PRIVACY POLICY

Introduction

This Privacy Notice explains in detail the types of personal data we may collect about you when you interact with us.

It also explains how we’ll store and handle that data, and keep it safe.

We know that there’s a lot of information here, but we want you to be fully informed about your rights, and how James Galt & Company Ltd uses your data; for example we will explain things such as how we collect and use data to build a picture of you.
We hope the following sections will answer any questions you have but if not, please do get in touch with us.

It’s likely that we’ll need to update this Privacy Notice from time to time. We’ll notify you of any significant changes, but you’re welcome to come back and check it whenever you wish.

When you are using the Galt Toys websites, James Galt & Company Ltd is the data controller.

 

Who is Galt Toys Inc

For simplicity throughout this notice, ‘we’ and ‘us’ means Galt Toys Inc and its brands (Galt & Ambi Toys).

1. Explaining the Legal bases we rely on

Consent

In specific situations, we can collect and process your data with your consent.

For example, when you tick a box to receive email newsletters.

When collecting your personal data, we’ll always make clear to you which data is necessary in connection with a particular service. 

Legal compliance

If the law requires us to, we may need to collect and process your data.

For example, we can pass on details of people involved in fraud or other criminal activity affecting Galt Toys Inc to law enforcement.

Legitimate interest

In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests.

For example, we will use your visit history and actions on our website to help us discover areas where we can improve our website or fix technical errors.

We will also use your email address details to send you direct marketing information by email, telling you about products and services that we think might interest you.

2. When do we collect your personal data?

• When you visit any of our websites.
• When you engage with us on social media.
• When you contact us by any means with queries, complaints etc.
• When you ask us to email you information about a product or service.
• When you enter prize draws or competitions.
• When you choose to complete any surveys we send you.
• When you comment on or review our products and services.
• When you fill in any forms. For example, a contact us form.
• When you’ve given a third party permission to share with us the information they hold about you.
• We collect data from publicly-available sources when you have given your consent to share information or where the information is made public as a matter of law.

3. What sort of personal data do we collect?

If you have subscribed to our email newsletter with us: your name and email address or in some cases just an email address.

Details of your interactions with us through contact centres or online (By email, live chat, social media messages).

For example, we collect notes from our conversations with you, details of any complaints or comments you make, products and brands you show interest in, web pages you visit and how and when you contact us.

Details of your visits to our websites, and which site you came from to ours.

Information gathered by the use of cookies in your web browser. Learn more about how we use cookies and similar technologies.

• Your comments and product reviews.
• To deliver the best possible web experience, we collect technical information about your internet connection and browser as well as the country and telephone code where your computer is located, the web pages viewed during your visit and any search terms you entered. 
• Your social media username, if you interact with us through those channels, to help us respond to your comments, questions or feedback.

 

4. How and why do we use your personal data?

We want to give you the best possible customer experience. One way to achieve that is to get the richest picture we can of who you are by combining the data we have about you.

The data privacy law allows this as part of our legitimate interest in understanding our customers and providing the highest levels of service.

Of course, if you wish to change how we use your data, you’ll find details in the ‘What are my rights?’ section below.

Remember, if you choose not to share your personal data with us, or refuse certain contact permissions, we might not be able to provide some services you’ve asked for.

For example, if you’ve asked us to let you know when an item comes back into stock, we can’t do that if you’ve withdrawn your general consent to hear from us.

 

Here’s how we’ll use your personal data and why:

• To respond to your queries and complaints. Handling the information you sent enables us to respond. We may also keep a record of these to inform any future communication with us and to demonstrate how we communicated with you throughout. We do this on the basis of our contractual obligations to you, our legal obligations and our legitimate interests in providing you with the best service and understanding how we can improve our service based on your experience.
  
  
• To protect our business and customers from fraud and other illegal activities. We’ll also monitor your browsing activity with us to quickly identify and resolve any problems and protect the integrity of our websites. We’ll do all of this as part of our legitimate interest.

