Vertical Leisure Limited, trading as X-POLE (“we“, “us”) is committed to protecting and respecting your privacy. This Privacy and Cookies Policy (“Policy”) (together with and any other documents referred to therein) sets out the basis on which the personal data collected from you, or that you provide to us will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
For the purpose of the General Data Protection Regulation (“GDPR”) and the UK Data Protection Act 2018 (collectively the “Data Protection Laws”), the Data Controller is Vertical Leisure Limited, trading as X-POLE.
YOUR PERSONAL INFORMATION
We collect and process some or all of the following types of information from you in the course of your use of https://x-pole.co.uk/ (the “Website”), and the goods and services we provide under the X-POLE brand:
- Information that you provide to us through the Website, when you register and in relation to ordering goods.
- Specifically we will process personal details such as your name, email address, telephone numbers, billing and delivery addresses, details of your transactions and any other information input by you when using the Website, completing our survey forms, and using our services. Please note that we never store your payment details on our Website.
- If you sign up to receive our newsletter, we will process your name, email address and country of residence.
- If you contact us, we may keep a record of that correspondence.
- We reserve the right to contact you for market research, although you do not have to respond to this.
- Details of your visits to the Website including, but not limited to, traffic data, location data, weblogs and other communication data, and the resources that you access.
USES MADE OF YOUR INFORMATION
Lawful basis for processing
We rely on legitimate interest as the lawful basis on which we collect and use your personal data. Our legitimate interests are:
- Performance of contracts with our customers and suppliers;
- Marketing and business development; and
- The administration and improvement of our Website.
Purposes of processing
We use information held about you in the following ways:
- To provide you or the organisation that you are engaged by with our goods and/or services (including managing your account).
- To carry out our obligations arising from any contracts entered into between you and us.
- To carry out our obligations arising from any contracts entered into between us and our other customers or suppliers (including trainers).
- To provide you with information and offers that you request from us or which we feel may interest you.
- To notify you about changes to our goods and/or services.
- For internal record-keeping.
- To ensure that content on the Website is presented in the most effective manner for you and for the device(s) you use to access and view the Website.
In addition to the above uses we may use your information and, where you have consented, permit selected third parties to use your information, to notify you about goods or services which may be of interest to you. Where we do this, we will contact you by electronic means (e-mail or SMS) only if you have consented to such communication. If you do not want us to use your data in this way please either (i) tick the relevant box situated on the form on which we collect your data (for example, the registration form); (ii) unsubscribe from our electronic communications using the method indicated in the relevant communication; or (iii) inform us at any time by contacting us at the contact details set out below.
DISCLOSURE OF YOUR INFORMATION
We may pass your information to our third party service providers, agents, subcontractors and other associated organisations for the purposes of completing tasks and providing services to you on our behalf (e.g. to process payments made over the Website, or to host our servers).
We may disclose your personal data to any member of our corporate group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006 (where applicable).
We may also disclose your personal data to third parties:
- in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets; or
- if we or substantially all of our assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets; or
- if we are under a duty to disclose or share your personal data in order to comply with any legal obligation (e.g. to facilitate the detection of crime, or for the collection of taxes or duties); or
- if we are under a duty to disclose or share your personal data in order to enforce or apply g. our Website Terms and Conditions and other agreements; or
- to protect our rights, property, or safety or that of our affiliated entities and our users and any third party we interact with them to provide the Website; or
- in relation to selected third parties only, only to the extent that you have consented to such selected third parties notifying you about certain goods or services, which may be of interest to you.
Other than as set out above, and save insofar as is necessary in order for us to carry out our obligations arising from any contracts entered into between you and us, we will not share your data with third parties unless we have procured your express consent to do so.
STORING YOUR PERSONAL DATA
We take appropriate measures to ensure that any personal data are kept secure, including security measures to prevent personal data from being accidentally lost, or used or accessed in an unauthorised way. For example, access to your account is controlled by a user name and password which is unique to you. We limit access to your personal data to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We are certified to SOC 2. This family of standards helps us manage your personal data and keep it secure.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
Unfortunately, the transmission of information 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 data transmitted to the Website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Keeping your personal data up to date
If your personal details change you may update them by contacting us using the contact details below.
We will endeavour to update your personal data within seven (7) working days of any new or updated personal data being provided to us, in order to ensure that the personal data we hold about you is as accurate and up to date as possible.
How long we keep your personal data
We will hold the data set out above for a reasonable time having regard to the nature of the personal data and the purpose for which it was collected. In particular:
- Where we hold your personal data in connection with the performance of a contract with one of our customers or suppliers, we will hold your data, and in particular any communications between you and us in relation to the negotiation or performance of the contract by either party for so long as that contract is in force and for a period of at least 7 years after;
- Where we hold your data in connection with the marketing or promotion of our business, we will hold your data for up to 3 years, or for up to 3 years after you last communicated with us, if later.
