Welcome to Combattivo Limited’s privacy notice.
Combattivo Limited respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our site, https://combattivo.com; ( ”site”), (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
Please use the Glossary at paragraph 10 to understand the meaning of some of the terms used in this privacy notice.
Contents
Important information and who we are. The data we collect about you.
How is your personal data collected? How we use your personal data.
Purposes for which we will use your personal data.
10.
- Marketing.
- Promotional offers from us.
- Third-party marketing.
- Opting out
- Cookies.
- About cookies.
- Our cookies.
- Change of purpose.
Disclosures of your personal data. International transfers.
Data security. Data retention
How long will you use my personal data for? Your legal rights.
• Marketing.
• Correction of information.
• Deletion of information.
• Object to processing.
• Restriction on processing.
• Access to information.
• Data Portability
1. Important information and who we are
Purpose of this privacy notice
This privacy notice aims to give you information on how we collect and processes your personal data through your use of our site, including any data you may provide through our site when you sign up to our newsletter, purchase a product or create an account with us.
Our site 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 data 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.
Controller
Combattivo Limited is the controller and responsible for your personal data.
We have appointed a data privacy manager (DPM) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPM using the details set out below.
Contact details
Our full details are:
Full name of legal entity: Combattivo Limited Name or title of DPM: Data Privacy Manager Email address: info@combattivo.com
Postal address: COMBATTIVO LIMITED, 124 Vivian Avenue, Wembley, HA9 6RT.
Should you have any concerns, we would appreciate the chance to deal with them in the first instance. If you would like to speak to us in relation to any concerns you have, please contact us by email at info@combattivo.com.
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).
Changes to the privacy notice and your duty to inform us of changes
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third-party links
Our sites 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 sites, we encourage you to read the privacy notice of every website you visit.
2. The data we collect about 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 the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data that you give us through our sites or by using our applications, corresponding with us by phone, e-mail or otherwise about you which we have grouped together as follows:
• Identity Data includes first name, middle name, maiden name, last name, username or similar identifier.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of products you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our sits.
• Profile Data includes your username and password, purchases or orders made by you.
• Usage Data includes information about how you use our sites, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific site feature. However, if we combine or connect Aggregated Data with your personal 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 privacy notice.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods). In this case, we may be unable to process an order for a product or we may have to cancel a product you have ordered with us but we will notify you if this is the case at the time.
Profiling
Profiling is a form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to you, for example to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movement. We use profiling software to
understand you and your interest in our products better, to match you with specific offers and to guide us in providing the best services and products to you.
Please note; we do not take automated decisions based on this profiling.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us, your Identity, Contact and 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;
- place an order for our products;
- submit a comment on our site;
- interact with us on our social media;
- submit an enquiry to us regarding our products;
- create an account on our site;
- subscribe to our mailing list and request marketing information;
- if you apply for a job with us; or
- give us some feedback.
- Automated technologies or interactions. As you interact with our site, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see below for further details on cookies.
- Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:
- Technical Data from the following parties:
- analytics providers such as Google based outside the EU; and
- advertising networks such as AdSense based inside and outside the EU.
- Identity and Contact Data from data brokers or aggregators.
- Financial, contract, Identity and Transaction data from HMRC, applicable fraud prevention schemes and credit reference agencies.
- Technical Data from the following parties:
4. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
• where we need to perform the contract we are about to enter into or have entered into with you;
• where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
• where we need to comply with a legal or regulatory obligation; and
• to the purchaser (or prospective purchaser) of any business or asset that we are (or are contemplating) selling.
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate (please see paragraph 10 (Glossary) for a definition of legitimate interest).
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
For the avoidance of doubt, you may fall into one or more of the below detailed categories (i.e. customer, job applicant or site user).
