London Stone's GDPR Privacy and Communications policy

Introduction

1. Welcome to our Privacy Policy. We want to be transparent in how we use your data so here is more information about how it is used, who it will be shared with and how you can easily request the information we hold about you.
2. Our commitment to data security and privacy means that we’ve been preparing for the introduction of the new EU law on data protection that comes into effect on 25 May 2018.
3. The General Data Protection Regulation (GDPR) is being billed as the most comprehensive data privacy law yet, and it requires businesses across the EU and globally to review and rethink how they handle and protect personal data.
4. By requesting a quotation, placing an order with London Stone, registering your details on our website or registering as a trade customer on the London Stone database you accept the terms contained in this Privacy Policy, which govern the processing of your personal data.
5. We, London Stone Paving Limited, The Berkshire Garden Centre, Sutton Lane, Langley, SL3 8AH,UK ("London Stone") recommend that you keep a copy of this Privacy Policy.

Data Protection

1. Data protection is of a particularly high priority for the management of London Stone. The use of the website pages of London Stone is possible without any indication of personal data; however, if a data subject wants to use request services via our website, processing of personal data could become necessary. If the processing of personal data is necessary and there is no statutory basis for such processing, we generally obtain consent from the data subject.
2. The processing of personal data, such as the name, address, e-mail address, or telephone number of a data subject shall always be in line with the General Data Protection Regulation (GDPR), and in accordance with the country-specific data protection regulations applicable to London Stone. By means of this data protection declaration, we would like to inform the general public of the nature, scope, and purpose of the personal data we collect, use and process. Furthermore, data subjects are informed, by means of this data protection declaration, of the rights to which they are entitled.
3. As the data controller, London Stone has implemented numerous technical and organisational measures to ensure the most complete protection of personal data processed through this website. However, Internet-based data transmissions may in principle have security gaps, so absolute protection may not be guaranteed. For this reason, every data subject is free to transfer personal data to us via alternative means, e.g. by email or by telephone.

Definitions

1. The data protection declaration of London Stone is based on the terms used by the European legislator for the adoption of the General Data Protection Regulation (GDPR). Our data protection declaration should be legible and understandable for the general public, as well as our customers and business partners. To ensure this, we would like to first explain the terminology used.
2. In this data protection declaration, we use, inter alia, the following terms:

   1. Personal data

      1. Personal data means any information relating to an identified or identifiable natural person (“data subject”). An identifiable natural person is one who can be identified, directly or indirectly, 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 natural person.

   2. Data subject

      1. Data subject is any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing.

   3. Processing

      1. Processing is any operation or set of operations which is performed on personal data or on sets of 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.

   4. Restriction of processing

      1. Restriction of processing is the marking of stored personal data with the aim of limiting their processing in the future.

   5. Profiling

      1. 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.

   6. Pseudonymisation

      1. Pseudonymisation is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.

   7. Controller or controller responsible for the processing

      1. Controller or controller responsible for the processing is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.

   8. Processor

      1. Processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

   9. Recipient

      1. Recipient is a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.

   10. Third party

       1. Third party is a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.

   11. Consent

       1. Consent of the data subject is any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

Name and Address of the controller

Data controller

1. The information for which London Stone is the data controller
   1. London Stone shall be data controller of the master data you enter in connection with your creation of a trade account or registration for marketing information, i.e. your name, your password and your email address, as well as registration of your IP address.
2. The information for which you are the data controller
   1. You shall be data controller of the content you choose to disclose on the Website and for the data disclosed on your profile on Social Networks, which is the consequence of the connection of your profile on the Website with your profile on the Social Network.

Data processor and transfer of personal data outside of the EU

1. London Stone uses external companies for data storage, maintaining the technical operation of the Website and general ICT systems. These companies are the data processor with regards to the personal data for which London Stone is the data controller. By accepting this personal data policy, you accept that London Stone also allows the data for which you are the data controller be processed by the same data processor.
2. The data processor shall solely act according to instructions from London Stone. By accepting these terms and conditions, you authorise London Stone to give such instructions to the data processor which are necessary for the processing of data in accordance with this personal data policy and for the purpose of use of the Website.
3. The data processor has made necessary technical and organisational safety measures against the information being accidentally or illegally destroyed, lost or deteriorated, and against the information coming to the knowledge of unauthorised persons, is misused or in other ways is processed in violation with the act on processing of personal data. On your request - and against remuneration of the data processor's current hourly rates at any time for such work - the data processor shall supply you with sufficient information to demonstrate that the above-mentioned technical and organisational safety measures have been made.
4. Some of these data processors and third party services are located outside of the European Union, such as in the US. You consent to us using data processors in unsecure third countries provided that there is a legal framework governing the transfer of your personal data, for example if the company is part of the EU-US Privacy Shield framework.

