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Privacy NOTICE

ABOUT THIS PRIVACY NOTICE

This privacy notice informs you of what happens to any personal data that you give to us, or any data that we may collect from you. It applies to all services and instances where we collect your personal data.

This privacy notice applies to personal information processed by Clive Morley Harps Ltd.

CHANGES TO THIS PRIVACY NOTICE

We may change this privacy notice from time to time by updating this page in order to reflect changes in the law and/or our privacy practices.

PRIVACY NOTICE FOR RELEVANT GROUPS

A: CUSTOMERS

What personal information about you do we process?

Information given to us by you, either by phone or via our website:

Contact details, such as full name, address, telephone number, email address

How is this data used?

To process orders

To contact you in relation to queries arising from an order or enquiry

How is this data stored?

Customer contact information is stored on our Sage Line 50 Program

Emails are stored with a secure and encrypted email client

Web orders are stored on our Actinic program and paper copies of orders are kept for 3 months

Records of monetary transactions are stored in Sagepay or PayPal platforms. Credit card details are encrypted. If we need to take card details over the phone, the information is shredded once the payment has been processed. Card details are not stored.

B: RENTAL CUSTOMERS

What personal information about you do we process?

Information required for preparing a Rental Contract. This includes:

Personal and contact details, such as full name, address, telephone number and email address. We also require date of birth, NI or Passport number and employment details. We require previous address information if you have lived at your current address for less than 3 years.

How is this data used?

To prepare a Rental Agreement.

This information is shared with Experian (consumer credit check), and Signable (for sending out electronic agreements). If your instrument is delivered by courier we share your address and contact details with a courier company (usually Parcelforce).

This information is not used for marketing purposes.

How is this Data stored?

Data is stored on our Sage Line 50 program and paper copies of rental agreements and supporting documentation are kept in a locked cabinet whilst active and archived for 7 years at the end of the rental period.

C: THOSE WHO HAVE CONTACTED US WITH ENQUIRIES

What personal information about you do we process?

Information given during initial contact may be taken. This includes:

Contact details such as full name, address, telephone and email address.

The nature of your enquiry.

How is this data used?

To provide you with a relevant and appropriate service

To contact you in response to your queries

How is this Data stored?

Emails are stored with a secure and encrypted email client

Paper notes are shredded once the enquiry has been dealt with

D: THOSE WHO HAVE GIVEN THEIR CONSENT TO BE SENT MARKETING MATERIALS

What personal information about you do we process?

Contact details limited to name, address, email address and telephone number

How is this Data stored?

Contact information is stored on our Sage Line 50 Program.

D: HARP TEACHERS LISTED ON OUR WEBSITE

What personal information about you do we process?

Contact details limited to name, address, email address and telephone number, website address if applicable

Information on type of teaching/performing and area where services are offered

How is this Data stored?

Contact information is stored on our Sage Line 50 Program

Teacher details are displayed on our website once prior permission has been received (either verbally or in writing)

FURTHER INFORMATION

What is the source of your personal information?

Personal information that we hold has been given to us by you. We do not collect personal information from any third party.

What are the legal grounds for our processing of your personal information (including when we share it with others)?

We rely on the following legal bases to use your personal data:

Where it is needed to provide you with our services

Where it is needed in order to trace your whereabouts, in order to recover instruments on hire, to recover debt (if necessary)

Where it is in our legitimate interests to do so such as:

Following guidance and recommended best practice of government and regulatory bodies

To keep records of our communications with you

Where we need to share your personal information with public bodies or organisations in order to comply with any legal and/or regulatory obligations

For direct marketing communications, where consent has been given

When do we share your personal information with other organisations?

As previously stated, if you are renting an instrument from us we will need to share your information with a credit reference agency and also with an eSignature provider (currently Signable), and occasionally with a debt collection agency.

Where customers have requested goods to be delivered by courier, we need to pass on address and contact details to the courier company (usually Parcelforce).

For customers requesting harp repairs or servicing, we may pass your contact information to one of our harp technicians (who work with us but as a self-employed contractors).

How and when you can withdraw your consent?

Where we are relying upon your consent to process personal data, you can withdraw this at any time, either by clicking on the Unsubscribe link at the bottom of the newsletter, by contacting us via the Contact Us section of our website, tel 01367 860493 or harps@morleyharps.com

Is your Personal information transferred outside the UK or the EEA?

Your personal information will not be transferred outside the European Economic Area.

What should you do if your personal information changes?

You should tell us so that we can update our records using the details in the Contact Us section of our website, or at 01367 860493.

Are you obliged to provide your personal information to us?

We are unable to provide you with our services if you do not provide certain information to us. In cases where providing some personal information is optional, this will be made clear.

For how long is your personal information retained by us?

Unless we explain otherwise to you, we shall hold your personal information based on the following criteria:

For as long as we have reasonable business needs, such as managing our relationship with you

For as long as we provide services to you and then, in the case of rental customers, for a period of 7 years.

Retention periods in line with legal and regulatory requirements or guidance (typically seven years).

What are your rights under data protection laws?

Here is a list of the rights that all individuals have under data protection laws. They do not apply in all circumstances. If you wish to use any of them, we will explain at that time if they are engaged or not. The right of data portability is only relevant from May 2018.

The right to be informed about the processing of your personal information

The right to have your personal information corrected if it is inaccurate and to have incomplete personal information completed.

The right to object to processing of your personal information.

The right to restrict processing of your personal information

The right to have your personal information erased (the “right to be forgotten”)

The right to request access to your personal information and to obtain information about how we process it

The right to move, copy or transfer your personal information (“data portability”)

Rights in relation to automated decision making which has a legal effect or otherwise significantly affects you.

You have the right to complain to the Information Commissioner’s Office which enforces data protection laws: https://ico.org.uk/

Are you a member of the ICO?

Yes. As a small business who controls data electronically, we are obliged to be registered with the ICO.

Contact Us

If you have any questions about this privacy notice, or if you wish to exercise your rights, you can contact us at this address:

Clive Morley Harps Ltd.

Goodfellows

Filkins

GL7 3JG Tel: 01367 860493