Concept2 Ltd Privacy Notice

Welcome to Concept2 Limited's privacy notice. Our company number is 02447885 and our registered office address is Block C Unit 8 Crossgate Drive, Queens Drive Industrial Estate, Nottingham, England, NG2 1LW.

We respect your privacy and are committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you get in touch with us, we contact you or when you visit our site www.concept2.co.uk or our shop shop-uk.concept2.com (our sites) (regardless of where you contact us or visit our site from) and tell you about your privacy rights and how the law protects you.

This privacy notice 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 notice.

Important information and who we are
The data we collect about you
How is your personal data collected?
How we use your personal data
Disclosures of your personal data
Transferring your personal data out of the UK and EEA
International transfers
Data security
Data retention
Your legal rights
Glossary
Changes to this privacy policy

Important information and who we are
1. Purpose of this privacy notice
  1. This privacy notice aims to give you information on how we collect and processes your personal data, including any data you may provide by phone or through our site when you purchase a product or service, sign up to our newsletter, or take part in a competition.
  2. Our site is not intended for children and we do not knowingly collect data relating to children.
  3. It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific
2. Controller
  1. Concept 2 Limited is the controller and responsible for your personal data (referred to as "we", "us" or "our" in this privacy notice).
  2. We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights as set out in paragraph 9.1, please contact the data privacy manager using the details set out below.
3. Contact Details. Our full details are:
  1. Full name of legal entity: Concept 2 Limited.
  2. Full name of data privacy manager: Rebecca Nowell
  3. Email address: dataprotection@concept2.co.uk
  4. Postal address: Unit C8, Queens Drive Industrial Estate, Crossgate Drive Nottingham NG2 1LW.
4. 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. Please contact us if you have any queries or concerns about our use of your personal data.
5. Changes to the privacy notice and your duty to inform us of changes
  1. The data protection law in the UK changed on 25 May 2018. We shall endeavour to inform you of any changes to this privacy notice in line with changes to the UK GDPR.
  2. 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.
6. Third-party links. Our site may include 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. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our site, we encourage you to read the privacy notice of every website you visit.
The data we collect about you
1. 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).
2. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
  1. Identity Data includes first name, last name, username or similar identifier, title, date of birth and gender.
  2. Contact Data includes billing address, delivery address, email address and telephone numbers.
  3. Financial Data includes bank account and payment card details.
  4. Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
  5. Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our site.
  6. Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
  7. Usage Data includes information about how you use our site, products and services.
  8. Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
3. 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.
4. 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.
5. 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.
How is your personal data collected?
We use different methods to collect data from and about you including through:
1. 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, face to face or otherwise. This includes personal data you provide when you:
  1. request a quotation for our products or services;
  2. purchase products or services;
  3. make payment for our products or services;
  4. contact us by phone, through our site or by other means;
  5. create an account on our site;
  6. subscribe to our newsletters or publications;
  7. request marketing or brochures to be sent to you;
  8. enter a competition, promotion or survey; or
  9. give us some feedback.
2. Automated technologies or interactions. As you interact with our site, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.
3. Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
  1. Technical Data from the following parties:
    1. analytics providers such as Google based outside the EU;
    2. search information providers such as SiteSearch360 based inside the EU.
  2. Identity and Contact Data from publicly availably sources [such as Companies House and the Electoral Register based inside the EU].
  3. Identity Data, Contact Data from organisations who we drop ship goods for such as Argos.

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:
1. Where we need to perform the contract we are about to enter into or have entered into with you.
2. 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.
3. Where we need to comply with a legal or regulatory obligation.
Click here to find out more about the types of lawful basis that we will rely on to process your personal data.
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.

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	(a) Identity (b) Contact	Performance of a contract with you
To process and deliver your order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to partake in a prize draw, competition or complete a survey	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications	(a) Performance of a contract with you (b) 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 our site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	(a) 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) (b) Necessary to comply with a legal obligation
To use data analytics to improve our site, products/services, marketing, relationships experiences	(a) Technical (b) Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our site updated and relevant, to develop our business and to inform our marketing strategy)

Marketing. We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
1. Promotional offers from us.
  1. 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).
  2. You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
2. Third-party marketing. We will get your express opt-in consent before we share your personal data with any other company for marketing purposes.
3. Opting out
  1. You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
  2. 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, warranty registration, product/service experience or other transactions.
Cookies. 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 our site may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.
Change of purpose
1. 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.
2. 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.
3. 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.

