Privacy & Cookies
George Robertson Ltd is committed to protecting and respecting your privacy. This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. For the purpose of the Data Protection Act 1998 (the Act), the data controller is George Robertson Ltd, 3-4 Carlton Place, Lerwick, Shetland ZE1 0ED.
We may collect and process the following data about you: information that you provide by filling in forms on Our Sitewww.grdirect.co.uk (Our Site), details of transactions you carry out through Our Site and of the fulfilment of your orders if you contact us, we may keep a record of that correspondence. We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them; details of your visits to Our Site and the resources that you access.
All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted. Where we have given you (or where you have chose a password which enables you to access certain parts of Our Site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to Our Site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
We use information held about you in the following ways: to carry out and to enable our third party agents and suppliers to carry out our obligations arising from any contracts entered into between you and us (such as the purchase of a product), to process and to enable our third party agents and suppliers to process payments made by credit/debit card, including validation of your personal data against third party databases (for example credit reference agencieto guard against fraud. Your data will not be used for credit checks and your credit rating will not be affected to ensure that content from Our Site is presented in the most effective manner for you and for your computer to provide you with information, products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes to allow you to participate in interactive features of our service, when you choose to do so
If you are an existing customer, we will only contact you by electronic means (e-mail or SMS) with information about goods and services similar to those which were the subject of a previous sale to you.
If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this.
If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please tick the relevant box situated on the form on which we collect your data.
You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your datif we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by ticking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at email@example.com. Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that 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.
The Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act. Any access request may be subject to a fee of £10 to meet our costs in providing you with details of the information we hold about you.
1) What is a cookie?
Cookies are simple text files that a site saves to your computer or mobile device using your website browser. Only that server will be able to retrieve or read the contents of that cookie and each cookie is unique to your web browser.
Cookies are either set by the website you are visiting, in which case they are referred to as ‘first-party cookies’, or are ‘third-party cookies’ set by other websites and services that run content on the page you are viewing.
They also allow a website to remember you, and your browsing preferences, either for the duration of your visit using a ‘session cookie’ or for repeat visits using a ‘persistent cookie’ (explanations for all types of cookies can be found under ‘types of cookies’).2) Our cookies policy
To make full use of the features on the GRDirect website, your computer or mobile device will need to accept cookies.
But some people dislike the idea of a website accessing and storing their data. And if that’s the case, you have the ability to accept or decline cookies by modifying the settings in your browser at any time. The ‘help’ function within your browser should tell you how, as will the ‘enabling/disabling cookies’ page on this site. However, you may not be able to use all the interactive features of our site if the cookies are disabled.3) Types of cookieFirst-party cookies
First-party cookies are set by the website you are visiting and they can only be read by that site.They can make your experience on the web more efficient by recording your browsing activities, such as what pages and content you’ve looked at, when you visited, what you searched for and whether you clicked on an ad.Third-party cookies
Third-party cookies are set by a different organisation to the owner of the website you are visiting. This could be a company advertising on the site you’re visiting, for example, or a site that contains embedded content, such as Twitter or Facebook.
Those websites may send you cookies and they control the setting of those cookies, not the site you are visiting.Session cookies
Session cookies are stored temporarily during a browsing session and are deleted from the user’s device when the browser is closed.Persistent cookies
This type of cookie is saved on your computer for a fixed period and is not deleted when the browser is closed. These cookies are used to save your preferences so that they persist when you return to the website.Flash cookies
Flash cookies work in a different way to web-browser cookies (first-party, third-party, session and persistent cookies are all set via your browser). Rather than having individual cookies for particular jobs, a flash website is restricted to storing all data in one cookie.
You can control how much data can be stored in that cookie, but you cannot choose what type of information is allowed to be stored.4) Enabling/disabling cookies
There are two types of website users: those who would like their visit to be as easy, quick and relevant as possible, and who (knowingly or unknowingly) therefore sit firmly in the cookie supporter camp; and then there are those who are discomforted by the idea that ‘Big Brother’ is watching them and would rather lose some of the functions cookies enable to remain more anonymous.
Different browsers have different ways of allowing you to enable or delete cookies, or limit the kinds of cookies that can be placed on your computer. When choosing your browser (ie, Google Chrome or Safari), you may want to consider which best suits your privacy preferences.
