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PRIVACY NOTICE

This disclaimer details our obligations to you regarding our Website –
www.magnet.co.uk.

Please read this disclaimer in full before you use this Website. Using the
Website implies that you accept the terms of this disclaimer.
We do occasionally update this disclaimer so please refer back to them in the
future.
Alternatively, download the latest copy here: Privacy Notice October 2021

 

(A) This Notice

Summary - This Notice
This Notice explains how we Process Personal Data. This Notice may be amended or
updated from time to time, so please check it regularly for updates.

This Notice is issued by each of the Controller entities listed in Section (R)
below (together, “Nobia”, “we”, “us” and “our”) and is addressed to individuals
outside our organisation with whom we interact, including customers, visitors to
our Sites, users of our Apps, other users of our products or services, and
visitors to our premises (together, “you”). Defined terms used in this Notice
are explained in Section (S) below.

This Notice may be amended or updated from time to time to reflect changes in
our practices with respect to the Processing of Personal Data, or changes in
applicable law. We encourage you to read this Notice carefully, and to regularly
check this page to review any changes we might make in accordance with the terms
of this Notice.

(B) Collection of Personal Data

Summary - Collection of Personal Data
We collect or obtain Personal Data: when those data are provided to us (e.g.,
where you contact us); in the course of our relationship with you (e.g., if you
make a purchase); when you make Personal Data public (e.g., if you make a public
post about us on social media); when you download, install, or use any of our
Apps; when you visit our Sites; when you register to use any of our Sites, Apps,
products, or services; or when you interact with any third party content or
advertising on a Site or in an App. We may also receive Personal Data about you
from third parties (e.g., law enforcement authorities).

Collection of Personal Data: We collect or obtain Personal Data about you from
the following sources:

 * Data provided to us: We obtain Personal Data when those data are provided to
   us (e.g., where you contact us via email or telephone, or by any other means,
   or when you provide us with your business card, or when you submit a job
   application).
 * Relationship data: We collect or obtain Personal Data in the ordinary course
   of our relationship with you (e.g., we provide a service to you, or to your
   employer).
 * Data you make public: We collect or obtain Personal Data that you manifestly
   choose to make public, including via social media (e.g., we may collect
   information from your social media profile(s), if you make a public post
   about us).
 * App data: We collect or obtain Personal Data when you download or use any of
   our Apps.
 * Site data: We collect or obtain Personal Data when you visit any of our Sites
   or use any features or resources available on or through a Site.
 * Registration details: We collect or obtain Personal Data when you use, or
   register to use, any of our Sites, Apps, products, or services.
 * Content and advertising information: If you interact with any third party
   content or advertising on a Site or in an App (including third party plugins
   and cookies) we receive Personal Data from the relevant third party provider
   of that content or advertising.
 * Third party information: We collect or obtain Personal Data from third
   parties who provide it to us (e.g., credit reference agencies; law
   enforcement authorities; etc.).

(C) Creation of Personal Data

Summary - Creation of Personal Data
We create Personal Data about you (e.g., records of your interactions with us).

We also create Personal Data about you in certain circumstances, such as records
of your interactions with us, and details of your purchase history.

(D) Categories of Personal Data we Process

Summary – Categories of Personal Data we Process
We Process: your personal details (e.g., your name); demographic data (e.g.,
your age); your contact details (e.g., your address); records of your consents;
purchase details; payment details (e.g., your billing address); information
about our Sites and Apps (e.g., the type of device you are using); details of
your employer (where relevant); information about your interactions with our
content or advertising; and any views or opinions you provide to us.

