Politique de Confidentialité
PRIVACY POLICY
Effective Date: 01/08/2022
1. INTRODUCTION AND IMPORTANT INFORMATION
McAdam Lloyd, Inc. (“We”, “Our” or “Us”) are committed to protecting and respecting your personal data and privacy.
This privacy policy describes how we use and collect personal data from you when you visit or make a purchase from our website at www.bloccsusa.com (the Website). This Privacy Policy applies only to our Website and to the goods, services and information provided through our Website. It does not apply to any third-party site accessible through any link from our Website or to any third-party site recommended or referenced by our Website.
Please note that:
- the goods, services and information provided through our Website are not intended for individuals under the age of majority and we do not knowingly collect personal information relating to such individuals;
- our Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share personal information about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Website, we encourage you to read the privacy policy of every website you visit.
This privacy policy also forms part of our terms of business and is not intended to override them. We may update this privacy policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons. We may change this privacy policy at any time by posting a new version on this page or a successor page. The new version will become effective on the date it is first posted to the Website which will be identified as the new Effective Date of our privacy policy. By your continued use of the Website, you acknowledge and agree that this form of notice is reasonable and sufficient notice of all changes to the privacy policy.
2.1 For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e-mail at privacy@bloccs.com.
3. THE DATA WE COLLECT ABOUT YOU
3.1 We collect and process personal data. Typically, the personal data we collect and process will include identity, contract, transactional, technical, profile, usage and marketing and communications data such as:
3.1.1 Identity Data includes first name, last name, title or other identifier (such as job title), marital status, date of birth, gender and images.
3.1.2 Contact Data includes billing address, email addresses and telephone numbers.
3.1.3 Transaction Data includes details about services you have purchased from us or your visits to our premises.
3.1.4 Financial Data includes bank account and payment card details.
3.1.5 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.
3.1.6 Profile Data includes your username and password, purchases or orders made by you, your interests, preferences (including details about your personal likes and dislikes as identified during your visits to our premises), feedback and survey responses.
3.1.7 Usage Data includes information about how you use our website, products and services.
3.1.8 Marketing and Communications data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
Please note that we may collect and/or process other personal data from time to time.
3.2 We also collect, use and share aggregated data, such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered to be personal data in law as it will not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate a percentage of users accessing a specific feature of our services. However, if we combine or connect your 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 solely in accordance with this policy.
3.3 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.
3.4 We only collect data from you directly or via third parties (see the section Third Parties below).
4. HOW IS YOUR PERSONAL DATA COLLECTED?
4.1 We use different methods to collect data from and about you including through:
4.1.1 Direct interactions. You may give us your Identity, Contact, Profile and Financial Data by filling in forms or by corresponding with us by post, phone, messaging service, email or otherwise. This includes personal data you provide when you:
(a) apply for our services;
(b) create an account on our Website;
(c) subscribe to our service;
(d) request marketing to be sent to you;
(e) enter a promotion or survey;
(f) give us feedback or contact us;
(g) network or connect with us for business development.
4.1.2 Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy for further details.
4.1.3 Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
(a) Technical Data from the following parties:- analytics providers;
- advertising networks; and
- search information providers.
(b) Contact, Financial and Transaction Data from providers of technical, or payment services.
5. 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 our services). In this case, we may have to cancel all or part of a service you have with us but we will notify you if this is the case at the time.
6. HOW YOUR DATA WILL BE USED
6.1 We use information held about you to:
6.1.1 carry out our obligations arising from any contracts entered into between you and us and provide our services, including any third party services we make available to you;
6.1.2 carry out feedback and research on our services;
6.1.3 ensure that content from our site is presented in the most effective manner for you and for your devices;
6.1.4 provide you with information, products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes or by Legitimate Interests;
6.1.5 allow you to participate in interactive features of our service when you choose to do so, e.g. asking a question through our website;
6.1.6 carry out necessary maintenance to our infrastructure; and
6.1.7 notify you about changes to our services.
6.2 We also embrace the use of social media and may wish to process any comments made public by you.
6.3 We never sell your data to third parties or allow third parties to contact you without your permission.
6.4 We share your data with third parties where there is a legal obligation for us to do so or we have identified a valid lawful basis as set out in the table below (please also see clause 7 below). We may process your personal data without your knowledge or consent where this is required or permitted by law.