To check out the settings in a browser, use the ‘help’ tab or look under ‘tools’ for settings like ‘options’ or ‘privacy’. From there, you may be able to delete cookies, or control when they can be placed.
If you disable cookies you may limit your browsing experience. For example, you may need to enter information repeatedly, or you might not get personalised content or ads that are meaningful to you. However, most browsers’ settings will allow you to block third-party cookies without also disabling first-party cookies.
George Robertson Ltd understands that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who visits this website, https://www.grdirect.co.uk (“Our Site”) and will only collect and use personal data in ways that are described here, and in a manner that is consistent with Our obligations and your rights under the law.
1. Definitions and Interpretation
Means an account required to access and/or use certain areas and features of Our Site;
Means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 13, below;
Means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;
Means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site. This definition shall, where applicable, incorporate the definitions provided in the Data Protection Bill 2018 and EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”);
Means George Robertson Ltd, a company registered in England under company number SC305786, of George Robertson (Shetland) Ltd, 3-4 Carlton Place, Lerwick, Shetland, ZE1 0ED.
2. Information About Us
2.1 Our Site is owned by George Robertson Ltd, a company registered in the United Kingdom under company number SC305786, of George Robertson (Shetland) Ltd, 3-4 Carlton Place, Lerwick, Shetland, ZE1 0ED.
2.2 Our site is operated by our professional marketing partner OneAgency, who assist us with website design, development and database support as required.
2.3 Our VAT number is 890523221.
2.4 Our Data Protection Officer can be contacted by email at firstname.lastname@example.org.
3. What Does This Policy Cover?
4. Your Rights
4.1 As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:
4.1.1 The right to be informed about Our collection and use of personal data;
4.1.2 The right of access to the personal data We hold about you (see section 12);
4.1.3 The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us using the details in section 14);
4.1.4 The right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you (We only hold your personal data for a limited time, as explained in section 6 but if you would like Us to delete it sooner, please contact Us using the details in section 14);
4.1.5 The right to restrict (i.e. prevent) the processing of your personal data;
4.1.6 The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);
4.1.7 The right to object to Us using your personal data for particular purposes; and
4.1.8 Rights with respect to automated decision making and profiling.
4.2 If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided in section 14 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.
4.3 For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.
5. What Data Do We Collect?
5.3 age range
5.4 contact information such as email addresses and telephone numbers;
5.5 demographic information such as post code, preferences, and interests;
5.6 financial information such as credit / debit card numbers;
5.7 IP address;
5.8 web browser type and version;
5.9 operating system;
5.10 a list of URLs starting with a referring site, your activity on Our Site, and the site you exit to;
6. How Do We Use Your Data?
6.1 All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the Data Protection Bill 2018 and GDPR at all times. For more details on security see section 7, below.
6.2 Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of your personal data (e.g. by subscribing to emails), or because it is in Our legitimate interests. Specifically, We may use your data for the following purposes:
6.2.1 Providing and managing your Account;
6.2.2 Providing and managing your access to Our Site;
6.2.3 Personalising and tailoring your experience on Our Site;
6.2.4 Supplying Our products and services to you (please note that We require your personal data in order to enter into a contract with you);
6.2.5 Replying to emails from you;
6.2.6 Supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time by clicking the unsubscribe link in our emails’ footers;
6.2.7 Market research;
6.2.8 Analysing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience;
6.3 With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email AND/OR telephone AND/OR text message AND/OR post with information, news and offers on Our products and services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the Data Protection Bill 2018 and GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003.
6.4 Third parties (as listed below) whose content appears on Our Site may use third party Cookies, as detailed below in section 13. Please refer to section 13 for more information on controlling Cookies. Please note that We do not control the activities of such third parties, nor the data they collect and use and advise you to check the privacy policies of any such third parties.
6.5 You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it.
6.6 We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Data will therefore be retained for the following periods (or its retention will be determined on the following bases):
6.6.1 Data relating to orders you have placed with Us will be held for a minimum of 6 years and may be held beyond this period for the purposes of marketing unless you withdraw consent thereafter.
6.6.2 Data relating to Marketing will be held for an unspecified time period and only until such time as consent is withdrawn by you.
7. How and Where Do We Store Your Data?
7.1 We only keep your personal data for as long as We need to in order to use it as described above in section 6, and/or for as long as We have your permission to keep it.
7.2 Your data will only be stored within the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein).
Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure data collected through Our Site.
