Privacy Policy

FIND OUR FULL TERMS & CONDITIONS, RETURNS AND REFUND POLICY HERE

When you place an order with us at www.polkadoodles.co.uk we may capture some of your information to facilitate that order. This information, which forms the basics of your order, ie your shipping/billing address, email etc, will never be sold onto any 3rd party and is only maintained as part of your account details on the website. We do not hold your information in paper form and we do not collect any of your payment information.

We are compliant with the European General Data Protection Regulations set in place April 2018 General Data Protection Regulation (GDPR) and the ePrivacy Directive 2009/136/EC (ePR).

All payments are processed via secure banking systems and our website Host, Big Commerce inc., and all information is held privately and securely on those 3rd Party systems - we do not hold your card details on this website but we must advise you that our 3rd party banking partners and website developers may have access to your data during the course of your transactions with us as a business. We need your information to effectively process your orders and to comply with UK VAT regulations.

If you order downloads, we are required to collect your billing/delivery addresses for tax reasons as we need to fulfil the EU Digital VAT regulations which need this information. EU digital VAT is calculated based on your billing address.

We reserve the right to send customers registered to the Polkadoodles newsletter marketing information to tell you about new products and services. We may send this newsletter via email or by post. You may unsubscribe from this at any time by using the unsubscribe feature on the emails you receive.

Your privacy is important to us as a business - at no time will your information or details ever be passed to any other 3rd party.

Your Personal data is transmitted to 'adequate countries' only (GDPR)

GDPR - Compliance Statement:

Our Commitment

Polkadoodles Ltd (‘we’ or ‘us’ or ‘our’) are committed to ensuring the security and protection of the personal information that we process, and to provide a compliant and consistent approach to data protection. We have always had a robust and effective data protection program in place which complies with existing law and abides by the data protection principles. However, we recognise our obligations in updating and expanding this program to meet the demands of the GDPR and the UK’s Data Protection Bill.

We are dedicated to safeguarding the personal information under our remit and in developing a data protection regime that is effective, fit for purpose and demonstrates an understanding of, and appreciation for the new Regulation. Our preparation and objectives for GDPR compliance have been summarised in this statement and include the development and implementation of new data protection roles, policies, procedures, controls and measures to ensure maximum and ongoing compliance.

Polkadoodles already have a consistent level of data protection and security across our organisation, however it is our aim to be fully compliant with the GDPR by 25th May 2018. Our preparation includes: -

