This Privacy Policy delineates the procedures by which HandCo manages personal data during various interactions such as visiting our warehouse stores, making purchases, utilizing our website (accessible at handco.com), employing our mobile application (“app”), contacting customer service, or engaging with us in any other way. We urge you to periodically review our Privacy Policy to ensure your comprehension of how we handle your personal data and the options available to you concerning such handling.The entity responsible for processing the personal data about you depends on whether you are a member of our warehouse or online services, or if you utilize our travel services. The data controllers may be HandCo Wholesale UK Limited, HandCo Online UK Limited, or HandCo Travel UK Limited (“HandCo”, “we”, or “us”). Our headquarters in the UK are situated at Unit 1 & 2 Globe Park, Moss Bridge Road, Rochdale, OL16 5EB.Kindly note that we may issue additional or distinct privacy notifications regarding specific products, services, or programs. Furthermore, any personal data provided during visits to HandCo’s warehouses or websites outside the UK are subject to the privacy policies of the respective HandCo entities in those particular countries.

1. HandCo’s Dedication to Personal Data and Privacy

At HandCo, safeguarding your privacy is paramount, and we adhere strictly to all pertinent laws and regulations concerning the protection of personal data.We firmly commit to not selling or leasing your personal data to any external parties. Any sharing of personal data with third parties is solely governed by the terms outlined in this Privacy Policy. Such sharing occurs only with your explicit prior consent or in adherence to relevant legislation where consent is not mandated. For a detailed understanding of how we collaborate with third parties in sharing personal data, please refer to Section 5.We highly value your ability to make informed decisions regarding the processing of your personal data. This Privacy Policy elucidates the avenues through which you can exercise your choices concerning the usage and processing of your personal data.

2. WHAT IS PERSONAL DATA?

Personal data refers to information concerning a known or potentially identifiable person.

3. WHAT PERSONAL DATA IS COLLECTED BY HANDCO?

At HANDCO, we gather personal information through various interactions, such as signing up or renewing your membership, visiting our warehouses, making purchases, returns, or exchanges, and engaging with our products and services. Your interaction with our website, app, or kiosks, participation in surveys, promotions, contests, or sweepstakes, as well as communication via email or phone, also leads to the collection of personal data. Here’s an overview of the types of personal data we collect and the circumstances under which we collect them:

• Identification Data: This includes your name, title, marital status, photograph (captured at HANDCO’s premises for your membership card or digitally for your digital membership card), date of birth, identity document (such as national identification card, passport, or residence permit), tax identification number, and your HANDCO membership number.
• Contact Data: We collect information such as your address, email address, home phone number, and mobile phone number for communication purposes.
• Transactional Data: Information regarding individual purchases and returns, payment card details (card number, expiry date, CVV), e-receipts when using the app, account notes associated with your transactions, and any additional information you choose to provide during a transaction, such as photographs for the HandCo Photo Centre.
• Electronic Data: This category encompasses the IP address used to access our website, mobile device ID, browser type, website activity, and video surveillance footage obtained from our warehouses. If you opt for geolocation services in our app, we may also collect geolocation data. We automatically gather electronic data through cookies, pixels, and local storage when you access and use our website. For detailed information, please refer to our Cookie Policy

In addition to direct interactions, we may receive personal data related to members and customers through indirect channels. For instance, when a member adds household members to their membership account, we collect their names, addresses, phone numbers, and email addresses from the member. Furthermore, we may obtain personal data, such as contact information, from third-party entities that assist us with specific processes like records correction, fraud prevention, delivery services, or special promotions. We merge this data with the information we directly collect to manage your membership effectively, deliver products and services, and maintain accurate records.

