PRIVACY POLICY

Welcome to Paul Hartmann Ltd.’s privacy policy.

Paul Hartmann Ltd respects your privacy and is committed to protecting your personal data. This privacy policy will inform you how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

This privacy policy is provided in a layered format, so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.

• 1. IMPORTANT INFORMATION AND WHO WE ARE
• 2. THE DATA WE COLLECT ABOUT YOU
• 3. HOW IS YOUR PERSONAL DATA COLLECTED
• 4. HOW WE USE YOUR PERSONAL DATA
• 5. DISCLOSURES OF YOUR PERSONAL DATA
• 6. INTERNATIONAL TRANSFERS
• 7. DATA SECURITY
• 8. DATA RETENTION
• 9. YOUR LEGAL RIGHTS
• 10. GLOSSARY

1. Important information and who we are

Who We Are

The HARTMANN family has pioneered healthcare and hygiene products since 1818, designing ground-breaking solutions for almost 200 years. Find out more about our company history.

Purpose of this privacy policy

This privacy policy aims to give you information on how Paul Hartmann Ltd collects and processes your personal data through your use of this website, including any data you may provide through this website when you purchase products, make enquiries about our products or sign up to our newsletter.

This website is not intended for children and we do not knowingly collect data relating to children through this website.

It is important that you read this privacy policy together with any other privacy policy or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements the other policies and is not intended to override them.

Controller

Paul Hartmann Ltd is the controller and responsible for your personal data (collectively referred to as “Paul Hartmann Ltd”, "we", "us" or "our" in this privacy policy).

We have a Data Protection Team led by an appointed Data Protection Officer, who are responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the Data Protection Team using the details set out below.

Contact details

Data Protection Coordinator

Paul Hartmann Ltd

Unit P2 Parklands,

Heywood Distribution Park,

Pilsworth Road,

Heywood,

OL10 2TT.

Email: [email protected]

Tel: 01706 363 200

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy policy and your duty to inform us of changes

This version was last updated on 28th November 2023 and historic versions can be obtained by contacting us.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

We may from time to time make available through our site certain services provided by third parties via 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. To gain access to these services, you must register with these third parties and deal with them directly.

We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit before you submit any personal data to these websites. We do not accept any responsibility or liability for these third party web-sites.

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

• When you purchase products or make enquiries about our products you will be asked to register with us. At this time or at any other when you otherwise provide us with your personal data while on our site we may collect personal data from you, such as your name, billing address and delivery address details, your email address and a contact telephone number.
• We will also require your credit/debit card details to process transactions. We do not directly store these details, as financial transactions are processed by our payment partners, but we do have access to Transaction Data which includes details about payments from you and other details of products and services you have purchased from us.
• When you sign up to be kept informed about our products we may collect your personal data, such as your name and email address.
• If you contact us by telephone or by using our interactive chat function we may collect your name, contact telephone number and email address.
• As you move around our site we will collect technical information about your visit, such as which pages you visit, how often you visit and what links you click on, the Internet protocol (IP) address used to connect your computer to the internet, your login information, browser type and version, operating system and platform.
• We may also collect other information about your visit such as the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.
• We store Profile Data which includes your username and password (although this is hidden from us) and purchases or orders made by you.
• Marketing and Communications preferences in receiving marketing from us and our third parties and your communication preferences.

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.

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 biometric data). Nor do we collect any information about criminal convictions and offences.

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 into 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. How is your personal data collected?

We use different methods to collect data from and about you, including:

• 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;
• create an account on our website;
• subscribe to our service;
• request marketing to be sent to you;
• give us some feedback.
• We may monitor, record, store and use any telephone, email or other communication with you.
• Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. Please see our cookie policy for further details.
• 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:
• Contact, Financial and Transaction Data from providers of technical, payment and delivery services.

4. How we use your personal data

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 contract we are about to enter into or have entered into with you, such as to process the transactions, to supply you with the products, to recover debt, and keep records about your purchases;
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests, such as administering and improving our site, including troubleshooting, data analysis, research, statistical and survey purposes, notifying you about enhancements to our services such as changes to the website, new services and special offers that may be of interest, and to help us prevent fraud.
• Where we need to comply with a legal or regulatory obligation.

We do not store or have access to your credit card information as this information is processed by our secure payment processor.

We may use the personal data we collect about you on an anonymised basis to create statistics and anonymised information which we then share with third parties including ad networks, search engines and analytics providers.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

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.

