TRULY PRIVACY POLICY – www.truly.co.uk

WHO IS TRULY?

www.truly.co.uk (together with any successor or replacement URL, the “Website”) is a website operated by Truly Group Limited ("Truly") a company registered in England and Wales under company number 10355694 with registered office at Network House, Third Avenue, Globe Park, Marlow, Buckinghamshire, United Kingdom, SL7 1EY.

ABOUT THIS PRIVACY POLICY

This policy sets out when and how Truly will use your personal information. Please keep in mind that if you follow a link to any other websites via the Truly Website, those other sites’ privacy policies will apply to how they use your personal information.

HOW DOES TRULY USE YOUR DATA?

Make a Purchase

When you make a purchase from the Website, Truly will use your personal information to complete your purchase. The details Truly collects from you will include your name, address, email address, phone number and payment details.

If you choose to create an account when using the Website, Truly uses the same information you provided to make a purchase to create your online account. Truly relies on your consent to do this, which you can withdraw at any time.

To complete your purchase, Truly will share your personal information with its subcontractors who are involved in the purchase process (e.g. payment providers, credit reference agencies who Truly use to assess fraud, credit and/or security risks, and fulfilment and delivery service providers). Truly needs to process your personal information in this way to enter into and perform the contract for your purchase.

Customer Service

When you contact Truly (including via its website chat service), Truly will use your personal information (your name, contact details and the other details you provide) in order to assist you with your enquiry. Truly relies on your consent to use your personal information in this way, which you can withdraw at any time.

If you do not provide Truly with the personal information it requests from you for the purposes of Truly dealing with your customer service enquiry, Truly may not be able to fully assist you with your enquiry.

Marketing Purposes

If you have opted in to receive marketing communications from Truly, Truly will use your personal information (such as your name, email address and age) to provide you with marketing communications in line with the preferences you selected when you opted in.

Truly relies upon your consent to contact you for marketing purposes. You can withdraw your consent at any time by logging into your Truly account and checking or unchecking relevant boxes to adjust your marketing preferences, or by following the opt-out/unsubscribe links on any marketing message that Truly sends to you. If in doubt, you can contact Truly at help@truly.co.uk at any time.

If you opt-out/unsubscribe from receiving marketing communications, you will stop receiving marketing communications from Truly as soon as Truly has processed your request and, in any event, within 28 days of your unsubscribe request.

DATA TRANSFER ON SALE OF TRULY’S BUSINESS

If Truly sells its business, it will transfer your personal information to the purchaser so that the purchaser can continue operating the Truly business. Truly processes your personal information in this way because of Truly’s legitimate interest to ensure its business can be continued by the purchaser. If you object to the use of your personal information in this way, the relevant purchaser of Truly’s business may not be able to provide products/services to you. Truly will always make sure any such transfer is subject to your rights under this Privacy Policy, and applicable laws.

COMPLIANCE WITH LEGAL OBLIGATIONS

Truly may need to share your personal information where it is under a legal obligation to to disclose or share it.

COOKIES

Truly uses cookies to give you the best and most relevant experience when using the Truly Website. For more information on cookies, how Truly uses them and your rights please read Truly’s Cookie Policy.

WHERE IS YOUR DATA STORED?

All information you provide to Truly is stored on secure servers (or those of its data storage partners) in locations within the EU.

HOW LONG DOES TRULY RETAIN YOUR DATA FOR?

Truly will only store, use and process your personal information for as long as it can in accordance with applicable laws. Details of retention periods for different aspects of your personal information are available in Truly’s data retention policy, which is available upon request.

WHAT ARE YOUR RIGHTS UNDER DATA PROTECTION LAWS?

Under certain circumstances you have the right to object to how Truly uses your personal information under applicable data protection laws. Your other rights include:

  • Right of access

    You are entitled to receive confirmation of the personal information belonging to you that Truly is processing together with details of Truly’s use of that personal information.

    You also have the right to have access to a copy of the personal information belonging to you which Truly is using.

  • Right to rectification

    You have the right to require Truly to rectify any inaccurate personal information it holds about you. You also have the right to complete any incomplete personal information that Truly holds about you by providing relevant additional supplementary information.

  • Right to restriction

    You can restrict Truly’s processing of your personal information where:

    • you think Truly holds inaccurate personal information about you;
    • Truly’s handling of your personal information is in breach of applicable law, but you do not want Truly to delete it;
    • Truly no longer needs to process your personal information, but you want Truly to keep it for legal reasons; or
    • where Truly is handling your personal information because it has a legitimate interest and you are in the process of objecting to such use of your personal information.

    Where you exercise your right to restrict Truly from using your personal information, Truly will then only process your personal information pursuant to its legitimate interests and where you otherwise consent to such processing.

  • Right to data portability

    You have the right to receive a copy of the personal information Truly holds about you in a structured, standard machine-readable format and to send this to another organisation controlling your personal information.

  • Right to erasure

    You have the right to require Truly to erase your personal information which it is handling in the following circumstances:

    • where Truly no longer needs to use your personal information for the reasons it told you it collected it for;
    • where Truly needs your consent to use your personal information and you have withdrawn your consent;
    • when you object to Truly’s use of your personal information and Truly has no legitimate interest to carry on handling your personal information;
    • if Truly’s handling of your personal information is in breach of applicable laws;
    • when Truly must erase your personal information to comply with a law it is subject to.
  • Right to complain

    You have the right to lodge a complaint in relation to Truly’s use of your personal data with the Information Commissioner's Office, the supervisory authority for data protection issues in England and Wales.

You will not have to pay a fee to exercise these rights. However, Truly may charge a reasonable fee if your request is unfounded, repetitive or excessive. Alternatively, Truly may refuse to comply with your request in these circumstances.

Truly may need to request specific information from you to help confirm your identity, and confirm your eligibility to exercise your rights in connection with your personal information. This is a security measure to ensure that your personal information is not disclosed to anyone who has no right to receive it. Truly may also contact you to ask you for further information in relation to your request, to speed up Truly’s response.

HOW TO CONTACT TRULY

Privacy law is often complicated, and whether these rights are available to you sometimes depends on the types of data Truly are handling about you. If you would like to exercise any of these rights, please contact Truly at privacy@truly.co.uk.

WHEN/HOW TRULY CHANGES ITS PRIVACY POLICY

This Privacy Policy will be updated regularly, any changes made will be posted on this page and, where appropriate, notified to you. Please check back frequently to see any updates or changes to Truly’s Privacy Policy.

This privacy policy was last updated on 12 November 2018.