- In respect of website usage data, we hold your data for 5 years from the date of collection.
- Even if we delete your data, it may persist on backup or archival media for legal, tax or regulatory purposes.
Where we store your personal data
We store customer information and information used for order processing on secure servers within the United Kingdom.
The data that we collect from you may be transferred to, and stored at, a destination outside the UK / EEA, for example, the United States of America. It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, website management, the fulfilment of your orders, the processing of your payment details and the provision of support services.
Such countries do not have the same data protection laws as the United Kingdom and EEA. Whilst the European Commission may not have made a formal decision that such countries provide an adequate level of data protection similar to those which apply in the United Kingdom and EEA, any transfer of your personal data will be subject to appropriate safeguards, for example, a European Commission approved form of contract (as permitted under Article 46(5) of the General Data Protection Regulation that are designed to help safeguard your privacy rights and give you remedies in the unlikely event of a misuse of your personal data.
To obtain a copy of these safeguards or if you would like further information, please contact us (see ‘Contact’ below).
Under the General Data Protection Regulation, you have a number of important rights free of charge. In summary, those include rights to:
- access to your personal data and to certain other supplementary information that this Policy is already designed to address
- require us to correct any mistakes in your information which we hold
- require the erasure of personal data concerning you in certain situations
- receive the personal data concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
- object at any time to processing of personal data concerning you for direct marketing
- object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
- object in certain other situations to our continued processing of your personal data
- otherwise restrict our processing of your personal data in certain circumstances
- claim compensation for damages caused by our breach of any data protection laws.
For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please:
- email, call or write to us,
- let us have enough information to identify you (e.g. full name, account/VL number, user name, e-mail address),
- let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill), and
- let us know the information to which your request relates (including any account or reference numbers, if you have them).
HOW TO COMPLAIN
We hope that we can resolve any query or concern you raise about our use of your information.
The General Data Protection Regulation also gives you the right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone: 0303 123 1113.
We may collect information about your mobile phone, computer or another device from which you access the Website including where available your IP address, operating system and browser type, for systems administration and to report aggregate information to third parties affiliates. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual. We may, however, use such information in conjunction with the data we have about you in order to track your usage of our services.
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.
The cookies we use include:
- “Analytical” They allow us to recognise and count the number of visitors and to see how visitors move around the Website when they are using it. This helps us to improve the way our Website works, for example, by ensuring that users are finding what they are looking for easily.
- “Strictly necessary” cookies. These are cookies that are required for the operation of our Website. They include, for example, cookies that enable you to log into secure areas of our Website, use a shopping cart or make use of e-billing services.
- “Functionality” cookies. These are used to recognise you when you return to our Website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
- “Targeting” cookies. These cookies record your visit to our Website, the pages you have visited and the links you have followed to our affiliates websites. We will use this information to make our Website, offers e-mailed to you and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
Cookies that are strictly necessary for the core functionality of the Website are enabled by default, and set automatically at the point you access the Website.
Any cookies which are not strictly necessary for the functioning of the Website will not be set unless you expressly consent to them through the cookie banner by clicking “accept”.
Below is a list of the cookies that we use. We have tried to ensure this is complete and up to date, but if you think that we have missed a cookie or there is any discrepancy, please let us know.
|__cfduid, wplc_cha||Used with our online chat system for customer support.|
|_ga, _gat, _gat_UA-(token), utmx, utmxx||Google Analytics, we use this to gather usage data related to your visit so we can improve our website.|
|_icl_current_language, googtrans_disable||Used with Google Translate for translating content|
|woocommerce_current_currency||Use with our online store to remember which currency customers wish to use.|
We use the following strictly necessary cookies:
|Description of Cookie||Purpose|
|Session cookie||We use this session cookie to remember you and maintain your session whilst you are using our website|
|Affiliate tracking||To attribute affiliate commission rates correctly|
We use the following analytical cookies:
|Description of Cookie||Purpose|
|Google Analytics||We use this cookie to analyse the traffic patterns on our website. This helps us to understand our customers better, as well as how we can improve our goods, services and website|
We use the following functionality cookies:
|Description of Cookie||Purpose|
|Traffic cookie||We use this cookie to identify your computer and analyse traffic patterns on our website|
We use the following targeting cookies:
|Description of Cookie||Purpose|
|Targeting cookie||We may choose to use this cookie to enable us to show you adverts while you are browsing our website and other websites on the internet|