When do we collect your personal data

1. When you visit of our website, and use your account to buy products and services.
2. When you make an online purchase and check out as a guest (in which case we just collect transaction-based data).
3. When you create an account with us.
4. When you purchase a product or service in store or by phone but don’t have (or don’t use) an account.
5. When you engage with us on social media.
6. When you download or install one of our apps.
7. When you apply to the Landscape Specialist Scheme.
8. When you contact us by any means with queries, complaints etc.
9. When you ask one of our staff to email you information about a product or service.
10. When you enter prize draws or competitions.
11. When you book any kind of appointment with us or book to attend an event, for example a tour of our factory.
12. When you choose to complete any surveys we send you.
13. When you comment on or review our products and services.
14. Any individual may access personal data related to them, including opinions. So if your comment or review includes information about the Staff who provided that service, it may be passed on to them if requested.
15. When you fill in any forms. For example, if an accident happens in store, a staff member may collect your personal data.
16. When you’ve given a third party permission to share with us the information they hold about you.
17. When our Finance suppliers and partners – such as HSBC – share information with us about the product you have purchased.
18. We collect data from publicly-available sources (such as Land Registry) when you have given your consent to share information or where the information is made public as a matter of law.
19. When you use our showrooms and other premises which usually have CCTV systems operated for the security of both customers and staff. These systems may record your image during your visit.
20. When you call us or when you receive a call from us the content of the phone call is recorded. Recordings are paused whilst card details are given.

What sort of personal data do we collect

1. If you have a web account with us: your name, billing/delivery address, orders and receipts, email and telephone number. For your security, we’ll also keep an encrypted record of your login password.
2. Details of your interactions with us through contact centres, in store or online.
   1. · For example, we collect notes from our conversations with you, details of any complaints or comments you make, details of purchases you made, items viewed or added to your basket, gift list and wish list choices, products you show interest in, web pages you visit and how and when you contact us.
3. Details of your visits to our website, and which site you came from to ours.
   1. Information gathered by the use of cookies in your web browser (see section 15).
   2. We’ll only ask for and use your personal data collected for recommending items of interest and to tailor your shopping experience with us. Of course, it’s always your choice whether you share such details with us.
   3. Your comments and product reviews.
   4. Your image may be recorded on CCTV when you visit a showroom or other premises of London Stone.
   5. Your voice will be recorded when you call us or when you receive a call from us. Recordings are paused whilst card details are given.
   6. To deliver the best possible web experience, we collect technical information about your internet connection and browser as well as the country and telephone code where your computer is located, the web pages viewed during your visit, the advertisements you clicked on, and any search terms you entered.
   7. Your social media username, if you interact with us through those channels, to help us respond to your comments, questions or feedback.

