Data protection is of the utmost importance here at Rugmart, and we do whatever we can to ensure data is secure. The use of the Rugmart website (https://rugmart.co.uk) is possible without any indication of personal data; however, if a data subject wants to use special services via our website, processing of personal data could become necessary. If the processing of personal data is necessary and there is no statutory basis for such processing, we generally obtain consent from the data subject.

The processing of personal data, such as the name, address, e-mail address, or telephone number of a data subject shall always be in line with the General Data Protection Regulation (GDPR), and in accordance with the country-specific data protection regulations applicable to Rugmart. By means of this data protection declaration, our company would like to inform the general public of the nature, scope, and purpose of the personal data we collect, use and process. Furthermore, data subjects are informed, by means of this data protection declaration, of the rights to which they are entitled.

As the controller, Rugmart has implemented numerous technical and organisational measures to ensure the most complete protection of personal data processed through this website. However, Internet-based data transmissions may in principle have security gaps, so absolute protection may not be guaranteed. For this reason, every data subject is free to transfer personal data to us via alternative means, e.g. by telephone or by post.

Definitions

The data protection declaration of Rugmart is based on the terms used by the European legislator for the adoption of the General Data Protection Regulations (GDPR). Our data protection declaration should be legible and understandable for the general public, as well as our customers and business partners. To ensure this, we would like to first explain the terminology used.

In this data protection declaration, we use the following terms:

Personal data – Personal data means any information relating to an identified or identifiable natural person (also known as a data subject). An identifiable natural person is one who can be identified (directly or indirectly), in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Data subject – Data subject is any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing.

Processing – Processing is any operation or set of operations that are performed on personal data or on sets of personal data. It doesn’t matter whether or not this is done manually or by automated means.

Restriction of processing – Restriction of processing is the marking of stored personal data with the aim of limiting their processing in the future.

Profiling – Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person. Profiling can be used to analyse or predict aspects concerning that natural person’s performance at work, economic situations, health, personal preferences, interests, reliability, behaviour, location or movements.

Pseudonymisation – Pseudonymisation is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.

Controller or controller responsible for the processing – Controller or controller responsible for the processing is the natural or legal person, public authority, agency or other body that determines the purposes and means of the processing of personal data.

Processor – Processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

Recipient – Recipient is a natural or legal person, public authority, agency or another body, to which the personal data is disclosed, whether a third party or not. Public authorities that receive personal data in the framework of a particular enquiry shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.

Third party – Third party is a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.

Consent – Consent of the data subject is any freely given, specific, informed and unambiguous indication that the data subject signifies agreement to the processing of personal data relating to them.

Name and Address of the controller

Controller for the purposes of the General Data Protection Regulation (GDPR), other data protection laws applicable in Member states of the European Union and other provisions related to data protection is:

Rugmart
2 – 3 Woodbridge Road,
Guildford,
GU1 4PU

Phone: 01483 578874
Email: info@rugmart.co.uk
Website: https://rugmart.co.uk

The Use of Cookies

The Rugmart website uses cookies, which are text files that are stored on your computer by your web browser. Many websites and web servers use cookies to store information. You can read more about our cookies in our cookie policy.

Newsletter Subscriptions

On our website, visitors are given the opportunity to subscribe to our newsletter. We share company news and offers with our customers and business partners regularly by means of a newsletter. The company newsletter may only be received by the data subject if :

• the data subject has a valid email address, and
• the data subject registers for the newsletter through our online form

Double opt-in is enabled, which means that before you receive an email from our newsletter you must confirm your subscription. A confirmation email will be sent to the email address registered by a data subject. This confirmation email is used to prove whether the owner of the email address as the data subject is authorised to receive the newsletter.

During the registration for the newsletter, we also store the IP address of the computer system assigned by the Internet service provider (ISP) and used by the data subject at the time of the registration, as well as the date and time of the registration. The collection of this data is necessary in order to understand the (possible) misuse of the email address of a data subject at a later date, and it therefore serves the aim of the legal protection of the controller.

We use an Email Newsletter service called MailChimp, who collect and process the personal data collected as part of a registration for the newsletter. The subscription to our newsletter may be terminated by the data subject at any time. There is an unsubscribe  link is found at the bottom of each newsletter that is sent out by MailChimp. It is also possible to unsubscribe from the newsletter at any time directly on the website of the controller, or to communicate this to the controller in a different way.