Customers
For individual and business customers, we may collect and process your personal data as follows:
| Purpose/Activity | Type of Data | Lawful basis for processing including basis of legitimate interest |
| To register you as a new customer/ create an account |
|
Performance of a contract with you |
To process and deliver your order including:
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To manage our relationship with you which will include:
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| To administer and protect our business and our sites (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
|
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| To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you |
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Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) |
| To use data analytics to improve our sites, products/services, marketing, customer relationships and experiences |
|
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) |
| To make suggestions and recommendations to you about products or services that may be of interest to you |
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| If you register a warranty for a product purchased from us |
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Job Applicants
For job applicants, we may collect and process your personal data as follows:
| Purpose/Activity | Type of Data | Lawful basis for processing including basis of legitimate interest |
| If you apply for a job with us |
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We will obtain your consent to process this data |
Site Users
For site users, we may collect and process your personal data as follows:
| Purpose/Activity | Type of Data | Lawful basis for processing including basis of legitimate interest |
| To administer and protect our business (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
|
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| To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you |
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Necessary for our legitimate interests (to study how individuals use our sites, to develop it, to grow our business and to inform our marketing strategy) |
| To use data analytics to improve our sites, services, marketing, customer relationships and experiences |
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Necessary for our legitimate interests (to define types of customers for our services, to keep our sites updated and relevant, to develop our business and to inform our marketing strategy) |
| To make suggestions and recommendations to you about goods or services that may be of interest to you |
|
|
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Promotional offers from us
If you would like to receive information on our products, offers and other news (marketing communications); we will request your consent to provide you with these marketing communications and, if you do not consent, we will not send you this information.
You will receive marketing communications from us if you have consented to join our email database and you have not opted out of receiving that marketing.
Third-party marketing
We will not share your information with any third parties for marketing purposes without your additional consent.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product purchase, warranty registration, product experience or other transactions.
Account Management
You may view or change your account information at any time on the My Account page. Any changes to your information will be updated as soon as possible. If you want to stop using your account you may deactivate it by closing your account on the My Account age. We will delete any information we hold, unless we have another legal basis or requirement to do so.
Business to Business Communications
We do not collect personal data for our business customers, beyond business emails and a telephone number of you or your employees, as well as recording a history of contact.
We rely on legitimate interest to store and use this information, because we need to communicate with you in order to provide our products and perform our functions, as well as responding to requests for information and placing orders. We believe it is within your reasonable expectations that we will process this minimal contract information and this will not impact the legal rights and freedoms of your and/or your employees. We also provide the opportunity for you to opt out of any communications and you may exercise your data rights (set out below)
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 our sites may become inaccessible or not function properly.
About cookies
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.
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.
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.
Cookies can be used by web servers to identity and track users as they navigate different pages on a website and identify users returning to a website.
Our cookies
We use the following cookies:
• Strictly necessary cookies.
Blocking cookies:
Most browsers allow you to refuse to accept cookies; for example:
• in Internet Explorer (version 10) you can block cookies using the cookie handling override settings available by clicking “Tools”, “Internet Options”, “Privacy” and then “Advanced”;
• in Firefox (version 24) you can block all cookies by clicking “Tools”, “Options”, “Privacy”, selecting “Use custom settings for history” from the drop-down menu, and unticking “Accept cookies from sites”; and
• in Chrome (version 29), you can block all cookies by accessing the “Customise and control” menu, and clicking “Settings”, “Show advanced settings” and “Content settings”, and then selecting “Block sites from setting any data” under the “Cookies” heading.
Blocking all cookies will have a negative impact upon the usability of many websites. If you block cookies, you will not be able to use all the features on our sites.
Deleting cookies:
You can delete cookies already stored on your computer; for example:
• in Internet Explorer (version 10), you must manually delete cookie files (you can find instructions for doing so at http:// support.microsoft.com/kb/278835);
• in Firefox (version 24), you can delete cookies by clicking “Tools”, “Options” and “Privacy”, then selecting “Use custom settings for history”, clicking “Show Cookies”, and then clicking “Remove All Cookies”; and
• in Chrome (version 29), you can delete all cookies by accessing the “Customise and control” menu, and clicking
“Settings”, “Show advanced settings” and “Clear browsing data”, and then selecting “Delete cookies and other site and plug-in data” before clicking “Clear browsing data”.
