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GDPR Privacy notice

The Data Protection Act 2018 – Protection for You

What is the purpose of this document?

As you know we collect some personal data from you when you join our Coach Drivers Club. Under the General Data Protection Regulation (GDPR) and Data Protection Act 2018 we have obligations to you with regards to how we use and hold that data and you have rights in relation to that data.

The Controller of your Data is The Edinburgh Woollen Mill Limited and is registered with ICO as a Data Controller;

The Edinburgh Woollen Mill Limited, registered number: SC024081, registered in Scotland at registered office; Waverley Mills, Langholm, Dumfriesshire, DG13 0EB. We are required under data protection legislation to notify you of the information contained in this privacy notice.

This notice does not form part of any contract of employment or other contract to provide services. Your data is precious and your privacy is important to us. The Edinburgh Woollen Mill Limited will comply with the General Data Protection Regulation and requires that any of the processors of your data will also comply. If, at any time, you wish to amend or access or make a complaint in relation to the use of your data please contact us as follows; Drivers Ledger Telephone: 01228 210642 Travel Club Simply the Best C/O The Edinburgh Woollen Mill Limited, Global House, 5 Castle St., Carlisle, CA3 8SY If at any time you think there is a problem with the way we handle your data, you can complain to the ICO, further details can be found at ico.org.uk/concerns.

Data protection principles

We will comply with data protection law. This says that the personal information we hold about you must be: 1. Used lawfully, fairly and in a transparent way. 2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes. 3. Relevant to the purposes we have told you about and limited only to those purposes. 4. Accurate and kept up to date. 5. Kept only as long as necessary for the purposes we have told you about. 6. Kept securely.

The kind of information we hold about you

Personal data, or personal information, 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). There are "special categories" of more sensitive personal data which require a higher level of protection. We do not collect any sensitive data from you.

We may collect, store, and use the following categories of personal information about you: · Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses. · The coach company you are employed by (your employer details). · National Insurance number. · Bank account details and tax status information. · Location of employment or workplace. · Information relating to any accidents or health and safety incidents you were involved in during your presence on our premises. · Information on purchases when logged in at our stores.

How is your personal information collected?

We only collect information directly from you.

How we will use information about you

We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances: 1. To calculate the commission due to you. 2. To send you the commission due. 3. To send you information and updates about our sites. 4. To comply with tax and legal obligations.

Situations in which we will use your personal information

We need all the categories of information in the list above primarily to allow us to perform our contract with you and to enable us to comply with legal obligations. In some cases we may use your personal information to pursue legitimate interests of our own, provided your interests and fundamental rights do not override those interests. The situations in which we will process your personal information are listed below.

· Paying you and complying with tax and other legal obligations. · Providing Coach Driver Club benefits. · Administering the contract we have entered into with you. · Business management and planning, including accounting and auditing. · Dealing with legal disputes involving you, including accidents on our premises. · Complying with health and safety obligations. · To prevent fraud.

Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.

If you fail to provide personal information

If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you (such as paying you or providing a benefit).

Change of purpose

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 information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Data sharing

We do not share your data with any other party with the exception of HMRC or other government agencies, where we are legally obliged to do so.

Data Transfer

We do not transfer your data outside the EEA, should we do so in the future we will ensure that any recipient to which we transfer your data are deemed to provide an adequate level of protection for your personal information.

Data security

We have put in place measures to protect the security of your information. Details of these measures are available upon request. Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. Details of these measures may be obtained from the Group Company Secretary.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

Data retention

How long will you use my information for?

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Details of retention periods for different aspects of your personal information are available in our retention policy which is available from the Group Company Secretary. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer a member of the Coach Drivers Club we will retain and securely destroy your personal information in accordance with our data retention policy.

Rights of access, correction, erasure, and restriction

Your duty to inform us of changes

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 by contacting the Drivers Ledger at the address above or by telephoning on the number given above.

Your rights in connection with personal information

Under certain circumstances, by law you have the right to: · Request access to your personal information (commonly known as a "data subject access request" or “SAR”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it. · Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected. · Request the erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to stop processing personal information where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground. · Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it. · Request the transfer of your personal information to another party.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact the Group Company Secretary in writing.

No fee usually required

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive, repetitive or vexatious. Alternatively, we may refuse to comply with the request in such circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

Right to withdraw consent

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact the Drivers Ledger. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

Data protection officer

The Board of Directors has made the decision that the EWM Group of Companies shall not appoint a Data Protection Officer. This decision will remain under regular review. However, the Group GDPR Steering Committee led by the Group Company Secretary shall oversee compliance with this privacy notice and other aspects of GDPR compliance and the Group Company Secretary shall report to the EWM Group Board on issues relating to GDPR compliance for the Group, while day to day responsibility is delegated from the EWM Group Board to the Group GDPR Steering Committee the ultimate responsibility for compliance with GDPR shall rest with the Group Board (EWM (Topco) Limited and EWM (2011) Limited as the immediate parents of the trading companies.

If you have any questions about this privacy notice or how we handle your personal information, please contact the Group Company Secretary. You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues.

Changes to this privacy notice

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information. If you have any questions about this privacy notice or concerns about your personal data, please contact the Group Company Secretary, The Edinburgh Woollen Mill Limited, Global house, 5 Castle St, Carlisle, CA3 8SY. Email: sar@ewm.co.uk or phone Drivers Ledger. If we do not satisfactorily deal with any concern or complaint you raise in relation to our use of your personal data then you have the right to seek advice from the ICO (Information Commissioner). You can access the free helpline on 0303 123 1113 or access live chat or make an online communication at https://ico.org.uk/concerns/

How we use Cookies

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We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

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