Reflex Marketing & Promotions Ltd is committed to ensuring that your privacy is protected.
This policy sets out how we use your personal information in a fair, lawful and transparent way; and explains how we comply with the GDPR (General Data Protection Regulation) and the PECR (Privacy and Electronic Communications Regulations).
It may be necessary to revise this policy in the future as we adapt to changes in legislation and our own business growth. We reserve the right to update it at any time and will inform customers if we make any substantial changes.
When assisting with your enquiries, quotation requests and orders we collect personal data such as your name, job title, postal address, telephone number and email address. We may periodically contact you for market research to help us improve our offering and to share our products & services through appropriate marketing channels.
Your personal data is stored at our head office address. As we continue to grow we may consider suitable Cloud-based solutions; our email account is currently stored and managed within the Cloud by Microsoft Office 365.
As a distributor, we share personal information solely for delivery purposes to our trusted suppliers and couriers in the UK and Globally. We only permit third parties to process your personal data for specified purposes and in accordance with our written instructions. We do not share or sell personal data to others for third party marketing activity.
Website & Social Media
You can choose to accept or decline Cookies, as noted in the PECR amendment of 2011. When visiting a website if you do not see a decision prompt, the personal settings on your web browser may be automatically set to either allow or block them.
Our website and social media sites may contain links to other websites of interest. Once you have used a link we do not have any control over how the external organisation uses or stores any information you divulge. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites.
We recommend you review the external organisation’s own privacy statement on the related website. While all precautions have been undertaken to ensure any downloadable documents or media files we have made available are genuine, these are accessed at the users own risk. We advise that you verify their authenticity using Anti-Virus software or similar applications.
We like to share special discounts, new to market products & branding solutions with individuals and organisations who may be interested. When contacting us to enquire about our services and request quotations via our website, social media, email and telephone, we use your personal information to assist and to contact you for marketing purposes.
We may also gather personal contact information from reputable data providers, where individuals have consented to their data being shared for marketing purposes and the recipient has a legitimate interest in our products and services.
In response to the GDPR we have conducted a Balancing Test to show how legitimate interest is established, as summarised below:
Purpose test: Any marketing or services provided by us will contain information that should be of genuine business interest to that organisation.
Necessity test: We provide services, company news and industry developments that are key to our function as a distributor of branded promotional merchandise and facilitator of corporate schemes.
Balancing test: Your individual rights will override the legitimate interest. All recipients can restrict or fully remove themselves from all marketing channels at any time; in addition to any rights detailed within the GDPR and the PECR.
You have a choice if you prefer not to receive marketing content from us:
Similarly, if you prefer not to receive contact through any marketing channels please update us by email, letter or telephone. Your information and preferences may be stored separately to ensure you are not re-added to our marketing lists, should you contact us in the future.
Personal Data Retention
We will hold personal information relating to orders for at least the minimum period required to adhere to legal, accounting and reporting requirements including HMRC instruction.
As the GDPR does not set specific maximum or minimum time periods to retain personal data, we regularly review what we hold and delete information that is out of date or no longer needed.
Personal data relating to customer quotations and orders may be held indefinitely for historical, statistical or research purposes. This helps us offer a better service to you and your organisation.
We are committed to ensuring that your personal data is secure. To prevent unauthorised access or disclosure, we regularly review our technical and security procedures to safeguard your information.
Our Anti-Virus, Spyware and Malware are updated continuously, both our main system and user PCs are protected with Firewalls. We use a Strong Security Password policy and access at our head office is restricted.
Payment for our services can be made by direct transfer or credit card and your details will be processed and stored by our bank. Payments made via our PayPal account will be encrypted and held with them, please visit www.paypal.com for full details.
Notice of Security Breach
If a security breach causes an unauthorized intrusion into our system we will provide appropriate notifications to the Information Commissioners Office (ICO) in accordance with the GDPR.
If any breach materially affects you, then we will notify you as soon as possible and later report the action we took in response.
Individual Rights Explained
Right to Rectify: It is important that the personal information we hold about you is accurate and current. If any of your details are incorrect please inform us, so we can update our processing systems.
Right to Object: We offer all new customers the right to remove themselves from our marketing opportunities.
Right to Restrict: You can ask us to suspend the processing of your personal information. Should you wish to remove yourself from our contact lists please advise us of your marketing preferences to ensure we get them right first-time.
Right to Erasure: If you want to be forgotten we will delete your details from our systems and only retain information that is essential to our legal and accounting responsibilities including HMRC.
Right to Access: You have the right to see a copy of the personal information that we hold, your request should be put in writing to the Data Protection Officer at the address below. We will respond within 14 days of receiving your instruction.
Right to Complain: If you have any issues please refer to the contact section below.
If you have any questions, concerns or wish to see a copy of the information we hold about you, please write to:
The Data Protection Officer
Reflex Marketing & Promotions LTD
Unit B5, Dolphin Way, Shoreham-by-Sea, West Sussex, BN43 6NZ, UK
You may alternatively email us at firstname.lastname@example.org and title your message ‘FAO the Data Protection Officer.’
We are committed to resolve any concerns about your privacy and use of personal information. If you have registered a complaint or dispute which following our internal process cannot be resolved to your satisfaction, UK customers may report their concerns to the ICO.
The Information Commissioner’s Office (ICO) is an independent authority established by the UK government to uphold information rights in the public interest. Please see their website for further details please visit: www.ico.org.uk