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  1. Introduction
    1.1 
    We are committed to safeguarding the privacy of our website visitors, service
    users, individual customers and customer personnel.
    1.2 This policy applies where we are acting as a data controller with respect to
    the personal data of such persons; in other words, where we determine the
    purposes and means of the processing of that personal data.
    1.3 Our website incorporates privacy controls which affect how we will process
    your personal data. By using the privacy controls, you can specify whether
    you would like to receive direct marketing communications and limit the
    collection, sharing and publication of your personal data. You can access the
    privacy controls via your account settings.
    1.4 We use cookies on our website. Insofar as those cookies are not strictly
    necessary for the provision of our website and services, we will ask you to
    consent to our use of cookies when you first visit our website.
    1.5 In this policy, “we”, “us” and “our” refer to UnitPackPower. For more information about us, see Section
    14.
  2. The personal data that we collect
    2.1
     In this Section 2 we have set out the general categories of personal data that
    we process and, in the case of personal data that we did not obtain directly
    from you, information about the source and specific categories of that data.
    2.2 We may process data enabling us to get in touch with you (“contact data”).
    The contact data may include your name, email address, telephone number,
    postal address and/or social media account identifiers. The source of the
    contact data is you and/or your employer. If you log into our website using a
    social media account, we will obtain elements of the contact data from the
    relevant social media account provider.
    2.3 We may process your website user account data (“account data”). The
    account data may include your account identifier, name, email address,
    business name, account creation and modification dates, website settings and
    marketing preferences. If you log into our website using a social media
    account, we will obtain elements of the account data from the relevant social
    media account provider.
    2.4 We may process information relating to transactions, including purchases of
    goods and/or services, that you enter into with us and/or through our website
    (“transaction data”). The transaction data may include your name, your
    contact details, your payment card details (or other payment details) and the
    transaction details. The source of the transaction data is you and/or our
    payment services provider.
    2.5 We may process information contained in or relating to any communication
    that you send to us or that we send to you (“communication data”). The
    communication data may include the communication content and metadata
    associated with the communication. Our website will generate the metadata
    associated with communications made using the website contact forms.
    2.6 We may process data about your use of our website and services (“usage
    data”). The usage data 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. The source of the usage
    data is our analytics tracking system.
  3. Purposes of processing and legal bases
    3.1
     In this Section 3, we have set out the purposes for which we may process
    personal data and the legal bases of the processing.
    3.2 Operations – We may process your personal data for the purposes of
    operating our website, the processing and fulfilment of orders, providing our
    services, supplying our goods, generating invoices, bills and other paymentrelated documentation, and credit control. The legal basis for this processing
    is our legitimate interests, namely the proper administration of our website,
    services and business.
    3.3 Publications – We may process account data for the purposes of publishing
    such data on our website and elsewhere through our services in accordance
    with your express instructions. The legal basis for this processing is consent.
    3.4 Relationships and communications – We may process contact data,
    account data, transaction data and/or communication data for the purposes
    of managing our relationships, communicating with you (excluding
    communicating for the purposes of direct marketing) by email, SMS, post,
    telephone, providing support services and complaint handling. The legal basis
    for this processing is our legitimate interests, namely communications with
    our website visitors, service users, individual customers and customer
    personnel, the maintenance of relationships, and the proper administration of
    our website, services and business.
    3.5 Direct marketing – We may process contact data, account data and/or
    transaction data for the purposes of creating, targeting and sending direct
    marketing communications by email, SMS, post and making contact by
    telephone for marketing-related purposes. The legal basis for this processing
    is consent.
    3.6 Research and analysis – We may process usage data and/or transaction
    data for the purposes of researching and analysing the use of our website and
    services, as well as researching and analysing other interactions with our
    business. The legal basis for this processing is consent.
    3.7 Record keeping – We may process your personal data for the purposes of
    creating and maintaining our databases, back-up copies of our databases and
    our business records generally. The legal basis for this processing is our
    legitimate interests, namely ensuring that we have access to all the
    information we need to properly and efficiently run our business in
    accordance with this policy.
    3.8 Security – We may process your personal data for the purposes of security
    and the prevention of fraud and other criminal activity. The legal basis of this
    processing is our legitimate interests, namely the protection of our website,
    services and business, and the protection of others.
    3.9 Insurance and risk management – We may process your personal data
    where necessary for the purposes of obtaining or maintaining insurance
    coverage, managing risks and/or obtaining professional advice. The legal
    basis for this processing is our legitimate interests, namely the proper
    protection of our business against risks.
    3.10 Legal claims – We may process your personal data 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.
    3.11 Legal compliance and vital interests – We may also process 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.
  4. Providing your personal data to others
    4.1
     We may disclose your personal data to our forwarders and shipping partners
    insofar as reasonably necessary for the purposes of obtaining or maintaining
    efficient deliveries of goods.
    4.2 Your personal data held in our website database will be stored on the servers
    of our hosting services providers.
    4.3 Financial transactions relating to our website and services may be handled by
    our payment services providers, PayPal, 2Checkout. 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. You can
    find information about the payment services providers’ privacy policies and
    practices at https://www.paypal.com/uk/webapps/mpp/ua/useragreementfull https://www.2checkout.com/legal/terms/.
