Email: admin[at]superfriction.co

We collect or use the following information to provide services and goods, including delivery:

• Names and contact details
• Addresses
• Purchase or account history
• Payment details (including card or bank information for transfers and direct debits)
• Credit reference information
• Account information
• Records of meetings and decisions

We collect or use the following information for service updates or marketing purposes:

• Names and contact details
• Marketing preferences
• Records of consent, where appropriate

We collect or use the following information to comply with legal requirements:

• Name
• Contact information
• Financial transaction information

Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.

Which lawful basis we rely on may affect your data protection rights which are set out in brief below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:

• Your right of access — You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for. Read more about the right of access.
• Your right to rectification — You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. Read more about the right to rectification.
• Your right to erasure — You have the right to ask us to delete your personal information. Read more about the right to erasure.
• Your right to restriction of processing — You have the right to ask us to limit how we can use your personal information. Read more about the right to restriction of processing.
• Your right to object to processing — You have the right to object to the processing of your personal data. Read more about the right to object.
• Your right to data portability — You have the right to ask that we transfer the personal information you gave us to another organisation, or to you. Read more about the right to data portability.
• Your right to withdraw consent — When we use consent as our lawful basis you have the right to withdraw your consent at any time. Read more about the right to withdraw consent.

If you make a request, we must respond to you without undue delay and in any event within one month.

To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.

Our lawful bases for the collection and use of your data

Our lawful bases for collecting or using personal information to provide services and goods are:

• Consent — we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
• Contract — we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
• Legal obligation — we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

Our lawful bases for collecting or using personal information for service updates or marketing purposes are:

• Consent — we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

Our lawful bases for collecting or using personal information for legal requirements are:

• Consent — we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
• Contract — we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
• Legal obligation — we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

• Directly from you

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements. For example, financial records are retained for 6 years in line with HMRC requirements; marketing contact data is retained until you unsubscribe or after 24 months of inactivity, whichever is sooner. Other records, such as meeting notes or account history, are retained for the duration of the customer relationship plus 6 years.

Others we share personal information with

• Professional or legal advisors
• Financial or fraud investigation authorities
• Relevant regulatory authorities

If you have any concerns about our use of your personal information, you can make a data protection complaint to us:

Email: admin[at]superfriction.co

If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.

The ICO’s address

Helpline number: 0303 123 1113

Website: ico.org.uk/make-a-complaint