Stairbox Privacy Notice
Table of contents
- 1. Who we are and other important information
- 2. What information we collect about you
- 3. How we'll use your information
- 4. Who we might share your information with
- 5. Transferring your information internationally
- 6. How we keep your information secure
- 7. How long we'll keep your information
- 8. Your privacy rights
- 9. What we need from you
Stairbox is the trading names of AVC (Stairbox) Limited (when we say "we" or "us", we mean AVC (Stairbox) Limited). We are member of Grafton Group ("Grafton Group" means Grafton Group plc and its subsidiaries).
This privacy notice tells you what you can expect us to do with your personal information when you make contact or buy something from us, and it also tells you about your privacy rights. This notice should be read alongside applicable terms and conditions (for example, website use or specific cash/credit accounts).
1. Who we are and other important information
We, AVC (Stairbox) Limited are the data controller of your personal data.
Data Protection Officer
Grafton Group has appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, please get in touch by either
- writing to The Data Protection Officer, Grafton Group plc, 2 Wythall Green Way, Wythall, Birmingham, B47 6LW, United Kingdom ; or
- emailing to firstname.lastname@example.org
Changes to this notice
This privacy notice is reviewed on a regular basis and was last updated on 16/01/2024, and is version 2.
You have the right to make a complaint at any time to the relevant supervisory authority. In the UK, this is the Information Commissioner’s Office (ICO) or to the data protection regulator in the country where you live or work.
We would appreciate the chance to deal with your concerns before you approach the relevant supervisory authority, so please contact the Data Protection Officer (see ‘Who we are and other important information/Data Protection Officer’ section above) in the first instance.
This website may include links to third-party websites, plug ins and applications. 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 to ensure that you are happy about using that site.
2. What information we collect about you
What personal information we might gather
Personal information or personal data as it is also referred to 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).
Some of the information will come directly from you (for example, when you purchase a product or when you open an account with us) and we might also get some from publicly available places. The information that we collect will depend on the reason for your contact with us.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Contact Data includes billing address, home address, email address and telephone numbers.
- Financial Data includes payment card details and, where you or your business have or apply for a credit account with us, bank account details and information held by credit reference and fraud prevention agencies.
- Transaction Data includes details about you/your business trading history, including payments from you/your business.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website/or any apps.
- Profile Data includes your username and password, products/services provided to you/your business, feedback and survey responses.
- Usage Data includes information as to how you use our website.
- Marketing and Communications Data includes your preferences as to whether you are happy to receive marketing from us and, if so, your communication preferences.
We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal information 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 information which will be used in accordance with this privacy notice.
In the normal course, we will not collect Special Categories of Personal Data about you.
Where we gather personal information from
We use different methods to collect information from and about you including:
- Through direct interactions with you. You may give us your Identity, Contact and
Financial Data by filling in forms or by corresponding with us by post, phone, email, via
this website, apps or on social media, or otherwise. This includes personal data you
provide when you or your business
- apply for, or operate, a credit or cash account with us;
- purchase goods and/or services at our factory;
- purchase goods and/or services at over the phone;
- purchase goods and/or services via our website;
- enter a competition, or respond to a promotion or survey; or
- give us some feedback.
- Through automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.
- From third parties and publicly available sources. We may receive personal data
about you from various third parties and public sources, examples of which are listed
- Technical Data from analytics providers and search information providers such as Google who may be inside OR outside the EU; or
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services based inside OR outside the EU; or/li>
- Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.
- From credit reference agencies and fraud prevention organisations. When you or your business in which you are a partner or a director makes an application for a credit account with us, we will or may make searches about you with credit reference agencies and fraud prevention organisations. Searches are made against addresses provided, and so may also return information relating to other household members. The relevant agencies/organisations will keep a record of that search and will share information from their records with us and with other business assessing applications for credit and to prevent fraud. Should it become necessary to review a credit account, a further check with credit reference agencies and fraud prevention organisations may be made, and a record kept by them of the search. Debt collection and debtor tracing organisations.
- Through other businesses within the Grafton Group. As part of our credit referencing and anti-fraud procedures, we may make enquiries of other businesses within Grafton Group as to your/your business' trading history with them.
What might happen if you decide not to provide personal information
If you fail to provide personal information 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 contract you have with us, but we will notify you if this is the case at the time.
3. How we'll use your information
What purposes might use your personal data for
We’ll only use your information if we have your permission, or we have another legal reason for using it. These reasons include:
- if we need to look into our legitimate interests;
- to enter into or carry out an agreement we have with you;
- where we’re required to by law;
- where we believe it’s in the public interest for us to do so e.g. to help prevent or detect crime;
- to establish, utilise or defend our legal rights;
We have set out below, the reasons we use your personal information, and which of the legal bases we rely on to do so and 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.
When we refer to legitimate interests, we mean the interest of our business in conducting and managing our business to enable us to give you the best service/product. 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).
|Type of data
|Lawful basis for processing including basis of legitimate interest
|To respond to an enquiry from you.
|Necessary to take steps at your request prior to entering into a contract with you.
|To undertake credit-referencing and anti-fraud checks in connection with applications for and the operation of a credit account with us.
Necessary to take steps at your request prior to entering into a contract with you.
Necessary for our legitimate interests in protecting our business from insolvent customers and fraud.
