Privacy Policy

A safe pair of hands!

Palmer Agencies takes your privacy seriously. We are committed to protecting your personal information. This policy sets out how Palmer Agencies uses the information that you provide us with in order to help further our business and your rights.

Your data

About us: Palmer Agencies Ltd is a leading import and distribution company specialising in the gift, souvenir, party and Halloween market. We operate on a strictly business to business basis offering a broad selection of exclusive merchandise to the party and gift retail trade. We have been in business for over 50 years and have gained enormous experience in product and service. We have an experienced team of agents throughout the UK and Ireland who would be pleased to call with you at your convenience. Our efficient office staff are also at your disposal for any enquiries that you may have. With an unrivalled reputation in the Party and Halloween markets; Palmer Agencies is amongst the most highly regarded suppliers to the trade offering a consistent top service, innovation, quality, value or unique designs.

We do not claim to be the biggest company and we will never be perfect, but we will never stop trying to be. Our mission is to become our customers’ preferred partner by supplying quality, unique, exciting, profitable and trail blazing merchandise whilst offering the best customer service in the market…and that includes treating your personal details with due respect, utmost attention and extreme care.

We will not sell your data to any third parties, subsidiaries, trusted service providers or selected partners or suppliers. We ensure that any third parties with access to your data are held to strict standards for data use and security.

Who we are

By Palmer Agencies (the data controller) we mean:

Palmer Agencies Ltd of Unit 1 Beechill Business Park, 96 Beechill Road, Belfast, BT8 7QN, registered in Northern Ireland No. 7156, VAT reg. GB 517 0693 48. Our Data protection officer can be contacted on 028 9064 7119

Your Information – what we collect and how we use it

Palmer Agencies collects information from its customers and leads in a number of different ways. For example, we ask for contact and other information when we are showing at a trade show and you have shown interest in our products, sign up to marketing communications or engage with one of our marketing campaigns. This may include information such as your name, business address, contact information…. We may use this information to help us provide and improve our services as a supplier and to keep a record of our communications with you.

If you are a customer of Palmer Agencies Ltd, we will ask for information that enables us to administer your account. This will normally include information such as your name, contact details such as address, email or telephone number and your payment details.

If you have given us your consent, we will contact you with information and updates on our company, products, catalogues, promotions, reminders (such as St Patrick’s Day, Halloween) and how you can place your orders with us. This may be by post, email, telephone, fax or text message or even social media, depending on your preferences. We will also continue to ask about your contact method preferences, to ensure that you are still happy to be contacted by us and by which means.

What the Law says about protection of personal information

The Law on Data Protection is derived from various pieces of legislation (can be found in a number of places). These include the Data Protection Act and the incoming General Data Protection Regulation (the ‘GDPR’) which will become enforceable in May 2018. The GDPR states that personal data (information relating to a person that can be individually identified) can only be processed if there is a legal ground to do so. Activities like collecting, storing and using personal information would fall into the GDPR’s definition of processing. The GDPR provides six legal grounds (reasons) under which personal information can be processed (used) in a way that is lawful. For the processing to be permitted by law (lawful), at least one of the legal grounds must apply.

These legal grounds are:

(a) the data subject has given consent to the processing of their personal data for one or more specific purposes;
(b) processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract;
(c) processing is necessary for compliance with a legal obligation to which the controller is subject;
(d) processing is necessary in order to protect the vital interests of the data subject;
(e) processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
(f) processing is necessary for the purposes of the legitimate interests pursued by a controller, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child. This shall not apply to processing carried out by public authorities in the performance of their tasks.

How the law applies to Palmer Agencies’ use of personal information

Palmer Agencies will only process your personal information if we have:

• asked you and have a record of your express and recent consent for us to do so;

• a ‘Legitimate Interest’ to do so in order to support commercial relation. Our use will always be fair and balanced and never unduly have an impact on your rights.

• a contract with you that we can only fulfil by using your personal information, e.g. to send you an item that you have requested or if you are an employee of Palmer Agencies Ltd;

• a legal obligation to use or disclose information about you.

