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Privacy Policy

Information about us

flashbay.mt (“this website”) is a website operated by Flashbay Limited ("we, our, us").

We are registered with Companies House (UK) in England and Wales under company number 04676938 and our registered office and trading address is 6 The Fountain Centre, Imperial Wharf, Fulham, London SW6 2TW United Kingdom.

Our contact details are telephone: +44(0) 207 371 7333, email: contactapisdnt@flashbay.com.

The Directors of the company are Mr Stephen Webster and Mr Ieuan Williams.

Flashbay Limited engages only in Business-to-Business (B2B) sales and does not sell to individual consumers.

As a controller of your data, we comply with Data Protection laws in the United Kingdom and the EU General Data Protection Regulation (GDPR). This Privacy Policy details how we process your personal data in the course of conducting business with your company or organisation.

Personal data we collect in the course of conducting business with your company or organisation

In the course of servicing your company or organisation the types of personal data collected, used, stored and transferred by us may include:

Identity Data: including your forename(s), middle name(s) and last name.
Contact Data: including your email address, business address(es), billing address(es), delivery address(es) and telephone numbers.
Transaction Data: including the details of payments made for products and services your company or organisation purchases from us.
Technical Data: including internet protocol (IP) address, 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 used to access our website.
Usage Data: including how you use our website, products and services.
Marketing and Communications Data: including your preferences in receiving marketing from us and your communications preferences.

How do we collect personal data?

In the course of servicing your company or organisation personal data is collected via the following methods:

Direct interaction: in person, by telephone, email, post or otherwise when you are enquiring about or conducting transactions for our products and services.
Automated Technologies: when you use our website to enquire about or purchase our products and services.
From third parties: when you review our products and services on third party review websites.

How do we use personal data in the course of conducting business with your company or organisation?

In the course of servicing your company or organisation personal data is used in the following ways:

Purpose / Activity	Type of Data	Lawful Basis for Processing
To initially contact you to discuss the requirements of your company or organisation	Identity Contact Technical	- Consent; and/or - Necessary for our legitimate interests (to respond to an enquiry made by your company or organisation)
To process and deliver orders placed by your company or organisation	Identity Contact Transaction Technical	- Performance of a contract with your company or organisation; and/or - Necessary for our legitimate interests (to process and deliver an order placed by your company or organisation); and/or - To comply with a legal obligation
To manage our relationship with your company or organisation which may include: - Contact to review prior orders placed by your business or organisation - Re-engagement with your company or organisation about future needs - Notifying your company or organisation about changes to our products, services or policies	Identity Contact Transaction Technical Usage Marketing and Communications	- Performance of a contract with your company or organisation; and/or - Necessary for our legitimate interests (to re-engage with your company or organisation to review your prior orders, your future needs and to improve our customer service standards); and/or - The legitimate interests of your company or organisation (notifying your company or organisation about changes to our products, services or policies); and/or - To comply with a legal obligation.
To respond to complaints, legal actions or to collect outstanding debts	Identity Contact Transaction Technical Usage Marketing and Communications	- To comply with a legal obligation; and/or - Necessary for our legitimate interests (to ensure complaints can be responded to accurately, to ensure legal actions can be pursued or defended, to ensure outstanding debts can be collected).
To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	Identity Contact Transaction Technical Usage Marketing and Communications	- To comply with a legal obligation; and/or - Necessary for our legitimate interests (for running our business, websites and technical services, to prevent fraud).
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	Identity Contact Transaction Technical Usage Marketing and Communications	- 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 website, products/services, marketing, customer relationships and experiences	Identity Contact Transaction Technical Usage Marketing and Communications	Necessary for our legitimate interests (to analyse customer usage, update our website, to develop our business and to inform our marketing strategy
To display reviews that you post about our products and services on third party review websites	Identity Transaction	Necessary for our legitimate interests (to promote the quality of our products and services).
To display content that you post to our blog	Identity Contact Technical	Necessary for our legitimate interests (to display content that you wish to share on our blog).

Change of purpose

We will only use your personal data for the purposes explained above, unless we reasonably consider that we need to use it for another reason and it is compatible with the original purpose. Please contact us for an explanation as to how any new processing is compatible with the original purpose.

If we need to use your personal data for an unrelated purpose, we will notify you and 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.

Changes to our Privacy Policy

We keep our Privacy Notice under regular review and we will place any updates on this web page. This Privacy Notice was last updated on 24th May 2018.

Marketing by third parties

Your personal information will not be passed to any third-party organisation for the purposes of their marketing to you.

Third party links or data

Our website may include links to third-party websites, plug-ins and/or 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 policies. When you leave our website, we encourage you to read the privacy policies of each website you visit.

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. We also limit access to your personal data to only those employees, advisers, business partners and suppliers 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.

Sharing of personal data outside of the European Economic Area

We operate multiple entities under the Flashbay brand, including in the UK, USA, Australia, China and the Philippines. Servicing your company or organisation may require assistance from or work to be conducted by multiple Flashbay entities and where we share data with other Flashbay entities we ensure that they provide the same level of protection for personal data as it has in the EEA.
Some of our external suppliers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA. In such cases we ensure that your personal data is sufficiently protected. We may also use specific contracts approved by the European Commission that provide the same level of protection for personal data as it has in the EEA.

Who do we disclose personal data to?

In the course of servicing your company or organisation personal data may be disclosed to the following parties:

Type of Recipient	Reason
Other Flashbay entities	To support and develop the relationship between us and your company or organisation, to provide you with products and services, to respond to your enquiries or otherwise communicate with you.
Courier or fulfilment companies	To effect delivery or collection of items
Third party review sites	To invite you to review our products and services if you choose to do so.
Legal or debt recovery advisors	To advise on legal issues and/or ensure overdue debts are collected
With regulators or authorities	To fulfil our legal obligations
Others	Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, if we acquire other businesses or restructure our business the new owners may use your personal data in the same way as set out in this privacy notice.

These parties are required to ensure appropriate security measures are in place and maintain the confidentiality of your personal data, and to use your personal data only in the course of providing such services and in accordance with our instructions.

How long is your personal data retained?

Your personal data is retained for as long as necessary to support our legitimate interests in dealing with your company or organisation and then for sufficient duration to ensure compliance with our obligations under the laws of England and Wales and to support or defend any claims made by or against us. After this time the data will be anonymised or deleted.

Your rights regarding your personal data

You have the right to:

Request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of your personal data. This enables you to have any incomplete or inaccurate data corrected. Please note that we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete personal data where there is no good reason for us continuing to process it. You can also ask us to delete your personal data where you have successfully objected to the processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with a legal obligation. Note, however, that we may not always be able to delete the data for specific legal reasons which will be notified to you, if applicable, in response to your request.
Object to processing of 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.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is not lawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal 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 your company or organisation.
Withdraw 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 or processing carried out under a legal basis other than consent. If you withdraw your consent, we may not be able to provide certain products or services to your company or organisation.

Questions?

If you have any questions or complaints relating to how we use your personal data, or if you wish to exercise any of your rights regarding your personal data, please email data.questionstinpdas@flashbay.com or write to us at our registered address. We will respond to you as soon as is practical. The length of time will depend on the type and complexity of the request and the volume of requests being processed, but you will receive a response no later than one month from receipt of the initial request.