How and why we use your personal data

1. To process any orders that you make by using our websites, on the phone or in store. If we don’t collect your personal data during checkout, we won’t be able to process your order and comply with our legal obligations.
   1. For example, your details may need to be passed to a third party to supply or deliver the product or service that you ordered, and we may keep your details for a reasonable period afterwards in order to fulfil any contractual obligations such as refunds, guarantees and so on.
2. To respond to your queries, refund requests and complaints. Handling the information you sent enables us to respond. We may also keep a record of these to inform any future communication with us and to demonstrate how we communicated with you throughout. We do this on the basis of our contractual obligations to you, our legal obligations and our legitimate interests in providing you with the best service and understanding how we can improve our service based on your experience.
3. To protect our business and your account from fraud and other illegal activities. This includes using your personal data to maintain, update and safeguard your account. We’ll also monitor your browsing activity with us to quickly identify and resolve any problems and protect the integrity of our website. We’ll do all of this as part of our legitimate interest.
   1. For example, by checking your password when you login and using automated monitoring of IP addresses to identify possible fraudulent log-ins from unexpected locations.
4. To protect our customers, premises, assets and staff from crime, we operate CCTV systems in our showrooms and other premises which record images for security. We do this on the basis of our legitimate business interests.
5. To train our staff, provide quality assurance and for dispute resolution we record phone calls to and from us. Recordings are paused whilst card details are given.
6. To process payments and to prevent fraudulent transactions. We do this on the basis of our legitimate business interests. This also helps to protect our customers from fraud.
7. If we discover any criminal activity or alleged criminal activity through our use of CCTV, fraud monitoring and suspicious transaction monitoring, we will process this data for the purposes of preventing or detecting unlawful acts. We aim is to protect the individuals we interact with from criminal activities.
8. With your consent, we may use your personal data, preferences and details of your transactions to keep you informed by email, web, text, and telephone about relevant products and services including tailored special offers, discounts, promotions, events, competitions and so on.
   1. Of course, you are free to opt out of hearing from us by any of these channels at any time (See section 13).
9. To send you relevant, personalised communications by email in relation to updates, offers, services and products. We’ll do this on the basis of our legitimate business interest.
   1. You are free to opt out of hearing from us by email at any time (See section 13).
10. To send you communications required by law or which are necessary to inform you about our changes to the services we provide you. For example, updates to this Privacy Notice, product recall notices, and legally required information relating to your orders. These service messages will not include any promotional content and do not require prior consent when sent by email or text message. If we do not use your personal data for these purposes, we would be unable to comply with our legal obligations.
11. To display the most interesting content to you on our website, we’ll use data we hold about your favourite products and so on. We do so on the basis of your consent for our website to place cookies or similar technology on your device.
    1. For example, we might display a list of items you’ve recently looked at, or offer you recommendations based on your purchase history and any other data you’ve shared with us.
12. To administer any of our prize draws or competitions which you enter, based on your consent given at the time of entering.
13. To develop, test and improve the systems, services and products we provide to you. We’ll do this on the basis of our legitimate business interests.
    1. For example, we’ll record your browser’s Session ID to help us understand more when you leave us online feedback about any problems you’re having
14. To comply with our contractual or legal obligations to share data with law enforcement.
    1. For example, when a court order is submitted to share data with law enforcement agencies or a court of law
15. To send you survey and feedback requests to help improve our services. These messages will not include any promotional content and do not require prior consent when sent by email or text message. We have a legitimate interest to do so as this helps make our products or services more relevant to you.
    1. Of course, you are free to opt out of receiving these requests from us at any time by updating your preferences in your online account.
    2. To process your booking/appointment requests (for example a templating site visit). Sometimes, we’ll need to share your details with a third party who is providing a service (such as delivery couriers). We do so to maintain our appointment with you. Without sharing your personal data, we’d be unable to fulfil your request.

How we protect your Personal Data

1. We know how much data security matters to all our customers. With this in mind we will treat your data with the utmost care and take all appropriate steps to protect it.
2. We secure access to all transactional areas of our websites and apps using ‘https’ technology.
3. Access to your personal data is password-protected, and sensitive data such as payment card information) is secured and tokenised to ensure it is protected.
4. We regularly monitor our system for possible vulnerabilities and attacks, and we carry out penetration testing to identify ways to further strengthen security.

How long will we keep your personal data

1. The criteria used to determine the period of storage of personal data is the respective statutory retention period. After expiration of that period, the corresponding data is routinely deleted or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning, as long as it is no longer necessary for the fulfilment of the contract or the initiation of a contract.

Who do we share your personal data with

1. We sometimes share your personal data with trusted third parties.
2. For example, delivery couriers, IT support companies, for fraud management, marketing companies who manage our electronic marketing communications with you and so on.
3. Here’s the policy we apply to those organisations to keep your data safe and protect your privacy:
   1. We provide only the information they need to perform their specific services.
   2. They may only use your data for the exact purposes we specify in our contract with them.
   3. We work closely with them to ensure that your privacy is respected and protected at all times.
   4. If we stop using their services, any of your data held by them will either be deleted or rendered anonymous.
4. Where the processing of personal data is based on Article 6(1) lit. f GDPR our legitimate interest is to carry out our business in favour of the well-being of all our employees and the shareholders.

