Privacy Policy

1. Introduction and Scope
2. Data We Collect
3. How Your Data is Collected
4. Lawful Basis for Processing Data
5. How Your Data is Used
6. Data Sharing & International Transfers
7. Data Retention
8. Data Security
9. Your Rights
10. Marketing Communications & Websites
11. Complaints
12. Policy Updates & Amendments

1.1. Introduction

Macfarlane Group is dedicated to protecting and respecting your privacy.

This policy explains how Macfarlane Group UK Limited, and our wholly owned subsidiaries, collect, use, disclose and safeguard process your personal data when you use our products, services and websites (collectively, the “Services).

1.2 Scope

For the purposes of this policy, Macfarlane refers to Macfarlane Group UK Limited. Companies and websites owned by Macfarlane Group and in scope of this policy include:

1.3 Acknowledgement

This policy is issued in accordance with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018 and, where applicable, EU GDPR. Please read this document carefully. By using our Services, you acknowledge that you have read and understood this policy.

Your Rights at a Glance

You have the right to access, correct, erase and port your data. You may also object to or restrict its processing and challenge any auto-decision making. See section XX for full details or contact our DPO at [email protected].

2.1 Data We Collect

We collect personal data in the below categories. This can be data you provide to us or data we collect when you use our Services (see section 3).

2.2 Data of Children

The products and services of Macfarlane Group are aimed at persons over the age of 18.

If we have reason to believe that we hold personal data under that age in any of our systems or databases, we will delete that personal data.

3.1 How Data is Collected

Throughout Macfarlane Group, we collect data through multiple methods. These include:

Data protection law in the UK allows us to collect, use, store and transfer personal information if we have one or more of the lawful bases for doing so. The primary lawful bases for Macfarlane Group processing your data are set out in section 4.

5.1 How Your Data is Used

Typical ways we will use your data to fulfil our contract with you and within the abovementioned lawful basis can include:

• Order processing – including taking payment, supplying products and any after sales services such as cancellations and returns;
• Identity verification and credit checking;
• Order fulfilment and tracking – including sharing data with courier partners, keeping you updated about the process of your order via email or phone. You may also be contacted directly by courier partners regarding delivery, for example if attempted and no one is at the delivery address;
• Account creation and administration – where you have registered with us, we may contact you via phone, email or post to administer your account;
• Audit, compliance and regulatory reporting;
• Processing competition or survey entries made by you;
• Administration, analysis, security and assessment of our websites – this may include their performance, to understand and develop our business and for the improvement and optimisation of our websites, including website security;
• Sending marketing communications – this can include email marketing, direct mail and digital advertising or targeting.

5.2. Automatic Decision Making

Automated decision making is decision making that can include:

• automated individual decision-making (making a decision solely by automated means without any human involvement); and
• profiling (automated processing of personal data to evaluate certain things about an individual). Profiling can be part of an automated decision-making process.

Macfarlane Group use automated decision making in a limited capacity, per the below.

5.2.a  We will use your personal data for the purposes of automated decision-making in relation to the content we display to you on our websites, and the types of marketing communications we send to you.

5.2.b  This automated decision-making will involve analysis of information you provide to us, including product interests (which may be signified by browsing behaviour, downloads etc.), geographical location, job role / title, industry sector and so on.

5.2.c  The significance and possible consequences of this automated decision-making are that the content made available to you should be more closely aligned with your interests and requirements.

Please note that no information or resources on our websites will be made unavailable to you as a result of this profiling.

6.1 Data Sharing

We may share your information within Macfarlane Group PLC and with our selected third parties for the purposes referred to above. Examples of providers we may securely share your data with may include:

• Payment Acquiring Services to process your payment;
• Delivery and Courier Companies to supply your order;
• Suppliers or Printers involved in the fulfilment of your order or for communication purposes where your preferences allow;
• Credit Reference & Fraud Prevention Agencies for credit checking and identity verification;
• Analytics and search engine providers that assist us in the improvement and optimisation of our website;
• Build and hosting service providers that help us to maintain the software that runs our website. They provide us with reporting statistics and serve cookies on our behalf to enable any website personalisation and sign-in functionality.
• Where you opted in to direct marketing, third party advertisers, affiliate marketing agencies and advertising networks engaged by us to select and serve relevant communications to you on our behalf.

We require all third parties engaged by us to respect the security of your personal data and to treat it in accordance with the law. Such third parties are only allowed to process your personal data in accordance with our instructions, and not for their own purposes.

From time to time, we may ask you if you would like to be contacted by other selected third parties, such as part of a joint promotion or a collaboration. If we do this, we will also provide you with a link to that third party’s privacy policy to help you decide if you wish to be contacted by them. If you do consent to this (by an express opt in), that third party would be the data controller in respect of any activity by them that you have consented to.

