Introduction

This privacy policy tells you how APL Packaging uses your personal data when you visit our website, interact with us, and buy our goods and services. It also tells you about your privacy rights and how the law protects you.

It is important that you read this privacy policy, together with any other privacy policies we may provide, so that you are fully aware of how and why we are using your data.

This privacy policy was last updated on 24th of May 2018 and historic versions can be obtained by contacting us.

If you have any questions, or would like to exercise your privacy rights, please follow the instructions in this privacy policy. See How to contact APL about our privacy below.

Our website

Our website at aplpackaging.co.uk sells both plain and printed packaging goods & services which are aimed at business users – including Business Start-Ups, Independant Traders, SMEs and larger Enterprise Organisations. This website is not intended for children and we do not knowingly collect data relating to children.

Personal data which 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 collect a variety of information about our brilliant customers and visitors to the APL Packaging Website. We also collect information when our customers and prospective customers call, email or live chat with us. This personal data falls into these categories:

Identity Data

This includes title, first name, last name, username or similar identifier and a hashed version of your password. If you interact with us through social media, this may include your social media username.

Contact Data

This includes billing address, delivery address, email address and telephone numbers.

Financial Data including payment card details.

We do not store payment card details. To enable us to remember your card details, we store a token, which is a random string of text that identifies you as a customer of your card provider.

Transaction Data

This includes details about payments to and from you and other details of products and services you have purchased from us.

Profile Data

This includes your username and hashed password, purchases or orders made by you, preferences, quotations, feedback and survey responses, as well as any profile data which we have added (for example, using analytics and profiling).

Technical Data

This includes your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, operating system and platform and other technology on the devices you use to access this website.

Usage Data includes information about how you use our website, products and services.

Tracking Data includes information we or others collect about you from tracking technologies, such as web beacons, pixels, and mobile identifiers.

Marketing and Communications Data includes your preferences in receiving direct marketing from us.

We will also collect, use and share Aggregated Data such as statistical or demographic data for any purpose to provide better content and service. APL Packaging's Website uses google analytics. 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 usage data to calculate the percentage of users accessing a specific website feature. To provide better content and service. APL Packaging record mouse actions and scrolling movement as well as basic interactions with website forms. APL Packaging does not track browsing habits across third party websites.

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 policy.

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 use any of these types of personal data on products you design or create on aplpackaging.co.uk, we will not be able to tell. We will treat all the personal data included in designs or products as ordinary personal data.

Remember, if you choose not to share personal data with us, or refuse certain contact permissions, we might not be able to provide the products and services you've asked for.

How is your personal data collected?

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

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 through chat or social media.

This includes personal data you provide when you:

  • make enquiries or request information be sent to you
  • create an account on our website
  • create designs for products on our website or email designs to us
  • order our products or services
  • ask for marketing to be sent to you
  • engage with us on social media
  • enter a competition, promotion or survey
  • contact customer services; or leave comments or reviews on our products or services

Automated technologies or interactions.

As you interact with us, including via the aplpackaging.co.uk website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We may also collect Tracking Data when you use our website, or when you click on one of our adverts (including those shown on third party websites).

We may receive personal data about you from various types of third parties, including:

Technical Data and/or Tracking Data from analytics providers, advertising networks and search information providers.

Contact, Financial and Transaction Data from providers of payment and fraud prevention services.

Identity and Contact Data from data partners; and

Data from any third parties who are permitted by law or have your permission to share your personal data with us, such as via social media or review sites. We will only use your personal data when the law allows us to.

How we use your personal data

Where we need to perform the contract we are about to enter into or have entered into with you. For example, when you purchase our products, that's a contract.

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. For example, when we carry out fraud screening as part of the check-out process.

Where we need to comply with a legal or regulatory obligation. For example, keeping records of our sales for tax compliance.

Generally, we do not rely on consent as a legal basis for processing your personal data other than where the law requires it, for example in relation to sending certain direct marketing communications.

See Explaining the legal bases we rely on to process personal data to find out more about the types of lawful basis that we will rely on to process your personal data.

Explaining the legal bases we rely on to process personal data

The following table shows you a description of all the ways we plan to use 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.

