1. Important noticeThis Privacy Policy describes how we obtain and use your personal data, why we are allowed to do so by the law, who has access to your personal data and what your rights are. Please review it carefully.

In the event that the Site contains a separate Privacy Statement linked to via the Site Home page, in the case of conflict between that Privacy Statement and this PrivacyPolicy, the Privacy Statement shall prevail over this Privacy Policy

We take your privacy seriously and use your personal data as further explained in thisPrivacy Policy. We are the “controller” of the personal data you provide to us.

You have the right to object to us processing your personal data for our legitimate business interests or for direct marketing purposes (including any related profiling). For more information about your rights and how you can exercise them, please see the section Your rights.

2. Personal Data we may collect and why

Personal data is any information which identifies you personally whether directly (forexample, your name) or indirectly (for example, information about your use of ourproducts and services).

We may collect the following data about you:

• Contact details: your name, email address, and telephone number so that wecan contact you in response to an enquiry you make via our Site or in relation to

the products and services that we have from time to time agreed to provide toyou;

• Correspondence: we collect any additional personal data you may provide to usfrom time to time if you contact us by email, letter or telephone, through our Site,by submitting a comment on our Site, or by any other means;

• Survey responses: information from surveys that we use for research purposes,if you choose to respond to them;

• Transaction details: we or our third party providers will collect informationrelating to transactions you carry out through our Site and for the purposes offulfilling your orders;

• Details of visits to the Sites: details of your visits to our Site, including, but notlimited to, traffic data, location data, weblogs and other communication data,whether this is required for our own billing purposes or otherwise and theresources that you access.

What are Cookies?

We collect information about your use of our Site through cookies. Cookies areinformation that files stored on your computer, tablet or smartphone that help websitesremember who you are and information about your visit. Cookies can help to displaythe information on our Site in a way that matches your interests. Most major websitesuse cookies.

The cookies we and our business partners use on our Site are broadly grouped into thefollowing categories:

• Essential – Some of the cookies on our Site are essential for us to be able toprovide you with a service you have requested. An example of this could be acookie used to enable you to log into your account on our Site or which allowscommunication between your browser and our Site. Our cookie preferencecookie described in the section “How can I reject or opt out of receiving cookies?”is also an essential cookie. You may not be able to use our Site without thesecookies.

• Analytics – We use analytics cookies to helps us understand how users engagewith our Site. An example is counting the number of different people coming toour Site or using a particular feature, rather than the total number of times thesite or feature is used. Without this cookie, if you visited our Site once each weekfor three weeks we would count you as three separate users. We would find itdifficult to analyse how well our Site was performing and improve it withoutthese cookies.

• User Cookies – We use cookies to improve your experience by rememberingyour preferences so we know how you like to use our Site. Examples of thiswould be remembering you so that you are served with the same content or toremember you when you come back to our Site.

• Social Sharing – We use third party cookies to allow you to share contentdirectly on the social networking/sharing sites like Facebook, Twitter orGoogle+. Examples would be if you wanted to “like” or “tweet” about us or ourproducts or services. Please see our “Third Party Cookies” section below formore details.

• Interest-Based Advertising – You will have noticed that when you visitwebsites you will be shown adverts for products and services you may wish tobuy. The money made by website owners for showing third party adverts ontheir websites often pays for the cost of running the website and thereforeusually allows you to use the website without having to pay a registration orusage fee. To try and ensure that the adverts you see are relevant to you thirdparty cookies may be used to collect information about the types of things thatinterest you, for example websites you visit and the geography that you arebased in. Having these cookies does not increase the number of adverts you willbe shown, but simply makes the adverts you see more relevant. Please see our“Third Party Cookies” section below for more details.

b. How can I reject or opt out of receiving cookies?

You may refuse to accept cookies by activating the setting on your browser whichallows you to refuse the setting of cookies. However, if you select this setting, you maybe unable to access certain parts of our Site. Unless you have adjusted your browsersetting so that it will refuse cookies, our system will issue cookies when you use ourSite. The “Help” menu of the toolbar on most browsers will tell you how to prevent yourbrowser from accepting new cookies, how to have the browser notify you when youreceive a new cookie, or how to disable cookies altogether. For more information aboutcookies and how to stop cookies being installed or how to delete existing cookies fromyour hard drive visit the following website: http://www.allaboutcookies.org.

c. Third party cookies

Some of the cookies described in the "What Cookies are used on our Site" section aboveare stored on your machine by third parties when you use our Site. Third parties mayalso read cookies on your browser to collect information or to serve content oradvertisements to you. We have no control over these cookies or how the third partiesuse them. They are used to allow that third party to provide a service to us, for exampleanalytics. For more information on these cookies and how to disable them, please see:

• Internet Advertising Bureau websiteat http://www.youronlinechoices.com/ where you will be able to opt-out ofreceiving Interest-Based Advertising cookies from some of the third partieslisted below; and/or If you want to know more about how cookies work and how to manage or deletethem, visit the World Wide Web Consortium's website.