How can you stop the use of your personal data for direct marketing

1. There are several ways you can stop direct marketing communications from us:
   1. Click the ‘unsubscribe’ link in any email communication that we send you. We will then stop any further emails from that particular division.
   2. Contact us via the details found in section 4.
2. Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated.

Links to websites

1. Our Website contains links to other websites. Note that by clicking such links you will be transferred to other websites for which London Stone is not the data controller. We thus recommend that you always read the personal data policy of these websites, as their procedure for collecting and processing personal data may be different from ours.

Cookies

1. The Internet pages of London Stone use cookies. Cookies are text files that are stored in a computer system via an Internet browser.
2. Many Internet sites and servers use cookies. Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier of the cookie. It consists of a character string through which Internet pages and servers can be assigned to the specific Internet browser in which the cookie was stored. This allows visited Internet sites and servers to differentiate the individual browser of the data subject from other Internet browsers that contain other cookies. A specific Internet browser can be recognized and identified using the unique cookie ID.
3. Through the use of cookies, London Stone can provide the users of this website with more user-friendly services that would not be possible without the cookie setting.
4. By means of a cookie, the information and offers on our website can be optimized with the user in mind. Cookies allow us, as previously mentioned, to recognise our website users. The purpose of this recognition is to make it easier for users to utilise our website. The website user that uses cookies, e.g. does not have to enter access data each time the website is accessed, because this is taken over by the website, and the cookie is thus stored on the user's computer system. Another example is the cookie of a shopping cart in an online shop. The online store remembers the articles that a customer has placed in the virtual shopping cart via a cookie.
5. The data subject may, at any time, prevent the setting of cookies through our website by means of a corresponding setting of the Internet browser used, and may thus permanently deny the setting of cookies. Furthermore, already set cookies may be deleted at any time via an Internet browser or other software programs. This is possible in all popular Internet browsers. If the data subject deactivates the setting of cookies in the Internet browser used, not all functions of our website may be entirely usable.

Collection of general data and information

1. The website of London Stone collects a series of general data and information when a data subject or automated system calls up the website. This general data and information are stored in the server log files. Collected may be (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our website (so-called referrers), (4) the sub-websites, (5) the date and time of access to the Internet site, (6) an Internet protocol address (IP address), (7) the Internet service provider of the accessing system, and (8) any other similar data and information that may be used in the event of attacks on our information technology systems.
2. When using these general data and information, London Stone does not draw any conclusions about the data subject. Rather, this information is needed to (1) deliver the content of our website correctly, (2) optimise the content of our website as well as its advertisement, (3) ensure the long-term viability of our information technology systems and website technology, and (4) provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack. Therefore, London Stone analyses anonymously collected data and information statistically, with the aim of increasing the data protection and data security of our company, and to ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from all personal data provided by a data subject.

Subscription to Landscape Specialist Scheme

1. On the website of London Stone, relevant trades are given the opportunity to sign up for our Landscape Specialist Scheme. The input mask used for this purpose determines what personal data are transmitted. The information provided is used to make your own company profile page which is visible to anyone who visits the website. Your profile page is searchable on the website via postcode lookup. The user inserts their own postcode and the 10 closest trades to that postcode will appear in a list for selection for viewing. By signing up for this service you agree to the possibility of being contacted by the user for the purpose of providing a design or installation service.
2. The following T&Cs apply to Landscape Specialist Scheme sign up:
   1. You must have the permission of the business owner to apply for London Stone Landscape Specialist Scheme membership.
   2. All information given must be correct to the best of your knowledge.
   3. Any photographs submitted during the London Stone Landscape Specialist Scheme application process must show your own work.
   4. You must own the copyright to any photographs that you submit during the London Stone Landscape Specialist Scheme application process.
   5. London Stone may use any images that you submit during the London Stone Landscape Specialist Scheme application process (provided that they show London Stone products) for marketing purposes including but not limited to using the images on our website, social media channels, online advertisements, printed advertisements.
   6. Your London Stone Connect profile and all of its content remains the property of London Stone and may be used, either in part or in its entirety, by London Stone for marketing purposes to displaying the Connect profile on our website, social media channels, online advertisements, printed advertisements.
   7. You agree to notify London Stone of any changes to the details you have given as soon as possible or in any event within 3 months of the change(s) taking place so that we may update your profile.
   8. We may also use the email address provided to send out relevant marketing information in relation to London Stone. You can opt out of this at any time by following the link within the email. We will not pass your details onto 3^rd party marketing companies.