Newsletter Tracking

The newsletter emails contains a tracking pixel, which is a miniature graphic. The pixel is embedded in emails, which are sent in HTML format to enable log file recording and analysis. This allows a statistical analysis of the success or failure of online marketing campaigns through MailChimp. Based on the embedded tracking pixel, Rugmart may see if and when an email was opened by a data subject, and which links in the email were clicked by data subjects.

Such personal data collected in the tracking pixels contained in the newsletters are stored and analysed by the controller to improve the content of future newsletters. If you do not wish to receive the newsletter you can unsubscribe at any time by clicking the link at the bottom of the email or you can simply contact us. After a revocation, the personal data will be deleted by the controller. Rugmart automatically regards a withdrawal from the receipt of the newsletter as a revocation.

Website Contact Forms

Our website contains information that enables users to contact us and we display our postal address, telephone and email address on our contact us page. If a data subject contacts the controller by email or via a contact form, the personal data transmitted by the data subject is automatically stored. Such personal data transmitted on a voluntary basis by a data subject to the data controller are stored for the purpose of processing or contacting the data subject. There is no transfer of this personal data to third parties.

Subscription to comments in our blog

The comments made in the blog of Rugmart may be subscribed to by third parties. In particular, there is the possibility that a commenter subscribes to the comments following thier comments on a particular blog post. If a data subject decides to subscribe to be notified of follow up comments then the controller will send an automated confirmation email to check the double opt-in procedure. Double opt-in is required to verify that the request has come from the data subject. The option to subscribe to comments may be terminated at any time by the data subject.

Routine erasure and blocking of personal data

The data controller shall process and store the personal data of the data subject only for the period necessary to achieve the purpose of storage, or as far as this is granted by the European legislator or other legislators in laws or regulations to which the controller is subject to. If the storage purpose is not applicable, or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data are routinely blocked or erased in accordance with legal requirements.