4. How we use your personal data

We use your personal data for the following purposes:

To provide you with the products and services you have requestedWe use your personal data to accept you as a new or returning customer to provide youwith the products and services you have requested in accordance with the TradingTerms or Terms of Trading.

To send you service communications, including in relation to changes to our Trading Terms or Terms of TradingWe use the contact details you have provided to us so that we can communicate withyou about the products and services that we provide, including to let you know aboutmajor changes to those products and services or to the Trading Terms or Terms ofTrading between us or to any related information.

Direct marketing (including by third parties)If you have provided your consent or we otherwise have the right to do so, we may useyour contact details to send you direct marketing and keep you informed ofpromotional offers by email, SMS, post or telephone relating to our products andservices.

You can unsubscribe from our direct marketing at any time by clicking the“Unsubscribe” link in any of our emails or by contacting us.

Our trusted business partners would also like to use your name, email address, postaladdress and telephone number to inform you of similar products, services andpromotional offers. We will only share your personal data with our partners where youhave provided us with your consent to do so. You can unsubscribe at any time byclicking the “Unsubscribe” link in any of their emails or by contacting us.

To track your usage of our website, communications, products and servicesWe use cookies and similar technologies to track your activity on our Site so that we canprovide important features and functionality on our Site, monitor its usage, and provideyou with a more personalised experienced.

To provide and improve customer supportWe use your personal data to be able to provide and improve the customer support weprovide to you (for example, where you have questions about our products andservices).

To maintain our records and improve data accuracyLike any business, we process personal data in the course of maintaining andadministering our internal records. This includes processing your personal data toensure that the information we hold about you is kept up to date and accurate.

To respond to enquiries, complaints and disputesWe use the personal data we hold about you to help us respond to any enquiries orcomplaints you have made, or deal with any dispute which may arise in the course of usproviding our products and services to you, in the most effective manner.

To investigate, detect and prevent fraud and comply with our legal obligationsIn certain circumstances, we use your personal data only to the extent required in orderto enable us to comply with our legal obligations, including for fraud detection,investigation and prevention purposes. This may require us to provide your personaldata to law enforcement agencies if they request it.

5. Legal grounds for processingData protection law requires us to only process your personal data if we satisfy one ormore legal grounds. These are set out in data protection law and we rely on a number ofdifferent grounds for the processing we carry out. These are as follows:

Consent In certain circumstances, we process your personal data after obtaining your consent to do so for the purposes of:

• sending you marketing communications about our products and services; • sharing your name, email address, postal address and telephone number with our trusted business partners so that they may market to you about their own similar products and services; • conducting marketing research; • obtaining your credit score so that we can establish the best possible payment terms we are able to offer to you.

Necessary for the performance of a contract and to comply with our legalobligations

It is necessary for us to process your basic contact details, payment details and information about the business you represent for the performance of the Trading Terms or Terms of Trading between us. In particular, we rely on this legal ground to:

• provide you with the products and services; • communicate with you about the products and services that we provide to you, including to let you know about major changes to those products and services or to the Trading Terms or Terms of Trading between us or to any related information; • provide and improve customer support; and • notify you about changes to our service

If you choose not to give some or all of the aforementioned information to us, this may affect our ability to provide our products and services to you.

In certain circumstances, we also use your personal data only to the extent required in order to enable us to comply with our legal obligations, including to detect, investigate and prevent fraud.

Necessary for the purposes of our legitimate business interests or those of a third party It is sometimes necessary to collect and use your personal data for the purposes of our legitimate interests as a business, which are to:

• provide you with products and services that are as useful and beneficial as possible, including by personalising our contact with you and making sure we tell you about all the offers that are relevant to you; • better understand our customer base so that we can improve our products and services and marketing activities (which could also benefit you); • comply with our contractual obligations to third parties; • develop and improve our Site to enhance the customer experience; • train our staff so that we can provide you with a better customer service; • respond to any enquiries or complaints you have made, or deal with any dispute which may arise in the course of us providing our products and services to you; and • to ensure that content from our Site is presented in the most effective manner for you and for your computer; • ensure effective operational management and internal administration of our business, document retention, compliance with regulatory guidance and exercise or defence of legal claims.

Where we think there is a risk that one of your interests or fundamental rights and freedoms may be affected we will not process your personal data unless there is another legal ground for us to do so (either that we have obtained your consent to the processing or it is necessary for us to perform our contract with you or to comply with our legal obligations).