We Process the following categories of Personal Data about you:

 * Personal details: given name(s); preferred name; and photograph.
 * Demographic information: gender; nationality; salutation; title; and language
   preferences.
 * Contact details: correspondence address; shipping address; telephone number;
   email address; details of Personal Assistants, where applicable; messenger
   app details; online messaging details; and social media details.
 * Consent records: records of any consents you have given, together with the
   date and time, means of consent and any related information (e.g., the
   subject matter of the consent).
 * Purchase details: records of purchases and prices; consignee name, address,
   contact telephone number and email address; and installation instructions.
 * Payment details: invoice records; payment records; billing address; payment
   method; payment amount; payment date; and records of cheques.
 * Data relating to our Sites and Apps: device type; operating system; browser
   type; browser settings; IP address; language settings; dates and times of
   connecting to a Site; App usage statistics; App settings; dates and times of
   connecting to an App; location data, and other technical communications
   information (some of which may constitute Personal Data); username; password;
   security login details; usage data; aggregate statistical information.
 * Employer details: where you interact with us in your capacity as an employee
   of a third party, the name, address, telephone number and email address of
   your employer, to the extent relevant.
 * Content and advertising data: records of your interactions with our online
   advertising and content, records of advertising and content displayed on
   pages or App screens displayed to you, and any interaction you may have had
   with such content or advertising (e.g., mouse hover, mouse clicks, any forms
   you complete in whole or in part) and any touchscreen interactions.
 * Views and opinions: any feedback you provide.

(E) Sensitive Personal Data

Summary - Sensitive Personal Data
We do not seek to collect or otherwise Process Sensitive Personal Data. Where we
need to Process Sensitive Personal Data for a legitimate purpose, we do so in
accordance with applicable law.

We do not seek to collect or otherwise Process Sensitive Personal Data in the
ordinary course of our business. Where it becomes necessary to Process your
Sensitive Personal Data for any reason, we rely on one of the following legal
bases:

 * Compliance with applicable law: We may Process your Sensitive Personal Data
   where the Processing is required or permitted by applicable law (e.g., to
   comply with our diversity reporting obligations);
 * Detection and prevention of crime: We may Process your Sensitive Personal
   Data where the Processing is necessary for the detection or prevention of
   crime (e.g., the prevention of fraud);
 * Establishment, exercise or defence of legal rights: We may Process your
   Sensitive Personal Data where the Processing is necessary for the
   establishment, exercise or defence of legal rights; or
 * Consent: We may Process your Sensitive Personal Data where we have, in
   accordance with applicable law, obtained your prior, express consent prior to
   Processing your Sensitive Personal Data (this legal basis is only used in
   relation to Processing that is entirely voluntary – it is not used for
   Processing that is necessary or obligatory in any way).

If you provide Sensitive Personal Data to us, you must ensure that it is lawful
for you to disclose such data to us, and you must ensure a valid legal basis
applies to the Processing of those Sensitive Personal Data.

(F) Purposes of Processing and legal bases for Processing


Summary - Purposes of Processing and legal bases for Processing
We Process Personal Data for the following purposes: providing our Sites, Apps,
products, and services to you; operating our business; communicating with you;
managing our IT systems; health and safety; financial management; conducting
surveys; ensuring the security of our premises and systems; conducting
investigations where necessary; compliance with applicable law; improving our
Sites, Apps, products, and services; fraud prevention; and recruitment and job
applications.

The purposes for which we Process Personal Data, subject to applicable law, and
the legal bases on which we perform such Processing, are as follows:

