PRIVACY POLICY

TD Tom Davies Ltd. and its corporate business affiliates (“Tom Davies,” “we,” or “us”) provide this notice (“Privacy Notice”) to inform you of our personal information handling practices for personal information we collect from those who contact us and visitors to www.tdtomdavies.com and other web and mobile sites operated by us that link to this Privacy Notice (collectively, the “sites”).

This Privacy Notice (together with our Cookie Notice) sets out the basis on which any personal data, personally identifiable information, or personal information (“personal data”) that you provide to us or we collect from you through our sites will be processed by us. This Privacy Notice does not cover any personal data we collect offline.

When you use our sites, contact us, or make an inquiry via our sites, your personal data will be collected and controlled by TD Tom Davies Ltd. (a UK company organised under the laws of the United Kingdom and based at 983 Great West Road, London, TW8 9DN).

We collect information about you when you: create an account on our sites; place an order from our sites; fill in forms on or interact with our sites; correspond with us (e.g., when you contact Tom Davies’ Customer Service team); request information about our services; book in for our services and report a problem with our sites.

The information you give us may include your name, alias, username, date of birth, gender, phone number, email address, and other information that you choose to provide. Providing such personal data is voluntary. However, without providing such personal data, we may not be able to provide you with information or services you request from us. You will know what personal data you provide because you will actively submit it to us.

In addition to the personal data that you actively provide, the sites may automatically collect, process, and store certain information about you:

COOKIES

We and our service providers may use cookies and similar tracking technologies to distinguish you from other users of our sites and collect information about how you access and use our sites and the device you use to access our sites. This helps us to provide you with a good experience when you browse our sites and also allows us to customise and improve our sites.

HOW WE USE YOUR INFORMATION

To the extent permitted under applicable law, we will use personal data held about you for the purposes detailed below:

THE PERIODS FOR WHICH WE RETAIN YOUR INFORMATION

We will not hold your personal information in an identifiable format for any longer than is necessary for the purposes for which we collected it. For certain purposes we retain your personal information (e.g. to suppress marketing messages where you have opted out), otherwise to establish, bring or defend legal claims, we only retain your personal information in accordance with our data retention policy and relevant statutory data retention periods that apply. For example:

Retention Periods

• We keep your personal information for no longer than necessary to fulfil the purposes for which the information is processed. We process personal information in accordance with our Data Retention Period and relevant statutory data retention period that may apply.

The only exceptions to this are where:

• The law requires us to hold your personal information for a longer period, or delete it sooner;
• You exercise your right to have the information erased (where it applies) and we do not need to hold it in connection with any of the reasons permitted or required under the law (see further Your Rights In Relation To Your Personal Information below);
• We bring or defend a legal claim or other proceedings during the period we retain your personal information, in which case we will retain your personal information until those proceedings have concluded and no further appeals are possible;
• We archive the information, in which case we will delete it in accordance with our deletion cycles which are based on good industry practice; or
• You exercise your right to require us to retain your personal information for a period longer than our stated retention period (see further Your Rights In Relation To Your Personal Information below).

DISCLOSURE OF YOUR INFORMATION

To the extent permitted under applicable data protection law, we may share your personal data with:

1. Any member of our group. For example, we may share your personal data with Tom Davies’ group companies to provide you with products and services, provide you with customer support, understand your preferences, offer targeted marketing, send you information about products and services that may be of interest to you, and conduct other activities described in this Privacy Notice.
2. Selected third parties including:
   • Service providers who act as our data processor. These service providers perform services on our behalf and assist us with the provision of our sites and services. For example, they may assist us with powering our sites, payment processing, processing and fulfilling orders placed by customers, fraud prevention, marketing, purchase financing, and customer support services.
   • Analytics and search engine providers that assist us in the improvement and optimisation of our sites.
   • Business partners that enhance our advertising efforts.
3. Other third parties in the following circumstances:
   • If we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
   • If we or our affiliates, or substantially all of the assets of any of the foregoing, is acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
   • To comply with any legal obligation or request from law enforcement, enforce or apply our agreements, or to protect the rights, property, or safety of us or our affiliates, employees, customers, users, or others.

DATA SECURITY

We have put in place technical and organisational security measures, to reduce the risk of your personal data being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed.

INTERNATIONAL DATA TRANSFERS

Your personal data may be disclosed to employees, representatives, or other third parties including our service providers operating outside of the country you are based and who work for, or are engaged by us or our affiliates in other countries, including the UK and in other countries that we operate. We note that these persons and third parties may also store, transfer, or access personal data outside of the country you are based. In disclosing your personal data overseas, we will take such steps as are reasonable in the circumstances to require that overseas recipients protect your personal data in accordance with applicable laws.