Privacy Policy

REFLECTION X PRIVACY POLICY

1. Introduction.

This is the Privacy Notice of Reflection X Ltd (company number 09036648) whose registered office is at 21 Church Road, Poole, BH14 8UF and Reflection X Ltd of 398-2416 Main St, Vancouver BC V5T 3E2, with registered business number: 70869 2090 BC 0002 (both ‘Reflection X Ltd’, “Company”, “we”, “our” or “us”) and sets out how we collect and process your personal data.

This Privacy Notice also provides certain information that is legally required and lists your rights in relation to your personal data.

This Privacy Notice relates to personal information that identifies ‘you’ meaning customers or potential customers/individuals/suppliers who use or browse our website and individuals outside our organisation with whom Reflection X Ltd interact.

We refer to this information throughout this Privacy Notice as “personal data” and paragraph 3 sets out further detail of what this includes. Please read this Privacy Notice to understand how Reflection X Ltd may use your personal data.

If you are an employee, contractor or otherwise engaged in work for us or applying to work for us, a separate privacy notice applies to you instead. This Privacy Notice is not intended for children and we do not knowingly collect personal data relating to children.

This Privacy Notice may vary from time to time so please check it regularly.

2. Contact Details.

2.1 Data controller and contact details

For the purposes of relevant data protection legislation, we are a controller of your personal data and as a controller we use the personal data we hold about you in accordance with this Privacy Notice.

If you wish to correct your personal data held by us or to opt out at any time from receiving marketing correspondence from us or to alter your marketing preferences please contact [email protected].

If you need to contact us in connection with our use or processing of your personal data, or gain access to it, then our contact details are [email protected] | Reflection X Ltd, 21 Church Road, Poole, BH14 8UF and our representative is James Roadnight.

2.2 Data Protection Officer

Our Data Protection Officers are James Roadnight and Richard Orme and you can contact them at [email protected].

3. Categories of Personal Data and What We Collect.

3.1 The categories of personal data about you that we may collect, use, store, share and transfer are:

Advertising Data. This includes personal data which relates to your advertising preferences, such as information about your preferences in receiving marketing materials from us and our third parties and your communication preferences as well as your personal interests;
Individual Data. This includes personal data which relates to your identity, such as your first name, middle name, last name, username or similar identifier, job title and your contact details such as your billing address, delivery address, email address and telephone numbers;
Sales Data. This includes personal data which relates to the transactions you have conducted with us, such as details about payments to and from you, details of subscriptions to our services or publications and other details of products and services you have purchased from us;
Information Technology Data. This includes personal data which relates to your use of our website, such as your internet protocol (IP) address, login data, traffic data, weblogs and other communication 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 our website;
Economic and Financial Data. This includes personal data which relates to your finances, such as your bank account and payment card details and information which we collect from you for the purposes of the prevention of fraud;
Market Research Data. This includes personal data which is gathered for the purposes of market research;
Audio and Visual Data. This includes personal data which is gathered using our CCTV or other recording systems in the form of images, video footage and sound recordings that is taken at any of our locations or otherwise by us for promotional purposes;
Health Data. This includes personal data which is gathered for health and safety purposes including any accident report or claim.

We may also create Personal Data about you, for example, if you contact us by telephone to make a complaint, for example about our services or goods, then we may make a written record of key details of the conversation so that we can take steps to address the complaint.

3.2 We also obtain and use certain aggregated data such as statistical or demographic data for any purpose (‘Aggregated Data’). Aggregated Data may be derived from your personal data but does not directly or indirectly reveal your identity. For example, we may aggregate your Information Technology Data to calculate the percentage of users accessing a specific feature on our website. However, if we re-combine or re-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 Notice.

3.3 In addition, we may obtain certain special categories of your data (‘Special Categories of Data’), and this Privacy Notice specifically sets out how we may process these types of personal data. The Special Categories of Data are: (i) personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership; and (ii) the processing of genetic data, biometric data for the purposes of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.

4. The Sources From Which We Obtain Your Personal Data.

4.1 We obtain your personal data from the following sources:

4.1.1 Directly from you, either in person (at our locations or otherwise), via our website, apps or by telephone or via hand held PDAs. This could include personal data which you provide when you:

(a) download a piece of content;

(b) register for an event;

(d) request information on our products or services;

(e) create an account on our website;

(f) place an order for our products or services;

(g) enter into a competition or promotion; and

(h) complete a survey from us or give us feedback

4.1.2 Automated technologies, such as CCTV or other recording systems, cookies, server logs and other similar technologies. We may automatically collect Information Technology Data about your equipment, browsing actions and patterns by using cookies, server logs and other similar technologies. We may also receive Information Technology Data about you if you visit other websites or apps employing our cookies.

4.1.3 Third parties, such as:

(a) analytics providers (such as Google Analytics);

(b) advertising networks (such as Facebook, Linkedin, Google Adwords);

(d) providers of social media platforms (such as Facebook, Twitter, LinkedIn, Google+ and Instagram) for example where you share our content through social media, for example by liking us on Facebook, following or tweeting about us on Twitter

4.1.4 Publicly available sources, such as:

(a) Companies House; and

(b) HM Land Registry;

5. How We Use Your Personal Data and Our Basis For Using It.

5.1 Where we are relying on a basis other than consent we may rely on one or more of the following legal bases when processing your personal data. We have set out below the purposes for which we may process your personal data:

Purposes for which we process your personal data

Categories of personal data

The basis on which we can do this (this is what the law allows)

To register you as a new customer and process your order.