Subscription to our newsletters

1. On the website of London Stone, users are given the opportunity to subscribe to our company's newsletter. The input mask used for this purpose determines what personal data are transmitted, as well as when the newsletter is ordered from the controller.
2. London Stone informs its customers and business partners regularly by means of a newsletter about company offers. The company's newsletter may only be received by the data subject if (1) the data subject has a valid e-mail address and (2) the data subject registers for the newsletter shipping. A confirmation e-mail will be sent to the e-mail address registered by a data subject for the first time for newsletter shipping, for legal reasons, in the double opt-in procedure. This confirmation e-mail is used to prove whether the owner of the e-mail address as the data subject is authorised to receive the newsletter.
3. During the registration for the newsletter, we also store the IP address of the computer system assigned by the Internet service provider (ISP) and used by the data subject at the time of the registration, as well as the date and time of the registration. The collection of this data is necessary in order to understand the (possible) misuse of the e-mail address of a data subject at a later date, and it therefore serves the aim of the legal protection of the controller.
4. The personal data collected as part of a registration for the newsletter will only be used to send our newsletter. In addition, subscribers to the newsletter may be informed by e-mail, as long as this is necessary for the operation of the newsletter service or a registration in question, as this could be the case in the event of modifications to the newsletter offer, or in the event of a change in technical circumstances. There will be no transfer of personal data collected by the newsletter service to third parties. The subscription to our newsletter may be terminated by the data subject at any time. The consent to the storage of personal data, which the data subject has given for shipping the newsletter, may be revoked at any time. For the purpose of revocation of consent, a corresponding link is found in each newsletter. It is also possible to unsubscribe from the newsletter at any time directly on the website of the controller, or to communicate this to the controller in a different way.

Marketing emails – Tracking

1. The newsletter of London Stone contains so-called tracking pixels. A tracking pixel is a miniature graphic embedded in such e-mails, which are sent in HTML format to enable log file recording and analysis. This allows a statistical analysis of the success or failure of online marketing campaigns. Based on the embedded tracking pixel, London Stone may see if and when an e-mail was opened by a data subject, and which links in the e-mail were called up by data subjects.
2. Such personal data collected in the tracking pixels contained in the newsletters are stored and analysed by the controller in order to optimise the shipping of the newsletter, as well as to adapt the content of future newsletters even better to the interests of the data subject. These personal data will not be passed on to third parties. Data subjects are at any time entitled to revoke the respective separate declaration of consent issued by means of the double-opt-in procedure. After a revocation, these personal data will be deleted by the controller. London Stone automatically regards a withdrawal from the receipt of the newsletter as a revocation.

Contact possibility via the website

1. The website of London Stone contains information that enables a quick electronic contact to our company, as well as direct communication with us, which also includes a general address of the so-called electronic mail (e-mail address). If a data subject contacts the controller by e-mail or via a contact form, the personal data transmitted by the data subject are automatically stored. Such personal data transmitted on a voluntary basis by a data subject to the data controller are stored for the purpose of processing or contacting the data subject. There is no transfer of this personal data to third parties.

Review Requests

1. We will provide your Name, Email Address and Order Number to Trustpilot who acts as a data processor for London Stone in regards to customer reviews of the company. This data is provided so that you may be contacted by email to leave the company a review which relates to your order with us.
2. https://uk.legal.trustpilot.com/end-user-privacy-terms

Subscription to comments in the blog on the website

1. The comments made in the blog of London Stone may be subscribed to by third parties. In particular, there is the possibility that a commenter subscribes to the comments following his comments on a particular blog post.
2. If a data subject decides to subscribe to the option, the controller will send an automatic confirmation e-mail to check the double opt-in procedure as to whether the owner of the specified e-mail address decided in favour of this option. The option to subscribe to comments may be terminated at any time.

