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Privacy Policy

SECTION 1 – GENERAL INFORMATION
1 Introduction
1.1 Hydropool Devon Ltd., (referred to in this Privacy Notice as we, us, or our) is a controller for the personal information that it collects and uses about you. Our contact details are set out in section 13 of this Privacy Notice. Any reference in this Privacy Notice to you or your refers to anyone whose personal information we process. This Privacy Notice is to inform you how we will use your personal information, the legal basis which allows us to use your personal information, how we share your personal information and inform you of your rights in accordance with the laws in place that protect your personal information, including the Data Protection Act 1998, the Privacy and Electronic Communications (EC Direction Regulations 2003) and the General Data Protection Regulation 2016/679 and any subsequent data protection legislation which is implemented in the United Kingdom (together, “Data Protection Legislation”).
1.2 We will treat all of your personal information as confidential and in accordance with the Data Protection Legislation and your personal information will only be shared with others in accordance with this Privacy Notice.
1.3 We keep this Privacy Notice up to date, so if there are any changes to the way in which your personal information is used this Privacy Notice will be updated and we will ensure a notice of such changes is displayed on our website homepage for a reasonable period of time.
1.4 Any reference in this Privacy Notice to Group means Hydropool Devon Ltd. and its associated Companies (including Riviera Decking Ltd and Hayes Wellness Ltd). Hydropool Devon Ltd. operates under a number of different brands and this Privacy Notice applies to those brands. For more information about the brands, we operate under and for any updates on the brands in which we operate under please visit https://hydropooldevon.co.uk/contact-us/.
2 How to use this Privacy Notice
1.1 This Privacy Notice is split into three sections as detailed below:
1.1.1 Section 1: general information applicable to all individuals;
2.1.1 Section 2: information only applicable to Website users; and
2.1.2 Section 3: information only applies to prospective or actual customers who either purchase a hot tub, swim spa, bbq, furniture, garden room, summer kitchen or show interest in purchasing any products or services from us.
2.2 Please note, in the event you use the Website services offered by us and purchase a product from us, all sections of this Privacy Notice will be applicable to you. If you have any questions as to what sections of this Privacy Notice are relevant to you, please contact our Privacy Officer via sales@hydropooldevon.co.uk for more information.
3 What is personal information?
3.1 Personal information is any information that tells you something about a living individual. This could include information such as name, contact details, account number, date of birth and bank account details.
4 For how long do we keep your personal information?
4.1 We will keep your personal information for 7 years commencing on the date of our last interaction with you to comply with our regulatory obligations. Your personal information will be retained in accordance with our retention policy, your rights under Data Protection Legislation and in line with our regulatory obligations.

