number

Receive personal data on the item label

The purpose of all activities is to deliver the item to the recipient

 

 

8.1       How Whistl treats Personal Data

8.2   Whistl will comply with all applicable requirements of Data Protection.

8.3   Although the overall purpose of the data processing described above is agreed with the Customer (to deliver relevant items provided by the Customer to the addressees of each item), Whistl retains control over the manner in which it processes the relevant personal data in order to fulfil the purpose concerned.  Accordingly, Whistl will in general be acting as a data controller when processing personal data as set out above, in line with the relevant guidance from the Information Commissioner in the UK.

8.4  The Customer confirms that any personal data provided to Whistl by the Customer or on its behalf has been collected and disclosed in accordance with the Data Protection Legislation. When using Whistl’s services, the Customer will take reasonable steps to ensure that no irrelevant or unnecessary information about individuals is provided to Whistl for or on behalf of the Customer.

8.5   If, and to the extent that, Whistl becomes a data processor of any personal data on behalf of the Customer in connection with the performance by Whistl of its services (in circumstances in which the Customer controls both the purpose and the manner of the processing and the processing is carried out by Whistl solely on behalf of the Customer, it will:

8.5.1 process the personal data only on the written instructions of the Customer unless Whistl is required to process it for other purposes by any laws of the European Union.

8.5.2 maintain appropriate physical, technical and organisational measures, to protect against unauthorised or unlawful processing of personal data and against accidental loss or destruction of, or damage to, personal data, appropriate to the harm that might result from the unauthorised or unlawful processing or accidental loss, destruction or damage and the nature of the data to be protected, having regard to the state of technological development and the cost of implementing any measures;

8.5.3 ensure that all personnel who have access to and/or process personal data are obliged to keep the personal data confidential;

8.5.4 transfer personal data outside of the European Economic Area only where:

8.5.4.1          appropriate safeguards in relation to the transfer are in place;

8.5.4.2          the data subject has enforceable rights and effective legal remedies;

8.5.4.3         Whistl complies with its obligations under the Data Protection Legislation by providing an adequate level of protection to any personal data that is transferred; and

8.5.4.4         Whistl complies with reasonable instructions notified to it in advance by the Customer with respect to the processing of the personal data;

8.5.5 assist the Customer, at the Customer's cost, in responding to any request from a data subject and in ensuring compliance with its obligations under the Data Protection Legislation with respect to security, breach notifications, impact assessments and consultations with supervisory authorities or regulators; 

8.5.6 at the written direction of the Customer, delete or return personal data and any copies to the Customer on termination of the agreement unless required by any applicable laws to store the personal data;

8.5.7 maintain complete and accurate records and information to demonstrate its compliance with the Data Protection Legislation;

 

9.         How Can You Access Your Data?

You have the right to ask for a copy of any of your personal data held by us (where such data is held under GDPR, no fee is payable and we will provide any and all information in response to your request free of charge.] Please contact us for more details at steve.betts@whistl.co.uk, or using the contact details below in section 9.

10.       Contacting Us

If you have any questions about Our Site or this Privacy Policy, please contact Us by email at steve.betts@whistl.co.uk, by telephone on 01628 891644, or by post at Meridian House, Fieldhouse Lane, Marlow, Buckinghamshire, England, SL7 1TB. Please ensure that your query is clear, particularly if it is a request for information about the data we hold about you (as under section 8, above).

11.       Changes to Our Privacy Policy

We may change this Privacy Policy from time to time (for example, if the law changes). Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date.

Implementation of Policy

This Policy shall be deemed effective as of 25th may 2018. No part of this Policy shall have retroactive effect and shall thus apply only to matters occurring on or after this date.

This Policy has been approved and authorised by:

Name:

Stephen A Betts

Position:

Director Security and nominated Data Protection Manager

Date:

25th May 2018

Due for Review by:

25th May 2019