4. HOW DOES HANDCO USE PERSONAL DATA?

At HandCo, we prioritize the protection and respectful use of personal data. We leverage this information to cater to your needs effectively, enhance our services, and keep you informed about relevant opportunities. Here’s an overview of how we utilize personal data:

• We process your personal data to facilitate your membership requests or renewals, ensuring smooth administration and adherence to our membership agreement.
• Your personal data aids us in delivering products and services seamlessly. This includes processing payments, sending purchase-related notifications via email or SMS, managing exchanges and returns, and honoring warranties.
• Should you reach out with queries or complaints, we utilize your personal data to promptly address your concerns, with your consent guiding this process.
• We may send you tailored marketing communications via various channels, such as email, direct mail, phone calls, and push notifications within our app. These communications are based on your membership account details and purchase history, aiming to provide you with relevant information and offers. You retain the right to opt out of promotional communications.
• Your personal data enables us to keep you informed about your orders, including status updates, shipping details, and product quality information. This helps us improve your shopping experience and deliver relevant information.
• We process personal data to fulfill our legal obligations, encompassing tax responsibilities, fraud prevention, consumer protection, and compliance with UK law.
• Understanding your website usage assists us in enhancing our online platform to better meet user expectations and needs.
• Personal data aids us in internal processes such as planning, resource allocation, policy development, and quality improvement, fostering a better shopping experience and business growth.
• We utilize personal data to detect, investigate, and prevent fraudulent activities, ensuring the safety and security of our members, customers, employees, and premises, including through the use of video surveillance systems.
• By employing personal data responsibly and transparently, we strive to maintain your trust while providing exceptional service.

5. HOW DOES HANDCO SHARE PERSONAL DATA WITH THIRD PARTIES?

We do not share personal data about you with third parties except as follows:

• Our Service Providers

We collaborate with reputable companies to facilitate various services such as web/app hosting, payment processing, product delivery, and data analysis. While engaging these service providers, certain personal data might be shared. It’s important to note that some of these providers operate internationally, potentially involving cross-border data transfers as elaborated in Section 6.

• Third-Party Suppliers

In partnership with selected suppliers, we offer specific products and services like optical and hearing aids. When you avail of such offerings, we may share necessary personal information such as your name and membership details to ensure seamless delivery. However, any additional information shared directly with these suppliers should be done cautiously, and we encourage you to review their privacy policies beforehand.

• Primary HandCo Account Holder

For HandCo members, each account has a designated primary holder who can manage add-on members and oversee account activities. Likewise, online subscription accounts have primary subscribers with similar privileges.

• Third Party Services

You can access certain products and services offered by HandCo through third-party providers, including financial and travel services. Information shared during such transactions will be disclosed to the respective third-party provider, as detailed in Section 9 for more details about Third Party Services.

• Our Affiliates and Entities that Belong to HandCo’s Corporate Group

Personal data may be shared with our corporate affiliates to fulfill the purposes outlined in Section 4. Please note that such sharing might involve cross-border data transfers due to the international presence of our affiliates.

• Fraud Control

HandCo collaborates with service providers and industry associations to combat fraudulent activities. Limited personal data, such as membership details or partial payment card numbers, may be shared for this purpose.

• Compliance with Law

We may disclose personal data when legally mandated or necessary to comply with applicable laws, legal proceedings, or to protect the rights and safety of HandCo, our customers, employees, or the public.

• Corporate Transactions

In the event of mergers, acquisitions, or asset sales, personal data may be transferred or disclosed to relevant third parties involved in such transactions.

• Consent

Personal data may be shared with third parties not covered above only with your explicit consent.