Purpose/ActivityType of dataLawful basis for processing
To register you as a new customerIdentity AND ContactPerformance 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 usIdentity
Contact
Financial
Transaction
Marketing and Communications
Performance of a contract with you Necessary for our legitimate interests (including 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 surveyIdentity
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 deliver direct marketing to youIdentity
Contact
Profile
Usage
Marketing and Communications Tracking
Technical
For most direct marketing communications, we rely on consent, however there are situations in which it is in our legitimate interests to use your personal data in this way

(Please see Advertising, marketing and your communications preferences below)
To enable you to take part in a prize draw, competition or complete a surveyIdentity
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
Tracking
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 youIdentity
Contact
Profile
Usage
Marketing and Communications
Technical
Tracking
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 experiencesUsage
Technical
Tracking
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 youIdentity
Contact
Technical
Usage
Profile
Necessary for our legitimate interests (to develop our products/services and grow our business)
To prevent and detect unlawful actsIdentity
Contact
Financial
Transaction
Technical
Tracking
Necessary for our legitimate interests (to protect our business and our customers by way of undertaking fraud monitoring and suspicious transaction monitoring) Necessary to comply with a legal or contractual obligation to share personal data for the purposes of law enforcement
In order to resolve legal claims or disputes involving you or usAll relevant data categories, depending on the nature of the allegation or claimNecessary to bring or defend a claim

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.

We do not carry out any automated decision making.

If you ever have any questions about this, all you have to do is ask. See How to contact APL Packaging about privacy below.

Advertising, marketing and your communications preferences

We may use your Identity, Contact, Technical, Tracking, Usage and Profile Data to form a picture of 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 and tell you about them. This is what we call direct marketing.

We may carry out direct marketing by email, phone, text or post. For example, customers may receive information about our latest blog to your inbox or a new promotion may land on your door mat.

On our website, we always try hard to make it really clear what we are doing and what communications you will be sent, whether it's you deciding to sign up for our offers or as part of creating an account or the purchase journey – and you have a right at any time to change your mind and say no thank you and opt out (but we'd be really sad to see you go, so please gives us a chance by fine tuning your preferences before really leaving us!). The easiest way to opt out is to use the unsubscribe link at the bottom of a communication.

We have created a contact centre where you can request certain changes to your personal data, please email privacy@aplpackaging.co.uk

Of course, there are lots of different ways you'll see adverts for APL Packaging out and about, and not all of these are based on using personal data – sometimes we just buy advertising space in the real world, on websites and social media. If you see APL's adverts on websites and in social media, these may not be directed specifically at you, we might just have bid for the space. But here's some things we may do that may be specifically directed at you:

emails, for example offers that we send out;

promotions by post, such as great money off offers;

Or

phone calls, to tell you something that might be relevant to you and your business.

We work with partners to try and promote the reach of our adverts and use analytics and retargeting for this reason. We use Tracking Data to deliver relevant online advertising, including via websites and social media.

Cookies

Cookies help aplpackaging.co.uk to work better and provide lots of help in the background to make the process of being a APL Packaging customer a lot easier. You'd miss a lot of these things if they were gone – like it being able to login, add things to your cart and even checkout.

When you use aplpackaging.co.uk, your device or browser may be sent cookies from third parties, for example when using embedded content and social network links. It's important for you to know that we have no access to or control over cookies used by these companies or third-party websites. We suggest you check the third-party websites for more information about their cookies and how to manage them.

There are three types of data that we store in cookies:

Tracking data - so we can remember the things you do on site. E.g. Add a product to cart or login.

Preference data - for example, to remember if you've dismissed a marketing dialog.

Analytics data - So our analytics provider (Google Analytics) can track you across the APL Packaging website.

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.

Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in this privacy policy. We may also share your personal data if the law otherwise allows or requires it.

We may share personal data with the following categories of third parties:

Suppliers and service providers (such as technology service providers, payment processing and fraud prevention providers, manufacturers and post and courier services);

We may share personal data with the following specific third parties:

Campaign Monitor: We share your data with Campaign Monitor to send our direct marketing campaigns to prospective and current customers. Please visit their privacy policy.

Google: We share your data with Google Analytics, Google AdWords and other Google services to track your usage across our websites and services.

We may also share data with 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 policy.

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.

We may share your data with law enforcement or other government officials if requested to or required to by law.

Payment information

APL Packaging uses third party payment processors SagePay and PayPal to process payments for products and services via the Website. All online payments will be conducted in accordance with Payment Card Industry Data Security Standards (PCI DSS) and your credit/debit card and billing information is encrypted before being communicated to them.

