Turtle Mat – Protecting your Privacy
Turtle Mat is committed to safeguarding the privacy of our customers and users.
This Privacy Notice explains in detail the types of personal data we may collect about you when you interact with us and how we use this. It also explains how we'll store and handle that data, and keep it safe.
This Privacy Notice may need to be updated from time to time. We'll notify you of any significant changes, but you're welcome to come back and check it whenever you wish.
Who we are
We are Kleen-Tex Industries Ltd. (registered in England and Wales, company number 03847996) We are also known as the ‘Data Controller'. We sell a large collection of dirt-trapping indoor and outdoor mats through catalogues, advertisements, on the internet and through email marketing. The www.turtlemat.co.uk website is owned and operated by us. Any questions regarding data protection should be directed to us at:
Kleen-Tex Industies Ltd., Emlyn Street, Bolton, Lancashire, BL4 7EB, UK
On what basis are we collecting and processing your data?
Data protection laws set out a number of legal bases a company may collect and your process your personal data, these are the bases on which we collect and process your data:
Consent – we collect your consent to contact you by email with offers and news (email marketing)
Contractual obligations - in certain circumstances, we need your personal data to fulfil our contractual obligations with you
For example, if you order an item from us for delivery, we'll collect your address to deliver you purchase and pass them to our courier.
Legal compliance - If the law requires us to, we may need to collect and process your data
Legitimate interest - In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests.
For example, we will use your purchase history to send you or make available personalise offers
We also combine the shopping history of many customers to identify trends and ensure we can keep up with demand, or develop new products/services.
We will also use your address details to send you direct marketing information by post, telling you about products and service that we think might interest you.
We will also share your details with third parties whom we think you would be interested in hearing from.
When do we collect your information?
- When you visit any of our websites, and use your account to buy products and services, or when you place an order over the phone.
- When you make an online or telephone purchase and check out as a guest.
- When you request a catalogue or samples from us
- When you sign-up to hear from us by email
- When you create an account with us
- When you engage with us on social media
- When you contact us by any means with queries, complaints etc.
- When you enter prize draws or competitions
- When you choose to complete any surveys we send you
- When you comment on or review our products and services
- We collect data from publicly-available sources when you have given your consent to share information or where the information is made public as a matter of law.
The information we collect and how we use it
In order to fulfil your order (for example - for the purchase of a Cape Cod outdoor mat), we need to know certain personal information collected at time of order.
The information we hold will consist of but not be limited to the following:
Title; Name; Address; Mailing Preference flags such as Do not mail, or Do not email; Products purchased from us in the past including their cost; Telephone number if offered to us (this will only be used for matters relating to your order); email address if offered; Where we believe you heard about us from. Credit card details are encrypted after data entry and are not stored on our systems once used. We do not collect any Special Category Data (sensitive data) such as race, religion, biometrics or health data.
It is our policy that your information is private and confidential. Accordingly, the personal information you provide to us is stored securely, and is accessible only by designated staff and third parties.
We also collect data because it is necessary for the pursuit of our legitimate interests. Our legitimate interests are set out below.
- Direct Marketing
- Understanding our customers wishes and shopping preferences (including profiling)
- Improving our service and our products (including profiling)
This data may include:
- Details of your shopping preferences,
- details of your visits to our website, and which site you came from to ours,
- order history details which help us to recommend items of interest,
- Payment card information – through Sage Pay, Kleen-Tex Industries Ltd. do not hold this information
- Your comments and product reviews
- Technical information about your internet connection and browser as well as the country and telephone code where your computer is located, the web pages viewed during your visit, the advertisements you clicked on, and any search terms you entered. Cookies Policy
- Your social media username, if you interact with us through those channels, to help us respond to your comments, questions or feedback
- Your consent to email marketing
- Mailing and third party mailing flags such as 'do not mail'
It's always your choice whether you share such details with us and you always have the right to object to certain types of use by via email to firstname.lastname@example.org, calling us, by post or other means convenient to you i.e social media.
Remember, if you choose not to share your personal data with us, or refuse certain contact permissions, we might not be able to provide some services you've asked for.
For example, if you've asked us to let you know when an item come back into stock, we can't do that if you have exercised your right to erasure ‘the right to be forgotten' as we will have forgotten this request.