Necessary for means of substantial public interest (preventing fraud).
|To provide goods and/or services to you, and to collect and recover money owed to us
Performance of a contract with you
Necessary for our legitimate interests (to operate our business and recover debts due to us)
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy notice
(b) Asking you for feedback
(d)Marketing and Communications
Performance of a contract with you
Necessary to comply with a legal obligation
Necessary for our legitimate interests (to keep our records updated and to study how customers use our services)
|To administer and protect our business including our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
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)
Necessary to comply with a legal obligation
|To deliver relevant website content to you and measure or understand the effectiveness/usability of our website
|Necessary for our legitimate interests (to study how customers use our services, to develop them, to grow our business and to inform our marketing strategy)
|To use data analytics to improve our website, services, marketing and customer relationships
|Necessary for our legitimate interests (to define types of customers for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
|To deal with issues, complaints or disputes arising out of our relationship with you/your business, and to prevent or detect crime, including fraud
|To establish, exercise or defend legal claims
Automated decision making
We do not currently undertake automated decision making using your personal information.
Tracking or recording what you say or do
We may store details of your interactions with us. We may also record and keep track of conversations with us including phone calls, face-to-face meetings, letters, emails, live chats, video chats and any other kinds of communication.
We may use these to check your instructions to us, improve our service, train our people, manage risk or to prevent and detect fraud and other crimes. We may also store additional information about these interactions, e.g. telephone numbers that you call us from and information about the devices or software that you use.
We use closed circuit television (CCTV) in and around our factory and these may collect photos or videos of you or record your voice. Our websites may track and record your interactions with them.
Marketing ⁄ promotional offers
We strive to provide you with choices regarding certain personal information uses, particularly around marketing. Where you have agreed to receive it, 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 goods, services and offers may be relevant for you.
We will only share your personal data for marketing purposes in accordance with your preferences/consent. To make a change to marketing messages at any time, you have the following options either:
Changing the purpose for using your personal information
We will only use your personal information 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 we need to use your personal information 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.
4. Who we might share your information with
Frequent reasons for sharing
We may share your information with others where lawful to do so including where we or they:
- need to in order to provide you with products or services you’ve asked for;
- have a public or legal duty to do so, e.g. to help with detecting and preventing fraud, tax evasion and financial crime;
- need to for any regulatory reporting, litigation or asserting or defending legal rights and interests;
- wish to send marketing to you or others, where you’ve given us your permission, or it’s within our legitimate interest to do so;
- other companies in the Grafton Group and any sub-contractors, agents or service providers who work for us or provide services to us or other Grafton Group companies (including their employees, sub-contractors, service providers, directors and officers) whether directly or providing underlying infrastructure services;
Occasional reasons for sharing
We may share your information for these purposes with others including:
- business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
- analytics and search engine providers that assist us in the improvement and optimisation of our services and website;
- professional advisers, including lawyers, banks, auditors and insurers;
- debt collection and/or debtor tracing agencies in connection with the recovery of your/your businesses unpaid debt;
- other businesses in the Grafton Group relating to your/your business' trading history with us;
- regulators and other authorities;
- entities involved in credit checking and anti-fraud activities, crime prevention/detection;
- third parties 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 information in the same way as set out in this privacy notice.
Where these third parties are our processors, we require them to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party processors to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions. Some of the third parties mentioned above, for example, many professional advisers and H M Revenue and Customs, are controllers who, like us, are subject to specific obligations under data protection law, and who will have their own privacy notices setting out how they deal with personal data.
5. Transferring your information internationally
Your information may be transferred to and stored in locations outside the European Economic Area (EEA) and the United Kingdom, including countries that may not have the same level of protection for personal information. This might be to certain other recipients such as other Grafton Group companies and third-party service providers (who processes your information on our behalf). When we do this, we’ll ensure it has an appropriate level of protection and that the transfer is in line with applicable legal requirements. We may need to transfer your information in this way to carry out our contract with you, to fulfil a legal obligation, and/or for our legitimate interests. Even in these cases, we’ll only share your information with people who have the right to see it.
You can get more details of the protection given to your information when it’s transferred outside the United Kingdom or the EEA by contacting the Data Protection Officer, see ‘Who we are and other important information’ section above.
6. How we keep your information secure
We use a range of measures to keep your information safe and secure which may include encryption and other forms of security. We require our staff and any third parties who carry out any work on our behalf to comply with appropriate compliance standards including obligations to protect any information and applying appropriate measures for the use and transfer of information.
7. How long we'll keep your information
We keep your information in line with our data retention policy. This allows us to comply with legal, accounting and reporting requirements or use it where we need to for our legitimate purposes such as managing your account and dealing with any disputes or concerns that may arise.
We may need to keep your information for longer where we need the information to comply with regulatory or legal requirements, help detect or prevent fraud and financial crime, etc.
If we don’t need to keep information for this length of time, we may destroy, delete or anonymise it sooner.
8. Your privacy rights
You have a number of rights in relation to the information that we hold about you. These rights include:
- the right to see information we hold about you and to get information about what we do with it;
- in some circumstances, the right to withdraw your permission to our processing of your information, that you can do at any time. We may continue to process your information if we have another legitimate reason for doing so;
- in some circumstances, the right to receive certain information you have provided to us in an electronic format and/or ask that we send it to a third party;
- the right to ask that we correct your information if it’s inaccurate or incomplete;
- in some circumstances, the right to ask that we delete your information. We may continue to keep your information if we’re entitled or required to keep it;
- the right to object to, and to ask that we limit our processing of your information in some circumstances. Again, there may be situations where you object to, or ask us to limit our processing of your information but we’re entitled to continue and/or to refuse that request.
You can exercise your rights by contacting the Data Protection Officer, see ‘Who we are and other important information’ section above.
9. What we need from you
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.