7.3 Steps We take to secure and protect your data include, but are not limited to:
7.3.1 Use of SSL Certificates
7.3.2 Use of Encrypted storage of data
7.3.3 Use of PCI compliance systems for payment transactions
7.3.4 Use of an encrypted password firewall for access to personal sensitive data (Such as My Account and Order History)
7.3.5 Periodic testing of systems against known vulnerabilities such as DDOS attacks or SQL injection and malware.
8. Do We Share Your Data?
8.1 We may share your data with other companies in Our group in order to facilitate processing of orders.
8.2 We may sometimes contract with third parties to supply products and services to you on Our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising, and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law.
8.3 We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.
8.4 We may sometimes use third party data processors that are located outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). Where We transfer any personal data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the Data Protection Bill 2018 and GDPR including:
8.5 In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal requirements, a court order, or a governmental authority.
9. What Happens If Our Business Changes Hands?
9.2 In the event that any of your data is to be transferred in such a manner, you will be contacted in advance and informed of the changes. When contacted you will be given the choice to have your data deleted or withheld from the new owner or controller.
10. How Can You Control Your Data?
10.1 In addition to your rights under the GDPR, set out in section 4, when you submit personal data via Our Site, you may be given options to restrict Our use of your data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details and by managing your Account).
10.2 You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
11. Your Right to Withhold Information
11.1 You may access certain areas of Our Site without providing any data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
12. How Can You Access Your Data?
You have the right to ask for a copy of your personal data held by Us (where such data is held and is not exempt for disclosure). Under the Data Protection Bill 2018, Under the GDPR, no fee is payable for a single request for data and We will provide non exempted information in response to your request in the first instance. Should you wish to make such a request on more than one occasion within a reasonable period, George Robertson Ltd reserved the right to charge a nominal fee to cover Our expense in providing data on subsequent occasions. This charge shall not exceed £10 for the second or subsequent requests. Please contact Us for more details at George Robertson (Shetland) Ltd, 3-4 Carlton Place, Lerwick, Shetland, ZE1 0ED.
13.2 By using Our Site you may also receive certain third party Cookies on your computer or device. Third party Cookies are those placed by websites, services, and/or parties other than Us. Third party Cookies are used on Our Site for improving user experience, advertising services, and review services. For more details, please refer to section 6, above, and to section 13.6 below. These Cookies are not integral to the functioning of Our Site and your use and experience of Our Site will not be impaired by refusing consent to them.
13.3 All Cookies used by and on Our Site are used in accordance with current Cookie Law.
13.4 Before Cookies are placed on your computer or device, you will be shown a notification message requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling Us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended.
13.5 Certain features of Our Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown below in section 13.6. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below in section 13.10, but please be aware that Our Site may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.
13.6 The following first party Cookies may be placed on your computer or device:
|Name of Cookie||Purpose||Strickly Necessary|
|PHPSESSID||Used to keep track of session and expires at the end of a user’s session.||Yes|
|X-Mapping-fjhppofk||Used to route data and page requests to the correct server where a site is hosted on multiple servers and expires at the end of a user’s session||Yes|
and the following third-party Cookies may be placed on your computer or device:
|Name of Cookie||Provider||Purpose|
|_ga||Google Analytics||Used to identify unique users. Expires after two years.|
|_gat||Google Analytics||Used to throttle the request rate. Expires after one minute.|
|_gid||Google Analytics||Used to distinguish users and has an expiration of two years.|
13.7 Our Site uses analytics services provided by Google Analytics. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling Us to better understand how Our Site is used. This, in turn, enables Us to improve Our Site and the products and services offered through it. You do not have to allow Us to use these Cookies, however whilst Our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable Us to continually improve Our Site, making it a better and more useful experience for you.
13.8 The analytics service(s) used by Our Site use(s) Cookies to gather the required information.
13.9 The analytics service(s) used by Our Site use(s) the following Cookies:
|Name of Cookie||First/Third Party||Provider||Purpose|
|_ga||Third||Google Analytics||Used to identify unique users. Expires after two years.|
|_gat||Third||Google Analytics||Used to throttle the request rate. Expires after one minute.|
|_gid||Third||Google Analytics||Used to distinguish users and has an expiration of two years.|
13.10 In addition to the controls that We provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third-party Cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
13.11 You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.
13.12 It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
14. Contacting Us