Revision: 1.00 Last modified: 01 MAY 2018
PERSONAL DATA PROCESSING1. What is personal data
Personal data means any information relating to an identified or identifiable natural person, such as for instance your contact information, your order data or your product data.2. General principles for personal data processing by Strathtec Retail Ltd
We adhere to the following principles when processing your personal data:
1. we will only collect personal data for
specified, explicit and legitimate
2. will not collect personal data beyond what is necessary to accomplish those purposes;
3. we will not use personal data for purposes other than that for which the data was collected, except as stated herein, or with prior consent;
4. we will not transfer personal data to third parties, except as stated herein, or with prior consent;
5. we will do our best to ensure that information is up to date by encouraging you to verify your personal data periodically;
6. we will maintain appropriate technical and organizational measures to protect your personal data against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access and against all other unlawful forms of processing; and
7. except when stated herein, we will not store personal data longer than is necessary to accomplish the purpose for which the data were collected or for which they are further processed, or as is required by law.
3. Personal data we collect and process
When you engage with Strathtec Retail Ltd via various channels, including our websites, apps, dealers and customer support, we collect and process your personal data. The personal data that we collect and process can be categorized as follows:1) Your personal details, such as your name, e-mail address, physical address (if provided), phone number (if provided), IP address, in some cases geo location and language.
2) Your purchase information, such as your personal details as specified above, company name (if provided), your delivery information, such as delivery address, if different from physical address, your order information, such as product name, quantity, product name, stock keeping unit no. and product serial no., quantity, date of purchase and dealer information, your payment information, such as credit card or similar payment information and friend referral (if applicable).
3) Requests for customer support and technical assistance, containing your personal details, as specified above, product serial number, product warranty information, place of purchase and other relevant information, which Strathtec Retail Ltd may inquire in order to proceed with your request.
4) Information provided when completing surveys, questionnaires and feedback forms, such as your personal details, as specified above, your product warranty ID, place of purchase, your feedback on your use of B&O product(s) and evaluation of the same, your location information.
4. How we use your personal data
We only collect and process personal data, if at least one of the below mentioned
1) We provide you with customized information on news, events, competitions and
similar marketing content related to Strathtec Retail Ltd, its products and products
sold in collaboration with third parties. Our processing in this regard will be based on
your consent thereto.
2) We handle your purchase orders, complete purchase transactions, ensure delivery of purchased product(s), handle possible returns. Our processing is necessary for the performance of a contract, to which you are a party.
3) We provide you with relevant product software updates and make your future purchases easier by remembering your shipping details. Our processing is necessary for the purposes of the legitimate interests pursued by Strathtec Retail Ltd and such processing is not considered to be harmful towards you.
4) We provide you with customer service, handle your requests or complaints and provide you with product warranty support. Our processing is necessary for the performance of a contract, to which you are a party.
5) We ensure better customer experience by providing you with personal benefits, such as discounts or customized offers based on previous purchases and possible friend referrals. Our processing in this regard will be based on your consent thereto.
6) We collect your feedback regarding your use of products and services by inviting you to complete surveys, questionnaires or feedback forms. Our processing in this regard will be based on your consent thereto.
Accordingly, some of your personal data is collected and processed in order for us to fulfil our contractual obligations to you, for instance, when you purchase our products, contact our customer support or claim warranty. Should you choose not to provide us with the requested and necessary personal data in this regard, we might not be able to fully satisfy your request.
5. Where we store and process your personal data
As a general principle, your personal data is stored and processed within the European Economic Area (EEA).
6. Our disclosure of your personal data to third parties
As a general principle, we collect and process data in order to facilitate or
improve Strathtec Retail Ltd's products, services or offers. We do not sell your
personal data or share the said data with third parties, except to the extent stated in this
We may disclose your personal data to third parties to the extent required by law, court order or a decision rendered by a competent public authority and for the purpose of law enforcement. In addition, we may share your personal data with the following third parties:
1) Our group companies and authorized dealers in order to deliver products and services to you, to ensure a consistent level of service across our products and services, to enhance our products, services and your customer experience.
2) Third party vendors carrying out services on our behalf, including billing, sales, marketing, IT support, advertising, analytics, research, customer service, product service support, shipping and purchase order fulfilment, data storage, validation, security, fraud prevention, payment processing, and legal services. Such third-party vendors have access to perform these services but are prohibited from using your personal data for other purposes.
3) Music Streaming Services. When you initiate a connection with a third-party streaming service through products bought from us, we may share information about you that is required to enable delivery of the third-party content.
4) Third parties in order to establish, exercise or defend legal rights of Strathtec Retail Ltd.
5) Third parties in the event of any merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of Strathtec Retail Ltd's assets or stock (including without limitation in connection with any bankruptcy or similar proceedings).
