Privacy and Security Policy
Tortoys is committed to respect and uphold everybody's right to privacy, to process personal data securely and to comply with legislation prevailing in the UK. This policy describes what we do to achieve this.
Definition of terms used in this policy
'We', 'Us' and 'Our' refer to John Ennals trading as Tortoys.
'You' and 'Your' refer to a client of Tortoys. This may be a customer, supplier or member of our emailing list.
'Processing' means collecting and storing data, and using it to contact you if consent is given.
'Our website' means https://www.tortoys.co.uk.
'Device' means any computer, tablet, smart phone or other equipment equipped with a web browser and connected to the internet.
'GDPR' means the General Data Protection Regulation.
'PCI-DSS' means Payment Card Industry Data Security Standard.
'HMRC' means Her Majesty's Revenue and Customs, the UK tax authority.
'Full card details' means the card number, expiry date, name of account holder and CVC number of any debit, credit or charge card.
'Information' and 'Data' are used interchangeably.
The data controller and data protection officer for Tortoys is John Ennals, address shown on the 'About Us' page of our website and at the foot of every page.
Tortoys.co.uk is a secure website protected by Secure Socket Layer (SSL), as indicated by the padlock symbol in your browser. SSL protects data by encrypting it as it travels over the internet between your web browser and the server.
Why do we process personal data?
We need to collect and store your personal information so that we can fulfil your order, and contact you in the event of any query about it. If you have given consent, we also add your email address to our emailing list.
If we have purchased items from you, we need a record of the provenance of those items for security reasons.
Our legal basis under Article 6 of the GDPR for processing personal data in any given instance is one or more of:
6.a) Consent has been given for the specific purpose of joining our emailing list to receive occasional news and updates from us. You may give consent by ticking the 'Opt-in' box in our online checkout when placing an order, or by contacting us by email. You may withdraw consent (opt out) at any time - see below.
6.b) Processing is necessary for the performance of a contract to which you are party, specifically the supply of goods by or to Tortoys.
6.c) Processing is necessary for compliance with a legal obligation to which we are subject, in particular the retention of records for a specified time for tax purposes (see below).
6.f) Processing is necessary for the purposes of legitimate interests pursued by the data controller, specifically the collection of statistical data to assist in improving our offer and website to the mutual benefit of you and us.
How do you opt out?
If you have previously opted in to our emailing list, you can withdraw consent (opt out) by:
- Placing an order and leaving blank the 'Opt-in' box in the online checkout.
- Using the 'Unsubscribe' link in a marketing email you have received from us.
- Contacting us via our 'Contact Us' page.
- Contacting us by email, SMS text message, mail or telephone.
What data do we process?
The personal information we collect and store is limited to that shown on our order confirmations and invoices, as follows:
- Your invoice name and address
- Your delivery name and address if different
- Your telephone number
- Your email address
- Your payment reference or method in abbreviated form (see below)
- A list of the items you purchased from us or sold to us
- An indicator to show if you have opted in to our emailing list.
If you have opted in to receiving our occasional emails but have not purchased anything from us or sold anything to us, the only personal information we store is your name and email address.
In addition we use Statcounter, a third party service, to collect data and report statistics about visitors to our website. The data includes:
- The number of visitors to our website and the number of pages viewed
- The number of visitors from different countries and regions
- A list of pages viewed by each visitor and the time spent on each
- The type of device, operating system and browser used by each visitor
Visitors are defined only by masked IP addresses and it is not possible to identify individual persons from this data, and no other personal data is collected. As the data is anonymous it falls outside the scope of the GDPR. Information is stored only on the Statcounter.com secure servers and is deleted on a 'last in, first out' basis, typically 6 weeks after collection.
Online payments and financial data
Online payments are made through the secure website of our Payment Service Provider (PSP). The PSP is either Sellerdeck Payments (provided by Creditcall) or PayPal, according to the payment method you choose. Each of these PSPs is PCI-DSS compliant to the highest level, ensuring that your card details are secure. We never see your full card details because you enter them directly through the PSP website. The only payment information we see and store is either the last 4 digits of the card number and the expiry date, or the PayPal transaction number. These details are shown on our invoices for your reference.
Offline payments and financial data
We will not collect and store your bank account number or full card details. If you pay by cheque we show the cheque number and your branch sort code on our invoice for your reference. If you pay by bank transfer we show the payment reference, if any, on our invoice.
How is personal information stored?
Personal information is stored electronically and is encrypted to prevent unauthorised access. Any personal information in the form of printed copies of sales orders and invoices is kept in a secure storage facility.
Your right to rectification
In accordance with article 16 of the GDPR, if you notice that we have stored any of your personal data incorrectly, please let us know and we will correct it straight away.
How long do we keep your data for?
HMRC rules require us to keep records for at least 5 years after the January tax return submission date. To make sure we comply, we keep sales and purchase invoices for 6 years before deleting or destroying them.
If you have opted in to our emailing list you may request that your email address is removed from the list at any time. If we have not had any contact with you for 6 years, all your personal data will automatically be deleted including your entry in our emailing list.
Your 'right to be forgotten'
In accordance with article 17 of the GDPR, your personal data will be deleted when:
a) The information is no longer necessary for the purposes for which it was collected, or
b) You withdraw consent and there is no other legal ground for processing under Article 6 (see 'Why do we process personal data?' above).
Can we supply a copy of the data we hold?
Yes, just get in touch and we will send a copy of all your personal data that we hold straight away. In some cases we may need to ask for proof of identity before doing so.
Do we share your personal data?
No. We never share your personal data with third parties, except:
- with carriers such as Royal Mail for the purpose of delivery
- with payment service providers as detailed above
- with Statcounter in the form of anonymous statistical data as detailed above
- if required to do so by law.
In the unlikely event of a data breach, we will contact the UK supervising authority (Information Commissioner's Office) and yourself in accordance with articles 33 and 34 of the GDPR.
This policy was updated on 13th April 2018.