6. DOES HANDCO TRANSFER PERSONAL DATA OUTSIDE THE UK?

At HandCo, we may transfer your personal data to countries beyond the borders of the UK, including those within the European Economic Area (“EEA”). It’s important to note that the laws governing data protection in these countries might not offer the same level of protection as those within the UK. For instance, we transfer personal data to our corporate affiliates situated in the United States and Canada as outlined in this Privacy Policy. Additionally, we utilize the services of providers like Google and Microsoft, who process personal data for us across various locations including the United States, Canada, and others.Rest assured, HandCo takes measures to ensure the protection of your personal data when it’s transferred outside the UK. We do this by employing the UK amendment to the Standard Contractual Clauses sanctioned by the European Commission or the UK IDTA. We may also rely on certifications obtained by the recipients of the personal data, ensuring that they maintain a level of security and protection equivalent to what is mandated by applicable legislation. If you wish to obtain copies of the UK amendment to the Standard Contractual Clauses or the UK IDTA utilized for facilitating data transfers outside the UK, please feel free to request them.

7. HOW DOES HANDCO PROTECT PERSONAL DATA?

HandCo employs a comprehensive approach encompassing physical, administrative, and technical security protocols to safeguard personal data from potential risks such as damage, loss, unauthorized access, alteration, or destruction while under our supervision. Particularly concerning credit card information, we adhere strictly to the data security guidelines set forth by major credit card entities like Visa, MasterCard, and American Express, ensuring the secure processing and maintenance of payment card data.

8. HOW LONG DOES HANDCO RETAIN PERSONAL DATA?

HandCo is committed to responsibly managing your personal data and adheres to stringent retention policies. We will retain your personal data only for the duration necessary to fulfill the purposes for which it was collected, unless longer retention is mandated by applicable laws.For instance, maintaining records of our members’ purchase histories is crucial for upholding our returns policy. If you wish to return an item purchased from us in the past, we must verify the transaction details such as when and where it was bought. Consequently, we typically retain records pertaining to our members’ accounts and purchase histories for a minimum of 7 years.Moreover, your consent to receive marketing communications from us entails the retention of your email address and marketing preferences throughout your membership, unless you choose to opt out of such communications or terminate your membership.In line with our commitment to privacy, image records obtained through video surveillance systems at our warehouses are retained for a period of 30 days, ensuring necessary security measures without compromising individual privacy.

9. THIRD PARTY SERVICES

When engaging with Third-Party Services through our platform, any information you provide will be disclosed to the respective third-party service provider. For instance, if you sign up for the HandCo Auto Programme, we may share your membership details with participating dealers to verify your enrollment. Subsequently, the third parties may also share information with us regarding your utilization of their services. It’s important to note that any additional information you furnish directly to these third parties is beyond our responsibility. We strongly advise acquainting yourself with their privacy and security protocols before divulging any information.

10. OPTICAL AND HEARING CENTRES

When you purchase eyeglasses, contact lenses, hearing devices, or related accessories from our establishment, we gather and retain essential prescription information and a limited set of background health details provided by you. This information ensures that we can adequately fulfill your service or medical device requirements. Our protocols are designed to safeguard your health-related data. In cases where you receive governmental assistance for optical or hearing aids, we might share your health data with the relevant agency. HandCo and our affiliates may handle your personal health information for the following purposes:

• Providing the requested health services.
• Facilitating communication between you and your healthcare providers.
• Maintaining electronic health records on secure onsite or offsite servers.
• Processing payments for government-funded health services, such as securing authorization from your insurer or a governmental entity.
• Processing payments for government-funded health services, such as securing authorization from your insurer or a governmental entity.
• Managing payments from your health insurance provider.
• Internally managing operations, including planning, resource allocation, policy development, quality enhancement, monitoring, audit, evaluation, and reporting.

We handle your personal health data with your explicit consent and when necessary for providing healthcare or treatment to you.In certain situations, we may disclose personal health information without your explicit consent if mandated by law, regulation, search warrant, subpoena, or court order, or when essential to protect the rights, property, or personal safety of HandCo, its clientele, staff, or the general public. Additionally, we may be obligated to disclose specific personal health details to maintain good standing with professional health bodies governing pharmacists, audiologists, and opticians.