6) Other third parties subject to your consent. When we disclose your personal data to a third party, we take all reasonable steps to ensure that those third parties are bound by confidentiality and privacy obligations with respect to the protection of your personal data. The disclosure is conducted in compliance with legal requirements, including entering into data processing agreements with the relevant third parties, to ensure that personal data is only processed in accordance with our instructions, applicable law and regulations and for the purpose specified by us and to ensure adequate security measures.
7. Retention of your personal data
We keep your information for no longer than necessary for the purposes for which it is
collected. The length of time for which we retain information depends on the purposes
for which we collected and use it.
Personal data related to your purchase and product warranty information is kept and processed for a period of five (5) years from the date of purchase, unless you have obtained extended warranty period or such data is legitimately processed for other purposes, such as providing you with personal benefits or customized direct marketing upon your consent or for pursuing our legal claims, where maintaining such information is considered necessary.
Personal data related to our provision of direct marketing to you is kept and processed for a period of three (3) years from the date you last have been active in opening our marketing communication or otherwise showing interest in such communication. Personal data related to your use of our apps and product software update(s) is kept and processed for a period of three (3) years from the date you last have been active in using any of our products apps.
Personal data related to your use of your products is kept and processed for a period of five (5) years from the first use day of the given product, unless such data is legitimately processed for other purposes, such as providing you with personal benefits or customized direct marketing upon your consent or for pursuing our legal claims, where maintaining such information is considered necessary.
Personal data related to our provision of personal benefits to you is kept and processed for a period of five (5) years from the date of your last purchase of B&O product. Personal data related to your feedback on our products and services is kept and processed for a period of two (2) years from the completion date of the given survey, questionnaire of feedback form.
Relevant personal information will be deleted after expiry of the above-mentioned periods, unless such data legitimately can be kept and processed for other processing purposes, which we have legal basis for.
order to remember your preferences, to understand how our websites and apps
are used and to customize our marketing offerings.
A cookie is a small text file that is placed on your computer or mobile device when you visit a site, that enables us to: (1) recognize your computer; (2) store your preferences and settings; (3) understand the web pages of Strathtec Retail Ltd you have visited; (4), enhance your user experience by delivering and measuring the effectiveness of content and advertising tailored to your interests; (5) perform searches and analytics; and (6) assist with security and administrative functions. Some cookies are placed in your browser cache while those associated with Flash technologies are stored with your Adobe Flash Player files.
Pixels are tiny electronic tags with a unique identifier embedded in websites, online ads and/or email that are designed to: (1) collect usage information like ad impressions or clicks and e-mail open rates; (2) measure popularity of the advertising; and (3) access user cookies.
As we adopt additional technologies, we may also gather information through other methods.
Please note that you can change your settings to notify you when a cookie is being set or updated, or to block cookies altogether. Please consult the "Help" section of your browser for more information. You can also manage the use of Flash technologies, including flash cookies and local storage objects with the Flash management tools available at Adobe's website. Please note that by blocking, disabling, or managing any or all cookies, you may not have access to certain features or offerings on our websites or apps. For example, to complete a purchase on our websites, you will need to accept cookies sent by our sites. For more information on the cookies we use and the purposes for which we use them, please refer to our Cookies Policy.
9. Responsible for processing
BOLLO.store, 180a Hutcheson Street, Glasgow, G1 1SL is the data controller and is responsible for the processing of your personal data.
10. Access to your personal data and data portability
You have right to access and receive the personal data concerning you, which you have provided to Strathtec Retail Ltd, in a structured, commonly used and machine-readable format and have the right to transmit those data to any third party, you should choose to. Your personal data processed by Strathtec Retail Ltd can be accessed by contacting the store by telephone, email or letter.
11. Updating and/or deleting your personal data
We encourage you to update your personal data provided to Strathtec
Retail Ltd any time there are changes in your personal data. This can be done
by contacting one of our stores.
In order to ensure that your personal data processed by us is up-to-date we request you to check and, if relevant, update your personal data at least once a year.
Your personal data can be deleted from Strathtec Retail Ltd servers unless entitled or obliged by applicable law and regulations to keep and process such information regardless withdrawal of your consent.
Following deletion your personal data will be deleted from servers of Strathtec Retail Ltd without undue delay, while it might take a period of two (2) months to ensure complete deletion of any information that might be stored in our backup. You may also contact Strathtec Retail Ltd to review, update or delete personal data stored about you. For relevant contact details please see section 19 below. Please note that prior to accessing and making changes to your account, we will need to verify your identity properly.
12. Right to withdraw your consent
Some of Strathtec Retail Ltd's processing activities may be based on your
consent. In such case, you will have the right to withdraw your consent at any
time. Withdrawal of your consent will not affect the lawfulness of processing
conducted prior to the withdrawal.
