To comply with UK law, we must manage your personal information fairly, lawfully and transparently. This means you know how we use your information and we inform you about your rights. You can then decide whether you want to give us your information so that we can keep you informed about our products and services in the future or provide you with products or services.
Data protection laws in the UK require Comfomatic to manage all personal information in compliance with the Data Protection Principles. You are entitled to know how we intend to use any information you provide, you can then decide if you want to give us that information. All our employees and agents are responsible for maintaining your confidentiality. We provide training and supervision to ensure that these obligations are met.
This Data Privacy Notice covers the following topics
- Who we are
- Why & how we process information
- Why we use personal information
- Lawful basis for processing
- Passing information to others
- Transferring information outside UK
- How long we keep information for
- Your rights
1. Who we are
We are Comfomatic Ltd., 15 Turnstone Business Park, Widnes, WA8 0WN. We have a dedicated customer service team that looks after data privacy rights.
Unit 15 Turnstone Business Park
2. Why and how we process information
Providing our products and services.
When you express an interest in a product, enter one of our competitions, purchase a product or service you will provide us or our agents with your personal information. You will also provide us with information throughout our relationship with you.
What type of information do we receive?
|About||Information we store & process||Who provides this information|
|Potential Customers. – Entrants to our competitions or participants in our marketing activities.||Name, Address and Contact details, including your contact preferences.
Notes about our contact with you. Correspondence with you. As calls made to or from our office may be recorded, this could include audio recordings of conversations with you
|Customers||In addition to that shown above, we store information about your transaction(s) with us. Including how you pay for the product or service.
If you make a purchase, we may be required to confirm that you have a chronic medical condition. Some products are contraindicated by some medical conditions or you may be entitled to special VAT rates. When needed this information will be stored securely on our systems but will not be processed for any other purpose.
We use this information to do all the things you expect from us as a business, to ensure that we deliver a first-class service and we meet our obligations to you under our Terms and Conditions.
- providing you with products and services
- responding to your enquiries and complaints
- administering offers, competitions and promotions
- updating, consolidating and improving the accuracy of our records
- managing your relationship with us
- crime detection, prevention and prosecution.
- manage and develop customer relations
- assess the suitability of existing and proposed products for our customers
- conduct internal or external reviews of our performance and quality
- instruct legal advisors
- detect and prevent crime including liaising with police and other agencies
- engage with and interact on social media
- make sure we manage Comfomatic as effectively and efficiently as possible
- you have provided your consent to us using the personal information;
- our use of your information is necessary to perform our contract with you, for example, processing sales and services, providing services in connection with our competitions and marketing programmes in accordance with the terms of our agreement with you;
- our use of your information is necessary to meet responsibilities we have to our regulators, HMRC, law enforcement, or otherwise meet our legal responsibilities;
- our use of your information is in our legitimate interest as a commercial organisation, for example to operate and improve our services and to keep people informed about our products and services (including for profiling and targeted advertising) – in these cases we will look after your information always in a way that is proportionate and respects your privacy rights and you have a right to object to us processing your information, simply contact our Customer Service team (section 1).
- HMRC or other authorities require it
- the law, a regulatory body, the BHTA or the public interest requires it
- it is required by us or others to detect, investigate or prevent crime or fraud.
- why we have it
- what type of information we possess
- whether we have or will send it to others, especially outside the European Economic Area
- how long we will keep it
- where we got it from
- details of any automated decision-making.
Unfortunately, we will not be able to provide you with any information, services or products if you fail to provide certain information.
Comfomatic also receives names and addresses (including email addresses) and telephone contact details of non-customers, from approved marketing companies, who it is thought may be interested in our products and services. In these circumstances, where we have your consent, we’ll let you know about the products and services by telephone or by email. If we don’t already have your consent, and it’s in our legitimate interest to promote our business, we’ll tell you about our products and services by post or if you are not a member of the Telephone Preference Service, we may contact you by telephone. You have the right to opt out of this marketing at any time, by following a link on the email or by contacting our Customer Service Team.
Other service providers.
Comfomatic work with business partners or agents to give you the best possible service. This involves some information continuing to pass between them and Comfomatic.
