TransAtlantic Safety LTD (“TransAtlantic,” “we,” “us,” “our”) is committed to protecting your privacy in all our dealings with you, whether through our website’s online services or through direct contact with our directors and consultants.

 

When using our website, we want you to have a safe and secure experience. We will endeavor to ensure that the information you submit to us remains private, and is only used for the purposes set out in this policy. Except in the case of complying with a legal or regulatory requirement, TransAtlantic does not and will not disclose your information to third parties without your consent.

 

In the event that the Site contains a separate Privacy Statement linked to via the Site homepage, in the case of conflict between that Privacy Statement and this Privacy Policy, the Privacy Statement shall prevail over this Privacy Policy.

 

We take your privacy seriously and use your personal data as further explained in this Privacy Policy. We are the “controller” of the personal data you provide to us.

 

You have the right to object to us processing your personal data for our legitimate business interests or for direct marketing purposes (including any related profiling). If you wish to invoke any of these rights or have any questions then you can either submit this request in writing to TransAtlantic at our address

 

TransAtlantic Safety LTD
Office One
1 Coldbath Square
Farringdon
London
EC1R 5HL

or via email contactus@transatlanticsafety.com.

 

For more information about your rights and how you can exercise them, please see the section Your rights.

 

1. Personal Data we may collect and why

 

Personal data is any information that identifies you personally whether directly (for example, your name) or indirectly (for example, information about your use of our products and services).

 

We may collect the following data about you:

 

1. Contact details: your name, email address, and telephone number so that we can contact you in response to an inquiry you make via our Site or in relation to the products and services that we have from time to time agreed to provide to you;
2. Correspondence: we collect any additional personal data you may provide to us from time to time if you contact us by email, letter or telephone, through our Site, by submitting a comment on our Site, or by any other means;
3. Survey responses: information from surveys that we use for research purposes, if you choose to respond to them;
4. Transaction details: we or our third party providers will collect information relating to transactions you carry out through our Site and for the purposes of fulfilling your orders;
5. Details of visits to the Sites: details of your visits to our Site, including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.

 

2. Cookies

 

What are Cookies?

 

We collect information about your use of our Site through cookies. Cookies are information that files stored on your computer, tablet or smartphone that help websites remember who you are and information about your visit. Cookies can help to display the information on our Site in a way that matches your interests. Most major websites use cookies.

 

1. What cookies are used on this Site?

 

Kindly refer to our Cookies Policy. 

 

1. How can I reject or opt-out of receiving cookies?

 

You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. However, if you select this setting, you may be unable to access certain parts of our Site. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you use our Site. The “Help” menu of the toolbar on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. For more information about cookies and how to stop cookies being installed or how to delete existing cookies from your hard drive visit the following website: http://www.allaboutcookies.org.

 

1. Third-party cookies

 

Some of the cookies described in our Cookies Policy are stored on your machine by third parties when you use our Site. Third parties may also read cookies on your browser to collect information or to serve content or advertisements to you. We have no control over these cookies or how third parties use them. They are used to allow that third party to provide a service to us, for example, analytics. For more information on these cookies and how to disable them, please see:

 

Internet Advertising Bureau website at http://www.youronlinechoices.com/ where you will be able to opt-out of receiving Interest-Based Advertising cookies from some of the third parties listed below; and/or

 

If you want to know more about how cookies work and how to manage or delete them, visit the World Wide Web Consortium’s website.

 

3. How we use your personal data

 

We use your personal data for the following purposes:

1. To provide you with the products and services you have requested
2. We use your personal data to accept you as a new or returning customer to provide you with the products and services you have requested in accordance with the Trading Terms or Terms of Trading.
3. To send you service communications.
4. We use the contact details you have provided to us so that we can communicate with you about the products and services that we provide, including to let you know about major changes to those products and services.
5. Direct marketing (including by third parties)

If you have provided your consent or we otherwise have the right to do so, we may use your contact details to send you direct marketing and keep you informed of promotional offers by email, SMS, post or telephone relating to our products and services.

