Data Protection Statement - DellRefurbished.co.uk
This policy explains how Dell Bank International d.a.c., trading as Dell Financial Services, operating in the online retail market as ‘Dell Refurbished’, ("Dell Financial Services" or “we”, "us" or "our") may use your Personal Data in relation to the DellRefurbished.co.uk website.
This Data Protection Statement governs Personal Data we collect from our customers and online users (“you” or “your”), as well as information we automatically collect from your online visits (e.g. data collected via cookies).
For the purposes of this Data Protection Statement, “Business Partner” means any subcontractor, vendor or other entity with whom we have an ongoing business relationship to provide products, or information. “Personal Data” means information that may directly or indirectly identify you, such as your name, telephone number, home address and email address.
We are the “controller” of any Personal Data that we process – this means we are legally responsible for ensuring such processing is in compliance with applicable privacy laws.
Information We Collect
Dell Financial Services asks for specific types of personal information. We ask you to provide information that will enable us to process your purchase or provide services to you, enhance your site visit, respond to requests for information, support your relationship with us, assist you with technical support issues or to follow up with you after your visit.
We may collect information when you interact with us. Some of the instances when this happens might be when you:
- register on the DellRefurbished.co.uk website;
- request us to provide you with a quote;
- place an order with us;
- request e-mail notification from us;
- request assistance from our online advisors;
- make a request for support either online or by telephone;
- provide feedback in a survey;
- participate in promotional offers;
- subscribe to a publication, newsletter or a mailing list; or
- visit the DellRefurbished.co.uk website.
When you interact with us, we may ask for some of the following information: your name, home or business address, e-mail address, phone number, username and passwords, transactional information such as your preferences, customer credit card information and other information that is needed to process your transaction or request.
We may collect information relating to your online interactions with us (including, for example, your IP address, the pages you view and the links and advertisements that you click on) so that we can offer you a more consistent and personalised experience in your relationship with Dell Financial Services and better serve your needs by customising the content, services and marketing material that we share with you. We may use your browser and purchase history to make recommendations to you and, subject to your prior consent, send customised communications via various communication methods, including email. For more information on how we use your information to provide a personalised experience please see below.
How We Use Personal Data
We may use your Personal Data to:
- to fulfil requests for products and services;
- to process your purchase or provide requested services, for example, the customer care service that we may provide you with;
- to enhance your experience on the site;
- to improve our products and services;
- to prevent or detect fraud or abuses of the services including use of this website;
- to comply with our legal obligations including but not limited to compliance with relevant international sanctions, embargoes and export restrictions;
- to contact you;
- to customise our communication with you and the marketing material we share with you and
- to allow our Business Partners to interact with you.
Legal basis for the processing
Our legal basis for collecting and using your Personal Data as described in this Data Protection Statement will depend on the Personal Data concerned and the specific context in which we collect it. In general, we collect and process your Personal Data on one or more of the following bases:
- Taking steps, at your request, to assess your purchase request (prior to entering into a contract) or for compliance with a contractual obligation;
- For compliance with our legal obligations where other laws require the processing of your Personal Data (for example compliance with relevant international sanctions, embargoes and export restrictions when we process an order upon your request);
- Your consent, for example where we have obtained your consent to process your personal data for certain activities (such as the provision of marketing material to you). You are free to withdraw your consent at any time, please see below for more details;
- Dell Financial Services (and its Business Partners’) legitimate interests which include the provision of this website and/or relevant products, and/or the carrying out of marketing activities, provided always that our legitimate interests are not outweighed by any prejudice or harm your rights and freedoms.
If you have any questions or need more information concerning the legal basis on which we collect your Personal Data, please contact us at firstname.lastname@example.org.
Retention of your data
We will retain your Personal Data for as long as your account is active or as necessary in connection with the purposes described in this Data Protection Statement and in accordance with our retention policies and applicable law.
In order to use, disclose and process Personal Data for the purposes and to the recipients described above, we may transfer your Personal Data to countries outside the United Kindom to companies, Business Partners or service providers of the Dell Technologies group (including, without limitation) those located in the European Economic Area (EEA), United States of America (USA), India, Brazil and Morocco, with whom we have appropriate contractual and security safeguards in place. This may involve the transfer of your Personal Data to countries that do not provide the same level of data protection as your home country. We will put in place adequate and appropriate protections to safeguard your Personal Data, including technical and organisational security measures. To find out more about these data transfers or to exercise your rights, please contact us (contact details provided below).
Disclosing Personal Data
We may share your Personal Data with other entities within the Dell Technologies group or our Business Partners for the purposes described in this Data Protection Statement, including (without limitation) to carry out transactions you request, or to make our business (or that of our subsidiaries) more responsive to your needs. We will only share your Personal Data with Dell subsidiaries and Business Partners who agree to protect your Personal Data and use it solely for the purposes specified by us.
We may also disclose your Personal Data in connection with law enforcement, fraud prevention or other legal action; as required by law or regulation; if we (or a part of the Dell Technologies group) is sold or merges with another company; or if we reasonably believe it is necessary to protect Dell Financial Services, our customers or the public.
Except as described above, we will not disclose your Personal Data to third parties for their own marketing purposes without your consent.