4.2 Any personal information will be deleted in accordance with our data retention policy.
5 What is the legal basis of our data processing?
5.1 Under Data Protection Legislation we are only permitted to use your personal information if we have a legal basis for doing so as set out in the data protection legislation. We rely on the following legal bases to use your personal information:
5.1.1 where you have provided consent for us to process your personal information;
5.1.2 where processing is necessary to enable us to perform our contract with you or take steps to enter into a contract with you at your request;
5.1.3 where we need to comply with a legal obligation; and
5.1.4 where it is necessary for our legitimate interests (of those of a third party) and your interests and fundamental rights do not override those interests.
5.2 In some cases we will need your consent to obtain and use your personal information. When this is the case, we will ask for your consent and we will explain why we need the personal information at the time when we ask for your consent. If we are relying on consent, you can withdraw your consent to our processing of your personal information at any time by contacting us using the contact details below.
5.3 The tables at the end of this Privacy Notice provide more detail about the personal information that we use, the legal basis that we rely on in each case and your rights.
5.4 Some information is classified as “special” data under Data Protection Legislation. This includes information relating to, amongst other things, health or information about any disability you may have. This information is more sensitive and we need to have further justifications for collecting, storing and using this type of personal information. We may process special categories of personal information in the following circumstances:
  • when processing disability information when managing a sale of a product to you (if applicable); and
  • when considering certain contents of a will that include special data when purchasing back a product from a deceased customer.
6 How do we share your personal information?
6.1 We will keep your personal information confidential and only share it with others for the purposes set out below and elsewhere in this Privacy Notice.
6.2 We will share your personal information in the following ways:
6.2.1 we share your personal information with any person working within the Group on a need to know basis to ensure we are able to perform our obligations to you;
6.2.2 we share your personal information with any organisation which you have given us permission to share it with;
6.2.3 we share your personal information with any organisation which we have sub-contracted or engaged to provide services on our behalf including Software providers and hosts, Postal fulfilment, Marketing fulfilment, Enquiry management, Payroll, Pensions and HR, Tax compliance, Training, Accident management, Legal and audit, Payment processing,product manufacturers,product logistics, Warranty providers, Leasing providers and finance companies, Service plan providers, and Market research which are based in the EEA, United States and India;
6.2.4 we may share your personal information with any other Hydropool retailers for inter-company referral purposes or if you make a complaint to a particular retailer and information from other retailers is needed to settle such complaint;
6.2.5 we may share your contact information with any of other retailers in the event you purchase anything from us to complete identity checks to ascertain whether you are a genuine retail customer or business customer;
6.2.6 we share your personal information with the relevant manufacturer (the manufacturer of the product purchased) to allow them to register your warranty and any required services for you;
6.2.7 we pass your personal information to selected third parties and agents who provide administrative support to us and who agree to only hold such personal information for the purposes set out in this Privacy Notice and under strict conditions to safeguard your personal information;
6.2.8 we share personal information with our regulators and law enforcement authorities and with courts, tribunals and arbitrators in order to comply with our regulatory and legal obligations; and
6.2.9 we share personal information in connection with any sale, merger, acquisition, disposal, reorganisation or similar change of our business.
7 Security
7.1 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 information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
7.2 We have put in place procedures to deal with any suspected personal data breaches and will notify you and any applicable regulator of a breach where we are legally required to do so.
7.3 Please note that as no data transmission over the Internet can be guaranteed to be 100% secure we cannot ensure or warrant the security of any information you transmit to us and you do so at your own risk.
8 Recording telephone calls
8.1 Telephone calls into and out of our business may be recorded for training or monitoring purposes as well as to assist with customer issues.
8.2 Telephone call records will be retained for seven years.
9 Overseas transfers of your personal information
9.1 Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
9.2 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:

(a) 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. For further details, see https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en
(b) 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. For further details, see https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en
(c) 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. For further details, see https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/eu-us-privacy-shield_en
10 Your rights in relation to your personal information
10.1 You have a number of rights in relation to your personal information, these include the right to:
10.1.1 Be informed about how we use your personal information;
10.1.2 Obtain access to your personal information that we hold;
10.1.3 Request that your personal information is corrected if you believe it is incorrect, incomplete or inaccurate;
10.1.4 Request that we erase your personal information in the following circumstances:

  • If Hydropool Devon is continuing to process personal information beyond the period when it is necessary to do so for the purpose for which it was originally collected;
  • If Hydropool Devon is relying on consent as the legal basis for processing the personal information and you withdraw consent;
  • If Hydropool Devon is relying on legitimate interests as the legal basis for processing the personal information and you object to this processing and there is no overriding compelling ground which enables us to continue with the processing;
  • If the personal information has been processed unlawfully (i.e. in breach of the requirements of the data protection legislation); or
  • If it is necessary to delete the personal information to comply with a legal obligation.

