- Important information and who we are
|Full name of legal entity:||Sherpr Global Ltd|
|Email address:||[email protected]|
|Postal address:||Unit 5 Falconer Road, Haverhill, England CB9 7BG|
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator 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.
Children Under the Age of 16
Our website and our services are not intended for children under 16 years of age. No one under age 16 may provide any personal information to us. We do not knowingly collect personal information from children under age 16. If you are under 16, do not use or provide any information to us or use our services. If we learned we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information about a child under 16, please contact us.
- 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, marital status, title, date of birth and gender.
- 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 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 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 or services;
- create an account on our website;
- subscribe to our service or publications;
- request marketing to be sent to you;
- enter a competition, promotion or survey; or
- give us feedback or contact us.
- Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
- Technical Data from the following parties:
- analytics providers [such as Google based outside the UK];
- advertising networks; and
- search information providers.
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services;
- Identity and Contact Data from data brokers or aggregators; and
- Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the UK.
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.
We use the following cookies:
- Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
- Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
- Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
- Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests.
We use the following individual cookies for the following respective purposes:
- _ga Used to distinguish user
- _gid Used to distinguish user
- _gat Used to throttle request rate. If Google Analytics is deployed via Google Tag Manager, this cookie will be named _dc_gtm_<property-id>
- AMP_TOKEN Contains a token that can be used to retrieve a Client ID from AMP Client ID service. Other possible values indicate opt-out, inflight request or an error retrieving a Client ID from AMP Client ID service
- _gac_<property-id> Contains Campaign related information for the user. If you have linked your Google Analytics and AdWords accounts, AdWords website conversion tags will read this cookie unless you opt-out
- _utmt Used to throttle request rate
- _utmc Not used in ga.js. Set for interoperability with urchin.js. Historically, this cookie operated in conjunction with the __utmb cookie to determine whether the user was in a new session/visit
- _utmv Used to store visitor-level custom variable data. This cookie is created when a developer uses the _setCustomVar method with a visitor level custom variable. This cookie was also used for the deprecated _setVar method. The cookie is updated every time data is sent to Google Analytics
We do not share the information collected by the cookies with any third parties.
- 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; and
- 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. For the purposes of this section, the following definitions will apply:
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 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 obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
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 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)|
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 services from us and you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase, or service experience.
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 share your personal data with the parties set out below for the purposes set out in the table above.
External Third Parties
- Service providers acting as processors based in the EU, UAE, United States or elsewhere who provide IT and system administration services.
- Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK and UAE who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
- Our third-party suppliers acting as processors based in the EU, UAE, United States and elsewhere who provide us with courier/delivery services.
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.
- International transfers
Many of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.
Whenever we transfer your personal data out of the UK, 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 (such as countries within the European Economic Area).
- Where we use certain service providers, such as in the United States we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.
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 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.
In some circumstances you can ask us to delete your data, and sometimes 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.
- 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
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.
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.