6. Who we share your personal data with

We may provide your personal data to our suppliers and service providers, includingother companies in our group, who provide certain business services for us and act as“processors” of your personal data on our behalf. In addition, we may disclose yourpersonal data if we are under a duty to disclose or share your personal data in order tocomply with any legal obligation, or in order to protect the rights, property, or safety, ofour business, our customers or others. This includes, in specific cases, exchanginginformation with other organisations for the purposes of fraud protection.

In some cases, the personal data we collect from you may, for the purposes set outabove, be transferred outside the European Economic Area (EEA) and such destinationsmay not have laws which protect your personal data to the same extent as in the EEA.We are required by data protection law to ensure that where we or our “processors”transfer your personal data outside of the EEA, it is treated securely and is protectedagainst unauthorised access, loss or destruction, unlawful processing and anyprocessing which is inconsistent with the purposes set out in this Privacy Policy.

7. How long we keep your personal data for

We retain your personal data for no longer than is necessary for the purposes(s) forwhich it was provided. What this means in practice will vary between different types ofdata. When determining the relevant retention periods, we take into account factorsincluding:• legal obligation(s) under applicable law to retain data for a certain period oftime;• statute of limitations under applicable law;• potential or actual disputes; and• guidelines issued by relevant data protection authorities.

Otherwise, we securely erase your personal data from our systems when it is no longerneeded.

8. Your rights

You have the following rights regarding your personal data:

1. Rights to be informed

You have the right to be provided with clear, transparent andeasily understandable information about how we use yourpersonal data and your rights. This is why we are providing youwith the information in this Privacy Policy.

2. Right of access

You have the right to obtain access to your personal data (if weare processing it) and certain other information (similar to thatprovided in this Privacy Policy). This is so you are aware andcan check that we are using your personal data in accordancewith data protection law.

3. Right to rectification

You are entitled to have your personal data corrected if it is inaccurate or incomplete.

4. Right to erasure

This is also known as ‘the right to be forgotten’ and, in simpleterms, enable you to request the deletion or removal of yourpersonal data where there is no compelling reason for us to keepusing it. This is not a general right to erasure; there areexceptions.

5. Right to restrict processing

You have the right to ‘block’ or supress further use of yourpersonal data in certain circumstances. When processing isrestricted, we can still store your personal data, but may not useit further.

6. Right of data portability

You have the right to obtain and reuse your personal data in astructured, commonly used and machine-readable format incertain circumstances. In addition, where certain conditionsapply, you have the right to have such information transferreddirectly to a third party.

7. Right to object to processing

You have the right to object to us processing your personal datafor our legitimate business interests or for direct marketingpurposes (including in each case any related profiling).

8. Right to withdraw consent to processing

If you have given your consent to us to process your personaldata for a particular purpose (for example, direct marketing),you have the right to withdraw your consent at any time(although if you do so, it does not mean that any processing ofyour personal data up to that point is unlawful).

9. Right to make a complaint to the data protection authorities

You have the right to make a complaint to the InformationCommissioner’s Office (ICO) if you are unhappy with how wehave handled your personal data or believe our processing ofyour personal data does not comply with data protection law.

9. How to contact usIf you would like to exercise your data protection rights or if you are unhappy with howwe have handled your personal data, please feel free to contact us by using the detailsset out on our Site.

If you’re not satisfied with our response to any enquiries or complaint or believe ourprocessing of your personal data does not comply with data protection law, you canmake a complaint to the Information Commissioner’s Office (ICO) by:• writing to: Information Commissioner’s Officer, Wycliffe House, Water Lane,Wilmslow, Cheshire, SK9 5AF;• calling: 0303 123 1113; or• submitting a message through the ICO’s website at: ico.org.uk

10. Links to other websitesOur website may contain hyperlinks to websites owned and operated by third parties.This Privacy Policy does not apply to those other websites. We encourage you to readthe privacy statements on the other websites you visit, as they will govern the use ofany personal data you provide when visiting those websites. We do not accept anyresponsibility or liability for the privacy practices of such third party websites and youruse of such websites is at your own risk.

11. Changes to this Privacy Policy

This Privacy Policy was last updated on 1 May 2018.

This Privacy Policy may be updated from time to time, so you may want to check it each time you provide personal data to us.

Our website may contain hyperlinks to websites owned and operated by third parties.This Privacy Policy does not apply to those other websites. We encourage you to readthe privacy statements on the other websites you visit, as they will govern the use ofany personal data you provide when visiting those websites. We do not accept anyresponsibility or liability for the privacy practices of such third party websites and youruse of such websites is at your own risk.