Routine erasure and blocking of personal data

1. The data controller shall process and store the personal data of the data subject only for the period necessary to achieve the purpose of storage, or as far as this is granted by the European legislator or other legislators in laws or regulations to which the controller is subject to.
2. If the storage purpose is not applicable, or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data are routinely blocked or erased in accordance with legal requirements.

Rights of the data subject

1. Right of confirmation

   1. Each data subject shall have the right granted by the European legislator to obtain from the controller the confirmation as to whether or not personal data concerning him or her are being processed. If a data subject wishes to avail himself of this right of confirmation, he or she may, at any time, contact our Data Protection Officer or another employee of the controller.

2. Right of access

   1. Each data subject shall have the right granted by the European legislator to obtain from the controller free information about his or her personal data stored at any time and a copy of this information. Furthermore, the European directives and regulations grant the data subject access to the following information:
      1. the purposes of the processing;
      2. the categories of personal data concerned;
      3. the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
      4. where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
      5. the existence of the right to request from the controller rectification or erasure of personal data, or restriction of processing of personal data concerning the data subject, or to object to such processing;
      6. the existence of the right to lodge a complaint with a supervisory authority;
      7. where the personal data are not collected from the data subject, any available information as to their source;
      8. the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject.
   2. Furthermore, the data subject shall have a right to obtain information as to whether personal data are transferred to a third country or to an international organisation. Where this is the case, the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer.
   3. If a data subject wishes to avail himself of this right of access, he or she may at any time contact our nominated point of contact.

3. Right to rectification

   1. Each data subject shall have the right granted by the European legislator to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
   2. If a data subject wishes to exercise this right to rectification, he or she may, at any time, contact our Data Protection Officer or another employee of the controller.

4. Right to erasure (Right to be forgotten)

   1. Each data subject shall have the right granted by the European legislator to obtain from the controller the erasure of personal data concerning him or her without undue delay, and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies, as long as the processing is not necessary:
   2. The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.
   3. The data subject withdraws consent to which the processing is based according to point (a) of Article 6(1) of the GDPR, or point (a) of Article 9(2) of the GDPR, and where there is no other legal ground for the processing.
   4. The data subject objects to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) of the GDPR.
   5. The personal data have been unlawfully processed.
   6. The personal data must be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.
   7. The personal data have been collected in relation to the offer of information society services referred to in Article 8(1) of the GDPR.
   8. If one of the aforementioned reasons applies, and a data subject wishes to request the erasure of personal data stored by London Stone, he or she may at any time contact our Data Protection Officer or another employee of the controller. The Data Protection Officer of London Stone or another employee shall promptly ensure that the erasure request is complied with immediately.
   9. Where the controller has made personal data public and is obliged pursuant to Article 17(1) to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform other controllers processing the personal data that the data subject has requested erasure by such controllers of any links to, or copy or replication of, those personal data, as far as processing is not required. The Data Protection Officer of London Stone or another employee will arrange the necessary measures in individual cases.

5. Right of restriction of processing

   1. Each data subject shall have the right granted by the European legislator to obtain from the controller restriction of processing where one of the following applies:
   2. The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.
   3. The processing is unlawful and the data subject opposes the erasure of the personal data and requests instead the restriction of their use instead.
   4. The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims.
   5. The data subject has objected to processing pursuant to Article 21(1) of the GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject.
   6. If one of the aforementioned conditions is met, and a data subject wishes to request the restriction of the processing of personal data stored by London Stone, he or she may at any time contact our Data Protection Officer or another employee of the controller. The Data Protection Officer of London Stone or another employee will arrange the restriction of the processing.

6. Right to data portability

   1. Each data subject shall have the right granted by the European legislator, to receive the personal data concerning him or her, which was provided to a controller, in a structured, commonly used and machine-readable format. He or she shall have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, as long as the processing is based on consent pursuant to point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR, or on a contract pursuant to point (b) of Article 6(1) of the GDPR, and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
   2. Furthermore, in exercising his or her right to data portability pursuant to Article 20(1) of the GDPR, the data subject shall have the right to have personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.

   In order to assert the right to data portability, the data subject may at any time contact the Data Protection Officer designated by London Stone or another employee.

