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Penny Black Glasgow Ltd Privacy Policy

Last updated: 1st May 2018


This privacy notice provides you with details of how Penny Black Glasgow Ltd collects and processes your personal data through your use of our website and some in-store services. This includes:

  • Any information you provide when purchasing products or services.
  • Any information you provide when signing up to our email newsletter.
  • Any information you provide when taking part in a prize draws, competitions or giveaways.

Additionally, if you choose to sign up to marketing in-store and provide your email address and/or other data at that time, this privacy policy also applies to that instance.

By providing us with your data, you warrant to us that you are over 13 years of age.

Contact Details

Company name: Penny Black Glasgow Ltd

Email address:

Phone number: 0141 339 9267

Registered address: 721-723 Great Western Road, Glasgow, G12 8QX, Scotland.

Complaints & Enquiries

If you have a complaint or enquiry about how we use your data, please write to us at the above postal or email address in the first instance.

If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (


Personal data means any information capable of identifying an individual. It does not include anonymised data.

We may process certain types of personal data about you as follows:

  • Identity Data may include your first name, maiden name, last name, username, marital status, title, date of birth and gender.
  • Contact Data may include your billing address, delivery address, email address and telephone numbers.
  • Financial Data may include your bank account and payment card details.
  • Transaction Data may include details about payments between me and other details of purchases made by you.
  • Technical Data may include your login data, internet protocol addresses, browser type and version, browser plug-in types and versions, time zone setting and location, operating system and platform and other technology on the devices you use to access this site.
  • Profile Data may include your username and password, purchases or orders, your interests, preferences, feedback and survey responses.
  • Usage Data may include information about how you use this site, products and services.
  • Marketing and Communications Data may include your preferences in receiving marketing communications from me and my third parties and your communication preferences.

We may also process anonymized Aggregated Data from your personal data but this data does not reveal your identity and as such in itself is not personal data.

Sensitive Data

We do not collect any sensitive data about you. Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We do not collect any information about criminal convictions and offences.

Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have requested. If we do, we will notify you wherever possible.


We collect data about you through a variety of different methods including:

Direct interactions: You may provide data by filling in forms on our website, social media, in-store or by communicating with us by post, phone, email or otherwise, including when you:

  • order products or services.
  • sign up for a customer rewards card
  • create an account on our website.
  • subscribe to our newsletter.
  • request resources or marketing be sent to you.
  • enter a competition, prize draw, promotion or survey.
  • give us feedback.

Automated technologies or interactions: As you use this site, we may automatically collect Technical Data about your equipment, browsing actions and usage patterns. We collect this data by using cookies, server logs and similar technologies. We may also receive Technical Data about you if you visit other websites that use our cookies. Please see our cookie policy on our website for further details.

Third parties or publicly available sources: We may receive personal data about you from various third parties and public sources as set out below:

  • Identity and Contact Data from publicly available sources such as Companies House based inside the EU


We will only use your personal data when legally permitted. The most common uses of your personal data are:

  • Where we need your data to perform the contract between us.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

You have the right to withdraw consent to marketing at any time by emailing us at or by clicking the unsubscribe link within any of our marketing emails.

Reasons for processing your personal data

We may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your data. Current lawful grounds are set out in our Customer Data Policy which should be read in conjunction with this Privacy Policy. 

Marketing Communications 

You will receive marketing communications from us if you have:

  • requested information from us.
  • if you provided us with your details when you registered for email marketing.
  • in each case, you have not opted out of receiving that marketing.

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

You can ask us or third parties to stop sending you marketing messages at any time by following the unsubscribe links on any marketing message sent to you or by emailing us at

Where you opt out of receiving our marketing communications, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions. For example, we will still send you emails regarding specific orders even if you have opted out of receiving marketing emails. This is necessary to fulfil the contract between us.

Change of Purpose

We will only use your personal data for the purposes for which it was collected, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to find out more about how the processing for the new purpose is compatible with the original purpose, please email us at

If we need to use your personal data for a purpose unrelated to the purpose for which we collected the data, we will notify you and explain the legal ground of processing.

We may process your personal data without your knowledge or consent where this is required or permitted by law.


We may have to share your personal data with the parties set out below where necessary and/or requested to:

  • Outsourced team members, including website designers and software providers.
  • Service providers who provide IT and system administration services.
  • Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
  • HM Revenue & Customs, regulators and other authorities based in the United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances.
  • Third parties to whom we may sell, transfer or merge parts of our business or assets.
  • Applications and third-party tools, such as social media and mailing platforms, that we use to run our business.

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions. We ensure that any third party your information is transferred to have comparable privacy and data policies in place before utilizing them.


Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.

Many of our third parties service providers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we will do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; or
  • Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or
  • Where we use providers based in the United States, we may transfer data to them if they are part of the EU-US Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.

