Privacy Policy

Siren Living respects your privacy and is committed to protecting your personal information. This privacy notice will inform you as to how we look after your personal information when you:

• visit our website (regardless of where you visit it from);
• use our mobile app;
• contact us directly via phone or email.

and to tell you about your privacy rights and how the law protects you.

PURPOSE OF THIS PRIVACY NOTICE

This privacy notice aims to give you information on how Siren Living collects and processes your personal information through your use of this website, our mobile app. including any data you may provide through these channels when you sign up to our newsletter or purchase a product or service or take part in a competition or contact us directly.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal information about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

IMPORTANT INFORMATION ABOUT WHO WE ARE

JDS Wholesale Limited is the controller and is responsible for all personal data it receives and holds.   We have appointed a data protection leader (DPL) who is responsible for overseeing questions in relation to this Policy.     Please contact the DPL using the details set out below:

Full name of legal entity:

JDS Wholesale Limited,  Unit B102, Portview Trade Centre,  310 Newtownards Road,  Belfast    BT4 1HE

Siren Living is a trading name wholly owned by JDS Wholesale Limited.

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority 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.

CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.

THE INFORMATION WE COLLECT

If you register with us, we will collect personal data or personal information from 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 a person’s identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of data about you which we have categorised as follows:

•   – ‘Identity Data’ includes first name and last name;
•   – ‘Contact Data’ includes delivery address, email address and telephone numbers;
•   – ‘Financial Data’ includes bank account, payment records and payment card details;
•   – Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect and use Aggregated Data (as defined in this paragraph) such as statistical or demographic data for internal purposes. Aggregated Data may be derived from Your Data but is not personal data as it does not directly or indirectly reveal your identity. For example, we may aggregate information about how you use our website and services to calculate the percentage of users accessing a specific website feature, but this is anonymised. However, if we combine or connect Aggregated Data with Your 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 Policy.

HOW IS YOUR DATA COLLECTED?

We use different methods to collect data from and about you, including through:

Automated technologies or interactions: If you interact with our website, we may automatically collect data about your equipment, browsing actions and patterns. When you visit our website, we automatically collect information about your use of our site including details of your visits such as pages viewed and the resources that you access. Such information may include Aggregated Data, traffic data, location data and other communication data.

Direct interactions: You may give us your Identity, Contact, 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:

•   – make an online enquiry;
•   – make an online payment;
•   – subscribe to our services or publications;
•   – request marketing material to be sent to you;
•   – provide us with feedback;
•   – contact our customer service team;
•   – enter a competition, promotion, survey or complete a questionnaire.

USE OF COOKIES

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

USE OF YOUR INFORMATION

We will only use the information that we collect from you as follows:

•   – To enable us to comply with regulatory requirements;
•   – To communicate with you in the event that there is a query or problem with your order;
•   – To inform you of any changes to our website, services or goods and products;
•   – For record keeping purposes;
•   – For internal training and creation of internal training materials;
•   – To improve our services to you through machine learning and artificial intelligence software and

• To track and analyse activity on our website.

MARKETING PURPOSES

We will only contact you for marketing purposes where you have given us your express consent to contact you for this purpose. Once you have given us your permission to contact you for marketing purposes, we may use Your Data for one or more of the following:

•   – To provide information to you that you request from us relating to our products or services.
•   – To provide information to you relating to other products that may be of interest to you.
•   – To allow selected third parties to use Your Data to enable them to provide you with information regarding unrelated goods and services, which we believe may interest you.

You may change your mind and withdraw your permission for us to contact you for marketing purposes at any time by emailing us at [email protected].  This will not affect your use of our services.

THIRD-PARTY LINKS

This 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 data 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 notice of every website you visit.

CHANGE OF PURPOSE

We will only use your personal information 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 at [email protected].

If we need to use your personal information 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 information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

STORING YOUR PERSONAL DATA

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

DISCLOSING YOUR DATA

As set out above, we may disclose Your Data to third parties, in accordance with this Policy, in the following circumstances:

We may share your Identity, Contact and Financial Data with our External Third Parties (as set out below) to enable us to provide our services (for example, we may provide your postal address to a courier or we may share your name, address and age with a third-party service provider in order to verify your age and identity). The External Third Parties we work with include:

We may share Marketing and Communications Data where you have provided your express consent for us to share such with third parties for marketing purposes.

We may also share Your Data:

•   – with our internal third parties including the business entities within the JDS Wholesale Limited Group
•   – where we are legally required or permitted by law to disclose Your Data
•   – In the event of a joint venture, collaboration, financing, sale, merger or reorganisation of the company. If a change happens to our business, then the new owners may use Your Data in the same way as set out in this Policy.
•   – To further fraud protection and reduce the risk of fraud (for example, to comply with anti-money laundering regulations.

HOW LONG WILL YOU USE MY PERSONAL INFORMATION FOR?

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.  In addition, this includes that we may retain personal information from closed accounts to comply with legal requirements, prevent fraud and resolve disputes. After it is no longer necessary for us to retain your personal information, we dispose of it securely according to our data retention and deletion policies.

When we determine the maximum retention duration of any personal data we hold we do so with regard to our legitimate interests to retain data, our obligation under GDPR to minimise data we hold, the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data by contacting us at [email protected].

In some circumstances we may anonymise your personal information (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

In certain circumstances, you have the following rights under data protection laws in relation to Your Data. You have the right to:

Request access to Your Data (commonly known as a “data subject access request”). This enables you to receive a copy of the Your 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 Data. This enables you to ask us to delete or remove Your 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 Data where you have successfully exercised your right to object to processing (see below), where we may have processed Your Data unlawfully or where we are required to erase Your 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 Data where we are relying on a legitimate interest (or those of a third party) and there is something about your 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 Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process Your Data which override your rights and freedoms.

Request restriction of processing of Your Data. This enables you to ask us to suspend the processing of Your Data in the following scenarios:

•   – if you want us to establish the data’s accuracy;
•   – where our use of Your Data is unlawful, but you do not want us to erase it;
•   – where you need us to hold Your Data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
•   – you have objected to our use of Your Data, but we need to verify whether we have overriding legitimate and/or legal grounds to use it.

Request the transfer of Your Data to you or to a third party. We will provide to you, or a third party you have chosen, Your 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 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. Please note that we may not be able to comply with this request where we have a legal obligation to keep Your Data.

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TIME LIMIT TO RESPOND

We try to respond to all legitimate requests within one month. Occasionally it may 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.