1.1 We are committed to safeguarding the privacy of our website visitors and customers.
1.2 This policy applies where we are act as a data controller with respect to the personal data of our website visitors and customers; in other words, where we determine the purposes and means of the processing of that personal data.
1.3 In this policy, "we", "us" and "our" refer to Alfafado Limited. For more information about us, see Section 14.
2. How we use your personal data
2.1 In the table below, we have set out:
(a) the general categories of personal data that we may process;
(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
(c) the purposes for which we may process personal data; and
(d) the legal bases of the processing.
|Category||Details||Source||Purposes of processing||Legal basis|
|Usage data||Data about your use of our website and services, which may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use||Our analytics tracking systems||Analysing the use of the website and analysing patters of ecommerce transactions||Legitimate interests, namely monitoring and improving our website and services, and fraud prevention|
|Account data||Your data associated with your account on our website, such as your name and email address||You||Operating our website, supplying our products, ensuring the security of our website, maintaining back-ups of our databases and sending you notifications and otherwise communicating with you||Legitimate interests, namely the proper administration of our website and business|
|Transaction data||Information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website, which may include your contact details, your card details and the transaction details||You and/or our payment services providers||Taking and managing payments, supplying our products and keeping proper records of the transactions||The performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract
Our legitimate interests, namely the proper administration of our website and business
|Communications data||Information contained in or relating to any communication that you send to us, which may include the communication content and metadata associated with the communication||You, and our website will generate the metadata associated with communications made using the website contact forms||Communicating with you and record-keeping||Legitimate interests, namely the proper administration of our website and business and communications with users|
|Newsletter data||Information that you provide to us for the purpose of subscribing to our newsletter(s)||You||Sending you the relevant newsletter(s)||Consent|
|Review data||Information that you post or provide to us for publication on our website or through our services||You||Enabling publication of the reviews and administering our website and services||Legitimate interests, namely the proper administration of our website and business|
2.2 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
2.3 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
2.4 In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
3. Automated decision-making
3.1 We may use your personal data as part of automated decision-making processes.
3.2 This automated decision-making will involve analysis of purchases on our website, and the categorisation of users, for example as business customers or consumers. The categories that the system allocates you to may affect the content that you see in our newsletter and on our website.
4. Providing your personal data to others
4.1 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
4.2 We may disclose your usage data to our analytics services providers identified in Section 12.3 insofar as reasonably necessary for the purpose of analysing the use of our website and improving the website.
4.3 Your personal data may be processed by our hosting, backup, support services infrastructure and communications services providers, details of which are set out in the appendix to this policy.
4.4 Financial transactions relating to our website are handled by our payment services providers, details of which are also set out in the appendix to this policy. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds.
4.5 In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
5. International transfers of your personal data
5.1 In this Section 5, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).
5.2 We have offices and facilities in the United States of America. Transfers to the USA will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission. See: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.
5.3 You acknowledge that personal data that you submit for publication on our website (such as personal data relating to a review) may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
6. Retaining and deleting personal data
6.1 This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
6.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
6.3 We will retain your personal data as follows:
(a) usage data will be retained for a period of 50 months following the date of collection;
(b) account data will be retained for the period during which the account live and for up to 12 months following the end of that period; in addition transaction data and associated account data will be retained for a minimum period of 6 years following the date of the transaction, and for a maximum period of 7 years following that date;
(c) communications data will be retained for a minimum period of 6 years following the date of the communication, and for a maximum period of 7 years following that date; and
(d) reviews data will be retained for a maximum period of 7 years following the date that we cease to publish the relevant review (although note that reviews provided to a third party will be subject to the rules and policies of that third party, and not this policy).
6.4 If you unsubscribe from our newsletter, you will have the opportunity to either delete your newsletter data or suppress the sending of newsletters. We usually recommend suppression over deletion. If you nonetheless would like us to delete your newsletter data, we immediately cease to send you newsletters and will delete the newsletter data within the period of 30 days following your request.
6.5 Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
7.1 We may update this policy from time to time by publishing a new version on our website.
7.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
8. Your rights
8.1 In this Section 8, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
8.2 Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
8.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
8.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
8.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
8.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
8.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
8.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
8.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
8.10 To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,
and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
8.11 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
8.12 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
8.13 You may exercise any of your rights in relation to your personal data by written notice to us.
9. Third party websites
9.1 Our website includes hyperlinks to, and details of, third party websites.
9.2 We have no control over, and are not responsible for, the privacy policies and practices of third parties.
10. Updating information
10.1 Please let us know if the personal information that we hold about you needs to be corrected or updated.
11. About cookies
11.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
11.2 Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
11.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
12. Cookies that we use
12.2 We may also use local storage on your computer for caching our website pages – in other words, increasing the speed at which our website loads in your browser.
12.3 We use a range of different services providers to analyse the use of our website. Details of these services providers are set out in the appendix to this policy. These services providers gather information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website.
13. Managing cookies
13.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can usually obtain up-to-date information about blocking and deleting cookies from the website of your browser creator or publisher.
13.2 Blocking all cookies will have a negative impact upon the usability of many websites.
13.3 If you block all cookies, you will not be able effectively to use our website.
14. Our details
14.1 This website is owned and operated by Alfafado Limited (trading as Battery Station).
14.2 We are registered in England and Wales under registration number 06486856, and our registered office is at Sher House, 46 Houghton Place, Bradford, West Yorkshire, BD1 3RG.
14.3 You can contact us:
(a) by post, to the address given above;
(b) using our website contact form;
(c) by telephone, on the contact number published on our website from time to time; or
(d) by email, using the email address published on our website from time to time.
Appendix - Recipients of personal data
1. Payments services providers
PayPal, Inc (https://www.paypal.com/en/webapps/mpp/ua/privacy-full)
Sage Pay Europe Limited (https://www.sagepay.co.uk/policies)
American Express Company (https://www.americanexpress.com/uk/legal/online-privacy-statement.html)
Amazon Pay (https://pay.amazon.com/ie/help/201751600)
2. Analytics services providers
Google Analytics, Google AdWords (https://www.google.com/policies/privacy/)
Bing Webmaster Tools, Bing Ads (https://advertise.bingads.microsoft.com/en-gb/resources/policies/microsoft-bing-ads-privacy-policy)
Zoho SalesIQ, Zoho PageSense (https://www.zoho.com/privacy.html)
Lucky Orange (https://www.luckyorange.com/privacy.php)
3. Other services providers