How we use your information for Direct Marketing & how to manage your marketing preferences
Marketing by us – Turtle Mat
We will contact you by mail with offers and products we believe will be of interest to you. You have the right to object to this at any time.
We will also contact you by email if you have consented to do so by ticking an opt-in box or providing your email address for this purpose.
We will also use your details, buying and browsing behaviours to help us tailor and improve our offering and services to you, this may be in the form of automated decision-making (profiling).
i.e. using algorithms based on your previous browsing history on our site to show you relevant products to the last ones you viewed.
You have the right to object to this at any time.
Marketing by other companies
We may share your details with other carefully selected retail companies and charities who we feel may be of interest to you. We also work with Epsilon Abacus (registered as Epsilon International UK Ltd), a company that manages the Abacus Alliance on behalf of UK retailers. The participating retailers are active in the following product categories: clothing, collectables, food & wine, gardening, gadgets & entertainment, health & beauty, household goods, and home interiors.
They share information on what their customers buy. Epsilon Abacus analyses this pooled information to help retailers understand consumers' wider buying patterns. From this information, retailers can tailor their communications, sending people suitable offers that should be of interest to them, based on what they like to buy.
Please note that Epsilon Abacus may transfer data outside the EEA. The transfer will take place in the presence of appropriate safeguards, including standard data protection clauses adopted by the EU Commission. If you would like more information, please call, write to us or email us at email@example.com
You have the right to object to this processing at any time, via email to firstname.lastname@example.org, calling us, by post or other means convenient to you i.e social media.
If you would like to stop all unsolicited postal communications, we suggest that you register with the Mailing Preference Service (MPS). MPS is a free service and funded by the direct mail industry to enable consumers to have their names and home addresses in the UK removed from lists used by the industry. It is actively supported by the Royal Mail and all directly involved trade associations and fully supported by The Information Commissioners Office (ICO). For more information or if you wish to register with the MPS please visit their website www.mpsonline.org.uk
How can you stop the use of your personal data for direct marketing?
There are several ways you can stop direct marketing communications from us:
- Click the ‘unsubscribe' link in any email communication that we send you. We will then stop any further emails.
- If you have an account, log in into your account, visit the ‘My Account' area and change your preferences.
- You can also stop mailings, third party mailings or automated decision making by contacting us either by post, email to email@example.com or by calling us
Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated
How we protect your personal data
We treat your data with the utmost care and take all appropriate steps to protect it.
We secure access to all transactional areas of our websites and apps using ‘https' technology.
Access to your personal data is password-protected, and sensitive data (such as payment card information) is secured by SSL encryption and is not held by Kleen-Tex Industries Ltd. directly but by Sage Pay a leader in secure payment facilities.
We regularly monitor our system for possible vulnerabilities and attacks, and we carry out penetration testing to identify ways to further strengthen security.
How long will we keep your personal data?
Whenever we collect or process your personal data, we'll only keep it for as long as is necessary for the purpose for which it was collected.
As a retailer, we are fortunate to have loyal customers who purchase our products over many years and also products that not only are guaranteed for 5 years but often last a lot longer – up to 20 years. With this in mind and to serve our customers in the best possible manner and to continue to inform them about new products and services we have decided to retain customer data for 25 years after the last purchase date.
At the end of that retention period, your data will either be deleted completely or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning.
Who do we share your personal data with?
We sometimes share your personal data with trusted third parties.
For example, delivery couriers, for fraud management, to handle complaints and to help Turtle Mat personalise our offers to you.
Here's the policy we apply to those organisations to keep your data safe and protect your privacy:
- We provide only the information they need to perform their specific services
- They may only use your data for the exact purposes we specify
- We work closely with them to ensure that your privacy is respected and protected at all times
- If we stop using their services, any of your data held by them will either be deleted or rendered anonymous
Examples of the kind of third parties we work with:
- IT companies who support our website,
- operational companies such as delivery couriers or customer service providers,
- direct marketing companies who help us manage our electronic or postal communications with you
- Google/Facebook to show you products that might interest you whilst you browse the internet. This is based on your acceptance of cookies on our website – see our cookie notice for more detail
- Data insight companies to ensure your details are up to date and accurate
- For fraud management, we may share information about fraudulent or potentially fraudulent activity on our systems. This may include sharing data about individuals with law enforcement bodies.