Processing Activity

 * Provision of Sites, Apps, products, and services: providing our Sites, Apps,
   products, or services; providing promotional items upon request; and
   communicating with you in relation to those Sites, Apps, products, or
   services.
 * Operating our business: operating and managing our Sites, our Apps, our
   products, and our services; providing content to you; displaying advertising
   and other information to you; communicating and interacting with you via our
   Sites, our Apps, our products, or our services; and notifying you of changes
   to any of our Sites, our Apps, our products, or our services.
 * Communications and marketing: communicating with you via any means
   (including via email, telephone, text message, social media, post or in
   person) news items and other information in which you may be interested,
   subject always to obtaining your prior opt-in consent to the extent required
   under applicable law; maintaining and updating your contact information where
   appropriate; and obtaining your prior, opt-in consent where required.
 * Management of IT systems: management and operation of our communications, IT
   and security systems; and audits (including security audits) and monitoring
   of such systems.
 * Health and safety: health and safety assessments and record keeping;
   providing a safe and secure environment at our premises; and compliance with
   related legal obligations.
 * Financial management: sales; finance; corporate audit; and vendor management.
 * Surveys: engaging with you for the purposes of obtaining your views on our
   Sites, our Apps, our products, or our services.
 * Security: physical security of our premises (including records of visits to
   our premises); CCTV recordings; and electronic security (including login
   records and access details).
 * Investigations: detecting, investigating and preventing breaches of policy,
   and criminal offences, in accordance with applicable law.
 * Legal proceedings: establishing, exercising and defending legal rights.
 * Legal compliance: compliance with our legal and regulatory obligations under
   applicable law.
 * Improving our Sites, Apps, products, and services: identifying issues with
   our Sites, our Apps, our products, or our services; planning improvements to
   our Sites, our Apps, our products, or our services; and creating new Sites,
   Apps, products, or services.
 * Fraud prevention: Detecting, preventing and investigating fraud.
 * Recruitment and job applications: recruitment activities; advertising of
   positions; interview activities; analysis of suitability for the relevant
   position; records of hiring decisions; offer details; and acceptance details.

Legal Bases for Processing

 * The Processing is necessary in connection with any contract that you have
   entered into with us, or to take steps prior to entering into a contract with
   us; or
 * The Processing is necessary for compliance with a legal obligation; or
 * We have a legitimate interest in carrying out the Processing for the purpose
   of providing our services (to the extent that such legitimate interest is not
   overridden by your interests, fundamental rights, or freedoms); or
 * We have obtained your prior consent to the Processing (this legal basis is
   only used in relation to Processing that is entirely voluntary – it is not
   used for Processing that is necessary or obligatory in any way).

(G) Disclosure of Personal Data to third parties

Summary - Disclosure of Personal Data to third parties
We disclose Personal Data to: legal and regulatory authorities; our external
advisors; our Processors; any party as necessary in connection with legal
proceedings; any party as necessary for investigating, detecting or preventing
criminal offences; any purchaser of our business; and any third party providers
of advertising, plugins or content used on our Sites or our Apps.

We disclose Personal Data to other entities within the Nobia group, for
legitimate business purposes and the operation of our Sites, Apps, products, or
services to you), in accordance with applicable law. In addition, we disclose
your Personal Data to:

 * you and, where appropriate, your appointed representatives;
 * legal and regulatory authorities, upon request, or for the purposes of
   reporting any actual or suspected breach of applicable law or regulation;
 * accountants, auditors, lawyers and other outside professional advisors to
   Nobia, subject to binding contractual obligations of confidentiality;
 * third party Processors (such as payment services providers; shipping
   companies; etc.), located anywhere in the world, subject to the requirements
   noted below in this Section (G);
 * any relevant party, law enforcement agency or court, to the extent necessary
   for the establishment, exercise or defence of legal rights;
 * any relevant party for the purposes of prevention, investigation, detection
   or prosecution of criminal offences or the execution of criminal penalties;
 * any relevant third party acquirer(s), in the event that we sell or transfer
   all or any relevant portion of our business or assets (including in the event
   of a reorganization, dissolution or liquidation); and
 * any relevant third party provider, where our Sites and our Apps use third
   party advertising, plugins or content. If you choose to interact with any
   such advertising, plugins or content, your Personal Data may be shared with
   the relevant third party provider. We recommend that you review that third
   party’s privacy policy before interacting with its advertising, plugins or
   content.

We may engage third-party Processors to Process your Personal Data. These
include marketing service providers (print and distribution, social media, media
agencies and advertising agencies), and IT service providers. If we do so, the
Processor will be subject to binding contractual obligations to: (i) only
Process the Personal Data in accordance with our prior written instructions; and
(ii) use measures to protect the confidentiality and security of the Personal
Data; together with any additional requirements under applicable law.