Deleting cookies will have a negative impact on the usability of many websites.
Change of purpose
We will only use your personal data 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.
If we need to use your personal data 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 data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
• Internal third parties such as our employees or officers and legal entities within the Hoodrich Group of companies.
• External third parties including e-commerce platforms, third party payment processors, Application service providers, delivery agents, specialist IT support, suppliers and sub- contractors for the performance of our sites, our applications and any contract we enter into with them or you, including; Shopify Inc, Shopify Payments, PayPal, Visa, Apple Pay,
Amazon Pay, Mastercard, Google Pay, Google Analytics, Google Shopping, Wishlist King, Referral Candy, Back in Stock, Air box Limited, Facebook, Instagram and Twitter.
• Professional advisers including lawyers, bankers, marketing agencies, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
• Credit reference agencies, law enforcement and fraud prevention agencies to help us prevent and deal with fraud;
• HM Revenue & Customs, regulators and other authorities who require reporting or processing activities in certain circumstances.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. International transfers
To perform the contract with you or provide you with requested materials and information, we may share your personal data between countries that we operate and with online sales platform and communication platforms. This will involve transferring your data outside the European Economic Area (EEA).
Countries to which we may transfer your personal data outside of the EEA either have an adequate level of protection for personal data by the European Commission or we have ensured that adequate safeguards are in place, for example Privacy Shield or specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
In addition, our employees and officers will be able to access emails and our IT systems whilst outside the EEA, in the course of their employment. This does mean that your personal data is accessible whilst outside the EU, however, we have assessed the risk and ensured adequate safeguards are in place, including the following:
• Secure email with password
• Password protected and encrypted IT systems
• IT security measures
• Training of our employees on data protection
• Robust policies and procedures
• Obligations in our contracts with employees
7. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. Data retention
How long will you use my personal data for?
We will only retain your personal data 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.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
For customers. your personal data will be stored for no longer than 7 years from when you last purchased a product from us, or following you ceasing to be registered with us as a customer of the relevant site (whichever is later).
If you have registered to receive communications from us as part of our mailing list, we will communicate with you on the basis of your consent. We will continue to review and/or refresh this consent, in accordance with our policies and procedures. Please note that you may withdraw your consent at any time by contacting us.
For full details of our retention policies, please contact us using [ ].
In some circumstances you can ask us to delete your data: see
Request erasure below for further information.
In some circumstances we may anonymise your personal data (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.
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
Marketing
We will inform you (before collecting your data) if we intend to use your data for marketing purposes. We will only use your data for this if you have agreed in advance.
Correction of information
If you notify us that the personal data we hold is complete or inaccurate we will correct or complete the information as soon as possible.
Deletion of information
You have the right to request that your personal data be deleted; including if we no longer need it for the purpose we collected it, or you withdraw your consent.
Following such a request we will erase your personal data without undue delay unless continued retention is necessary and permitted by law. If we made the personal data public, we will take reasonable steps to inform other data controllers processing about your erasure request.
Object to processing
You have the right to object to us processing your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular 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 personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Restriction on processing
You have the right to request that we suspend processing your personal data, but hold it for you, in the event the personal data we hold is inaccurate, the processing is unlawful or we no longer need the personal data. Once the processing is restricted, we will only continue to process your personal data if you consent or we have another legal basis for doing so.
Access to information
You have the right to access information held about you and any access request will usually be free of charge. We will endeavour to provide information in a format requested, but we may charge you a reasonable fee for additional copies.
Data Portability
You have the right to receive a copy of your personal data which you gave to us. The copy will be provided in a commonly used and machine-readable format. You can also have it transmitted directly from us to another data controller, where technically possible.
If you wish to exercise any of the rights set out above, please Contact us.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
Withdraw consent at any time
You may withdraw your consent at any time where we are relying on consent to process your personal 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.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
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.
11. Glossary
LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
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