 

You can unsubscribe from our direct marketing at any time by clicking the “Unsubscribe” link in any of our emails or by contacting us.

 

Our trusted business partners would also like to use your name, email address, postal address and telephone number to inform you of similar products, services and promotional offers. We will only share your personal data with our partners where you have provided us with your consent to do so. You can unsubscribe at any time by clicking the “Unsubscribe” link in any of their emails or by contacting us.

 

1. To track your usage of our website, communications, products and services

 

We use cookies and similar technologies to track your activity on our Site so that we can provide important features and functionality on our Site, monitor its usage, and provide you with a more personalised experienced.

 

2. To provide and improve customer support

 

We use your personal data to be able to provide and improve the customer support we provide to you (for example, where you have questions about our products and services).

 

3. To maintain our records and improve data accuracy

 

Like any business, we process personal data in the course of maintaining and administering our internal records. This includes processing your personal data to ensure that the information we hold about you is kept up-to-date and accurate.

 

4. To respond to enquiries, complaints and disputes

 

We use the personal data we hold about you to help us respond to any enquiries or complaints you have made, or deal with any dispute which may arise in the course of us providing our products and services to you, in the most effective manner.

 

5. To investigate, detect and prevent fraud and comply with our legal obligations

 

In certain circumstances, we use your personal data only to the extent required in order to enable us to comply with our legal obligations, including for fraud detection, investigation and prevention purposes. This may require us to provide your personal data to law enforcement agencies if they request it.

 

4. Legal grounds for processing

 

Data protection law requires us to only process your personal data if we satisfy one or more legal grounds. These are set out in data protection law and we rely on a number of different grounds for the processing we carry out. These are as follows:

 

Consent

 

In certain circumstances, we process your personal data after obtaining your consent to do so for the purposes of:

 

1. sending you marketing communications about our products and services;
2. sharing your name, email address, postal address and telephone number with our trusted business partners so that they may market to you about their own similar products and services;
3. conducting marketing research;
4. obtaining your credit score so that we can establish the best possible payment terms we are able to offer to you.
5. Necessary for the performance of a contract and to comply with our legal obligations

 

It is necessary for us to process your basic contact details, payment details and information about the business you represent for the performance of the obligations between us. In particular, we rely on this legal ground to:

 

1. provide you with the products and services;
2. communicate with you about the products and services that we provide to you, including to let you know about major changes to those products and services;
3. provide and improve customer support; and
4. notify you about changes to our service

 

If you choose not to give some or all of the aforementioned information to us, this may affect our ability to provide our products and services to you.

 

1. In certain circumstances, we also use your personal data only to the extent required in order to enable us to comply with our legal obligations, including to detect, investigate and prevent fraud.
2. Necessary for the purposes of our legitimate business interests or those of a third party

 

It is sometimes necessary to collect and use your personal data for the purposes of our legitimate interests as a business, which are to:

 

1. provide you with products and services that are as useful and beneficial as possible, including by personalising our contact with you and making sure we tell you about all the offers that are relevant to you;
2. better understand our customer base so that we can improve our products and services and marketing activities (which could also benefit you);
3. comply with our contractual obligations to third parties;
4. develop and improve our Site to enhance the customer experience;
5. train our staff so that we can provide you with a better customer service;
6. respond to any enquiries or complaints you have made, or deal with any dispute which may arise in the course of us providing our products and services to you; and
7. to ensure that content from our Site is presented in the most effective manner for you and for your computer;
8. ensure effective operational management and internal administration of our business, document retention, compliance with regulatory guidance and exercise or defence of legal claims.

 

Where we think there is a risk that one of your interests or fundamental rights and freedoms may be affected we will not process your personal data unless there is another legal ground for us to do so (either that we have obtained your consent to the processing or it is necessary for us to perform our contract with you or to comply with our legal obligations).

 

5. Who we share your personal data with

 

We may provide your personal data to our suppliers and service providers, including other companies in our group, who provide certain business services for us and act as “processors” of your personal data on our behalf. In addition, we may disclose your personal data if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to protect the rights, property, or safety, of our business, our customers or others. This includes, in specific cases, exchanging information with other organisations for the purposes of fraud protection.