Credit/Debit card billing information that we store:

  • PAN (first 6 digits of card number) - These identify which bank issued your card
  • Last 4 digits of card number - We use this for fraud prevention
  • Transaction ID and auth codes - Used to identify the transaction
  • Token - This is what we store when you ask us to remember your card details (see Stored Cards below)

PayPal information that we store:

  • Transaction ID - Used to identify the transaction

Stored Cards

We have provided the facility to store your payment information to make future transactions faster.

In accordance with Payment Card Industry Data Security Standards (PCI DSS), we do not store your full card number, valid from, valid to, name on card or security code information. We simply ask our payment provider, SagePay, to give us a secure string of text that identifies you as a customer of your card issuer, which we can use, along with reconfirmation of your security code to process further payments without full card details.

International data transfers

Whenever we transfer your personal data out of the EEA, we will comply with applicable data protection law. Some of the mechanisms we may choose to use when undertaking an international transfer are:

The transfer of your personal data is to a country that has officially been deemed to provide an adequate level of protection for personal data by the European Commission.

We may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe (called the “EU Model Clauses”).

Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. If the provider is not EU-US Privacy Shield certified, we may use the EU Model Clauses.

Many of our external third-party providers are based outside the EEA, so their processing of your personal data will involve a transfer of data outside the EEA.

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.

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.

Third-party links

This website may include links to third-party websites, plug-ins and applications (for example, the ability to sign in with Facebook and Twitter). 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 website, we encourage you to read the privacy policy of every website you visit.

Data retention

We will only keep 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 stop being customers for tax purposes.

We also make a promise to you that you can come back at any time in the future and reprint products you have ordered from us in the past. So, unless you actively delete this information, we keep it, so we can keep our promise to you.

In some circumstances you can ask us to delete your data; see Your legal rights 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.

Your legal rights

If the General Data Protection Regulation applies to you because you are in the European Union, you have rights under data protection laws in relation to your personal data:

The right to be informed – that's an obligation on us to inform you how we use your personal data (and that's what we're doing that in this privacy policy);

The right of access – that's a right to make what's known as a ‘data subject access request' for copy of the personal data we hold about you;

The right to rectification – that's a right to make us correct personal data about you that may be incomplete or inaccurate;

The right to erasure – that's also known as the ‘right to be forgotten' where in certain circumstances you can ask us to delete the personal data we have about you (unless there's an overriding legal reason we need to keep it);

The right to restrict processing – that's a right for you in certain circumstances to ask us to suspend processing personal data;

The right to data portability – that's a right for you to ask us for a copy of your personal data in a common format (for example, a .csv file);

The right to object – that's a right for you to object to us processing your personal data (for example, if you object to us processing your data for direct marketing); and

Rights in relation to automated decision making and profiling – that's a right you have for us to be transparent about any profiling we do, or any automated decision making.

These rights are subject to certain rules around when you can exercise them. You can see a lot more information on them, if you are interested, on the UK Information Commissioner's Office website.

If you wish to exercise any of the rights set out above, please contact us (see How to contact APL Packaging about privacy).

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.

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.

We will try to respond to all legitimate requests within one calendar month. Occasionally it may take us longer than a calendar month if your request is particularly complex or you have made a number of requests. In this case, we will tell you within one calendar month that we cannot complete the request in time and why, and give an estimated time of completion if possible. We will keep you updated at a minimum of once per calendar month.

We have appointed a data privacy manager who is 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 privacy manager using the details in How to contact APL Packaging about privacy.

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 (https://ico.org.uk/). However, if you approach the ICO before raising a complaint with us directly, you will usually be asked to do so by them as a first course of action.

Please see our complaints procedure for more information.

How to contact APL Packaging about privacy

If you have any questions about our privacy policy, or you would like to exercise any of your rights, please email us at privacy@aplpackaging.co.uk or alternatively write to us with your letter addressed to: Data Privacy Manager, APL Packaging Limited, Unit 10, Silverdale Industrial Estate, Meadow Road, Worthing, West Sussex, United Kingdom, BN11 2RZ

If you need help about any of our products and services, or this website generally, please contact us at info@aplpackaging.co.uk.

A kind request from APL Packaging to you

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. You can do this by updating your account. Thank you.

Changes to this privacy policy

The General Data Protection Regulation is new and the ICO is still issuing guidance about how businesses should follow it; so, you may see little updates to our privacy policy over the coming months. Please be sure to check in and have a read every now and then. Thank you.

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