Privacy Policy

1. Introduction

1.1 This privacy notice explains in detail the types of personal data we may collect about you when you interact with us. It also explains how we will store and handle that data and keep it safe.

1.2 We know that there is a lot of information here, but we want you to be fully informed about your rights, and how Phone Clinic uses your data.

1.3 It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information. This privacy notice supplements the other notices and is not intended to override them.

1.4 Our Privacy Notice may be modified when there is a change to the way we process your personal data. We may update this Privacy Notice from time to time, to ensure that the information we provide to you is up to date and in accordance with the relevant data protection laws. Any new version of this Notice will be published on our website.

2. Personal Data Controller

2.1 Our Privacy Notice applies to the personal data that Phone Clinic collects and use to provide you with the service. Phone Clinic UK Trading Limited is the controller and responsible for your personal data (collectively referred to as “Phone Clinic”, “we”, “us” or “our” in this privacy notice). Phone Clinic controls the ways your personal data are collected and the purposes for which your personal data under the data protection laws that apply to us like UK GDPR and Data Protection Act 2018.

2.2 If you have any questions about this Privacy Notice, please contact our customer service team using the details below:

Email: customerservice@phoneclinicrepair.co.uk
Address: Phone Clinic Head Office, Suite 3.08, 20 Procter Street, London, WC1V 6NX.

3. The Data We Collect About You

3.1 When we refer to “personal data” in this notice, we mean information that related to you. We may collect, use, store, and transfer different kinds of personal data about you which we have grouped as follows:

- Identity Data – First name, last name, and title.
- Contact Data – Billing address, delivery address, email address, telephone number.
- Financial Data – Bank account and payment card details. (if applicable)
- Transaction Data – Details about payment to and from you and other details of products and services you have purchased from us.
- Technical Data – Internet Protocol (IP) Address, browser type and version, time zone and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
- Profile Data – Purchases or orders made by you, your interests, preferences, feedback, and survey responses.
- Usage Data – information about how you use our website, products, and services.
- Marketing and Communications Data – Your preferences in receiving marketing from us and our third parties and your communication preferences.

3.2 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. 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 notice.

3.3 We do not 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 bio-metric data). Nor do we collect any information about criminal convictions and offences.

3.4 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 with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

3.5 Device Passcode We collect device passcode data from our customers so that we can fully test the functionally of the device before and after we conduct each repair. The passcode is not used for any other purpose and no personal data is accessed as part of the functionality test. The passcode is automatically deleted after each repair. If you would prefer not to provide your passcode this is also fine although we will not be able to test your device after it has been repaired until you come back to collect it, which may cause delays should any repair adjustments need made following the test.

4. How is Your Personal Data Collected?

4.1 We use different methods to collect data from and about you including through direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

- Apply for our products or services
- Subscribe to our services
- Request marketing to be sent to you
- Enter a competition, promotion, or survey
- Give us some feedback
- Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see the Cookies section.
- Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
  - - Technical Data from the following parties: analytics providers [such as Google Analytics]
    - Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Shopify & Vend.

5. How and Why, We Use Your Personal Data

5.1 We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

- Where we need to perform the contact, we are about to enter or have entered into with you.
- Where it is necessary for our legitimate interests (or those of third party), by which we mean in the interest of our business in conducting and managing our business to enable us to give you the best service/product and the most secure experience.
- Where we need to comply with a legal or regulatory obligation.
- Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email or text message.

5.2 We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

5.3 Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.

Purpose/Activity

Type of Data

Lawful basis for processing including basis of legitimate inter

To register you as a new customer

Full Name
Contact

Performance of a contract with you

To process and deliver your order including:

- Manage payments, fees, and charges
- Collect and recover money owed to us
- Provision of device repair services

Full Name
Contact
Financial
Transaction

Performance of a contract with you
Necessary for our legitimate interests (to recover debts due to us)

To test the functionality of your device before and after the repair

Device Passcode

Performance of a contract with you

To manage our relationship with you or your organisation which will include:

- Notifying you about changes to our terms or privacy notice
- Asking you to leave a review or take a survey

Full Name
Contact
Marketing and Communications

Performance of a contract with you
Necessary for our legitimate interests (to keep our records updated
and to study how customers use our products/services)

To administer and protect our business and this website (including troubleshooting,
data analysis, testing, system maintenance, support, reporting and hosting of data)

Full Name
Contact
Technical

Necessary for our legitimate interests (for running our business, provision of
administration and IT services, network security, to prevent fraud and
in the context of a business reorganisation or group restructuring exercise)
Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and
measure or understand the effectiveness of the advertising we serve to you

Full Name
Contact
Usage
Marketing and Communications
Technical

Consent

To use data analytics to improve our website, products/services, marketing,
customer relationships and experiences

Technical
Usage

Consent

To make suggestions and recommendations to you about goods or services
that may be of interest to you

Full name
Contact
Technical
Usage

Consent

We capture CCTV footage from cameras operating at all our stores to help
protect the safety and wellbeing of our customers and employees and to protect our property and assets

CCTV Footage

Legitimate interest

To defend, manage or process legal claims and comply with legal obligations

CCTV dootage
Details provided in
incident reports

Necessary for compliance with our legal obligations

5.4 Marketing
We may use your Identity, Contact, Technical and Usage 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 (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased services from us and, in each case, you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any company outside of Phone Clinic UK Trading Ltd for marketing purposes.