Rights of the data subject

• a) Right of confirmation – Each data subject shall have the right granted by the European legislator to obtain from the controller the confirmation as to whether or not personal data concerning him or her are being processed. If a data subject wishes to avail himself of this right of confirmation, he or she may, at any time, contact any employee of the controller.
• b) Right of access – Each data subject shall have the right granted by the European legislator to obtain from the controller free information about their personal data stored at any time. You can submit a data access request to us and we have 30 calendar days to comply with your request. We usually respond to emails within 48 hours but to compile the report about what information is stored, collected and processed would take longer.
• The European directives and regulations grant the data subject access to the following information:
  • the purposes of the processing;
  • the categories of personal data concerned;
  • the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
  • where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
  • the existence of the right to request from the controller rectification or erasure of personal data, or restriction of processing of personal data concerning the data subject, or to object to such processing;
  • the existence of the right to lodge a complaint with a supervisory authority;
  • where the personal data are not collected from the data subject, any available information as to their source;
  • the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject.
• Furthermore, the data subject shall have a right to obtain information as to whether personal data is transferred to a third country or to an international organisation. Where this is the case, the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer of information.
• c) Right to Rectification – Each data subject shall have the right granted by the European legislator to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.If a data subject wishes to exercise this right to rectification, he or she may, at any time, contact any employee of the controller.
• d) Right to be Forgotten – Each data subject shall have the right granted by the European legislator to request the erasure of personal data concerning them without undue delay. The controller shall have the obligation to erase personal data where one of the following grounds applies, as long as the processing is not necessary:
• • The personal data is no longer necessary in relation to the purposes for which they were collected or otherwise processed.
  • The data subject withdraws consent to which the processing is based according to point (a) of Article 6 of the GDPR, or point (a) of Article 9 of the GDPR, and where there is no other legal ground for the processing.
  • The data subject objects to the processing pursuant to Article 21 of the GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21 of the GDPR.
  • The personal data have been unlawfully processed.
  • The personal data must be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.
  • The personal data have been collected in relation to the offer of information society services referred to in Article 8 of the GDPR.
• If one of the aforementioned reasons apply, and a data subject wishes to request the erasure of personal data stored by Rugmart then they can contact us. An employee of Rugmart shall check the proof of identity records before handling the erasure request is complied with immediately.The right to be forgotten isn’t an absolute right – we may have a legal obligation to store personal information for several years to comply with other legislation. The controller, taking account of available technology and the cost of implementation, shall take reasonable steps to inform other controllers processing the personal data that the data subject has requested erasure.
• e) Right to restriction of processing – Each data subject shall have the right granted by the European legislator to obtain from the controller restriction of processing where one of the following applies:
• • The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.
  • The processing is unlawful and the data subject opposes the erasure of the personal data and requests instead the restriction of their use instead.
  • The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims.
  • The data subject has objected to processing pursuant to Article 21(1) of the GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject.
• If one of the aforementioned conditions is met, and a data subject wishes to request the restriction of the processing of personal data stored by Rugmart, he or she may at any time contact any employee of the controller. The employee of Rugmart will arrange the restriction of the processing.
• f) Right to data portability – Each data subject shall have the right granted by the European legislator, to receive the personal data concerning him or her, which was provided to a controller, in a structured, commonly used and machine-readable format. He or she shall have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, as long as the processing is based on consent pursuant to point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR, or on a contract pursuant to point (b) of Article 6(1) of the GDPR, and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.Furthermore, in exercising his or her right to data portability pursuant to Article 20(1) of the GDPR, the data subject shall have the right to have personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.In order to assert the right to data portability, the data subject may at any time contact any employee of Rugmart.
• g) Right to object – Each data subject shall have the right granted by the European legislator to object, on grounds relating to his or her particular situation, at any time, to processing of personal data concerning him or her, which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to profiling based on these provisions. Rugmart shall no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defence of legal claims.
• If Rugmart processes personal data for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing. This applies to profiling to the extent that it is related to such direct marketing. If the data subject objects to Rugmart to the processing for direct marketing purposes, Rugmart will no longer process the personal data for these purposes.In addition, the data subject has the right, on grounds relating to his or her particular situation, to object to processing of personal data concerning them by Rugmart for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
• In order to exercise the right to object, the data subject may contact any employee of Rugmart. In addition, the data subject is free in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to use his or her right to object by automated means using technical specifications.
• h) Automated individual decision-making (including profiling) – Each data subject shall have the right granted by the European legislator not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her, or similarly significantly affects him or her, as long as the decision (1) is not is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) is not authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, or (3) is not based on the data subject’s explicit consent.
• If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) it is based on the data subject’s explicit consent, Rugmart shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and contest the decision.If the data subject wishes to exercise the rights concerning automated individual decision-making, he or she may, at any time, contact any employee of Rugmart.
• i) Right to withdraw data protection consent – Each data subject shall have the right granted by the European legislator to withdraw his or her consent to processing of his or her personal data at any time.f the data subject wishes to exercise the right to withdraw the consent, he or she may, at any time, contact any employee of Rugmart.

Legal basis for the processing

Art. 6(1) lit. a GDPR serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is party, as is the case, for example, when processing operations are necessary for the supply of goods or to provide any other service, the processing is based on Article 6(1) lit. b GDPR. The same applies to such processing operations which are necessary for carrying out pre-contractual measures, for example in the case of inquiries concerning our products or services. Is our company subject to a legal obligation by which processing of personal data is required, such as for the fulfillment of tax obligations, the processing is based on Art. 6(1) lit. c GDPR.

In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or of another natural person. This would be the case, for example, if a visitor were injured in our company and his name, age, health insurance data or other vital information would have to be passed on to a doctor, hospital or other third party. Then the processing would be based on Art. 6(1) lit. d GDPR.

Finally, processing operations could be based on Article 6(1) lit. f GDPR. This legal basis is used for processing operations which are not covered by any of the abovementioned legal grounds, if processing is necessary for the purposes of the legitimate interests pursued by our company or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data. Such processing operations are particularly permissible because they have been specifically mentioned by the European legislator. He considered that a legitimate interest could be assumed if the data subject is a client of the controller (Recital 47 Sentence 2 GDPR).

The legitimate interests pursued by the controller or by a third party

Where the processing of personal data is based on Article 6(1) lit. f GDPR our legitimate interest is to carry out our business in favor of the well-being of all our employees and the shareholders.

Period for which the personal data will be stored

The criteria used to determine the period of storage of personal data is the respective statutory retention period. After expiration of that period, the corresponding data is routinely deleted, as long as it is no longer necessary for the fulfillment of the contract or the initiation of a contract.

Automated decision-making

As a responsible company, we do not use automatic decision-making or profiling.