Where it’s necessary to deliver the service you’ve asked for, we may need to pass some of your personal information to Comfomatic business partners or agents. These are businesses who help provide some services (for example delivery or engineering) on our behalf. We only pass the minimum information needed to these partners. And we always make sure that your information remains protected as required under UK law, including laws regulating the sending of marketing messages to you.
Where you apply for a linked credit product, as Comfomatic are not lenders, that credit product will be delivered by a finance company. We will collect your personal information, we will pass that information to the credit provider and use it to process your application for credit.
3. Why we use personal information
We use information so that we can market our products, provide our customers with support and deliver a first-class service. This includes: –
We’ll use your information to make sure we give you and other customers the best possible service This includes testing new systems, checking upgrades to existing systems, training, undertaking transactional analysis and conducting audits. It also involves customer modelling and analysis aimed at developing and improving products and services, as well as providing information to Regulators. We do this to meet our legitimate interests in providing better services to our customers and making sure your information is protected.
Marketing and Promotional Material.
We value our relationship with you and so we do our best to only provide you with information we think may be of interest to you. We will offer you an opportunity to receive direct marketing and promotional information from us. We provide this material by post, email, telephone or SMS. We will only send direct marketing if you’ve consented to receive it. And you can withdraw your consent at any time.
We will not share any information you have provided to us with any other company or organisation for them to use for marketing purposes of any type.
We work very hard to make sure that we only provide you with information or market products or services that are likely to be of interest to you. Although we will only provide marketing information to you if you have consented to this, the work we do to make sure any marketing is likely to be of interest to you is done to meet our legitimate interests in sending marketing material about products you might be interested in. You can tell us to stop doing this at any time by contacting our Customer Service Team, by clicking ‘unsubscribe’ in any marketing email we send you or by following the instructions in our marketing SMS’.
If you interact with us through social media, we may use your information to help us communicate.
Meeting your requests.
If you request a service or product from us, or ask a question, we’ll use your personal information to respond. This is to make sure we can provide the best possible service.
Comply with legal obligations.
This might include providing information to HMRC, preventing fraud, money laundering and doing what our Regulators require. We only do this where strictly necessary to comply with these legal obligations.
Deliver a first-class service.
This includes using personal information to make sure we:
We use your personal information in this way because it is in our business interests. It also allows us to defend our rights, provide a better service to our customers and understand what our customers want from us. Whenever we use your personal information, we will always make sure we work to protect your interests and rights. We will keep your personal information secure, and let you know if we intend to use it for any new purpose.
Occasionally Comfomatic will need to ask for your specific consent to use sensitive personal information. This might be when we want to record sensitive information, such as details about your health to confirm your qualification for VAT zero rating. Asking for your consent gives you control over how we use this information. You can withdraw this consent at any time.
4. Legal basis for processing
We are committed to collecting and using your information in accordance with applicable data protection laws. We will only collect, use and share your information where we are satisfied that we have an appropriate legal basis to do this.
This may be because:
If you have provided your consent to our processing of your information you can withdraw this consent at any time by contacting our Customer Service team (see section 1)
5. Passing information to others
We will always treat your personal information as private and confidential. In some instances, we may disclose it outside of Comfomatic for the purposes set out above (including sharing information with partners who help us provide services). This may include sharing it with subcontractors. They will act solely on our instructions or behalf and will only use your information for the purposes set out above.
We will disclose information to others to meet our contractual obligations to you in accordance with the Terms and Conditions. We will also disclose information where it is strictly necessary to comply with our legal obligations, including where:
Information can also be made available to others if you ask us to provide that information or if you consent to us asking that information. If you give your consent, you can withdraw it at any time and we will stop disclosing the information.
6. Transferring information outside UK
Because the UK and other EEU countries provide a high standard of protection and privacy we process all data within the UK. However, other service providers such as delivery agents, finance companies, banks and software providers may process information you have provided from centres outside the UK and EEA that do not have a similar standard of data protection laws. If so, our business partners or agents will require your personal information to be protected to at least UK standards.
We may process payments through banks and other financial institutions, such finance companies and payment card processing companies. These external organisations may process and store your personal information abroad and may have to disclose it to foreign authorities to help them in their fight against crime and terrorism. If these are based outside the UK and EEA, your personal information may not be protected to standards like those in the UK. However, we will only use banks and financial institutions with bases in the UK who are committed to providing the same standard or data protection.
