​PRIVACY POLICY
Effective Date: 1st July 2024

SLADDERS LTD (“SLADDERS”, “we”, “us” and “our”) is committed to respecting the privacy rights of users to its website/app. This privacy policy ("Policy") explains how we collect, store and use your personal data when you browse www.sladders.com website (the "Site") and the Mobile Applications (the “App”) – collectively referred to as the “platform”.
This Privacy Policy is for all registered users of our platform and explains how SLADDERS LTD collects, uses and shares your personal data and explains your rights in relation to the data.
YOU MUST READ THIS PRIVACY POLICY CAREFULLY AND WE RECOMMEND THAT YOU PRINT AND RETAIN A COPY FOR YOUR FUTURE REFERENCE. BY BROWSING OR OTHERWISE USING OUR PLATFORM YOU MUST HAVE READ THIS POLICY.
When we say “SLADDERS”, “us”, “our” or “we” in this Policy, we are referring to SLADDERS LTD.
For the purposes of the General Data Protection Regulation (Regulation (EU) 2016/679, the (“GDPR”), SLADDERS LTD is the “data controller” (as defined in the GDPR) of the personal data, when it determines the purposes and means of the processing of personal data.
In addition, under the GDPR:
• ‘Personal data’ means any information relating to you and that identifies you, directly or indirectly;

• ‘Processing’ means any operation or set of operations which is performed on personal data or on sets of personal data.
We process your personal data on the basis of several legal grounds, including your consent (where you have given it), our contractual obligations to you (such as when you purchase our services), our legal obligations (as required by EU or member state law), and our legitimate interests (such as to improve our services).
We reserve the right to make changes to this Policy at any time and we may notify you of changes to this policy by email or through the private messaging or notification system on our platform. Your continued use of our products, applications, services and websites that are subject to this Policy will signify your acceptance of any and all changes to this Policy made by us from time to time and you should check this page occasionally to ensure you are happy with any changes to this Policy.

How we use your personal data
We use and share your personal data in accordance with the legal bases set out below to help us provide, operate, improve, understand, customize, support and market our Services to you. We use the personal data we collect to help us operate our business, provide and improve our products and services, communicate with you, and advertise effectively.
We may share your data with third-party service providers who perform services on our behalf, such as hosting, data analysis, IT services, and customer service. All our third-party service providers are required to take appropriate security measures to protect your personal data in line with our policies
Categories of personal data we may collect
• Forename
• Surname
• Username/User ID
• Profile and Cover Photos (should you choose to use one)
• Age category
• Email address
• Telephone no.
• Country of Residence and/or Postcode
• Competition Entry Information (for competition entries)

Personal Information about other individuals
If you give us information on behalf of someone else, you confirm that the other person has appointed you to act on his/her behalf and has agreed that you can:
• give consent on his/her behalf to the processing of his/her data;
• receive on his/her behalf and data protection notices;
• give consent to any transfer of his/her data;

Information that will be collected automatically
Cookies: We may monitor your use of our platform through the use of cookies and similar tracking devices.

Device information: We may also collect information about your device each time you use our platform. For example, we may collect information on the type of mobile device that you are using and its unique device identifier (for example, the IMEI number, the device’s mobile phone number, or the MAC address of the device’s wireless network interface), the type of mobile browser that you are using, the mobile operating system that you are using, mobile network information and the time zone setting.

Location data: We may also collect information to determine your location using GPS technology or such other location tracking software we may use from time to time. Some of the features of the Website/App may require access to such location data to work. If you would like to use any such feature, you will be asked to consent to provide such location information. You can withdraw your consent to providing this information at any time by emailing privacy@sladders.com or contacting us via the contact details at the bottom of this policy.
How your personal data will be used
We will use your personal data for the following purposes:
• to offer our services;
• to offer our competitions;
• to help identify you and any accounts you hold with us;
• administration;
• research, statistical analysis and behavioural analysis;
• customer profiling and analysing your purchasing preferences;
• marketing—see 'Marketing and opting out', below;
• fraud prevention and detection;
• customizing our platform and its content to your particular preferences;
• to notify you of any changes to our platform or to our services that may affect you;
• improving our services.

Profiling
We might display or send personalized content or communications using profiling techniques (defined by the GDPR as any form of automated processing of personal data evaluating the personal aspects relating to a natural person, in particular to analyze or predict aspects concerning the data subject's personal preferences or interests, behavior or location).
We use automated decision-making processes, including profiling, to enhance your experience and our service efficiency. For instance, we might use automated algorithms to personalize the content and offers you see. You have rights in relation to automated decision making, including the right to challenge decisions made about you based solely on automated processes.