7. Right to object

   1. Each data subject shall have the right granted by the European legislator to object, on grounds relating to his or her particular situation, at any time, to processing of personal data concerning him or her, which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to profiling based on these provisions.
   2. London Stone shall no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defence of legal claims.
   3. If London Stone processes personal data for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing. This applies to profiling to the extent that it is related to such direct marketing. If the data subject objects to London Stone to the processing for direct marketing purposes, London Stone will no longer process the personal data for these purposes.
   4. In addition, the data subject has the right, on grounds relating to his or her particular situation, to object to processing of personal data concerning him or her by London Stone for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
   5. In order to exercise the right to object, the data subject may directly contact the Data Protection Officer of London Stone or another employee. In addition, the data subject is free in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to use his or her right to object by automated means using technical specifications.

8. Automated individual decision-making, including profiling

   1. Each data subject shall have the right granted by the European legislator not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her, or similarly significantly affects him or her, as long as the decision (1) is not is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) is not authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject's rights and freedoms and legitimate interests, or (3) is not based on the data subject's explicit consent.
   2. If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) it is based on the data subject's explicit consent, London Stone shall implement suitable measures to safeguard the data subject's rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and contest the decision.
   3. If the data subject wishes to exercise the rights concerning automated individual decision-making, he or she may at any time directly contact our Data Protection Officer of London Stone or another employee of the controller.

9. Right to withdraw data protection consent

   1. Each data subject shall have the right granted by the European legislator to withdraw his or her consent to processing of his or her personal data at any time.
   2. If the data subject wishes to exercise the right to withdraw the consent, he or she may at any time directly contact our Data Protection Officer of London Stone or another employee of the controller.

Data protection for employment applications and the employment application procedures

1. The data controller shall collect and process the personal data of applicants for the purpose of the processing of the application procedure. The processing may also be carried out electronically. This is the case, in particular, if an applicant submits corresponding application documents by e-mail or by means of a web form on the website to the controller. If the data controller concludes an employment contract with an applicant, the submitted data will be stored for the purpose of processing the employment relationship in compliance with legal requirements. If no employment contract is concluded with the applicant by the controller, the application documents shall be automatically erased two months after notification of the refusal decision, provided that no other legitimate interests of the controller are opposed to the erasure. Other legitimate interest in this relation is, e.g. a burden of proof in a procedure under the General Equal Treatment Act (AGG).

Data protection provisions about the application and use of Facebook

1. On this website, the controller has integrated components of the company Facebook. Facebook is a social network.
2. A social network is a place for social meetings on the Internet, an online community, which usually allows users to communicate with each other and interact in a virtual space. A social network may serve as a platform for the exchange of opinions and experiences, or enable the Internet community to provide personal or business-related information. Facebook allows social network users to include the creation of private profiles, upload photos, and network through friend requests.
3. The operating company of Facebook is Facebook, Inc., 1 Hacker Way, Menlo Park, CA 94025, United States. If a person lives outside of the United States or Canada, the controller is the Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.
4. With each call-up to one of the individual pages of this Internet website, which is operated by the controller and into which a Facebook component (Facebook plug-ins) was integrated, the web browser on the information technology system of the data subject is automatically prompted to download display of the corresponding Facebook component from Facebook through the Facebook component. An overview of all the Facebook Plug-ins may be accessed under https://developers.facebook.com/docs/plugins/. During the course of this technical procedure, Facebook is made aware of what specific sub-site of our website was visited by the data subject.
5. If the data subject is logged in at the same time on Facebook, Facebook detects with every call-up to our website by the data subject—and for the entire duration of their stay on our Internet site—which specific sub-site of our Internet page was visited by the data subject. This information is collected through the Facebook component and associated with the respective Facebook account of the data subject. If the data subject clicks on one of the Facebook buttons integrated into our website, e.g. the "Like" button, or if the data subject submits a comment, then Facebook matches this information with the personal Facebook user account of the data subject and stores the personal data.
6. Facebook always receives, through the Facebook component, information about a visit to our website by the data subject, whenever the data subject is logged in at the same time on Facebook during the time of the call-up to our website. This occurs regardless of whether the data subject clicks on the Facebook component or not. If such a transmission of information to Facebook is not desirable for the data subject, then he or she may prevent this by logging off from their Facebook account before a call-up to our website is made.
7. The data protection guideline published by Facebook, which is available at https://facebook.com/about/privacy/, provides information about the collection, processing and use of personal data by Facebook. In addition, it is explained there what setting options Facebook offers to protect the privacy of the data subject. In addition, different configuration options are made available to allow the elimination of data transmission to Facebook, e.g. the Facebook blocker of the provider Webgraph, which may be obtained under http://webgraph.com/resources/facebookblocker/. These applications may be used by the data subject to eliminate a data transmission to Facebook.