7. How long we keep information for
We will keep your information for as long as you have Comfomatic products, have a finance agreement linked to a Comfomatic sale or you may require service from us. We’ll also keep your personal information for a certain period after our relationship has ended.
When determining how long this will be, we consider our legal obligations, the expectations of financial and data protection regulators, and the amount of time we may need to hold your personal information for to enable us to carry on our business or defend our rights.
For example, if you have a Comfomatic product, we’ll keep your information for as long as you own the product and may need our assistance. In addition to meet our statutory and regulatory duties, we must keep much of this information for several years after our relationship has ended even if you do not have another product and we are no longer using your information for marketing purposes.
We will also need to keep your information in archived form so that we can defend our legal rights if the need arose. This may be for the period during which legal claims can be made under applicable law, in the UK this is six years. We have policies and procedures in place to make sure that we delete information no longer needed for any of these purposes.
If you have not purchased a Comfomatic product or service but you have provided us with consent to market to you, we will retain and process your personal information for as long as your consent remains valid. You can withdraw this consent at any time by contacting our Customer Service team, section 1, and we will periodically re-solicit your consent.
If you have not purchased a Comfomatic product or service but we have obtained your information as part of our legitimate interests, we will retain and process your personal information for as long as it is proportionate for us to do so but no more than 6 years or see below. You can ask us to stop processing your information at any time by contacting our Customer Service team, section 1.
To comply with the various statutory and regulatory regimes that govern the way we work, to allow us to defend our legal rights should the need arise or to investigate concerns; we archive basic information about our transactions, contacts and attempted contacts with consumers. This information includes name and contact details. We will retain this information for the period required by the various regulators or during which legal claims can be made, in the UK this is 6 years. We have policies and procedures in place to make sure that we delete information no longer needed for any of these purposes.
8. Your rights
You have several rights over your personal information. These include the right to access a copy of your personal information or have some elements of it transmitted to you or another company in a common electronic format. In certain circumstances you can have your personal information corrected or erased, or you can restrict our use of it. You also have the right to object to the way we use your personal information as described above. We normally will not charge you to exercise any of these rights.
You have the following rights: –
You have a right to ask Comfomatic if we have any of your personal information. If we do, you have a right to know:
If you want, you can ask for a copy of all your information that we hold.
Where any of your information is incorrect, you have a right to tell us to correct it promptly. Please tell us as quickly as possible if you change your address or other contact details. If your information is incomplete, you can ask us to correct this too.
In certain circumstances, you will have the following extra rights: –
Right to object
Depending on the legal basis for which we are using your information, you may be entitled to object.
For example, if we are using your information for marketing purposes, we will stop all marketing to you, if you object. However, if we are using your information to meet legal obligations, we may continue to use your information in this way even if you object.
You may have a right to have some or all the information we hold about you deleted. However, as a business, we are required by law to retain many records even after our relationship has ended.
In certain circumstances you are entitled to receive some of your information from us electronically. We can pass the information to you, or to another person or business if you want.
You might also be entitled to ask us to restrict our use of your information, for example if you think the information we hold on you is incorrect.
Comfomatic do not use automated decision making.
If you consent to us using your information, you have the right to withdraw that consent at any time.
You can exercise these rights by contacting our Customer Service Team. using the contact details shown in section 1 above.
We will work with you on any request, complaint or question you have about our obtaining, storage and processing of your personal information. However, if you believe we have not adequately resolved a matter, you have the right to complain to the Information Commissioner’s Office (the ‘ICO’). You have a right to complain to the ICO at any time. You can visit the ICO website at https://ico.org.uk.
Comfomatic work hard to deliver an exceptional consumer experience. If we fail to deliver that experience, we are committed to do that which we can to fairly investigate concerns and put right any failings on our part. We are members of the British Healthcare Traders Association (BHTA) so we follow a Trading Standards Institute approved code of practice. If you are unhappy with the outcome of our investigation and you have exhausted our complaints procedure you will have the right to ask the BHTA to investigate your complaint. A copy of our complaints procedure and the BHTA leaflet Get Wise To making A Complaint is available free of charge on request.