11. HANDCO TRAVEL UK

HandCo Travel, UK Limited serves as a facilitator for our members in arranging travel both within the UK and internationally. (Currently, HandCo Travel UK facilitates car rentals and cruises, with potential expansion into hotel bookings and other travel-related services in the future.) As an intermediary connecting our members with various travel service providers, any personal information you provide to us will be shared with these providers and their representatives, subject to their respective privacy policies and local regulations. Your personal data may be accessible to law enforcement and national security authorities, both domestically and internationally. We advise you to acquaint yourself with the privacy and security practices of these service providers before finalizing your travel arrangements through us.The personal information requested by travel service providers may encompass financial details, travel document particulars, itinerary specifics, nationality, gender, date of birth, credit card data, disability information, dietary preferences, travel inclinations, loyalty program particulars, and emergency contact information. This information is necessary for tasks such as trip booking, communication related to your trip, compliance with governmental requirements, customization of your travel experiences, and other purposes outlined in the service providers’ privacy policies. We may retain some or all of this data to facilitate our services in conjunction with your bookings, subject to our own Privacy Policy.When making a reservation on behalf of another individual through our platform, you are responsible for ensuring that you have obtained their consent to provide us with their personal information. By furnishing us with this information, it will be presumed that you have the necessary consent and authorization from the concerned individuals to share their personal data and to make bookings on their behalf in accordance with the privacy policies of our travel service providers.In the event that an individual with access to your full name and booking reference numbers contacts us seeking information or modifications regarding your booking, we will provide them with the requested details and allow them to make changes, under the assumption that you have granted them consent to do so. Similarly, if your bookings are facilitated by third parties such as employers, family members, or others, we will consider these parties authorized by you to provide your personal information as per the provisions outlined in this section, unless and until you instruct us otherwise.

12. WHAT PERSONAL DATA RIGHTS DO YOU HAVE?

You possess several legal rights concerning the handling of your personal data, subject to specific limitations and exceptions. These rights include:

• The right to request information: You can ask for details about how we handle your personal data. The right of access: You have the privilege to request access to, or a copy of, the personal data we hold about you.
• The right of correction: You can request that we rectify or supplement any inaccurate or incomplete personal data we hold about you.
• The right of deletion: You have the right to request the deletion of personal data concerning you.
• The right to limit processing: You can request that we restrict the processing of your personal data, allowing us to store the data without further processing.
• The right to data portability: You can request that we provide the personal data you’ve provided to us in a structured, commonly used, and machine-readable format. Additionally, you can transmit this data to another controller without any obstruction from us.
• The right to object to processing: You can request that we cease processing personal data about you. For instance, if your data is being processed for direct marketing purposes, you have the right to object to such processing at any time.
• The right to withdraw consent: If our processing relies on your consent, you have the right to withdraw that consent at any time.
• The right to lodge a complaint: You have the right to lodge a complaint about our data protection practices with a supervisory authority. You can do this by contacting the Information Commissioner’s Office (www.ico.org.uk).

13. USE OF THE WEBSITE/APP BY CHILDREN

We advocate for parental involvement in monitoring their children’s online activities. Our policy strictly prohibits the collection of data from minors or individuals under 18 years old. If you are under 18, refrain from providing any personal information through our website/app.

14. CHANGES TO THIS PRIVACY POLICY

Our Privacy Policy may undergo periodic revisions. Should modifications occur, we will update the date displayed at the beginning of this policy. In the event of significant alterations, we will also furnish you with supplementary notification. We recommend that you regularly review this Privacy Policy to stay informed about how your personal data will be handled and the options at your disposal.

15. QUESTIONS OR CONCERNS

Should you have any inquiries or concerns regarding this Privacy Policy or wish to reach out to us for any reason, such as filing a claim, please feel free to contact us via email at [email protected] or reach out to our Data Protection Officer at [email protected]. If you prefer to communicate via mail, you can send your questions to us at the following address: H&Co Wholesale UK Ltd Unit 1 & 2 Globe Park, Moss Bridge Road, Rochdale, OL16 5EB