- We may also be required to disclose your personal data to the police or other enforcement, regulatory or Government body, in your country of origin or elsewhere, upon a valid request to do so. These requests are assessed on a case-by-case basis and take the privacy of our customers into consideration.
To help personalise your shopping experience with Turtle Mat we currently use the following companies, who will process your personal data as part of their contracts with us:
- The Mailshop
- Ingram Micro
- Abacus (Epsilon)
- Sage Pay
Sharing your data with third parties for their own purposes:
We may share your details with other carefully selected retail companies and charities who we feel may be of interest to you. We also work with Epsilon Abacus (registered as Epsilon International UK Ltd), a company that manages the Abacus Alliance on behalf of UK retailers. For more detail on this, see section above “Marketing by other Companies”
Where your personal data may be processed
Sometimes we will need to share your personal data with third parties and suppliers outside the European Economic Area (EEA), such as Australia or the USA.
If you are based outside the UK and place an order with us, we will transfer the personal data that we collect from you to the UK.
Protecting your data outside the EEA
The EEA includes all EU Member countries as well as Iceland, Liechtenstein and Norway. We may transfer personal data that we collect from you to third-party data processors in countries that are outside the EEA. This may be required to fulfil your order, process payment or provide support
If we do this, we have procedures in place to ensure your data receives the same protection as if it were being processed inside the EEA. For example, our contracts with third parties stipulate the standards they must follow at all times. If you wish for more information about these contracts please contact us.
Any transfer of your personal data will follow applicable laws and we will treat the information under the guiding principles of this Privacy Notice.
What are your rights over your personal data?
An overview of your different rights
You have the right to request:
- Access to the personal data we hold about you, free of charge in most cases.
- The correction of your personal data when incorrect, out of date or incomplete.
- To withdraw consent, or object and for which we have no legitimate overriding interest, or once the purpose for which we hold the data has come to an end
- That we stop using your personal data for direct marketing (either through specific channels, or all channels).
- That we stop any consent-based processing of your personal data after you withdraw that consent.
- Object to any decision made based solely on automatic processing of your data (i.e. where no human has yet reviewed the outcome and criteria for the decision).
You have the right to request a copy of any information about you that Kleen-Tex Industries Ltd. holds at any time, and also to have that information corrected if it is inaccurate. To ask for your information or to get this amended, please contact:
Kleen-Tex Industies Ltd., Emlyn Street, Bolton, Lancashire, BL4 7EB, UK or email firstname.lastname@example.org or contact our customer service team
If we choose not to action your request we will explain to you the reasons for our refusal.
Your right to withdraw consent
Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent.
Where we rely on our legitimate interest
In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.
You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We must always comply with your request.
Checking your identity
To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Notice. If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.
Contacting the Regulator
If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the Information Commissioner's Office.
You can contact them by calling 0303 123 1113. Or go online to www.ico.org.uk/make-a-complaint (opens in a new window; please note we can't be responsible for the content of external websites)
If you are based outside the UK, you have the right to lodge your complaint with the relevant data protection regulator in your country of residence.
If you live outside the UK
For all non-UK customers
By using our services or providing your personal data to us, you expressly consent to the processing of your personal data by us or on our behalf. Of course, you still have the right to ask us not to process your data in certain ways, and if you do so, we will respect your wishes.
Sometimes, we'll need to transfer your personal data between countries to enable us to supply the goods or services you've requested. In the ordinary course of business, we may transfer your personal data from your country of residence to ourselves and to third parties located in the UK.
By dealing with us, you are giving your consent to this overseas use, transfer and disclosure of your personal data outside your country of residence for our ordinary business purposes.
This may occur because our servers are located outside your country of residence, and could include storage of your personal data on servers in the UK.
We'll ensure that reasonable steps are taken to prevent third parties outside your country of residence using your personal data in any way that's not set out in this Privacy Notice. We'll also make sure we adequately protect the confidentiality and privacy of your personal data.
We wish to be as clear and transparent as possible regarding our data collection, security and how we use it. If at any time you have any questions or comments regarding this we would be happy to speak to you in person. Alternatively you can write to us at:
Kleen-Tex Industies Ltd., Emlyn Street, Bolton, Lancashire, BL4 7EB, UK
You can also email us at email@example.com