In extreme situations, such as an accident or medical emergency, we may share your personal details with the emergency services if it is essential for the preservation of life (yours or another persons’) for us to do so (traceability of articles that may contain allergens, or product safety). This is the ‘vital interest’ ground for using your personal information. After the emergency, we will always try to inform you about how we had to use your information in that extreme situation.

We will not unduly prioritise our interests as a limited company over your interests as an individual. We will always balance our interests with your rights. We will only use personal information in a way and for a purpose that you would reasonably expect in accordance with this Policy.

Palmer Agencies will not rent, swap or sell your personal information to other organisations for them to use in their own marketing activities.

Consent

Palmer Agencies will assume your consent when we scan your data or get your contact details at trade shows before we communicate with you for certain purposes. For example, we will only email or phone you about our promotions and new product development if we have had recent interaction with you (trade shows, sales, promotions…) and you have not waived your consent for us to do so. You can withdraw your consent at any time by phoning +44 (0) 28 9064 7119 or emailing sales@palmeragencies.com

There are times when it is not practical to obtain and record consent. At those times, we will only process personal information if that processing would meet another legal ground e.g. Legitimate Interests, in which case we would only process in accordance with the law’s strict rules on legitimate interest processing.

What is Legitimate Interest?

This legal ground for processing means that organisations can process your personal information if they have both a genuine and legitimate reason for doing so and this use does not harm any of your rights and interests as an individual.

Palmer Agencies’ Legitimate Interest

We do not unduly prioritise our legitimate business interests over your interests as an individual. We always respect your rights: which is why we carry out a balancing exercise of the rights of the charity with the rights of our supporters.

We believe that the best way to look after the interests of our customers and leads is to consider their unique interests and expectations. As a result, we have established the following categories of Palmer Agencies’ business partners. This provides us with an additional method for assessing that we use your personal information in a way that matches your relationship with us; your interests; and your expectations about your rights.

The five groups for our data protection business partners are:

• Employees

• Suppliers and service providers

• Customers

• Business Leads

• New supporters that have demonstrated an interest in our products by contacting us for more information, e.g. to find out more about one of our products, services or campaigns.

What we have a Legitimate Interest to do

We believe that Palmer Agencies business partners are connected to our mission and want to know how they can continue to enjoy our customer service and, unless you tell us not to, we think you agree for us to process (keep and use) your personal information for the following lengths of time. As of May 2018, we promise not to keep your personal information for longer than we specify below. This is not the length of time that we will continue to contact you – this could be a shorter period of time (see below for an explanation on our personalised approach to communications).

• Employees

We will keep your contact details like, addresses, banking details, National Insurance related information, and any other legally required information on record for as long as you are employed by Palmer Agencies and for five years after the employment relation has ceased.

• Suppliers and service providers

We need to keep your information to ensure that we can continue to do business and place orders.

• Customers

We will keep this information for as long as your business is still trading and you do not revoke your consent. We will contact with you throughout the business lifetime and we will therefore keep your personal information to allow for this.

• Business Leads

As in many cases, these details are given at trade shows or exhibitions, we will keep your personal information for as long as we are showing in trade shows, and you have not opted out or revoked your consent

• New contacts that have demonstrated an interest in our products by contacting us for more information, e.g. to find out more about one of our products, services or campaigns.

These are people or organisations who are aware of our products or services, who have demonstrated an interest in our company or its products by contacting us for more information, e.g. to find out more about one of our products, services or campaigns. We think someone that has reached out to us to find out more about Palmer Agencies and what we do, would like us to provide that information; perhaps a little more information; and even some support in fulfilling their initial query or request. To support this, we may keep your personal information for a period of 4 years, unless they state they do not want to be contacted again, revoke their consent or opt out of our communications.

Business partners demonstrate their support in our business and products in a number of ways and so could be in more than one, or even all, of the above categories. We will commit to reviewing and refreshing these categories and the timescales on a rolling basis to ensure that as times and needs change we continue to do the very best by our supporters.