10.1.5 Ask us to restrict our data processing activities where you consider that:

  • Personal information is inaccurate;
  • Our processing of your personal information is unlawful;
  • Where we no longer need the personal information but you require us to keep it to enable you to establish, exercise or defend a legal claim; or
  • Where you have raised an objection to our use of your personal information;

10.1.6 Request a copy of certain personal information that you have provided to us in a commonly used electronic format. This right relates to personal information that you have provided to us that we need in order to perform our agreement with you and personal information where we are relying on consent to process your personal information;
10.1.7 Object to our processing of your personal information where we are relying on legitimate interests or exercise of a public interest task to make the processing lawful. If you raise an objection we will carry out an assessment to determine whether we have an overriding legitimate ground which entitles us to continue to process your personal information; and
10.1.8 Not be subject to wholly automated decisions which produce legal effects or which could have a similarly significant effect on you.
10.2 If you would like to exercise any of your rights or find out more, please write to use at sales@hydropooldevon.co.uk. The tables at the end of this notice provide more detail about the personal information that we use, the legal basis that we rely on in each case and your rights.
11 Processing your personal information based on consent – Marketing
11.1 If you have consented to receive marketing and/or promotional communications from us you can change your mind and opt out at any time. If you would like to stop receiving marketing and/or promotional communications from us, please contact us using the details below in section 13, or you can click on any of the opt-out links contained in our communications.
12 Complaints
12.1 If you have any complaints about the way we use your personal information please contact our Privacy Team who will try to resolve the issue. If we cannot resolve any issue, you have the right to complain to the data protection authority in your country (the Information Commissioner in the UK) via their website www.ico.org.uk. If you need more information about how to contact your local data protection authority please let us know by contacting sales@hydropooldevon.co.uk, call 01803 872 666 or write to us at Hydropool Devon, Units 1 – 3 Aller Mills, Kingskerswell, Newton Abbot, Devon, TQ12 5AU.
13 Contact details
13.1 If you have any questions, comments or requests regarding any aspect of this Privacy Notice, please do not hesitate to contact us at:
Privacy Officer Hydropool Devon, Units 1 – 3 Aller Mills, Kingskerswell, Newton Abbot, Devon, TQ12 5AU