    4.4 In addition to the specific disclosures of personal data set out in this Section
    5, 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 a third country under UK and/or EU
    data protection law.
    5.2 The hosting facilities for our website are situated in EU. The competent data
    protection authorities have made an adequacy determination with respect to
    the data protection laws of each of EU countries.
    5.3 You acknowledge that personal data that you submit for publication through
    our website or services 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 procedures, 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) contact data will be retained for a minimum period of 1 year following
    the date of the most recent contact between you and us, and for a
    maximum period of 3 years following that date;
    (b) account data will be retained for a minimum period of 1 year following
    the date of closure of the relevant account, and for a maximum period
    of 3 years following that date;
    (c) transaction data will be retained for a minimum period of 1 year
    following the date of the transaction, and for a maximum period of 3
    years following that date;
    (d) communication data will be retained for a minimum period of 1 year
    following the date of the communication in question, and for a
    maximum period of 3 years following that date; and
    (e) usage data will be retained for 1 year following the date of collection.
    6.4 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. Your rights
    7.1
     In this Section 7, we have listed the rights that you have under data
    protection law.
    7.2 Your principal rights under data protection law are:
    (a) the right to access – you can ask for copies of your personal data;
    (b) the right to rectification – you can ask us to rectify inaccurate
    personal data and to complete incomplete personal data;
    (c) the right to erasure – you can ask us to erase your personal data;
    (d) the right to restrict processing – you can ask us to restrict the
    processing of your personal data;
    (e) the right to object to processing – you can object to the processing
    of your personal data;
    (f) the right to data portability – you can ask that we transfer your
    personal data to another organisation or to you;
    (g) the right to complain to a supervisory authority – you can
    complain about our processing of your personal data; and
    (h) the right to withdraw consent – to the extent that the legal basis of
    our processing of your personal data is consent, you can withdraw that
    consent.
    7.3 These rights are subject to certain limitations and exceptions. You can learn
    more about the rights of data subjects by visiting
    https://edpb.europa.eu/our-work-tools/general-guidance/gdpr-guidelinesrecommendations-best-practices_en and https://ico.org.uk/fororganisations/guide-to-data-protection/guide-to-the-general-data-protectionregulation-gdpr/individual-rights/.
    7.4 You may exercise any of your rights in relation to your personal data by
    written notice to us, using the contact details set out below.
  8. About cookies
    8.1
     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.
    8.2 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.
    8.3 Cookies may not contain any information that personally identifies a user, but
    personal data that we store about you may be linked to the information
    stored in and obtained from cookies.
  9. Cookies that we use
    9.1
     We use cookies for the following purposes:
    (a) authentication and status – we use cookies to identify you when you
    visit our website and as you navigate our website, and to help us
    determine if you are logged into our website;
    (b) shopping cart – we use cookies to maintain the state of your shopping
    cart as you navigate our website;
    (c) personalisation – we use cookies to store information about your
    preferences and to personalise our website for you;
    (d) security – we use cookies as an element of the security measures used
    to protect user accounts, including preventing fraudulent use of login
    credentials, and to protect our website and services generally;
    (e) advertising – we use cookies to help us to display advertisements that
    will be relevant to you;
    (f) analysis – we use cookies to help us to analyse the use and
    performance of our website and services; and
    (g) cookie consent – we use cookies to store your preferences in relation
    to the use of cookies more generally.
  10. Cookies used by our service providers
    10.1
     Our service providers use cookies and those cookies may be stored on your
    computer when you visit our website.
    10.2 We use Google Analytics. Google Analytics gathers information about the use
    of our website by means of cookies. The information gathered is used to
    create reports about the use of our website. You can find out more about
    Google’s use of information by visiting
    https://www.google.com/policies/privacy/partners/ and you can review
    Google’s privacy policy at https://policies.google.com/privacy.
  11. Managing cookies
    11.1
     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 however obtain up-to-date information about blocking and
    deleting cookies via these links:
    (a) https://support.google.com/chrome/answer/95647 (Chrome);
    (b) https://support.mozilla.org/en-US/kb/enhanced-tracking-protectionfirefox-desktop (Firefox);
    (c) https://help.opera.com/en/latest/security-and-privacy/ (Opera);
    (d) https://support.microsoft.com/en-gb/help/17442/windows-internetexplorer-delete-manage-cookies (Internet Explorer);
    (e) https://support.apple.com/en-gb/guide/safari/manage-cookies-andwebsite-data-sfri11471/mac (Safari); and
    (f) https://support.microsoft.com/en-gb/help/4468242/microsoft-edgebrowsing-data-and-privacy (Edge).
    11.2 Blocking all cookies will have a negative impact upon the usability of many
    websites.
    11.3 If you block cookies, you will not be able to use all the features on our
    website.
  12. Amendments
    12.1 We may update this policy from time to time by publishing a new version on
    our website.
    12.2 You should check this page occasionally to ensure you are happy with any
    changes to this policy.
    12.3 We may notify you of significant changes to this policy by email.

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