(H) International transfer of Personal Data

Summary - International transfer of Personal Data
We transfer Personal Data to recipients in other countries. Where we transfer
Personal Data from the EEA to a recipient outside the EEA that is not in an
Adequate Jurisdiction, we do so on the basis of the Standard Contractual Clauses
with our partners.

Because of the international nature of our business, we transfer Personal Data
within the Nobia group, and to third parties as noted in Section (G) above, in
connection with the purposes set out in this Notice. For this reason, we
transfer Personal Data to other countries that may have different laws and data
protection compliance requirements to those that apply in the country in which
you are located.

Where we transfer your Personal Data from the EEA to recipients located outside
the EEA who are not in Adequate Jurisdictions, we do so on the basis of the
Standard Contractual Clauses with our partners.

Please note that when you transfer any Personal Data directly to a Nobia entity
established outside the EEA, we are not responsible for that transfer of your
Personal Data. We will nevertheless Process your Personal Data, from the point
at which we receive those data, in accordance with the provisions of this
Notice.

(I) Data security

Summary - Data security
We implement appropriate technical and organisational security measures to
protect your Personal Data. Please ensure that any Personal Data that you send
to us are sent securely.

We have implemented appropriate technical and organisational security measures
designed to protect your Personal Data against accidental or unlawful
destruction, loss, alteration, unauthorised disclosure, unauthorised access, and
other unlawful or unauthorised forms of Processing, in accordance with
applicable law.

Because the internet is an open system, the transmission of information via the
internet is not completely secure. Although we will implement all reasonable
measures to protect your Personal Data, we cannot guarantee the security of your
data transmitted to us using the internet – any such transmission is at your own
risk and you are responsible for ensuring that any Personal Data that you send
to us are sent securely.

(J) Data accuracy

Summary - Data accuracy
We take every reasonable step to ensure that your Personal Data are kept
accurate and up-to-date and are erased or rectified if we become aware of
inaccuracies.

We take every reasonable step to ensure that:

 * your Personal Data that we Process are accurate and, where necessary, kept up
   to date; and
 * any of your Personal Data that we Process that are inaccurate (having regard
   to the purposes for which they are Processed) are erased or rectified without
   undue delay.

From time to time we may ask you to confirm the accuracy of your Personal Data.

(K) Data minimisation

Summary - Data minimisation
We take every reasonable step to limit the volume of your Personal Data that we
Process to what is necessary.

We take every reasonable step to ensure that your Personal Data that we Process
are limited to the Personal Data reasonably necessary in connection with the
purposes set out in this Notice.

(L) Data retention

Summary - Data retention
We take every reasonable step to ensure that your Personal Data are only
retained for as long as they are needed in connection with a lawful purpose.

We take every reasonable step to ensure that your Personal Data are only
Processed for the minimum period necessary for the purposes set out in this
Notice. The criteria for determining the duration for which we will retain your
Personal Data are as follows:

(1) we will retain Personal Data in a form that permits identification only for
as long as:

 1. we maintain an ongoing relationship with you (e.g., where you are a user of
    our services, or you are lawfully included in our mailing list and have not
    unsubscribed); or
 2. your Personal Data are necessary in connection with the lawful purposes set
    out in this Notice, for which we have a valid legal basis (e.g., where your
    personal data are included in a contract between us and your employer, and
    we have a legitimate interest in processing those data for the purposes of
    operating our business and fulfilling our obligations under that contract;
    or where we have a legal obligation to retain your Personal Data),

plus:

(2) the duration of:

 1. any applicable limitation period under applicable law (i.e., any period
    during which any person could bring a legal claim against us in connection
    with your Personal Data, or to which your Personal Data are relevant); and
 2. an additional two (2) month period following the end of such applicable
    limitation period (so that, if a person brings a claim at the end of the
    limitation period, we are still afforded a reasonable amount of time in
    which to identify any Personal Data that are relevant to that claim),

and:

(3) in addition, if any relevant legal claims are brought, we continue to
Process Personal Data for such additional periods as are necessary in connection
with that claim.

