Privacy Policy

Contents

1. Data protection policy - General Statement
2. Data Controller
3. Reference documents
4. Privacy Notice
5. Data Subject Rights
6. Making a complaint
7. Data protection contact details
8. Cookie Policy

1. Data Protection General Statement

This Data Protection Policy outlines Arrowsmith Marlowe Holdings (1980) Limited (“Arrowsmith”) commitment to its clients, staff, business partners, suppliers and other individuals to operate its business activities in a manner which meets the compliance obligations of the new Guernsey legislation, The Data Protection (Bailiwick of Guernsey) Law, 2017 (“TDPGL”).

Arrowsmith understands and respects your right to privacy and we are committed to ensuring the confidentiality and security of your personal data and the personal data processing activities within our organization by applying the appropriate technical and organisational measures required to achieve this objective. 

This document covers the policies and procedures for processing personal data in a compliant manner and outlines the rights of the data subjects (including clients, staff, intermediaries and other third parties) in respect of that data. The Privacy Notice below explains how we may use, process and store your personal data.

2. Data Controller

Arrowsmith Marlowe Holdings (1980) Limited is the data controller of all personal data and data processing activities of it’s laundry and dry cleaning business in Guernsey, Channel Islands. Our registered office is located at Arrowsmith Marlowe Holdings (1980) Limited, La Hure Mare Industrial Estate, Vale, Guernsey, GY3 5UB.

3. Reference documents

• The Data Protection (Bailiwick of Guernsey) Law, 2017  
• The Data Protection (Commencement, Amendment and Transitional) (Bailiwick of Guernsey) Ordinance, 2018
• The Data Protection (General Provisions) (Bailiwick of Guernsey) Regulations, 2018
• The Data Protection (Law Enforcement and Related Matters)(Bailiwick of Guernsey) Ordance, 2018 
• Employee Personal Data Protection Policy
• EU General Data Protection Regulation 2016 679

4. Privacy Notice

4.1 Scope of application

This policy applies to our business activities operating in Guernsey, Channel Islands, UK.

4.2 Personal data

Personal data means any information relating to an identified or identifiable natural person. 

Arrowsmith collects the following categories of personal information;

• Name and address
• Email address
• Telephone number and other contact information
• Bank details
• Delivery address
• Tax and/or GST number

Please note that this list is not exhaustive and Arrowsmith may also collect and process personal data to the extent that it is useful or necessary for the provision of our services.

4.3 Purposes of processing

Arrowsmith uses this personal data for the following range activities:

Purpose	Lawful basis for processing
Customer sales transactions for product and services	In the performance of services undertaken by Arrowsmith under Contract, when the customer agrees to the Terms of Business and Offer of Services as presented at time of transaction.
Building and managing customer, and other relationships	Legitimate interest basis for Arrowsmith to operate their business to improve services offered to interested parties.  You have the right to object to such processing by contacting our data protection representative.
Managing security and access to our computer systems, premises, platforms, website and applications	Legitimate interest basis for Arrowsmith to protect it’s business computer systems, business premises and staff. You have the right to object to such processing by contacting our data protection representative.
Recruitment of retail, office and laundry operational support staff	Legitimate interest basis for Arrowsmith to promote it’s business to attract suitably skilled staff. You have the right to object to such processing by contacting our data protection representative.
Comply with legal, tax and regulatory obligations	In the performance of a task carried out in compliance with a Legal Obligation.

4.4 Data collection methods

We collect personal data in the following ways;

• directly from you as a customer, staff member, business partner, supplier or agent when engaging with us directly and/or
• from third party channels such as public registers, social media networks and any other public open forums

4.5 Information collected

The personal data collected is used to meet consumer laws and other obligations, in the performance of the contract for services requested and where identified as assisting in the delivery of best practice standards of our business. Personal data may be used for legitimate business interest of Arrowsmith as indicated above.

4.6 Recipients of data

Personal data collected may be disclosed or transferred to;

• Arrowsmith data processors who provide services in relation to the running of its business systems 
• between group companies of Arrowsmith Marlowe Holdings (1980) Limited in performance of services
• competent authorities as required by law
• other third parties where requested by you and when relevant consent has been obtained  

4.7 Transfer and access to personal data

Arrowsmith will only transfer data outside of the EEA where it is necessary for the performance of the contract agreed by you.