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. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new customer	Identity Contact	Performance of a contract with you
To process and deliver your order including: Manage payments	Identity Contact Financial Transaction Marketing and Communications	Performance of a contract with you
To manage our relationship with you which will include: Notifying you about changes to our terms or privacy policy Asking you to leave a review or take a survey	Identity Contact Profile Marketing and Communications	Performance of a contract with you Necessary to comply with a legal obligation Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to complete a survey	Identity Contact Profile Usage Marketing and Communications	Performance of a contract with you Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	Identity 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	Identity Contact Profile Usage Marketing and Communications Technical	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	Technical Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you	Identity Contact Technical Usage Profile	Necessary for our legitimate interests (to develop our products/services and grow our business)

Marketing

We want to keep you informed about all our products, promotions and news, and where you have stated that you are happy to receive marketing by post, email, or phone we will keep in touch with the latest news.

If you are an existing customer, we will contact you by post, email, or phone with information about products and services similar to those which you have already purchased from us.

If you would like to receive promotional or marketing information from us, please ensure that you tick the appropriate box when you provide us with your personal data.

You can change your mind about what marketing you receive at any time by either contacting us at [email protected] quoting your full name, address and postcode; by writing to the Marketing Manager at Paul HARTMANN Ltd, Unit P2 Parklands, Heywood Distribution Park, Pilsworth Road, Heywood, OL10 2TT; or by updating your marketing preferences online in the “My Account” section.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data 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 goods or services from us and, in each case, you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside the Hartmann Group of companies for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or, 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 product/service purchase.

Cookies

Our site uses cookies, as almost all websites do, to help provide you with the best experience we can. For more information please see our cookies policy at www.hartmanndirect.co.uk/cookie-policy

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.

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.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

• Internal Third Parties, including any member of our group (being our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006).
• External Third Parties as set out in the Glossary. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction. We may disclose your personal data to our service providers who operate elements of our site service and process personal data on our behalf. These may include businesses who provide technology services such as hosting for our servers and email distribution, business partners who provide delivery fulfillment services and legal and debt recovery representatives for debt collection and debtor tracing purposes. We may also disclose your personal data to our supply and delivery partners for the purpose of processing and fulfilling your order. Where such disclosures are made, this will be under contractual arrangements with us and carried out in accordance with the requirements of the GDPR.
• 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.

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

6. International transfers

We do not transfer your personal data outside the European Economic Area (EEA).

7. Data security

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 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.

The personal data that we collect from you is stored on secure information technology systems located in the EEA which are operated by us.

Some data processing in relation to web and email services and delivery of any products ordered by you is carried out on our behalf by a third party. We will take all steps reasonably necessary to ensure that your personal data is kept secure and in accordance with this privacy notice.

Unfortunately, the transmission of information from you via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your personal data transmitted to our site; any transmission is at your own risk. Once we have received your personal data, we will use strict procedures and security features to prevent unauthorised access.

Our online shop uses up-to-date industry procedures to protect your personal information. We also protect the security of your data during transmission using Secure Sockets Layer (SSL) Transport Layer Security (TLS) technology. We may vary this in the future if we feel you will benefit from greater security whilst using our site.

We have appropriate security measures in place in our physical facilities to protect against the loss, misuse or alteration of information that we have collected from you via our site.

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.

8. Data retention

How long will you use my personal data for?

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 you can ask us to delete your data: see ‘Request erasure’ below for further information.

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.

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. 

• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us using the contact details in the Important Information and Who We Are section of this notice.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

THIRD PARTIES

Internal Third Parties

Other companies in the Hartmann Group and who are based within the European Economic Area and provide IT and system administration services and undertake leadership reporting.

External Third Parties

• Service providers who provide IT and system administration services.
• Professional advisers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.
• Our supply and delivery partners for the purpose of processing and fulfilling your order.

YOUR LEGAL RIGHTS

You have the right to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. You can exercise this right at any time by writing to Customer Services at Paul HARTMANN Ltd, Unit P2 Parklands, Heywood Distribution Park, Pilsworth Road, Heywood, OL10 2TT. Alternatively, you can email [email protected]

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. If you believe your details are incorrect, you can amend your details by writing to Customer Services at Paul HARTMANN Ltd, Unit P2 Parklands, Heywood Distribution Park, Pilsworth Road, Heywood, OL10 2TT. Alternatively, you can email [email protected]

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

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 particular 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. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

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: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

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.