Liberator Ltd Privacy Notice
Liberator Ltd respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you interact with us and tell you about your privacy rights and how the law protects you.
Liberator Ltd gather and process your personal information in accordance with this privacy notice and in compliance with the relevant data protection legislation. This notice provides you with the necessary information regarding your rights and obligations, and explains how, why and when we collect and process your personal data.
Who we are
Liberator Ltd is part of the Prentke Romich Group, details of which can be found here. This privacy notice is issued on behalf of Liberator Ltd so when we mention "Liberator", "we", "us" or "our" in this privacy notice, we are referring to the relevant company in the Prentke Romich Group responsible for processing your data. Liberator Ltd is the controller and responsible for this website.
We have appointed a designated Compliance Officer who is responsible for overseeing questions in relation to this privacy notice.
Liberator Limited is a company registered in England and Wales under company number 02590367.
We are registered on the Information Commissioner's Office Register of Data Controllers under registration number Z8445988 and act as the data controller.
If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the Compliance Officer at: 25-27 High Street Swinstead Grantham Lincolnshire NG33 4PA or by email at firstname.lastname@example.org or phone 01733 370470.
Changes to the privacy notice and your duty to inform us of changes
This version was last updated on 03/05/2018. It’s likely that we’ll need to update this Privacy Notice from time to time. We’ll notify you of any significant changes, but you’re welcome to come back and check it whenever you wish.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
This website may include links to third-party websites. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
The Data We Collect About You
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender. If you provide a passport or driving licence to prove your identity (for example in order to obtain finance with us), the data will also include your place of birth, facial image and nationality.
- Medical Data includes relevant health and medical information about you. Where we collect Medical Data, we will only request the information required for the specified purpose and always ask for your explicit consent through a signature, or, under urgent circumstances based on legitimate interest.
- Contact Data includes billing address, delivery address, email address and telephone numbers - both work and personal and Skype address.
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
- Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses, notes from our conversations with you, details of any complaints or comments you make, items viewed or added to your basket, web pages you visit and how and when you contact us.
- Usage Data includes information about how you use our website, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
The only Special Categories of Personal Data we collect about you is Medical Data. We do not collect other Special Category Data such as details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
When and how we collect your personal data
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity, Contact, Financial, Marketing and Communications Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- apply for or buy our products or services on line, over the phone or during a consultant visit;
- apply for a product loan;
- contact us for enquiries or for product support or repairs;
- visit and / or create an account on our website;
- subscribe to our newsletter;
- request marketing to be sent to you;
- book any kind of appointment with us such as a consultant appointment or assessment;
- book to attend an event (for example an exhibition, a roadshow or a customer training event either on line or face to face);
- enter a competition, promotion or survey;
- give us some feedback or use our on-line chat facility;
- fill in any forms – for example, a VAT exemption form, a product return form or a photo & video media permission form.
- Third parties or publicly available sources. We may receive personal data about you from the following third parties:
- Technical Data from the following parties:
- analytics providers such as Google based outside the EU
- advertising networks such as MailChimp based outside the EU
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Paypal based outside the EU.
How We Use Your Personal Data (Legal Basis for Processing)
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you for example to ensure that orders are completed and can be sent out to your preferred address.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests for example we collect your sensitive personal data to enable us to provide personalised customer assessments to allow the selection of best product options and setup according to your personal needs, and to ensure that product setup is completed in a satisfactory manner for your daily use.
- Where we need to comply with a legal or regulatory obligation for example for accounting and tax purposes.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Type of data
Lawful basis for processing including basis of legitimate interest
To register you as a new customer
Performance of a contract with you
To process and deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(c)Choose and correctly set up a suitable device for you
(d) Deliver a product to you (we may need to share your details with a third party providing a service, such as delivery couriers)
(f) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to ensure we provide you with the right product, correctly set up or recover debts due to us and protect you from fraud)
(c) Consent for purpose (c) in certain circumstances
To manage our relationship with you which will include:
(b) Sending you legally required information relating to your orders or information about product recalls
(c) Asking you to leave a review or take a survey
(d) Responding to your queries, refund requests or complaints.