6.2. International Data Transfers

The data that we collect from you may be transferred to, and stored at, a destination outside of the UK.

Some of our service providers are located outside the United Kingdom and European Economic Area (EEA). Where we transfer data internationally, we ensure adequate protection is in place through one of the following mechanisms:

• UK Government adequacy decisions or adequacy regulations
• International Data Transfer Agreements (IDTAs) or Standard Contractual Clauses (SCCs) approved by the ICO or European Commission
• Binding Corporate Rules (BCRs) where applicable

You may request a copy of the safeguards in place for any specific transfer by contacting our DPO.

7.1 Why We Retain Data

Macfarlane Group will retain your data, where relevant, for as long as you are a customer and/or we believe you are a potential user of our products or services (for example you have requested information or have completed an enquiry form).

We may keep it for longer in order to respond to any questions or complaints and to maintain necessary records to satisfy legal, accounting or reporting requirements. We may also keep your data for research or statistical purposes.

8.1 Data Security Approach & Protections

At Macfarlane Group, we take data security very seriously. We understand that security is
important to our customers and therefore implement security systems that provide security to the latest industry standards to prevent loss, misuse and alteration of the data under our control.

Data security measures being taken across the Group include (but are not limited to):

• Secure configuration of platforms and servers to internationally recognised standards
• User access controls for both digitally and manually stored data
• Malware protection
• Robust security update management
• Firewalls and data encryption to protect and anonymise data
• Secure website hosting and Secure Sockets Layer (SSL) certificates on our websites
• Comprehensive staff training
• Security audits and testing

In addition, we do not hold credit / debit or other payment details on our websites. Once payments have been validated and approved, payment details are deleted.

8.2 Links to Other Organisations

If you follow links to any other websites from our websites, these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

Under UK and EU GDPR data protection laws, you have the following subject access rights in respect to your personal data.

Your Rights at a Glance

You have the right to access, correct, erase and port your data. You may also object to or restrict its processing and challenge any auto-decision making. To do so contact our DPO at [email protected].

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.

You will not have to pay a fee to access your personal data and we try to respond to all requests within one month.

To opt out of marketing, you can do so by emailing the DPO, emailing [email protected] or doing so directly with the Group brand from whom you have received the marketing campaign. Marketing emails will include an unsubscribe link that allows you to update preferences for that brand.

Within Macfarlane Group, we operate multiple marketing communications programmes and websites for our brand portfolio.

 10.1 Data collected for marketing purposes

Data collected for marketing purpose includes identity data, account data, transaction data, technical & usage data, as well as marketing specific data such as communication preferences.

The below table outlines the legal basis for collecting this data.

10.2 Types of marketing communication

Marketing communications activities that involve your data can include (but is not limited to):

• Email marketing
• Website targeting or profiling (showing you content based on your preferences or behaviour)
• Social media advertising
• Pay per click advertising
• Direct mail (communication by post)

10.3 Opting out of marketing communications

You may opt out of marketing communications from Macfarlane Group and any of our subsidiaries at any time.

To opt out of marketing, you can do so by emailing the DPO, emailing

10.4 Websites and cookies

Macfarlane Group operates multiple websites (listed below). These websites will use functional and analytics cookies to help the websites function and understand how users behave on the websites.

Cookies are small files of letters and numbers that are downloaded on to your computer when you visit a website. Cookies can do lot of things, depending on their function.

You can use your web browser to:

• delete all cookies;
• block all cookies;
• allow all cookies;
• block ‘third-party’ cookies (ie, cookies set by online services other than the one you are visiting);
• clear all cookies when you close the browser;
• open a ‘private browsing’ / ‘incognito’ session, which allows you to browse the web without recording your browsing history or storing local data such as cookies (you should however be aware of the limitations of this feature in a privacy context); and
• install add-ons and plugins that extend browser functionality.

Full options will depend on your browser.

Each Macfarlane Group website has its own cookie policy, listing the cookies used by that site. For more information about the cookie policy for a particular brand, please visit that site.

The cookie policy for the website you are reading this privacy policy on can be found by clicking here.

On all our websites, you will be given a choice about which cookies you accept or decline. You can choose to accept all or some of the cookies on our websites. Alternatively, you can choose to decline them too.

11.1 Making a Complaint to Macfarlane Group

You have the right to complain about your data and/or its use at any time. To do so, you can email our DPO at [email protected] or contact us on 0800 288 8822 (if you are based in the UK) or IE +353 404 37370 (if you are based in Ireland).

11.2 Making a Complaint to the Information Commissioner’s Office (ICO)

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 (www.ico.org.uk). However, we would appreciate the chance to deal with any concerns you may have before you approach the ICO so please contact us in the first instance.

Any changes we make to this policy in the future will be posted on this page and, if appropriate, notified to you by email so please check this page regularly.