For example, using automated monitoring of IP addresses to identify possible fraudulent visits from unexpected locations.

• To send you relevant, personalised communications by email and web in relation to updates, offers, services and products. We’ll do this on the basis of our legitimate business interest. 

Of course, you are free to opt out of hearing from us by any of these channels at any time. 

• To send you communications required by law or which are necessary to inform you about our changes to the services we provide you. For example, updates to this Privacy Notice, product recall notices, and legally required information relating to your orders. These service messages will not include any promotional content and do not require prior consent when sent by email or text message. If we do not use your personal data for these purposes, we would be unable to comply with our legal obligations.
  
  
• To administer any of our giveaways, prize draws or competitions which you enter, based on your consent given at the time of entering.
  
  
• To develop, test and improve the systems, services and products we provide to you. We’ll do this on the basis of our legitimate business interests.

For example, we’ll record your browser’s Session ID to help us understand more when you leave us online feedback about any problems you’re having

• To send you survey and feedback requests to help improve our services. These messages do not require prior consent when sent by email or via onsite pop-up messages. We have a legitimate interest to do so as this helps make our products or services more relevant to you.
  
  

5. How we protect your personal data

We know how much data security matters to all our customers. With this in mind we will treat your data with the utmost care and take all appropriate steps to protect it.

Our site is built on the Shopify platform which secures all pages of our website using ‘https’ secure technology. For more information on HTTPs click here (Link opens in a new window; please note we can't be responsible for the content of external websites)

Shopify is certified Level 1 PCI DSS compliant. For more information, see Shopify's PCI page.

 

6. How long will we keep your personal data?

Whenever we collect or process your personal data, we’ll only keep it for as long as is necessary for the purpose for which it was collected.
At the end of that retention period, your data will either be deleted completely or anonymised.

For example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning.

 

7. Who do we share your personal data with?

We sometimes share your personal data with trusted third parties.

For example, web developers, to handle complaints, email software providers, and so on.

Here’s the policy we apply to those organisations to keep your data safe and protect your privacy:

• We provide only the information they need to perform their specific services.
• They may only use your data for the exact purposes we specify in our contract with them.
• We work closely with them to ensure that your privacy is respected and protected at all times.
• If we stop using their services, any of your data held by them will either be deleted or rendered anonymous.

Examples of the kind of third parties we work with are:

• IT companies who support our website and other business systems.
• Direct marketing companies who help us manage our electronic communications with you.
• Social Media platforms (Google/Twitter/Facebook, etc) to collect comments process customer service related queries.

 

Sharing your data with third parties for their own purposes:

We will only do this in very specific circumstances, for example:

 

• With your consent, given at the time you supply your personal data, we may pass that data to a third party for their direct marketing purposes.

For example, if you enter a joint competition and tick a box agreeing that you agree to receive direct communications from both Galt and the partner brand.

• For fraud management, we may share information about fraudulent or potentially fraudulent activity in our premises or systems. This may include sharing data about individuals with law enforcement bodies.

• We may also be required to disclose your personal data to the police or other enforcement, regulatory or Government body, in your country of origin or elsewhere, upon a valid request to do so. These requests are assessed on a case-by-case basis and take the privacy of our customers into consideration.

• We may, from time to time, expand, reduce or sell Galt Toys Inc and/or its brands and this may involve the transfer of divisions or the whole business to new owners. If this happens, your personal data will, where relevant, be transferred to the new owner or controlling party, under the terms of this Privacy Notice.

For further information please contact our Data Compliance Team.

To help personalise your journey through Galt’s websites we currently use the following companies, who will process your personal data as part of their contracts with us:

 

• Justuno

8. Where your personal data may be processed?

Sometimes we will need to share your personal data with third parties and suppliers outside the European Economic Area (EEA), such as the USA.

Protecting your data outside the EEA

The EEA includes all EU Member countries as well as Iceland, Liechtenstein and Norway. We may transfer personal data that we collect from you to third-party data processors in countries that are outside the EEA.