Your data protection rights
You have the following data subject rights. Please note, these rights are not absolute and in certain cases are subject to conditions set out in applicable law:
Access: you have the right to request information about how we process your Personal Data and to obtain a copy of that Personal Data;
Rectification: you have the right to request the rectification of inaccurate Personal Data about you and for any incomplete Personal Data about you to be completed;
Objection: you have the right to object to the processing of your Personal Data, which is based on our legitimate interests (as described above);
Erasure: you have the right to request the erasure of your Personal Data (subject to certain conditions);
Automated decision-making: you have the right not to have a decision made about you that is based solely on automated processing if that decision produces legal effects about you or significantly affects you;
Restriction: you have the right to ask us to restrict our processing of your Personal Data, so that we no longer process that information until the restriction is lifted;
Portability: you have the right to receive your Personal Data, which you have provided to us, in a structured, commonly used and machine-readable format and to have that information transmitted to another organisation in certain circumstances.
In addition to the above, you have the right to lodge a complaint with a supervisory authority if you consider that our processing of your Personal Data infringes applicable data protection law.
If you have any questions about the type of Personal Data we hold about you or if you wish to request deletion or correction of Personal Data we hold about you, or exercise any other data subject right, please send a written request to email@example.com or to the postal address provided at the bottom of this Data Protection Statement. While we will make reasonable efforts to accommodate your request, we reserve the right to reject such access requests or to impose restrictions or requirements upon such requests if required or permitted by applicable law.
Opting Out of Marketing Communications
You may provide your consent to receive marketing communications from Dell Financial Services. You are free to withdraw your consent at any time by Clicking here. If you withdraw your consent, it will not affect the lawfulness of any processing based on your consent before you withdrew.
Any marketing by Dell Financial Services, or any third parties on behalf of Dell Financial Services, will be conducted in accordance with applicable laws.
How We Secure Your Personal Data
We take all reasonable steps to protect your Personal Data from misuse, interference and loss, as well as unauthorised access, modification or disclosure. The ways we do this include:
- using encryption when collecting or transferring sensitive information, such as credit card details;
- having in place technical and organisational measures designed to ensure the ongoing integrity, availability and resilience of processing systems and services; limiting physical access to our premises;
- limiting access to the information we collect about you;
- ensuring that we and our Business Partners have appropriate security safeguards to keep Personal Data secure; and
- where required by law, destroying or de-identifying Personal Data.
We encourage you to keep any passwords you use confidential and to be careful to avoid “phishing” scams where someone may send you an email that appears to be from Dell Financial Services asking for your Personal Data.
Collection and Use of Children's Personal Data
We take children's privacy seriously. We do not knowingly collect Personal Data from children under the age of 13 through our websites. If you are under 13 years of age, please do not submit any Personal Data through our websites without the express consent and participation of a parent or guardian.
Cookies and similar technologies
Dell Financial Services and our Business Partners may use information about your visit to our website. The information could include pages you visit, the items you view or place in your shopping cart, or your responses to our ads and emails.
This information allows us to make our ads more relevant to you. This is referred to as interest-based advertising. For example, if you recently looked at laptops online, you may be more likely to see an advertisement regarding a laptop from our website.
A cookie is a piece of text that is placed on your computer's hard drive. Depending on the settings you have selected, your browser adds the text to your device as a small file. Many browsers are set to accept cookies by default. You have the ability to accept or decline cookies as you prefer. The Help portion of your web browser, most likely found on the toolbar, typically tells you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether.
“Do Not Track” Signals
How We and Our Business Partners Use Web Beacons, Pixel Tags and Tracking Technology
We or our Business Partners may use web beacons on our websites, in our email messages, in our advertisements on other websites, or in our advertisements in others' email messages.
A web beacon is an electronic image that can be used to recognise a cookie on your computer when you view a web page or email message. Web beacons help us measure the effectiveness of our website and our advertising in various ways. For example, web beacons may count the number of individuals who visit our website from a particular advertisement or who make a purchase from our website after viewing a particular advertisement or they may tell us when a web page is viewed and provide a description of the page where the web beacon is placed. Web beacons may also measure the effectiveness of our email campaigns, by counting the number of individuals who open or act upon an email message, determining when an email message is opened and determining how many times an email message is forwarded. Subject to local laws, we may combine the information that we collect through web beacons with other Personal Data we have collected from you.
We may allow some of our Business Partners to compile individual or aggregated statistics from the use of web beacons on the DellRefurbished.co.uk website by Dell Financial Services its agents or others, to determine the effectiveness of online marketing and to develop statistics on how often clicking on an advertisement results in a purchase or other action on the advertiser's site. Aggregate information may include demographic and usage information.
When you visit our websites or view one of our email messages, we may use pixel tags (also called "clear" gifs), tracking links and/or similar technology to note some of the pages you visit on our websites. We may also use pixel tags to determine what types of email your browser supports. We may use the information collected through web beacons, pixel tags, tracking links and similar technology in combination with your Personal Data to personalise your experience on our website and to provide you with more useful and relevant advertisements.
Third Party Sites
Please be aware that other websites including sites that may be accessed through our site, e.g., via a hyperlink, may collect personal data about you. This Data Protection Statement does not cover the information practices of those third party sites linked to https://www.dellrefurbished.co.uk or any other site.
Changes to this Data Protection Statement
We will occasionally update this Data Protection Statement. If we make changes to this Data Protection Statement or make any material changes to how we use your Personal Data, we will revise this Data Protection Statement to reflect such changes and revise the effective date of this Data Protection Statement included at the end of this section. We encourage you to periodically review this Data Protection Statement to be informed of how we are using and protecting your Personal Data.
If you have any questions in relation to this Data Protection Statement, please contact our Data Privacy Manager by post at Dell Bank International d.a.c / Dell Financial Services, P.O. Box 12335, Dublin 18, Ireland or by email at: firstname.lastname@example.org.
Effective Date: 31st January 2020.