It is always your choice. If you don’t think this is quite right for you, you can tell us to change your communication preferences and our use of your information. You can do this at any time by phoning +44 (0) 28 9064 7119 or emailing sales@palmeragencies.com

Legitimate Interest to send you direct mail

Unless you tell us not to, we will rely on our Legitimate Interest ground (explained above) for sending you direct mail. From time to time, we would like to post you exciting updates about our work, products, services and how you can support us, including fundraising activities and research. Unless you have requested that we do not send you some, or all of this, our direct mailings do include marketing and information campaigns.

We are always mindful of trying to only send you what you are interested in and only as often as is appropriate. If we do not appear to be sending communications that are of interest, we will review this and will endeavour to reduce and then stop these types of communications in a much shorter time than the above defined period of Legitimate Interest e.g. if you placed an order with us two years ago and do not seem to have been interested since then we are likely to reduce these communications, even though we have a legitimate interest to process for longer. The average length of time required for us to be able to properly assess and reflect on your pattern of response is about two years. But you’re in control so if you want to ensure that we do not send this type of communication anymore, you can update your preferences at any time by phoning +44 (0) 28 9064 7119 or emailing sales@palmeragencies.com

Legitimate Interest to process your information

We aim to be clear about what information we collect, to enable you to make meaningful choices about how it is used. When it is necessary we will contact you for administrative purposes, e.g. to contact you regarding a payment. We will also hold the minimum personal information required to support our ability to respect your preferences for communication with us.

To help you to understand when and why Palmer Agencies would use Legitimate Interest to process your personal information we provide the following examples:

• To send postal communications (invoices, statements, catalogues, etc…)

• To enhance, modify, personalise and improve our services and communications for the benefit of our business partners.

• To improve security of our websites and systems.

• To prevent fraud when transacting on our website.

• To process your payments.

• To fulfil online transactions; process and deliver your order(s). To take payment and arrange delivery, we need to collect personal information, including your payment details, your full name, delivery address and contact details.

• To analyse your personal information to ensure that our communications are relevant to you.

The above list of examples are on the basis that the processing will not be done if it harms your rights and interests as an individual, or if you tell us that you’d like us to stop. You can do this at any time by phoning +44 (0) 28 9064 7119 or emailing sales@palmeragencies.com

Data Analysis

In order to communicate with you more effectively, better understand your preferences and ability to support our work, we may analyse your data.

We like to find out about your personal motivation for contacting Palmer Agencies and your experiences as a customer or business partner. This helps us to give you the information about products and services most relevant to you. In some instances, we may carry out research and/or analysis of the personal information that you have provided to us and add publicly available information (such as public records or social media) to help us tailor our communications to you, this may include credit checks to allow you to continue having credit facilities with Palmer Agencies. We do this to create a fuller picture of our business partners, to improve our service and to manage our contact with you in an appropriate and cost-effective way. This information could include things like your interests, preferences and the level of any potential orders.

Data Sharing

To help us communicate the work we are doing and provide these services we may use trusted service providers including electronic data analysis, marketing agencies and direct mailing providers. Palmer Agencies do not share, sell or swap your information with other organisation for their own marketing outside of our group.

In some circumstances it is necessary for Palmer Agencies to give relevant staff at our service providers access to your personal information. This access is only granted to the extent necessary for them to perform their services for us. We do require all service providers to comply with strict rules to protect the information you have given us.

Changes to your data

From time to time we may contact you to ensure that the information you have provided us with remains accurate and up to date. In some circumstances we may use external data lists to avoid misdirecting our communications with you, this includes FPS and TPS. Should you wish to change your preferences you can do this phoning +44 (0) 28 9064 7119 or emailing sales@palmeragencies.com

Like all organisations, we comply with requests for the disclosure of personal information where this is required or permitted by law. This could include requests from law enforcement or tax agencies. In these circumstances, the request must be submitted in writing and in accordance with the relevant legal requirements.

If you believe your privacy rights have been violated, you may file a complaint with us or with the Information Commissioners office https://ico.org.uk/. Palmer Agencies Ltd is registered under reference Z7486474

Cookies and Web Privacy

We at Palmer Agencies guarantee our commitment to respecting and protecting your online privacy.

This includes your need and your right to know what we do with the personal information you share with us. It also guides our company’s policies regarding the management of this data, including how the information is collected, processed, and for what purposes.