Marketing and opting out
If you prefer not to receive any further direct marketing communications from us you can opt out at any time, by clicking on the unsubscribe button on our emails or by contacting us directly via email or letter at the addresses shown at the end of this policy.
The Website/App may contain links to other websites or apps which we or our partners own, or websites or apps of our partners or third parties. Please note that if you follow any of these links, the websites, apps and services provided through them will have their own privacy policies/terms of use. We do not accept any responsibility or liability for their respective privacy policies/terms of use or the collection and use of any personal data collected through these websites, apps or services. Please ensure that you review the relevant privacy policies/terms of use prior to providing any personal data to, or using these websites, apps and services.

Keeping your data secure

We will use technical and organizational measures to safeguard your personal data, for example:
• Where you create an account on our platform, this will be controlled by a password and username that are unique to you;
• We will store your personal data on secure servers;
While we will use all reasonable efforts to safeguard your personal data, you acknowledge that the use of the internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal data that are transferred from you or to you via the internet.

Transfers of data out of the EEA
We will make reasonable efforts to ensure that your data is not transferred outside the European Economic Area (EEA). Where we use data servers that may transfer data out of the EEA we will take steps to ensure adequate protections are in place to ensure the security of your information and give you remedies in the unlikely event of a security breach.
All information you provide to us is stored with secure data processors for the purposes of storing your data, accounting purposes and social media purposes for example. A copy of your information is also stored securely on our internal server and computers where access is restricted.
Please note that any processors we utilize that may transfer your data to the US, comply with the EU-US Privacy Shield Framework, which is a mechanism that ensures compliance with EU data protection requirements when transferring personal data from the European Union to the United States. You can learn more about Privacy Shield here: https://www.privacyshield.gov/welcome
While we will use all reasonable efforts to safeguard your personal data, you acknowledge that the use of the internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal data that are transferred from you or to you via the internet. If you have any particular concerns about your information, please contact us using our contact details at the bottom of this policy.
When necessary, we rely on the Commission Adequacy decision on the EU-U.S. Privacy Shield or we may ask them to enter into contracts based on the template adopted by the European Commission according to Article 46.2 of the GDPR.

Monitoring
We may monitor and record communications with you (such as telephone conversations and emails) for the purpose of quality assurance, training, fraud prevention and compliance.

Your Consent and Rights of Access
We will only collect and store information about you as detailed above. You will be provided with opportunities to consent to this Privacy Policy and marketing when you provide your personal details to us.
You can change your mind or remove or amend your consent at any time.
• You have the right of access to your personal records or other information that we hold about you. There is no administrative charge for this service.
• You have the right to rectify any errors in the data we hold about you. If any data or information we hold about you is inaccurate, or out of date, please contact us and we will correct this immediately.
• You have the right to have the data we hold about you erased.
• If you wish us to continue to store your information but wish us to keep your data separate and not process it in any way, please let us know and we will do so.
• You have the right to ask us to stop processing your personal data for direct marketing purposes. You may also specify that you object to direct marketing by particular channels such as by email or telephone. If this is the case, please specify the channels you are objecting to in your communications with us.
• You have the right to data portability. If you wish to obtain your data for your own purposes across different services, we will provide this information to you. There is no administrative charge for this service.
To revise your consent, access, amend or remove your records or assert any of your rights set out above, you should send your request in writing to us at the address shown at the bottom of this policy.
You will need to provide proof of identity and address (e.g. a copy of your driving licence or passport, and a recent utility or credit card bill); and specify the personal data you want access to, amended or removed.

How long we will store your data
We will store your data for as long as necessary for the purpose of processing. The data will be deleted in the following circumstances:
• You have withdrawn your consent to data processing
• The original purpose for processing the data is no longer relevant or cannot be performed any more.
• The data is no longer up to date or accurate.
We retain your personal data only as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Specific retention periods can be provided upon request.

Changes to this privacy policy
We may change this Policy from time to time. You should check this policy frequently to ensure you are aware of the most recent version that will apply each time you use the Website/App.

Children
We do not and will not knowingly collect information from any unsupervised person under the age of 18. For the processing of the personal data of a child below the age of 18, the consent of the holder of parental responsibility is necessary. We shall make reasonable efforts to verify in such a case that consent is given or authorized that way, taking into consideration available technology.

False e-mails
We will never ask you to confirm any account or credit card details via e-mail. If you receive an e-mail claiming to be from SLADDERS asking you to do so, please ignore it and do not respond.

Data Protection Supervisory Authority
The Data Protection Supervisory Authority in the UK is the Information Commissioners Office. Should you have any complaints about the way we handle your data, you may direct them to the ICO. More information on the ICO can be found on their website here: https://ico.org.uk



Contact Us
We welcome your feedback and questions. If you wish to contact us, please send us an email to privacy@sladders.com.