5.5 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.

6. Your Data Protection Rights

6.1 The GDPR and other data protection laws give you specific rights that help you be in control of your personal data. We want to make it easy for you to exercise these rights. Below you will find more information about your rights and how we work to fulfil these. You can exercise any right in relation to the data that Phone Clinic holds about you, by completing the form at the end of this section.

6.2 For us to be able to process your request, you will need to provide us with the required information below:

- Your full name
- A description of the data you would like to access including a date range. An accurate description of your request will save you time and effort and will allow us to focus our searches on what you need and quickly reply to you.
- Email address you have used to book or communicate with us.
- Other information that may help us locate your data (e.g., your booking references).

6.3 If you submit a request on behalf of another person, we will need to ensure that this person has authorised you to make this request and receive their data.

6.4 Data Access
You are entitled to know whether we hold your personal data and if so, receive a copy of your data. You can use the form at the end if this section to request a copy or your personal data.

6.5 Data Rectification
If you believe that we hold incorrect or incomplete information about you, please let us know and we will correct it. Most of the times, you will be able to correct and update your information by contacting our customer service team. If this not possible, you can use the form below to notify us.

6.6 Data Retention
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

6.7 Objection
You can 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 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.

6.8 Restriction
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:

- If you want us to establish the data’s accuracy.
- Where our use of the data is unlawful, but you do not want us to erase it.
- 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.
- You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.

6.9 Withdrawing Consent
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. 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.

6.10 Opting out
You can ask us or third parties 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 at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase, warranty registration, product/service experience or other transactions.

7. Protecting Your Personal Data

7.1 We are committed to protecting the personal data we hold by taking appropriate technical and organisational measures against unauthorised, unlawful, or accidental access, loss, destruction, or damage of such personal data. We are constantly taking steps to improve in the field of Information Security as the sector itself is constantly changing as well.

7.2 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.

7.3 International Transfers
Our customer relationship management, marketing and accounting systems are either UK-based or, in cases where this is not true, data transfers are made in accordance with the requirements of the GDPR and may be based on the use of the European Commission’s Standard Contract Clauses for transfers of personal data outside the EEA (while awaiting UK’s Standard Contract Clauses). We will ensure that the transfer of personal data is adequately protected.

8. Why We Use Cookies

8.1 To improve our services, to provide you with more relevant content and to analyse how visitors use our website, we may use technologies such as cookies. Cookies are alphanumeric identifiers that are transferred to your computer’s hard drive through your Web browser when you visit one of our websites to enable our systems to recognise your browser and track when you return to our websites. All websites that you visit will use cookies.

8.2 The ‘Help’ menu on the menu bar of most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie and how to disable cookies altogether. However, cookies allow you to take full advantage of some of our websites’ most innovative and useful features and we recommend that you leave them turned on.

8.3 You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

8.4 Phone clinic work to protect the security of all your information during transmission by using the most up-to-date SSL software, which encrypts information you input, and offers the most advanced security software. Although we do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site – any transmission is at your own risk.

8.5 Phone Clinic maintain physical, electronic, and procedural safeguards in connection with the collection, storage, and disclosure of personally identifiable customer information.

9. Disclosure of Personal Data

9.1 We may have to share your personal data with other companies for the purposes set out in the table above (Section 5.2). Service providers acting as processors based inside and outside of the EU who provide IT and system administration services, logistics services, and downstream processing, including the following:

- Wordpress – Host the website
- Sage Pay – payment gateway
- Amazon Web Services – software host
- MS Office 365 – email
- TextBurst – SMS messages
- Royal Mail – postal records
- Dotdigital – marketing emails
- Companies House – company records & SIC searches
- Sign Now – electronic copies for all agreements
- Trustpilot – customer review service
- FreshDesk – customer service software
- Xero – accounting software
- Woodside, camerascan – CCTV
- HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the UK who require reporting of processing activities in certain circumstances.

9.2 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 Notice.

9.3 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.

10. Website Information

10.1 If you choose to use Phone Clinic website, your visit to the website and any other dispute or concerns that you may have over privacy is subject to this Privacy Notice. Phone Clinic UK Trading terms and conditions, including limitation on damages and application of the laws of England.

10.2 We may from time to time amend our privacy notice and/or our terms & conditions. Unless stated otherwise, our current privacy notice applies to all information that we have received from you.

10.3 Third-party Links
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 nor are responsible for their privacy statements. When you leave our website, we encourage you to the Privacy Notice of every website you visit.

11. Contact Infromation

11.1 We promise to make it easy and be open and upfront with you – this also applies to how we use your personal data. We always aim to be clear and transparent with our customers, but we understand that sometimes this can be complicated. If you have a concern in relation to how we use your personal data and satisfy your rights, please let us know; we will reply to your queries and if necessary, take steps to ensure our practices are consistent with our promise and our obligations.

11.2 If you have any concern about our website, business, or our privacy notice, please contact us so we can try to resolve your issue through:

Email: customerservice@phoneclinicrepair.co.uk
Customer Service, Phone Clinic Head Office
Suite 3.08
20 Procter Street
London
WC1V 6NX

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