If none of the above safeguards are available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.


We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know such data and they are subject to a duty of confidentiality.

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


We will only retain your personal data 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. In some cases, this is an indefinite period.

By law, we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances, you can ask for your data to be deleted. See below for further information.

In some circumstances, we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.


Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:

  • Request access to your personal data.
  • Request correction of your personal data.
  • Request erasure of your personal data.
  • Object to processing of your personal data.
  • Request restriction of processing your personal data.
  • Request transfer of your personal data.
  • Withdraw consent.

You can see more about these rights on the ICO website.

If you wish to exercise any of the rights set out above, please email us at

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

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who is not permitted to receive it. We may also contact you to ask you for further information in relation to your request to expedite our response.

We try to respond to all legitimate requests within one month.


Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.


You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookies policy on our website.

12. STAFF TRAINING & Data Protection Officer

Our staff receive data protection awareness training and are regularly tested on compliance with data protection processes.

The Data Protection Officer for Penny Black Glasgow Ltd is Claire Brown.


We will take all measures possible to protect customer data. In the event a breach of security is discovered, measures will be taken at once to remedy the situation. Where a customer is affected by a breach of data security, we will notify them as soon as possible to inform them of what happened and how they are affected, as well as steps we have taken to remedy the breach and any action the customer must take.

14. Data protection impact assessment

Where we embark on a new method or instance of data processing, we will, if it is deemed a risk to the protection of customer data, carry out a Data Protection Impact Assessment, in conjunction with the guidelines set out by the Information Commissioner’s Office.

15. Policy review

This document is regularly reviewed and updated, where necessary, to ensure compliance with changes in the law. If you have any queries, please


This document is designed to be read in conjunction with our Customer Data Policy which goes into more detail about specific actions taken to collect, process and retain customer information. If you would like a copy of this sent directly to you, please email

Penny Black Glasgow Ltd Customer Data Policy May 2018

What personal customer information do we hold?

We hold customer names, postal addresses, email addresses and telephone numbers. In some instances, we may also hold information on gender and date of birth.

How do we gather this information?

Information comes from a number of places:

Customers who have actively signed up for our email newsletter.

Customers who place an order through a retail channel such as Amazon, eBay or PayPal.

Customers who sign up in store for our Rewards Card programme.

What do we do with this information

For customers who have actively signed up for our email newsletter: we will add their email address securely to our mailing list software (currently Mailchimp) and periodically email them for marketing purposes. Date of birth and gender information may be used to target marketing, where we hold this information. We do not actively use postal address or telephone numbers but may choose to do so in future, where this information is held. When signing up to the mailing list, we use double opt-in emails to ensure customers have to explicitly agree to subscribing.

The lawful basis for holding this data is Consent.

For customers who have placed an order via Amazon, eBay or PayPal: we will store their name, postal address, email address and telephone number automatically within our EPOS system. This information is not used for any purpose other than to fulfil the order they have placed with us. We do not hold gender or date of birth for these customers. This information is necessary for us to fulfil the customer’s order and is not used for any other purpose, including marketing.

The lawful basis for holding this data is Contract.

For customers who signed up to our rewards programme instore: Prior to 25/05/18, we store the customer’s name and email address in an account in our EPOS system. In some instances, we may also hold the customer’s postal address, date of birth and/or gender. This information was given verbally in-store and entered into the EPOS system by a staff member. A "Consents To Marketing" Yes/No box was selected at time of entry, again, with consent verbally given by the customer.

Post-25/05/18, when a customer signed up for a rewards card, we do not take any personal information from customers at all. The card is activated and assigned to a unique but non-personalised account. Customers are then directed to register an account and link their card online via our website. At that time, they will be asked to explicitly consent with a check box that they agree to receiving online marketing from us.

The lawful basis for holding this data is Consent.

Where is this information stored?

Customer information is securely stored on our EPOS system provided by Intelligent Retail and is accessible only by authorised staff members. Customers who have actively opted in to our email newsletter have their data securely stored on Mailchimp, which is password protected and accessed only by members of staff responsible for marketing.

How long do we keep this information?

This information is held indefinitely.

How do customers find out what information we hold about them?

Customers can request a copy of information we hold about them free of charge. We will respond with this information within one calendar month. If the customer wishes any information to be changed or rectified, they may request this by the same method.

Customers can request this by emailing or by writing to Penny Black Glasgow Ltd, 721-723 Great Western Road, Glasgow, G12 8QX.

How do customers request their data be deleted from our records?

Customers can request that we delete the information we hold about them at any time. Customers can also request that processing of the data we hold be restricted also. We will action this request and confirm it with the customer within one calendar month. 

Customers can request this by emailing or by writing to Penny Black Glasgow Ltd, 721-723 Great Western Road, Glasgow, G12 8QX.



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