For example, this might be required in order to provide support or customer services.

If we do this, we have procedures in place to ensure your data receives the same protection as if it were being processed inside the EEA. 

For example, our contracts with third parties stipulate the standards they must follow at all times. If you wish for more information about these contracts please contact our Data Compliance Team.

Any transfer of your personal data will follow applicable laws and we will treat the information under the guiding principles of this Privacy Notice.

9. What are your rights over your personal data?

An overview of your different rights

You have the right to request:

• Access to the personal data we hold about you, free of charge in most cases.
• The correction of your personal data when incorrect, out of date or incomplete.
• The deletion of the data we hold about you, in specific circumstances; for example, when you withdraw consent or object, and we have no legitimate overriding interest, or once the purpose for which we hold the data has come to an end.
• A computer file in a common format (CSV or similar) containing the personal data that you have previously provided to us, and the right to have your information transferred to another entity where this is technically possible.
• Restriction of the use of your personal data, in specific circumstances, generally while we are deciding on an objection you have made. 
• That we stop processing your personal data, in specific circumstances; for example, when you have withdrawn consent, or object for reasons related to your individual circumstances.
• That we stop using your personal data for direct marketing (either through specific channels, or all channels).
• That we stop any consent-based processing of your personal data after you withdraw that consent.
• Review by a Partner of any decision made based solely on automatic processing of your data (so where no human has yet reviewed the outcome and criteria for the decision).
• If we choose not to action your request, we will explain the reasons for our refusal.

You have the right to request a copy of any information about you that Galt Toys Inc holds at any time, and also to have that information corrected if it is inaccurate.

To ask for your information, please contact Galt Toys Inc Data Compliance Team, 2nd Floor, Sovereign House, Stockport Road, Cheadle, Cheshire, United Kingdom, SK8 2EA, or email: compliance@jamesgalt.com

To ask for your information to be amended, please contact our Customer Services team.

Your right to withdraw consent
Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent.

Where we rely on our legitimate interest
In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.

Direct marketing
You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We must always comply with your request.

Checking your identity
To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Notice. If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.

 

10. How can you stop the use of your personal data for direct marketing?

There are several ways you can stop direct marketing communications from us:

• Click the ‘unsubscribe’ link in any email communication that we send you. We will then stop any further emails from that particular division.
• Write to Data Compliance Team, 2nd Floor, Sovereign House, Stockport Road, Cheadle, Cheshire, United Kingdom, SK8 2EA, or email compliance@jamesgalt.com.

Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated.

 

11. If you live outside the US?

For all non-US customers

By using our services or providing your personal data to us, you expressly consent to the processing of your personal data by us or on our behalf. Of course, you still have the right to ask us not to process your data in certain ways, and if you do so, we will respect your wishes.

Sometimes we’ll need to transfer your personal data between countries to enable us to supply the goods or services you’ve requested. In the ordinary course of business, we may transfer your personal data from your country of residence to ourselves and to third parties located in the US and UK.

By dealing with us, you are giving your consent to this overseas use, transfer and disclosure of your personal data outside your country of residence for our ordinary business purposes.

This may occur because our information technology storage facilities and servers are located outside your country of residence, and could include storage of your personal data on servers in the UK, Ireland or the US.

We’ll ensure that reasonable steps are taken to prevent third parties outside your country of residence using your personal data in any way that’s not set out in this Privacy Notice. We’ll also make sure we adequately protect the confidentiality and privacy of your personal data.

To learn more about our cookies and website ‘track’ and ‘do not track’ practices please see our Cookies Notice.

12. Any Questions?

We hope this Privacy Notice has been helpful in setting out the way we handle your personal data and your rights to control it.

If you have any questions that haven’t been covered, please contact our Data Compliance Team who will be pleased to help you:

Email us at customerservice@galttoys.com
Or
Write to us at Data Compliance Team, 2nd Floor, Sovereign House, Stockport Road, Cheadle, Cheshire, SK8 2EA

This notice was last updated on 17/07/2020.