“Palmer Agencies”: refers to the web pages. By accessing our website you are consenting to the way information is collected and used, as described within this Privacy Policy. In return, Palmer Agencies gives the commitment that we will use the personal data you provide only in ways that are compatible with our Privacy Policy.

The collection of information

Every time you log on to our website your IP (Internet Protocol) address registers on our servers. Your IP address reveals no information other than the number assigned to you. We do not use this technology to get any personal data against your knowledge or free will (i.e., automatically recording e-mail addresses of visitors). Nor do we use it for any purpose other than to help us monitor traffic on our website, or (in case of criminal activity or misuse of our information) to cooperate with law enforcement.

Cookies

We use a number of different cookies on our site. If you do not know what cookies are, or how to control or delete them, then we recommend you visit http://www.aboutcookies.org for detailed guidance.

The list below describes the cookies we use on this site and what we use them for. Currently we operate an ‘implied consent’ policy which means that we assume you are happy with this usage. If you are not happy, then you should either not use this site, or you should delete the cookies having visited the site, or you should browse the site using your browser’s anonymous usage setting (called “Incognito” in Chrome, “InPrivate” for Internet Explorer, “Private Browsing” in Firefox and Safari etc.)

• First Party Cookies

These are cookies that are set by this website directly.

Google Analytics: We use Google Analytics to collect information about visitor behaviour on our website. Google Analytics stores information about what pages you visit, how long you are on the site, how you got here and what you click on. This Analytics data is collected via a JavaScript tag in the pages of our site and is not tied to personally identifiable information. We therefore do not collect or store your personal information (e.g. your name or address) so this information cannot be used to identify who you are.

Find out more about Google’s position on privacy as regards its analytics service.

• Third Party Cookies

These are cookies set on your machine by external websites whose services are used on this site. Cookies of this type are the sharing buttons across the site allow visitors to share content onto social networks. Cookies are currently set by LinkedIn, Twitter, Facebook, Google+ and Pinterest. In order to implement these buttons, and connect them to the relevant social networks and external sites, there are scripts from domains outside of our website. You should be aware that these sites are likely to be collecting information about what you are doing all around the internet, including on this website.

You should check the respective policies of each of these sites to see how exactly they use your information and to find out how to opt out, or delete, such information.

Emails

Some emails that we send you have no tracking in at all e.g. service emails with invoices attached. Other emails we send we can track, at an individual level, whether the user has opened and clicked on the email. We do not use this information at a personal level, rather we use it to understand open and click rates on our emails to try and improve them. If you want to be sure that none of your email activity is tracked then you should opt out of our emails which you can do via the unsubscribe link at the bottom of every marketing email we send.

Web Security

No financial transactions are made online at Palmer Agencies using our site. No one can access your credit card details via the internet.

How our website works: When you have completed your order, your web browser will have created an order at Palmer Agencies the order is received in our system. We will then process the order and contact you about availability, delivery timescales, payment requests and back orders (if any).

Information

All information given on this site is to the best of our ability.

Whilst Palmer Agencies is happy to supply any assistance and guidance regarding our products to customers and members of the public, it must be appreciated that such guidance is based only on information supplied to Palmer Agencies and Palmer Agencies will NOT be liable for injury, loss or damage arising from such guidance supplied.

You may print any pieces of information or images on this site for your own information but you may NOT sell it, reproduce it on the internet, distribute it, alter it, or reprint it in any publication without permission from Palmer Agencies.

Please note that all material on this website is the copyright of Palmer Agencies or third parties. You may print any pieces of information or images on this site for your own information or personal use, private study or for teaching purposes in schools colleges or universities provided all material is marked “By kind permission of Palmer Agencies” and the material cannot be adapted, used for profit or used in any way that will bring the company into disrepute.

The name and logo of Palmer Agencies remain the property of Palmer Agencies Ltd of Unit 1 Beechill Business Park, 96 Beechill Road, Belfast, BT8 7QN, registered in Northern Ireland No. 7156, VAT reg. GB 517 0693 48

This information was last updated in March 2018. From time to time, we will make changes to the information on this page. The amended information will apply from the date it is posted on the site and will govern the way in which we collect and use personal information from then on.

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