During the periods noted in paragraphs (2)(a) and (2)(b) above, we will restrict
our Processing of your Personal Data to storage of, and maintaining the security
of, those data, except to the extent that those data need to be reviewed in
connection with any legal claim, or any obligation under applicable law.

Once the periods in paragraphs (1), (2) and (3) above, each to the extent
applicable, have concluded, we will either:

 * permanently delete or destroy the relevant Personal Data; or
 * anonymize the relevant Personal Data.

(M) Your legal rights

Summary - Your legal rights
Subject to applicable law, you may have a number of rights, including: the right
not to provide your Personal Data to us; the right of access to your Personal
Data; the right to request rectification of inaccuracies; the right to request
the erasure, or restriction of Processing, of your Personal Data; the right to
object to the Processing of your Personal Data; the right to have your Personal
Data transferred to another Controller; the right to withdraw consent; and the
right to lodge complaints with Data Protection Authorities. In some cases it
will be necessary to provide evidence of your identity before we can give effect
to these rights.

Subject to applicable law, you may have the following rights regarding the
Processing of your Relevant Personal Data:

 * the right not to provide your Personal Data to us (however, please note that
   we will be unable to provide you with the full benefit of our Sites, Apps,
   products, or services, if you do not provide us with your Personal Data –
   e.g., we might not be able to process your requests without the necessary
   details);
 * the right to request access to, or copies of, your Relevant Personal Data,
   together with information regarding the nature, Processing and disclosure of
   those Relevant Personal Data;
 * the right to request rectification of any inaccuracies in your Relevant
   Personal Data;
 * the right to request, on legitimate grounds:
   * erasure of your Relevant Personal Data; or
   * restriction of Processing of your Relevant Personal Data;
 * the right to have certain Relevant Personal Data transferred to another
   Controller, in a structured, commonly used and machine-readable format, to
   the extent applicable;
 * where we Process your Relevant Personal Data on the basis of your consent,
   the right to withdraw that consent (noting that such withdrawal does not
   affect the lawfulness of any Processing performed prior to the date on which
   we receive notice of such withdrawal, and does not prevent the Processing of
   your Personal Data in reliance upon any other available legal bases); and
 * the right to lodge complaints regarding the Processing of your Relevant
   Personal Data with a Data Protection Authority (in particular, the Data
   Protection Authority of the EU Member State in which you live, or in which
   you work, or in which the alleged infringement occurred, each if applicable).

Subject to applicable law, you may also have the following additional rights
regarding the Processing of your Relevant Personal Data:\

 * the right to object, on grounds relating to your particular situation, to the
   Processing of your Relevant Personal Data by us or on our behalf; and
 * the right to object to the Processing of your Relevant Personal Data by us or
   on our behalf for direct marketing purposes.

This does not affect your statutory rights.

To exercise one or more of these rights, or to ask a question about these rights
or any other provision of this Notice, or about our Processing of your Personal
Data, please use the contact details provided in Section (R) below. Please note
that:

 * in some cases it will be necessary to provide evidence of your identity
   before we can give effect to these rights; and
 * where your request requires the establishment of additional facts (e.g., a
   determination of whether any Processing is non-compliant with applicable law)
   we will investigate your request reasonably promptly, before deciding what
   action to take.

(N) Cookies and similar technologies

Summary – Cookies and similar technologies
We Process Personal Data by using Cookies and similar technologies. For more
information, please see our Cookie Notice.

When you visit a Site or use an App we will typically place Cookies onto your
device, or read Cookies already on your device, subject always to obtaining your
consent, where required, in accordance with applicable law. We use Cookies to
record information about your device, your browser and, in some cases, your
preferences and browsing habits. We Process Personal Data through Cookies and
similar technologies, in accordance with our Cookie Notice.

(O) Terms of Use

Summary – Terms of Use
Our Terms and Conditions govern all use of our Sites, our Apps and our services.

All use of our Sites, Apps, products, or services is subject to our Terms and
Conditions. We recommend that you review our Terms of Use regularly, in order to
review any changes we might make from time to time.