Or via email, at sales@hydropooldevon.co.uk

SECTION 2 – WEBSITE USERS
Any reference to Website in this Privacy Notice refers to www.hydropooldevon.co.uk, hayeswellness.co.uk and rivieradecking.co.uk.
1 How do we collect personal information from our Website?
1.1 We collect personal information about you from various sources including:
1.1.1 web forms located on our Website (including, but not limited to, brochure downloads, voucher downloads, buyers guide downloads, contact form submissions and email list sign ups);
1.1.2 emails we provide to you so that you can contract us with enquiries and send us your details; and
1.1.3 through the use of cookies.
2 What personal information do we collect using our Website?
2.1 We collect the following types of personal information:
2.1.1 your name, email address, postal address, telephone or mobile number;
2.1.2 information about the products you’re interested in;
2.1.3 details of any contact made with you (either initiated by us or by yourself) including contact made with us;
2.1.4 details about any products and services which you have an interest in as offered on our Website; and
2.1.5 your marketing preferences (including any requests to opt-out of marketing).
2.2 If you give us personal information about somebody else, such as a colleague or family member etc., we will assume you have their permission to do so, and their data will also be subject to this Privacy Notice.
3 For what purposes do we use your personal information from our Website?
3.1 We use your personal information for the following purposes:
3.1.1 to respond to any enquiries or requests you make via our Website including requests to download brochures;
3.1.2 to provide our services to you and to manage our business;
3.1.3 to keep you informed of other services we provide which may be of interest to you (if you have consented to such marketing or an exemption applies), unless you have opted not to receive such information. We will use your name and email address to send the marketing communications to you;
3.1.4 to personalise and improve our services by analysing how many times you visit the Website, analysing your location data and behavioural patterns;
3.1.5 to analyse how users utilise the Website; and
3.1.6 to comply with our legal obligations and professional codes and to identify, prevent or detect fraud or other crimes.
4 Using your personal information for profiling/automated decision making
4.1 We do not use your personal information for profiling or automated decision making.
5 Social Media
5.1 The Website offers you the opportunity the recommend our Website to your friends on third-party social media site (for example, through ‘liking’ options).
5.2 We offer this functionality to raise interest in our Website, however, please be aware that when sharing information with third-party social media sites, your personal information may become public. We recommend you always read the privacy notices of the third party social media site to understand how your data is being used.
6 Links to other website
6.1 Our Website provides links to other sites, which may not be governed by this Privacy Notice and you should view the particular privacy notices of those sites for further information.
SECTION 3 – PROSPECTIVE OR ACTUAL CUSTOMERS
1 How do we collect personal information from you?
1.1 We collect personal information about you from various sources including:
1.1.1 through the provision of a sale of a product we sell;
1.1.2 through the marketing of a product we sell to you in your pursuit to purchase said product;
1.1.3 the personal information you provide us when any contact is made with you (by way of telephone call, email or by any other means) in accordance with the provision of our services;
1.1.4 any personal information we already hold about you;
1.1.5 and personal information provided in customer surveys; and
1.1.6 any personal information we obtain from searching public records, such as the Electoral Roll, that are available from credit rating agencies to help us verify your identity or determine your financial status.
2 What personal information do we collect during the potential or actual sale of a product?
2.1 We collect the following types of personal information:
2.1.1 your name, date of birth, email address, postal address, telephone or mobile number;
2.1.2 information about your product including theproduct make, model, registration number and mileage (if applicable);
2.1.3 identity documentation such as your national insurance number, driving licence or passport number;
2.1.4 financial details such as your income, salary and statements of net worth (in the event you require financing);
2.1.5 bank details;
2.1.6 records/letters from your doctor or details of any disability you may have;
2.1.7 death certificates, marriage certificates, wills and power of attorneys;
2.1.8 documentation evidencing you are eligible for a VAT free sale (if applicable);
2.1.9 CCTV footage (we retain CCTV footage for one month);
2.1.10 details of any contact made with you (either initiated by us or by yourself);
2.1.11 details about any products and services which you have an interest in as offered during the potential or actual sale of a product; and
2.1.12 your marketing preferences (including any requests to opt-out of marketing).
2.2 If you give us personal information about somebody else, such as a colleague, we will assume you have their permission to do so, and their data will also be subject to this Privacy Notice.
3 For what purposes do we use your personal information during a potential or actual sale of a product?
3.1 We use your personal information for the following purposes:
3.1.1 to provide financing services to you to assist with the purchase of your product;
3.1.2 to provide our services to you and to manage our business;
3.1.3 to manage discrete cases when customers purchase a product;
3.1.5 to keep you informed of other services we provide which may be of interest to you (if you have consented to such marketing or an exemption applies), unless you have opted not to receive such information. We will use your name and email address to send the marketing communications to you;
3.1.6 if you are acting on behalf of a business and you make this explicitly clear to us, we may send you marketing material that we feel you/your business may be interested in. If we send electronic marketing to you, we will ensure there is a clear option allowing you to opt-out of future marketing;
3.1.7 to monitor and improve the services we offer to you;
3.1.8 to comply with our legal obligations and professional codes and to identify, prevent or detect fraud or other crimes; and
3.1.9 in connection with any sale, merger, acquisition, disposal, reorganisation, restructuring or similar change to our organisation.
3.2.1 Your contact details including your title and name;
3.2.2 Your address; and
3.2.3 Any directorship information.
4 Using your personal information for profiling/automated decision making
4.1 We do not use your personal information for profiling or for automated decision making. However if you apply for any finance or credit product via a third party they may use your personal information in this manner. We therefore recommend you review those third parties’ privacy notices to confirm you are satisfied with the way in which they process your personal information.
A quick check of Hydropool Devon’s use of your personal information: Website Users