6.5 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. 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 user or customer. |
Identity Contact |
Performance of a contract with you. |
|
To provide our services to you and to process related transactions, including: Manage payments, fees and charges; or Collect and recover money owed to us. |
Identity Contact Transaction Usage Marketing and Communications |
Performance of a contract with you. Necessary for our legitimate interests (to recover debts due to us). |
|
To manage our relationship with you which will include: Notifying you about changes to our terms or privacy policy; or Asking you to leave a review or take a survey. |
Identity Contact Profile Marketing and Communications |
Performance of a contract with you. Necessary to comply with a legal obligation. Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services). |
|
To enable you to partake in a competition or complete a survey. |
Identity Contact Profile Usage Marketing and Communications |
Performance of a contract with you. 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 our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data). |
Identity Contact Technical |
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). Necessary to comply with a legal obligation. |
|
To measure or understand the effectiveness of the advertising we serve to you. |
Identity Contact Profile Usage Marketing and Communications 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. |
Technical Usage Profile |
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. |
Identity Contact Technical Usage Profile Marketing and Communications |
Necessary for our legitimate interests (to develop our products/services and grow our business).
|
7. LAWFUL BASIS FOR PROCESSING
7.1 We only process your data (which may include providing it to a third party) where we have identified a valid lawful basis to do so. These are as follows:
7.1.1 Contractual obligation – means processing that is necessary to comply with our obligations arising out of a contract, for example, where you have bought services from us we will use the personal data you provide to fulfil our contractual obligations .
7.1.2 Legitimate Interest - means in 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 you personal data for our legitimate interests. Where we use legitimate interests we will record our decision on making this decision. We rely on legitimate interest where processing of the data we hold on you does not, in our opinion, affect your rights or freedoms and is proportionate to our interests e.g. keeping you up to date with our latest services or obtaining your feedback on our service.
7.1.3 Consent – We will seek to obtain your consent to process:
your data outside our contractual obligations (see above) unless we have identified a
(a) Legitimate Interest (see above); and
(b) any potential special category data in future.
7.1.4 Legal obligation – We may process your data where we determine it is necessary for us to do so to comply with the law, respond to a subpoena, accept service of a search warrant or otherwise act in accordance with a lawful order.
7.1.5 Vital Interests – We may process your data where it is necessary for the vital interests for saving a life.
8. THIRD PARTIES AND SHARING INFORMATION
8.1 We will keep your personal information within our possession and control except where disclosure is required or permitted by law or when we use third party service providers to supply and support our services to you. We have contracts in place with our third party service providers. This means that they cannot do anything with your personal data unless we have instructed them to do so. They will not share your personal data with any organisation apart from us. They will hold it securely and retain it for the period we instruct.
8.2 Please see below the list which sets out the categories of recipients of personal data.
|
SERVICE PROVIDED |
|
T Provider – Cloud Service – IT Support |
|
Email Provider |
|
Secure document disposal service |
|
Internal HR systems provider |
|
Storage Facility |
|
Cleaning service (Offices) |
|
Accountants |
|
Shopify Inc. |
9. MARKETING
9.1 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).
9.2 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.
9.3 We strive to provide you with choices regarding certain personal data uses, namely around marketing and advertising. In particular:
9.3.1 We will always obtain your express opt-in consent before we share your personal data with any third party for marketing purposes; and
9.3.2 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 your or by contacting us at any time.
10.1 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.
10.2 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.
10.3 We employ data security tools to protect your personal data including encryption and authentication tools. All orders made through the Website are secured through our third-party providers. Even with these tools in place and properly functioning, we cannot guarantee the unconditional security of any personal Data. By using the Website, you acknowledge and agree that we make no such guarantee, and that you use the Website “as is” and at your own risk.
11.1 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.
11.2 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.
11.3 By law we have to keep basic information about our clients (including Contact, Identity, Financial and Transaction Data) for 6 years after they cease being clients.
11.4 In some circumstances you can ask us to delete your data (see below for further information).
11.5 We may 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. Please see clause 2.
12. APPLICATIONS TO WORK FOR US
If you apply to work for us (directly or indirectly) in any role we may receive data about you from third parties. In addition, we will keep the details of your application and any additional information provided to us by you or others during your application so that we can keep you informed of future opportunities that you may be interested in. If you do not wish for us to keep your details for this reason, please let us know by contacting us using the details provided in this policy.