(P) Direct marketing

Summary – Direct marketing
We Process Personal Data to contact you with information regarding Sites, Apps,
products, or services that may be of interest to you. You may unsubscribe for
free at any time.

We Process Personal Data to contact you via email, telephone, direct mail or
other communication formats to provide you with information regarding Sites,
Apps, products, or services that may be of interest to you. If we provide Sites,
Apps, products, or services to you, we may send information to you regarding our
Sites, Apps, products, or services, upcoming promotions and other information
that may be of interest to you, using the contact details that you have provided
to us, subject always to obtaining your prior opt-in consent to the extent
required under applicable law.

You may unsubscribe from our promotional email list at any time by simply
clicking on the unsubscribe link included in every promotional email we send.
After you unsubscribe, we will not send you further promotional emails, but in
some circumstances we will continue to contact you to the extent necessary for
the purposes of any Sites, Apps, products, or services you have requested.

(Q) Details of Controllers

Summary - Details of Controllers
There are several Nobia entities that act as Controllers for the purposes of
this Privacy Notice.

For the purposes of this Notice, the relevant Controllers are:

Controller entity
Nobia AB

Contact details
Klarabergsviadukten 70, A5, Stockholm
P.O Box 70376, SE-107 24 Stockholm
Phone: +46 8 440 16 00
Email: info@nobia.com

Magnet Trade Customer Care Team
Nobia UK, Allington Way, Darlington,DL1 4XT
Phone: +44 1325 744093
Email: gdprcustomer@nobiauk.com

(R) Definitions

 * “App” means any application made available by us (including where we make
   such applications available via third party stores or marketplaces, or by any
   other means).
 * “Adequate Jurisdiction” means a jurisdiction that has been formally
   designated by the European Commission as providing an adequate level of
   protection for Personal Data.
 * “Cookie” means a small file that is placed on your device when you visit a
   website (including our Sites). In this Notice, a reference to a “Cookie”
   includes analogous technologies such as web beacons and clear GIFs.
 * “Controller”means the entity that decides how and why Personal Data are
   Processed. In many jurisdictions, the Controller has primary responsibility
   for complying with applicable data protection laws.
 * “Data Protection Authority” means an independent public authority that is
   legally tasked with overseeing compliance with applicable data protection
   laws.
 * “EEA” means the European Economic Area.
 * “Personal Data” means information that is about any individual, or from which
   any individual is directly or indirectly identifiable, in particular by
   reference to an identifier such as a name, an identification number, location
   data, an online identifier or to one or more factors specific to the
   physical, physiological, genetic, mental, economic, cultural or social
   identity of that individual.
 * “Process”, “Processing” or “Processed”means anything that is done with any
   Personal Data, whether or not by automated means, such as collection,
   recording, organisation, structuring, storage, adaptation or alteration,
   retrieval, consultation, use, disclosure by transmission, dissemination or
   otherwise making available, alignment or combination, restriction, erasure or
   destruction.
 * “Processor”means any person or entity that Processes Personal Data on behalf
   of the Controller (other than employees of the Controller).
 * “Profiling” means any form of automated Processing of Personal Data
   consisting of the use of Personal Data to evaluate certain personal aspects
   relating to a natural person, in particular to analyse or predict aspects
   concerning that natural person's performance at work, economic situation,
   health, personal preferences, interests, reliability, behaviour, location or
   movements.
 * “Relevant Personal Data” means Personal Data in respect of which we are the
   Controller.
 * “Sensitive Personal Data” means Personal Data about race or ethnicity,
   political opinions, religious or philosophical beliefs, trade union
   membership, physical or mental health, sexual life, any actual or alleged
   criminal offences or penalties, national identification number, or any other
   information that are deemed to be sensitive under applicable law.
 * “Standard Contractual Clauses” means template transfer clauses adopted by the
   European Commission or adopted by a Data Protection Authority and approved by
   the European Commission.
 * “Site”means any website operated, or maintained, by us or on our behalf.


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