Where the destination of the data transfer is outside the EEA and does not include a third country that has an “adequacy/equivalence” status, as recognized by the EU Commission, we would always ensure that appropriate safeguards in place. 

Where we cannot guarantee these safeguards, we would always request your consent before the data is transferred. 

4.8 Retention of data

Arrowsmith will only retain your personal data for as long as is necessary to fulfill the purpose for which it was collected. 

Arrowsmith will retain data in relation to customer transactions, supplier transactions and employee records for 6 years as required by the Company (Guernsey) Law 2008. 

5. Data subject rights

Where a data subject in the Channel Islands wishes to exercise their rights under applicable data protection laws, they should contact our Arrowsmith data protection representative at tracyasmlaundry@suremail.gg 

Data subjects have a number of rights available; 

• access to your personal data, 
• rectification of any inaccuracies, 
• restriction on the processing your data
• to object to the processing of your data
• to be forgotten (erasure of your data)
• right to data portability
• right to object to automated decision making and profiling 
• right to withdraw consent for those data processing activities based on consent 

Arrowsmith does not make any decisions based on purely automated means, but if we do, you have a right to object.

6. Making a complaint

The Office of the Information Commissioner in Guernsey, Channel Islands, is an independent statutory authority where you can make a complaint or learn more about data protection in Guernsey. Their website is www.odpc.gg and telephone number is 01481 742074.

6.1 Security features

Arrowsmith is committed to ensuring the security of your personal data and has implemented appropriate commercially reasonable technical, physical and organizational measures to prevent unauthorized or unlawful processing of your personal data or accidental loss or destruction of your personal data. 

Employees are trained in their data protection responsibilities and obligation to handle personal data in a confidential manner.

6.2 Change to this notice

Arrowsmith may update this Privacy Notice at any time. The updated notice will appear on our website www.arrowsmithmarlowe.co.uk and in our Terms of Business.  

This Privacy Notice was last approved on 29 June 2018.

7. Contact details

If you have any questions, concerns or complaints with respect to this Privacy Notice or the handling of your privacy or personal information, please contact our data protection representative on tracyasmlaundry@suremail.gg or 01481 247633.

8. Cookie Policy

Cookies are small text files which are stored on your computer by your web browser. There are eleven types of Cookies known as session Cookies and persistent Cookies. A session Cookie is a temporary file which is stored in your computer for the duration of your visit to a website. The Cookie is deleted when you leave the site. A persistent Cookie is saved to your computer and will remain there for the duration set within the Cookie.

8.1 How does our website use Cookies

The Arrowsmith website www.arrowsmithmarlowe.co.uk uses 11 cookies to enhance the user experience, control access to parts of the site, to provide analytics on how people engage with our website and to record consent for our “opt-in” direct marketing consent request. Specific detail on these Cookies is shown below; 

 

Cookie Name	Lifespan	Type	Purpose
_ga	2 years	1st Party - Google Analytics	These Google Analytic cookies are used to collect information about how visitors use our site. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited. This cookie is used to distinguish users.
_gat	1 minute	1st Party - Google Analytics	This cookie is used to throttle request rates to maintain website performance.
_gid	24 hours	1st Party - Google Analytics	This cookie is used to distinguish users.
NID	6 months	3rd Party - Google.com	This Cookie is used to make advertising more engaging to users. It logs an interaction with a google property (in this instance the map functionality).

 

We require consent to store Cookies on your computer. By using our website, you are consenting to our setting Cookies and using the data collected by them from the purposes set out in this Cookie policy.

8.2 Declining Cookies

If you have previously browsed or used our website and no longer wish to accept Cookie, you should be aware that some Cookies will have been set. You may delete these Cookies at any time by changing the Cookie settings on your computer. Further guidance on reviewing and amending these settings can be found through the help section of your internet browser.

8.3 Google Analytics

We use Google Analytics Cookies. These Cookies gather analytical information about the users of our website to help us understand better usage patterns. We typically use Google Analytics for this purpose.

The information generated by the Google Analytics Cookie (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google use this information for the purpose of evaluating your use of our website, compiling reports on website activity and providing other services relating to website activity and internet usage.

Google may also transfer this information to third parties where required to do so by law, or where third parties process the information on Google’s behalf.

8.4 Contact details

If you have any questions, concerns or complaints with respect to this Cookie Notice, please contact our data protection representative on tracyasmlaundry@suremail.gg or 01481 247633.