 

In some cases, the personal data we collect from you may, for the purposes set out above, be transferred outside the European Economic Area (EEA) and such destinations may not have laws which protect your personal data to the same extent as in the EEA. We are required by data protection law to ensure that where we or our “processors” transfer your personal data outside of the EEA, it is treated securely and is protected against unauthorised access, loss or destruction, unlawful processing and any processing which is inconsistent with the purposes set out in this Privacy Policy.

 

6. How long we keep your personal data for

 

1. We retain your personal data for no longer than is necessary for the purposes(s) for which it was provided. What this means in practice will vary between different types of data. When determining the relevant retention periods, we take into account factors including:
2. legal obligation(s) under applicable law to retain data for a certain period of time;
3. statute of limitations under applicable law;
4. potential or actual disputes; and
5. guidelines issued by relevant data protection authorities.

 

Otherwise, we securely erase your personal data from our systems when it is no longer needed.

7. Your rights

 

You have the following rights regarding your personal data:

 

1. Rights to be informed. You have the right to be provided with clear, transparent and easily understandable information about how we use your personal data and your rights. This is why we are providing you with the information in this Privacy Policy.
2. Right of access. You have the right to obtain access to your personal data (if we are processing it) and certain other information (similar to that provided in this Privacy Policy). This is so you are aware and can check that we are using your personal data in accordance with data protection law.
3. Right to rectification. You are entitled to have your personal data corrected if it is inaccurate or incomplete.
4. Right to erasure. This is also known as ‘the right to be forgotten’ and, in simple terms, enable you to request the deletion or removal of your personal data where there is no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions.
5. Right to restrict processing. You have the right to ‘block’ or supress further use of your personal data in certain circumstances. When processing is restricted, we can still store your personal data, but may not use it further.
6. Right of data portability. You have the right to obtain and reuse your personal data in a structured, commonly used and machine-readable format in certain circumstances. In addition, where certain conditions apply, you have the right to have such information transferred directly to a third party.
7. Right to object to processing. You have the right to object to us processing your personal data for our legitimate business interests or for direct marketing purposes (including in each case any related profiling).
8. Right to withdraw consent to processing. If you have given your consent to us to process your personal data for a particular purpose (for example, direct marketing), you have the right to withdraw your consent at any time (although if you do so, it does not mean that any processing of your personal data up to that point is unlawful).
9. Right to make a complaint to the data protection authorities. You have the right to make a complaint to the Information Commissioner’s Office (ICO) if you are unhappy with how we have handled your personal data or believe our processing of your personal data does not comply with data protection law.

 

8. Privacy Notice for California Residents 

 

This Privacy Notice for California Residents supplements the information contained in our Privacy Policy and applies to individuals, who reside in the State of California (”consumers” or “you”). We adopt this notice along with the Privacy Policy to comply with the California Consumer Privacy Act of 2018, as amended (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this notice.

 

Information We Collect

 

We have collected the following categories of Personal Information from consumers within the last twelve (12) months:

 

Category	Examples
A. Identifiers.	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number (from employees—see B), or other similar identifiers.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Personal Information does not include publicly available information that is lawfully made available to the general public from federal, state, or local government records. Note: Some personal information included in this category may overlap with other categories.
C. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
D. Internet or other electronic network activity.	Browsing history, search history, and information on a consumer’s interaction with an internet website, application, or advertisement.
E. Geolocation data.	Physical location or movements.
F. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.
G. Professional or employment-related information.	Current or past job history or performance evaluations.
H. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
I. Inferences drawn from other personal information to create a profile about a consumer.	Profile reflecting a consumer’s preferences, behavior.

 

We obtain the categories of Personal Information listed above from the following categories of sources:

 

• Directly from you. For example, from forms you complete on our website.
• Indirectly from you. For example, from observing your actions on our website or interactions with our advertisers,
• From Third Parties such as third parties you use to log in to our Services.

 

Disclosures of Personal Information for a Business Purpose

 

We may disclose your Personal Information to a service provider or a third party for a business purpose.  When we disclose Personal Information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the contract.