Disclosures of your personal data
1. 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.
  1. Internal Third Parties. Concept 2 Inc., a company registered in the United States of America with company number V-27195-0 and having its registered office at 105 Industrial Park Drive, Morrisville VT 05661 USA acting as joint controllers or processors and who are based in the USA and provide back-office services which run our site, help us process orders and host all our data (including your personal data we collect).
  2. External Third Parties
    1. Service providers including Rackspace US Inc. based in the USA who provide IT and system administration services.
    2. Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
    3. HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom and Ireland who require reporting of processing activities in certain circumstances.
    4. Shipping and 3rd party logistics companies for the purposes of processing, despatching and delivering goods ordered by you.
    5. SagePay for the purposes of processing your payment of Goods.
  3. Specific third parties listed in the table in paragraph 3.3 above.
  4. 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.
2. 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.
Transferring your personal data out of the UK and EEA
It is sometimes necessary for us to transfer your personal data to countries outside the UK and EEA. In those cases we will comply with applicable UK and EEA laws designed to ensure the privacy of your personal data. We will transfer your personal data to:
- Our parent company, Concept 2 Inc, located in the USA
- Rackspace US Inc. located in the USA
- Amazon Web Services, located in the USA
Under data protection laws, we can only transfer your personal data to a country outside the UK/EEA where:
- the UK government has decided the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy regulation’) further to Article 45 of the UK GDPR. A list of countries the UK currently has adequacy regulations in relation to is available here. We rely on adequacy regulations for transfers to the following countries: the USA.
- in the case of transfers subject to EEA data protection laws, the European Commission has decided that the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy decision’) further to Article 45 of the EU GDPR. A list of countries the European Commission has currently made adequacy decisions in relation to is available here. We rely on adequacy decisions for transfers to the following countries: the USA.
- there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you; or
- a specific exception applies under relevant data protection law.
Where we transfer your personal data outside the UK or EEA, we do so on the basis of an adequacy regulation or (where this is not available) we will do so further to Article 46(2) of the UK GDPR and/or EU GDPR. In the event we cannot or choose not to continue to rely on either of those mechanisms at any time, we will not transfer your personal data outside the UK/EEA unless we can do so on the basis of an alternative mechanism or exception provided by UK data protection law and reflected in an update to this policy.

Any changes to the destinations to which we send personal data or in the transfer mechanisms we rely on to transfer personal data internationally will be notified to you in accordance with the section on ‘Changes to this privacy policy’.

International transfers of your personal data outside the UK—in more detail

More details about the countries outside the UK to which your personal data is transferred are set out in the table below:

Recipient country	Recipient	Processing operation (use) by recipient	Lawful safeguard
USA	Concept 2 Inc., a company registered in the United States of America with company number V-27195-0 and having its registered office at 105 Industrial Park Drive, Morrisville VT 05661 USA	Acting as joint controllers or processors and who are based in the USA and provide back-office services which run our site, help us process orders and host all our data (including your personal data we collect)	Decision made on 12 October 2023 by the UK Government, “UK Extension to the EU-US Data Privacy Framework” (UK Extension) under Article 45 of the UK General Data Protection Regulation (GDPR) without the need for further safeguards such as those set out in Articles 46 and 49 of the UK GDPR

Data security
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 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.
2. 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.
Data retention
How long will you use my personal data for?
1. 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.
2. 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.
3. Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.
4. In some circumstances you can ask us to delete your data: see Request erasure below for further information.
5. 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.
Your legal rights
1. Under certain circumstances, you have rights under data protection laws in relation to your personal data. Your legal rights are:
  1. 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.
  2. 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.
  3. 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.
  4. 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.
  5. 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.
  6. 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.
  7. 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.
2. If you wish to exercise any of the rights set out in paragraph 9.1 above, please contact us.
3. 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.
4. 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.
5. 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.
Glossary
LAWFUL BASIS
1. 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.
2. 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.
3. 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.
Changes to this privacy policy
This privacy notice was published on July 5, 2018 and last updated on January 9, 2024. We keep our privacy notices under regular review. If there are any changes we will update this page to tell you, for example, about any new uses of personal data.

From time to time, we may also tell you in other ways about the processing of your personal data.

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