Information Audit - carrying out a company-wide information audit to identify and assess what personal information we hold, where it comes from, how and why it is processed and if and to whom it is disclosed.
- Policies & Procedures - [revising/implementing new] data protection policies and procedures to meet the requirements and standards of the GDPR and any relevant data protection laws, including: -
  - Data Protection – our main policy and procedure document for data protection has been overhauled to meet the standards and requirements of the GDPR. Accountability and governance measures are in place to ensure that we understand and adequately disseminate and evidence our obligations and responsibilities; with a dedicated focus on privacy by design and the rights of individuals.
  - Data Retention & Erasure – we have updated our retention policy and schedule to ensure that we meet the ‘data minimisation’ and ‘storage limitation’ principles and that personal information is stored, archived and destroyed compliantly and ethically. We have dedicated erasure procedures in place to meet the new ‘Right to Erasure’ obligation and are aware of when this and other data subject’s rights apply; along with any exemptions, response timeframes and notification responsibilities.
  - Data Breaches – our breach procedures ensure that we have safeguards and measures in place to identify, assess, investigate and report any personal data breach at the earliest possible time. Our procedures are robust and have been disseminated to all employees, making them aware of the reporting lines and steps to follow.
  - International Data Transfers & Third-Party Disclosures – where [insert organisation name] stores or transfers personal information outside the EU, we have robust procedures and safeguarding measures in place to secure, encrypt and maintain the integrity of the data. Our procedures include a continual review of the countries with sufficient adequacy decisions, as well as provisions for binding corporate rules; standard data protection clauses or approved codes of conduct for those countries without. We carry out strict due diligence checks with all recipients of personal data to assess and verify that they have appropriate safeguards in place to protect the information, ensure enforceable data subject rights and have effective legal remedies for data subjects where applicable.
  - Subject Access Request (SAR) – we have revised our SAR procedures to accommodate the revised 30-day timeframe for providing the requested information and for making this provision free of charge. Our new procedures detail how to verify the data subject, what steps to take for processing an access request, what exemptions apply and a suite of response templates to ensure that communications with data subjects are compliant, consistent and adequate.
  - Legal Basis for Processing - we are reviewing all processing activities to identify the legal basis for processing and ensuring that each basis is appropriate for the activity it relates to. Where applicable, we also maintain records of our processing activities, ensuring that our obligations under Article 30 of the GDPR and Schedule 1 of the Data Protection Bill are met.
  - Privacy Notice/Policy – we [have revised/are revising] our Privacy Notice(s) to comply with the GDPR, ensuring that all individuals whose personal information we process have been informed of why we need it, how it is used, what their rights are, who the information is disclosed to and what safeguarding measures are in place to protect their information.
  - Obtaining Consent - we [have revised/are revising] our consent mechanisms for obtaining personal data, ensuring that individuals understand what they are providing, why and how we use it and giving clear, defined ways to consent to us processing their information. We have developed stringent processes for recording consent, making sure that we can evidence an affirmative opt-in, along with time and date records; and an easy to see and access way to withdraw consent at any time.
  - Direct Marketing - we [have revised/are revising] the wording and processes for direct marketing, including clear opt-in mechanisms for marketing subscriptions; a clear notice and method for opting out and providing unsubscribe features on all subsequent marketing materials.
  - Data Protection Impact Assessments (DPIA) – where we process personal information that is considered high risk, involves large scale processing or includes special category/criminal conviction data; we have developed stringent procedures and assessment templates for carrying out impact assessments that comply fully with the GDPR’s Article 35 requirements. We have implemented documentation processes that record each assessment, allow us to rate the risk posed by the processing activity and implement mitigating measures to reduce the risk posed to the data subject(s).
  - Processor Agreements – where we use any third-party to process personal information on our behalf (i.e. Payroll, Recruitment, Hosting etc), we have drafted compliant Processor Agreements and due diligence procedures for ensuring that they (as well as we), meet and understand their/our GDPR obligations. These measures include initial and ongoing reviews of the service provided, the necessity of the processing activity, the technical and organisational measures in place and compliance with the GDPR.
  - Special Categories Data - where we obtain and process any special category information, we do so in complete compliance with the Article 9 requirements and have high-level encryptions and protections on all such data. Special category data is only processed where necessary and is only processed where we have first identified the appropriate Article 9(2) basis or the Data Protection Bill Schedule 1 condition. Where we rely on consent for processing, this is explicit and is verified by a signature, with the right to modify or remove consent being clearly signposted.
    Data Subject Rights
    
    In addition to the policies and procedures mentioned above that ensure individuals can enforce their data protection rights, we provide easy to access information via [our website, in the office, during induction etc] of an individual’s right to access any personal information that [Insert Organisation Name] processes about them and to request information about: -
    - What personal data we hold about them
    - The purposes of the processing
    - The categories of personal data concerned
    - The recipients to whom the personal data has/will be disclosed
    - How long we intend to store your personal data for
    - If we did not collect the data directly from them, information about the source
    - The right to have incomplete or inaccurate data about them corrected or completed and the process for requesting this
    - The right to request erasure of personal data (where applicable) or to restrict processing in accordance with data protection laws, as well as to object to any direct marketing from us and to be informed about any automated decision-making that we use
    - The right to lodge a complaint or seek judicial remedy and who to contact in such instances
  - Polkadoodles Ltd takes the privacy and security of individuals and their personal information very seriously and take every reasonable measure and precaution to protect and secure the personal data that we process. We have robust information security policies and procedures in place to protect personal information from unauthorised access, alteration, disclosure or destruction and have several layers of security measures, including: -
    - SSL, access controls, password policy, encryptions, pseudonymisation, practices, restriction, IT, authentication.
      GDPR Roles and Employees
      
      Polkadoodles Ltd have designated Nichola Hall as our [Data Protection Officer (DPO) and have appointed a data privacy team to develop and implement our roadmap for complying with the new data protection Regulation. The team are responsible for promoting awareness of the GDPR across the organisation, assessing our GDPR readiness, identifying any gap areas and implementing the new policies, procedures and measures.
      
      Polkadoodles Ltd understands that continuous employee awareness and understanding is vital to the continued compliance of the GDPR and have involved our employees in our preparation plans. We have implemented an employee training program specific to the which will be provided to all employees prior to May 25^th, 2018, and forms part of our induction and annual training program.
      
      If you have any questions about our preparation for the GDPR, please contact our Data Protection Officer (DPO).