· Individual Data;

· Economic and Financial Data;

· Account and Profile Data.

The processing is necessary

· To Perform a contract with you; and

· For our legitimate interest in the provision of goods and services to our customers.

In order to perform our contractual obligations to you. This would include:

· processing and performing any bookings and order placed by you;

· orders placed by us where you are a supplier;

· making or receiving payments, fees and charges; and

· collecting and recovering money owed.

· Individual Data;

· Economic and Financial Data;

· Account and Profile Data.

· Sales Data.

The processing is necessary

· To perform any contract entered into with you; and

· Our legitimate interest in recovering debts owed to us.

In order to comply with our own legal obligations, e.g. health and safety legislation, or to assist in an investigation (e.g. from the police).

· Individual Data;

· Audio and Visual Data;

· Health Data.

The processing is necessary

· for us to comply with the law; and

· in order to protect the vital interests of an individual.

In order to use your personal data in life or death situations and there is no time to gain your consent (e.g. in the event of an accident or illness or injury or some other related emergency or to record any accident or injury or other incident you may suffer when visiting any of our locations or we have to give your personal details to medical personnel).

· Individual Data;

· Health Data.

The processing is necessary

· for us to comply with the law; and

· in order to protect the vital interests of an individual; and

· defence and legal proceedings

In order to manage our relationship with you including:

· to send you important notices such as communications about changes to our terms and conditions and policies (including this Privacy Notice);

· to provide you with important real-time information about products or services you have ordered from us (e.g. a change of time or location due to unforeseen circumstances); and

· to send you information you have requested;

· to deal with your enquiries; and

· to ask you to leave a review or feedback on us

· to use our third party processors to help us to administer and carry out the contract and our relationship with you.

· Individual Data;

· Account and Profile Data;

· Sales Data;

· Advertising and Marketing Data.

5.1.1 The processing is necessary:

· to perform any contract entered into with you;

· to comply with the law; and

· for our legitimate interests in the management and operation of our business, to keep our records updated and to study how customers use our products/services.

In order to administer and protect our business, deal with any misuse of our website and to comply with our security policies at our locations.

· Individual Data;

· Account and Profile Data;

· Audio and Visual Data;

· Information and Technology Data.

· Economic Data

The processing is necessary:

· for our legitimate interest in provision of administration of our business and IT services, network security, to prevent fraud and; and

· necessary to comply with the law.

In order to make suggestions and recommendations to you about goods or services that may be of interest to you, deliver relevant website and app content and advertisements to you and to measure or understand the effectiveness of our advertising.

· Individual Data;

· Sales Data;

· Information and Technology Data;

· Advertising and Marketing Data.

· The processing is necessary for our legitimate interests to study how guests use our products/services, to develop our products and services and ensure our marketing is relevant to you, to grow our business and to inform our marketing strategy; or

· We have obtained your consent where relevant

For internal purposes to use data analytics, to identify usage trends, determine and measure the effectiveness of promotional campaigns and advertising and to improve our website, products/services, marketing, customer relationships and experiences.

· Individual Data;

· Information and Technology Data;

· Advertising and Marketing Data;

· Market Research Data

The processing is necessary for our legitimate interests in defining 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 communicate with you about, and administer your participation in, special events, programs, promotions, any prize draws or competitions.

· Individual Data;

· Account and Profile Data;

· Sales Data;

· Information and Technology Data;

· Advertising and Marketing Data.

The processing is necessary:

· For performance of a contract with you; and

· for our legitimate interests to promote our business

To sell, make ready for sale or dispose of our business, in whole or in part including to any potential buyer or their advisers, or in relation to any refinancing.

· Individual Data;

· Account and Profile Data;

· Sales Data;

· Information and Technology Data;

· Advertising and Marketing Data;

· Economic and Financial Data;

The processing is necessary for our legitimate interests in the sale or disposal of our business or assets and in the context of a business reorganisation or group restructuring exercise

In order to enforce or apply our terms of use, terms and conditions of supply and other agreements with third parties.

· Individual Data;

· Account and Profile Data;

· Sales Data; and

· Economic and Financial Data.

The processing is necessary for our legitimate interests in protecting our business and property and recovering debts owed to us.

5.2 Where we may rely on consent

5.2.1 We would like to use your personal data for a variety of different purposes. For certain of these purposes it is appropriate for us to obtain your prior consent. The legal basis of consent is only used by us in relation to processing that is entirely voluntary – it is not used for processing that is necessary or obligatory in any way. Where we rely on consent, you may at any time withdraw the specific consent you give to our processing your personal data by following the opt-out links on any marketing message sent to you or by contacting us at any time. Please contact us using the contact details set out in paragraph 2.