 

In the preceding twelve (12) months, we have disclosed the following categories of Personal Information in our role as a business for a business purpose:

 

Category A:   Identifiers

Category B:   Personal information categories in Cal. Customer Records statute

Category C:   Commercial information

Category D:   Internet information

Category E:   Geolocation

Category F:   Professional or employment-related information

Category G:  Non-public education information

Category H:   Inferences

 

We disclose your Personal Information for a business purpose to the following categories of third parties:

 

• Our affiliates
• Service providers
• Advertising networks, internet service providers, data analytics providers, government entities, operation systems and platforms, social networks and consumer data resellers
• Third parties to whom you or your agents authorize us to disclose your Personal Information in connection with products or services we provide to you.

 

 Sales of Personal Information

 

In the preceding twelve (12) months, we have sold the following categories of Personal Information for valuable consideration:

 

Category A:   Identifiers

Category D:   Internet information

Category E:   Geolocation

 

 Your Rights and Choices

 

The CCPA provides consumers (California residents) with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.

 

Access to Specific Information and Data Portability Rights

 

You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

 

• The categories of Personal Information we collected about you.
• The categories of sources from which the Personal Information is collected about you.
• Our business or commercial purpose for collecting or selling that Personal Information.
• The categories of third parties with whom we share that Personal Information.
• The specific pieces of Personal Information we collected about you (also called a data portability request).
• If we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing:
  • sales, identifying the Personal Information categories that each category of recipient purchased; and disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.

 

 Deletion Request Rights

 

You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.

 

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

 

• Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the rights of other consumers to exercise their free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the business’ deletion may likely render impossible or seriously impair the research’s achievement if you previously provided informed consent.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

 

 Exercising Access, Data Portability, and Deletion Rights

 

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by sending logging into your account or by emailing support@refreshkid.com. Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child (12 and under).

 

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

 

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

 

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or your authority to make the request and confirm the Personal Information relates to you. In some instances, if we cannot verify your identity to provide you access to personal information, you may choose to delete such personal information.

 

We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

 

Response Timing and Format

 

Where possible, we will respond to a verifiable consumer request within forty-five (45) days of its receipt; however, if we require more time, we will inform you of the reason and extension period.

 

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

 

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

 

Personal Information Sales Opt-Out and Opt-In Rights (“Do Not Sell My Info”)

 

You have the right to direct us to not sell your Personal Information at any time (the “right to opt-out”). To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by emailing support@refreshkid.com.

 

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize Personal Information sales. However, you may change your mind and opt back in to Personal Information sales at any time by emailing us at support@refreshkid.com.

 

We will only use Personal Information provided in an opt-out request to review and comply with the request.

 

Non-Discrimination

 

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

 

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer, will reasonably relate to your Personal Information’s value to us and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.

 

Authorized Representative

 

You may designate an authorized agent to make a request under the CCPA on the consumer’s behalf by emailing us from the email address associated with your account, indicating: your name, the fact that you would like to indicate an authorized agent, the name of your authorized agent, and the email address of your authorized agent.

 

8. How to contact us

 

If you would like to exercise your data protection rights or if you are unhappy with how we have handled your personal data, please feel free to contact us by using the details set out on our Site.

 

If you’re not satisfied with our response to any enquiries or complaint or believe our processing of your personal data does not comply with data protection law, you can make a complaint to the Information Commissioner’s Office (ICO) by:

 

writing to: Information Commissioner’s Officer, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF;

 

calling: 0303 123 1113; or

 

submitting a message through the ICO’s website at: ico.org.uk

 

9. Links to other websites

 

Our website may contain hyperlinks to websites owned and operated by third parties. This Privacy Policy does not apply to those other websites. We encourage you to read the privacy statements on the other websites you visit, as they will govern the use of any personal data you provide when visiting those websites. We do not accept any responsibility or liability for the privacy practices of such third-party websites and your use of such websites is at your own risk.

 

10. Changes to this Privacy Policy

 

This Privacy Policy may be updated from time to time, so you may want to check it each time you provide personal data to us.