Privacy Statement

1. Introduction

Welcome to First Tunnels' privacy statement.

We respect your privacy and are committed to protecting your personal data. This privacy statement will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you.

In short, we use your personal data to provide you with goods and services, to improve our website and services, and to comply with our legal obligations. We’re much like any other business. We don’t sell your personal data or share it with anyone unless we need to in the usual course of business (for example telling our delivery company where to deliver your parcels to, and giving our accounts to our accountants). However, our lawyers have told us that we need to provide you with more details than this, so here they are.

This privacy statement applies to information we collect about:

  • Visitors to our websites;
  • Visitors to our premises;
  • Customers (current and past); and
  • Suppliers (current and past).

This privacy statement was last updated on 1 July 2018. Historic versions can be obtained by contacting us.

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.

2. Important information and who we are

First Tunnels Limited is the controller and responsible for your personal data (referred to as "we", "us" or "our" in this privacy statement).

Our full details are:

Full name of legal entity: First Tunnels Limited

Email address: [email protected]

Postal address: First Tunnels Limited, Unit 5, Metcalf Drive, Altham Business Park, Altham, Accrington, BB5 5SJ

Registered address: First Tunnels Limited, c/o Walkers Accountants Ltd, Aireside House, Aireside Business Centre, Royd Ings Avenue, Keighley, West Yorkshire, BD21 4BX

Telephone number: 01282 601253

3. 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 about you which we have grouped together follows:

  • Identity Data includes first 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 and services 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 websites.
  • Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
  • Usage Data includes information about how you use our website, 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 website feature, or the number of customers purchasing certain products. 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 statement.

We do not actively 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 actively collect any information about criminal convictions and offences.

4. How is your personal data collected and used?

We use different methods to collect data from and about you including through:

4.1 Online

Details of how we use cookies can be found here.

When you visit our websites, we use a third party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the websites. This information is only processed by us in a way which does not identify anyone.

Our website search engine is also powered by Google. Search queries and results are logged anonymously to help us improve our website and search functionality. We do not collect any user-specific data.

You may decide to submit personal information to us through the website, for example when purchasing products or signing up to a newsletter.

To maintain the security and performance of our websites we use a third party service which processes the IP address of visitors and other Technical Data. This information is retained for a maximum period of 12 months.

When you set up an online account with us, we will request personal data from you in order to verify your identity and set up your account. This information will also be used when you interact with us through the websites. We will keep this information for a period of 12 months from the date of your last log in to the service, unless you have purchased products through our websites or we are allowed to send you marketing communications in which case such accounts will be kept active for so long as we keep such information in line with the rest of this policy.

We are also able to access certain personal data from social media platforms when you interact with our pages or accounts, so if you ‘like’ or share’ our Facebook page, then Facebook tells us that you have done this. For more details you should read Facebook’s privacy statements.

Our website 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.

4.2 Direct interactions.

We may collect personal information during our direct interactions with you. This may include through correspondence, telephone conversations or actually meeting you in person.

4.3 Data received from third parties

If you are a business customer and apply for a credit account we may use third party credit reference agencies to enable us to assess your application. Such information will retain on your account file for so long as the credit account is kept active, or until the date 12 months following the balance of your account being cleared.

5. 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 products). In this case, we may have to cancel an order for a product but we will notify you if this is the case at the time.

6. Customers RECORDS

By law we have to keep basic information about our customers for six years after they cease being customers for tax purposes.

We will also keep your purchase history information for the duration of any warranty period applicable to the products purchased, which may be in excess of the period stated above.

7. Marketing

We may use your personal data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.

You will receive marketing communications from us if you have requested information from us or purchased products from us and, in each case, you have not opted out of receiving that marketing.

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us.

Where you opt out of receiving these marketing messages, this will not apply to any messages that we send you about a product/service purchase, warranty registration, product/service experience or other transactions.

8. Service development

We use Aggregated Data to develop our services and products, but we may from time to time use your personal data, including feedback, responses to polls and surveys and other information provided by you to improve our service. This may include using recordings of calls for training purposes, and we will tell you if this is likely to be the case. You can ask for the call to not be used in this manner.

We may also use personal information that you have provided (including your communications with us) to offer customer support and fix problems.

9. 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.

10. Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out above. These parties may be:

  • Logistics providers (acting as processors) organising the delivery of your products.
  • Service providers (acting as processors) who provide IT and system administration services and support.
  • Professional advisers (acting as processors or joint controllers) including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
  • HM Revenue & Customs, regulators and other authorities (acting as processors or joint controllers) based in the United Kingdom who require reporting of 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 statement.

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.

11. International transfers

Some of our external third party 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.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
  • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

12. 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.

13. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These are summarised below:

  • Request access to your personal data (commonly known as a "data subject access request"). 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 the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though 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 or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of 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 may object to our processing of your personal data. 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 unlawful 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 you.
  • Withdraw consent at any time. Where we are relying on consent to process your personal data you may withdraw this consent at any time. 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.

If you wish to exercise any of the rights set out above, please contact us. If you are submitting a data subject access request it would be helpful if you could complete a copy of our subject access request form which can be found here. This will enable us to identify and deal with your request much more quickly.

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.

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.

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.

14. Your right to complain to the Information Commissioner’s Office.

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). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.