5.2.2 Please note even if you withdraw consent for us to use your personal data for a particular purpose we may continue to rely on other bases to process your personal data for other purposes.

6. Who Receives Your Personal Data?

We may disclose your personal data to:

our group companies and affiliates or third-party data processors who may process data on our behalf to enable us to carry out our usual business practices. Any such disclosure will only be so that we can process your personal data for the purposes set out in this Privacy Notice;
our data sub-processor, Microsoft;
our PR agency, and customer feedback providers;
our market research agency;
HMRC, legal and other regulators or authorities, including those who request your personal data or to report any potential or actual breach of applicable law or regulation;
external professional advisers such as accountants, bankers, insurers, auditors and lawyers;
law enforcement agencies, courts or other relevant party, to the extent necessary for the establishment, exercise or defence of legal rights;
third parties where necessary for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties;
third parties which are considering or have decided to acquire some or all of our assets or shares, merge with us or to whom we may transfer our business (including in the event of a reorganisation, dissolution or liquidation);
third parties operating plugins or content (such as Facebook, Twitter and Instagram) on our website or app which you choose to interact with;
suppliers and subcontractors for the performance of any contract we enter into with them or you.

7. Personal Data About Other People Which You Provide to Us.

7.1 If you provide personal data to us about someone else (such as one of your directors or employees, or someone with whom you have business dealings) you must ensure that you are entitled to disclose that personal data to us and that, without our taking any further steps, we may collect, use and disclose that personal data as described in this Privacy Notice.

7.2 You must ensure the individual concerned is aware of the various matters detailed in this Privacy Notice, as those matters relate to that individual, including our identity, how to contact us, the way in which we collect and use personal data and our personal data disclosure practices, that individual's right to obtain access to the personal data and make complaints about the handling of the personal data, and the consequences if the personal data is not provided.

8. Accuracy of Your Personal Information.

It is important that the personal data we hold about you is accurate and current and we take all reasonable precautions to ensure that this is the case but we do not undertake to check or verify the accuracy of personal data provided by you. Please keep us informed if your personal data changes during your relationship with us either by logging onto your account on the website or by contacting us. We will not be responsible for any losses arising from any inaccurate, inauthentic, deficient or incomplete personal data that you provide to us.

9. International Transfers of Personal Data.

9.1 It is possible that personal data we collect from you may be transferred, stored and/or processed outside the European Economic Area, specifically in the United States or America and Argentina or by Reflection X Ltd.

In connection with such transfers we shall ensure the following safeguards or reasons applies:

9.1.1 the relevant safeguard in place is the standard data protection contractual clauses between us and the recipient and a copy can be obtained by contacting us using the contact details set out in paragraph 2; or

9.1.2 is made on the basis of an adequacy decision, including that:

(a) the Privacy Shield for transfers to the US;

(b) the European Commission has decided that the relevant non-EU country ensures an adequate level of protection; or

9.1.3 one of the derogations for specific situations in Article 49 GDPR applies to the transfer including for example explicit consent or necessary for the contract.

10. How Long Do We Store Your Personal Data For?

We will store your personal data the time period which is appropriate for the purpose for which the personal data is used. We keep the length of time that we hold your personal data for under review. These reviews take place annually.

11. Contractual or Statutory Requirements on You to Provide Personal Data.

11.1 In certain circumstances the provision of personal data by you is a requirement to comply with the law or a contract, or necessary to enter into a contract.

11.2 It is your choice as to whether you provide us with your personal data necessary to enter into a contract or as part of a contractual requirement. If you do not provide your personal data then the consequences of failing to provide your personal data is that we may not be able to perform to the level you expect under any contract with you. An example of this would be where we are unable to provide you with essential information around the service we offer you or confirmation of event registration as we do not have your full details, or where we cannot perform our contract with you at all because we rely on the personal data you provide in order to do so. Please see our terms and conditions for further details.

12. Your Rights in Relation to Your Personal Data.

Subject to applicable law including relevant data protection laws, in addition to your ability to withdraw any consent you have given to our processing your personal data (see paragraph 5.2), you may have a number of rights in connection with the processing of your personal data, including:

the right to request access to your personal data that we process or control;
the right to request rectification of any inaccuracies in your personal data or, taking into account the purposes of our processing, to request that incomplete data is completed;
the right to request, on legitimate grounds as specified in law:
erasure of your personal data that we process or control; or
restriction of processing of your personal data that we process or control;
- the right to object, on legitimate grounds as specified in law, to the processing of your personal data;
- the right to receive your personal data in a structured, commonly used and machine-readable format and to have your personal data transferred to another controller, to the extent applicable in law; and
- the right to lodge complaints regarding the processing of your personal data with the Information Commissioner’s Office or other relevant supervisory body. Please see https://ico.org.uk/concerns/ for how to do this.

If you would like to exercise any of the rights set out above, please contact us using the contact details set out in paragraph 2.

13. Links to Other Websites.

This policy only applies to Reflection X Ltd. If you link to another website from our website, you should remember to read and understand that website’s privacy policy as well. We do not control unconnected third-party websites and are not responsible for any use of your personal data that is made by unconnected third-party websites.

Revision 5.2

15th March 2021