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated, to study how customers use our products/services, to provide you with the best service and to understand how we can improve our service based on your experience)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you; send you relevant communications by post in relation to updates, offers, services or products; measure or understand the effectiveness of the advertising we serve to you
(e) Marketing and Communications
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy and to run our loyalty scheme)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To share data with law enforcement.
(a) Necessary to comply with a legal obligation.
(b) Necessary to perform a contract with you.
For credit checks and fraud management
(a) Necessary to comply with a legal obligation.
(b) Necessary to perform a contract with you.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (marketing).
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any company outside Liberator for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences, by following the opt-out links on any marketing message sent to you or by contacting us. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
- External Third Parties as set out in the Glossary.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
If we do this, we have procedures in place to ensure your data receives the same protection as if it were being processed inside the EEA. For example, our contracts with third parties stipulate the standards they must follow at all times. If you wish for more information about these contracts please contact us.
Any transfer of your personal data will follow applicable laws and we will treat the information under the guiding principles of this Privacy Notice.
We know how much data security matters to all our customers. With this in mind we will treat your data with the utmost care and take all appropriate steps to protect it.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. For example, we secure access to all transactional areas of our websites using ‘https’ technology, use IT authentication and restricted access practices and secure sensitive data (such as payment card information) by SSL encryption.
In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
How Long We Keep Your Data
Liberator only ever retains personal information for as long as is necessary and we have strict review and retention policies in place to meet these obligations. We are required under UK tax law to keep your basic personal data (including Contact, Identity, Financial and Transaction Data) for a minimum of 6 years after which time it will be destroyed.
We also retail products that are classified as Class 1 Medical Devices. Under the Medical Devices Directive, we have a legal obligation to provide support until end of product life and beyond. To be able to do this, we keep customer data related to such products for 5 years from the last sale date of products manufactured within that category.
Where you have consented to us using your details for direct marketing, we will keep such data until you notify us otherwise and withdraw your consent.
In some circumstances you can ask us to delete your data: see Your legal rights below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Under certain circumstances, you have rights under data protection laws in relation to your personal data as set out below:
- Access to the personal data we hold about you, free of charge in most cases.
- Correction of your personal data when incorrect, out of date or incomplete - please update your online account, or contact our Customer Services team.
- Erasure of your personal data for example, when you withdraw consent, or object and we have no legitimate overriding interest, or once the purpose for which we hold the data has come to an end (such as the end of a warranty).
- That we stop using your personal data for direct marketing (either through specific channels, or all channels).
- That we stop any consent-based processing of your personal data after you withdraw that consent. Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent.
- That we restrict the way we process your personal data in the following scenarios:
- if you want us to establish the data's accuracy;
- where our use of the data is unlawful but you do not want us to erase it;
- where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
- you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- That we transfer your personal data to a third party by providing to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
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.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
We do not share or disclosure any of your personal information without your consent, other than for the purposes specified in this notice or where there is a legal requirement. Liberator uses third-parties to provide the below services and business functions, however all processors acting on our behalf only process your data in accordance with instructions from us and comply fully with this privacy notice, the data protection laws and any other appropriate confidentiality and security measures. Third parties include:
- Service providers acting as processors based in the UK who support our website and other business systems.
- Operational companies based in the UK such as delivery couriers.
- Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.
- Fraud prevention agencies based in the UK in relation to our product loans.HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
- Direct marketing companies based in the UK/US who help us manage our electronic communications with you.
- Google/Facebook to show you products that might interest you while you’re browsing the internet. This is based on either your marketing consent or your acceptance of cookies on our websites. See our Cookies Policy for details.
Lodging A Complaint
Liberator only processes your personal information in compliance with this privacy notice and in accordance with the relevant data protection laws. If, however you wish to raise a complaint regarding the processing of your personal data or are unsatisfied with how we have handled your information, you have the right to lodge a complaint with the supervisory authority.
25-27 High Street Swinstead Grantham Lincolnshire NG33 4PA
Tel: 01733 370 470
Information Commissioner's Office
Tel: 0303 123 1113 (local rate) or 01625 545 745 if you prefer to use a national rate number
Fax: 01625 524 510