Purpose Data used Legal basis Which rights apply?*
To respond to any enquiries or requests you make via our Website including requests to have your product serviced Your name, email address, postal address, telephone number, mobile number. Contractual necessity The generally applicable rights plus the right to data portability
To respond to any enquiries or requests you make via our Website including requests to have your hot tub or swim spa serviced Your name, email address, postal address, telephone number, mobile number, information about your hot tub or swim spa including the  make, model, serial number and age and details of any contact made with you Legitimate interest. It is in our interest to ensure that its customers’ requests are responded to in a timely manner to ensure customer satisfaction remains high The generally applicable rights plus the right to object
To provide our services to you Your name, email address, postal address, telephone number, mobile number, information about your product including, details of any contact made with you, details about any products and services which you have an interest in and your marketing preferences. Contractual necessity. It is in our interest to ensure it complies with its contractual obligations to customers The generally applicable rights plus the right to data portability
To keep you informed of other services we provide which may be of interest to you (if you have consented to such marketing or an exemption applies), unless you have opted not to receive such information. Your name, email address, postal address, telephone number, mobile number, details about any products and services which you have an interest in and your marketing preferences. Legitimate interest. It is in Hydropool Devon’s interest to ensure that all customers are receiving the most up-to-date services and products. This will increase customer satisfaction and hopefully reduce any complaints about service offerings etc. The generally applicable rights plus the right to object
To keep you informed of other services we provide which may be of interest to you (if you have consented to such marketing or an exemption applies), unless you have opted not to receive such information. Your name, email address, postal address, telephone number, mobile number, details about any products and services which you have an interest in and your marketing preferences. Consent The generally applicable rights plus the right to data portability
If you are acting on behalf of a business (not including a sole trader or a partnership) and you make this clear to us, we may send you marketing material that we feel you/your business may be interested in. If we send electronic marketing to you, whilst this is not required by law, we will ensure there is a clear option allowing you to opt-out of future marketing. Your name, email address, postal address, telephone number and mobile number Legitimate interest. It is in Hydropool Devon’s interest to ensure all business customers receive up-to-date information about our products and services that would benefit your business and increase customer satisfaction. The generally applicable rights plus the right to object
To personalise and improve our services by analysing how many times you visit the Website, analysing your location data and behavioural patterns Your name, email address, telephone number, mobile number, details of any contact made with you, your marketing preferences and details about any products and services which you have an interest in as offered on our Website Legitimate interest. It is in Hydropool Devon’s interest to always offer customers the most appropriate and applicable services to increase and maintain customer satisfaction The generally applicable rights plus the right to object
To analyse how users utilise the Website Your name, email address, telephone number, mobile number, details of any contact made with you and details about any products and services which you have an interest in Legitimate interest. It is in Hydropool Devon’s interest to analyse how users utilise the website to ensure that our can focus on improving any webpages of functionalities which users used frequently The generally applicable rights plus the right to object
To comply with our legal obligations and professional codes Your name, email address, postal address, telephone number, mobile number, and details of any contact made with you Legitimate and public interest The generally applicable rights plus the right to object
To comply with our legal obligations and professional codes Your name, email address, postal address, telephone number, mobile number, and details of any contact made with you Legal obligations The generally applicable rights
To identify, prevent or detect fraud or other crimes Your name, email address, postal address, telephone number, mobile number, and details of any contact made with you Legitimate interest. It is in both our interest as well as your interest to ensure the prevention of fraud and other crime is monitored. The generally applicable rights plus the right to object

*The following generally applicable rights always apply: right to be informed, right of access, right to rectification, right to erasure, right to restriction and rights in relation to automated decision making. Please see the “Your rights in relation to your information” section above for more detail of your rights and how to exercise them.