If you withdraw your consent, Strathtec Retail Ltd and third parties involved in personal data processing will cease to process your personal data, unless and to the extent the continued processing or storage is permitted or required according to the applicable personal data legislation or other applicable laws and regulations. Please note that as a consequence of your withdrawal of your consent, Strathtec Retail Ltd may not be able to meet your requests or provide you with our services.
13. Right to restriction of processing and right to object
You have the right to restriction of processing of your personal data, if the
personal data is not correct, if the processing is unlawful, but you oppose erasure
of your personal data, if Strathtec Retail Ltd no longer needs your personal
data for the purposes of processing, but storing such data is requested by you for
the establishment, exercise or defence of legal claims, or if you have objected to
processing and verification, whether Strathtec Retail Ltd still has legitimate
interest in the given personal data is pending. Please see section 19 for relevant
At any time you have the right to object to processing of your personal data collected and processed for purposes of the legitimate interests pursued by Strathtec Retail Ltd, for instance, when we provide you with relevant product software updates, make your future purchases easier by remembering your shipping details, or when we conduct analytics and statistics on your use type, date and frequency of your products. Please see section 19 for relevant contact details.
Furthermore, you have the right to object to processing of your personal data for direct marketing purposes. You can do so by unsubscribing from our marketing information by clicking on the unsubscribe link in the bottom of marketing communication from Strathtec Retail Ltd or by contacting one of our stores.
14. Right to complain
If you want to complain about a privacy breach, please contact Strathtec
Retail Ltd by sending your complaint to BOLLO.store, 180a Hutcheson Street,
Glasgow, G1 1SL or by sending e-mail to email@example.com.
We will acknowledge receipt of your complaint within five (5) business days. We will do our best to resolve it as quickly as possible and within one (1) month from the date of complaint. In case response would require longer term than one (1) month, we will let you know and inform you of the relevant reason(s). If you are not satisfied with outcome of your complaint or with handling of your complaint at Strathtec Retail Ltd, you may refer your complaint to Information Commissioners Office (ICO) https://ico.org.uk/global/contact-us/
15. Third-party websites, plug-ins and services
Websites, apps and products of Strathtec Retail Ltd may contain links to third
party websites, plug-ins, for instance social media login plug-in, or services, for
instance voice control functionality provided by Amazon or Google. As regards
your use of voice enabled products, please note that Strathtec Retail Ltd does
not collect or process any sound recordings on its own behalf, but only makes
available third party services.
16. Data security
Strathtec Retail Ltd is committed to protecting the security of your personal
data. We use necessary organizational, technical, and administrative measures to
protect your personal data under control of Strathtec Retail Ltd, such as
control of access, transmission, input and availability and the separation of data.
Access to a number of online services at Strathtec Retail Ltd are protected by
access restrictions based on user name and password. It is important that you
always choose a password which is hard to guess for others, and protect your
password against disclosure.
Your personal details and your credit card details, if you have provided such to Strathtec Retail Ltd remain encrypted in Strathtec Retail Ltd's secure web servers. Credit card information is directed to one or more approved and certified service provider(s), and will not be stored for longer than it takes to process the data. All external transmissions of personal data facilitated by Strathtec Retail Ltd are protected by encryption.
All data storage and processing at computer facilities of Strathtec Retail Ltd as well as at business partner facilities are subject to written contracts.
If you have reason to believe that your interaction with Strathtec Retail Ltd is no longer secure (for example, if you feel that the security of any account you might have with Strathtec Retail Ltd has been compromised), please notify us of the problem immediately by contacting us. Please see section 19 for relevant contact details.
17. Use by children
Strathtec Retail Ltd does not target and is not intended to attract children. Accordingly, our online services, including personal accounts on websites and apps provided by Strathtec Retail Ltd that collect any personal data are not directed at and should not be accessed by individuals under the age of sixteen (16 years), and we request that such individuals do not provide any personal data to Strathtec Retail Ltd. Minors must obtain express consent from parents or legal guardians prior to accessing or providing any personal data. If notified by a parent or guardian or discovered by other means, that a child under age of sixteen has provided his or her personal data to Strathtec Retail Ltd, we will cancel the child's account, if any, and delete the child's personal data in our possession.
to reflect changes in Strathtec Retail Ltd products and services, changes in applicable
legislation, regulations or practice and to address customer feedback.
Accordingly, please review it periodically. Date of the latest update is always provided on the top of the document.
19. Contact details
processing of your personal data, please contact us at:
Strathtec Retail Ltd
80a Hutcheson Street
or by sending e-mail to firstname.lastname@example.org
Strathtec Retail Ltd consists of BOLLO.store,
80a Hutcheson Street,
& Bang & Olufsen of Merchant City,
153 Ingram Street,