Quick check of Hydropool Devon’s use of your personal information: Customers

Purpose Data used Legal basis Which rights apply?*
To provide financing services to you to assist with the purchase of your product Your name, date of birth, email address, telephone or mobile number, identity documentation such as your national insurance number, driving licence or passport number, financial details such as your income and salary, bank details and records/letters from your doctor (if they are relevant to the financing of your product) Contractual necessity The generally applicable rights plus the right to data portability
To provide our services to you and to manage our business Your name, date of birth, email address, telephone or mobile number, identity documentation such as your national insurance number, driving licence or passport number, bank details, CCTV footage and details of any contact made with you Contractual necessity The generally applicable rights plus the right to data portability
To provide our services to you and to manage our business Your name, date of birth, email address, telephone or mobile number, identity documentation such as your national insurance number, driving licence or passport number, bank details, CCTV footage and details of any contact made with you Legitimate interest. It is in our interest to ensure our business is managed in the most effective way to ensure we provide a high standard of service to our customers. The generally applicable rights plus the right to object
To manage discrete cases when customers purchase a product (i.e. if you are eligible for a VAT free sale) Your name, date of birth, email address, telephone or mobile number, identity documentation such as your national insurance number, driving licence or passport number, bank details, records/letters from your doctor (including documentation evidencing a disability), documentation evidencing you are eligible for a VAT free sale and details of any contact made with you Contractual necessity The generally applicable rights plus the right to data portability
To keep you informed of other services we provide or updates on our current services which may be of interest to you (if you have consented to such marketing or an exemption applies), unless you have opted not to receive such information. We will use your name and email address to send the marketing communications to you Your name, email address, telephone or mobile number, details of any contact made with you, details about any products and services which you have an interest in as offered during the potential or actual sale of aproduct and your marketing preferences Legitimate interest. It is in our interest to ensure that all customers are receiving the most up-to-date services and products. This will increase customer satisfaction and hopefully reduce any complaints about service offerings etc. The generally applicable rights plus the right to object
To keep you informed of other services we provide or updates on our current services which may be of interest to you (if you have consented to such marketing or an exemption applies), unless you have opted not to receive such information. We will use your name and email address to send the marketing communications to you Your name, email address, telephone or mobile number, information about your product, details of any contact made with you, details about any products and services which you have an interest in as offered during the potential or actual sale of a product and your marketing preferences Consent The generally applicable rights plus the right to data portability
If you are acting on behalf of a business (not as a sole trader or a partnership) and you make this clear to us, we may send you marketing material that we feel you/your business may be interested in. If we send electronic marketing to you, whilst this is not required by law, we will ensure there is a clear option allowing you to opt-out of future marketing Your name, email address (including your business email address) and your telephone or mobile number (including your business telephone or mobile number) Legitimate interest. It is in our interest to ensure that all customers, including businesses, are receiving information that may provide a benefit to them or may assist in improving the services they receive from us The generally applicable rights plus the right to object
To monitor and improve the services we offer to you Your name, email address, telephone or mobile number, details of any contact made with you, details about any products and services which you have an interest in as offered during the potential or actual sale of a product, CCTV footage and your marketing preferences Legitimate interest. It is in our interest to monitor our services we offer you so we can adapt to customer trends to ultimately make the overall experience better for you The generally applicable rights plus the right to object
To comply with our legal obligations and professional codes Your name, date of birth, email address, telephone or mobile number, identity documentation such as your national insurance number, driving licence or passport number, bank details and details of any contact made with you Legal obligation The generally applicable rights
To identify, prevent or detect fraud or other crimes Your name, date of birth, email address, telephone or mobile number, identity documentation such as your national insurance number, driving licence or passport number, bank details and details of any contact made with you Legitimate interest. It is in both our interest as well as your interest to ensure the prevention of fraud and other crime is monitored. The generally applicable rights plus the right to object
In connection with any sale, merger, acquisition, disposal, reorganisation, restructuring or similar change to our organisation Your name, date of birth, email address, telephone or mobile number, identity documentation such as your national insurance number, driving licence or passport number, bank details and details of any contact made with you Legitimate interest. It is in our interest to ensure that in the event of any sale, merger or any other reorganisation, the appropriate parties post the reorganisation can provide services to you without any significant disruption The generally applicable rights plus the right to object
To record personal details in the event of non-payment at point of sale Your name, date of birth, email address, telephone or mobile number, identity documentation such as your national insurance number, driving licence or passport number, bank details and details of any contact made with you Contractual necessity The generally applicable rights plus the right to data portability

*The following generally applicable rights always apply: right to be informed, right of access, right to rectification, right to erasure, right to restriction and rights in relation to automated decision making. Please see the “Your rights in relation to your information” section above for more detail of your rights and how to exercise them.