Data protection provisions about the application and use of Facebook Pixel

1. We use the ‘visitor action pixels’ from Facebook Inc (1 Hacker Way, Menlo Park, CA 94025, United States. If a person lives outside of the United States or Canada, the controller is the Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.) This allows user behaviour to be tracked after they have been redirected to our website by clicking a Facebook ad. This enables us to measure the effectiveness of our Facebook ads and to improve them.
2. The following data is being recorded:
   1. Http Headers – Anything present in HTTP headers. HTTP Headers are a standard web protocol sent between any browser request and any server on the internet. HTTP Headers include IP addresses, information about the web browser, page location, document, referrer and person using the website.
   2. Pixel-specific Data – Includes Pixel ID and the Facebook Cookie.
   3. Button Click Data – Includes any buttons clicked by site visitors, the labels of those buttons and any pages visited as a result of the button clicks.
   4. Optional Values – Developers and marketers can optionally choose to send additional information about the visit through conversion tracking. Example custom data events are conversion value, page type, and more.
   5. Form Field Names – Includes website field names like ‘email’, ‘address’, ‘quantity’ for when you purchase a product or service.
3. The data protection guideline published by Facebook, which is available at https://facebook.com/about/privacy/, provides information about the collection, processing and use of personal data by Facebook. In addition, it is explained there what setting options Facebook offers to protect the privacy of the data subject. In addition, different configuration options are made available to allow the elimination of data transmission to Facebook, e.g. the Facebook blocker of the provider Webgraph, which may be obtained under http://webgraph.com/resources/facebookblocker/. These applications may be used by the data subject to eliminate a data transmission to Facebook.

Data protection provisions about the application and use of Google Analytics (with anonymization function)

1. On this website, the controller has integrated the component of Google Analytics (with the anonymizer function). Google Analytics is a web analytics service. Web analytics is the collection, gathering, and analysis of data about the behaviour of visitors to websites. A web analysis service collects, inter alia, data about the website from which a person has come (the so-called referrer), which sub-pages were visited, or how often and for what duration a sub-page was viewed. Web analytics are mainly used for the optimisation of a website and in order to carry out a cost-benefit analysis of Internet advertising.
2. The operator of the Google Analytics component is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, United States.
3. For the web analytics through Google Analytics the controller uses the application "_gat. _anonymizeIp". By means of this application the IP address of the Internet connection of the data subject is abridged by Google and anonymised when accessing our websites from a Member State of the European Union or another Contracting State to the Agreement on the European Economic Area.
4. The purpose of the Google Analytics component is to analyse the traffic on our website. Google uses the collected data and information, inter alia, to evaluate the use of our website and to provide online reports, which show the activities on our websites, and to provide other services concerning the use of our Internet site for us.
5. Google Analytics places a cookie on the information technology system of the data subject. The definition of cookies is explained above. With the setting of the cookie, Google is enabled to analyse the use of our website. With each call-up to one of the individual pages of this Internet site, which is operated by the controller and into which a Google Analytics component was integrated, the Internet browser on the information technology system of the data subject will automatically submit data through the Google Analytics component for the purpose of online advertising and the settlement of commissions to Google. During the course of this technical procedure, the company Google gains knowledge of personal information, such as the IP address of the data subject, which serves Google, inter alia, to understand the origin of visitors and clicks, and subsequently create commission settlements.
6. The cookie is used to store personal information, such as the access time, the location from which the access was made, and the frequency of visits of our website by the data subject. With each visit to our Internet site, such personal data, including the IP address of the Internet access used by the data subject, will be transmitted to Google in the United States of America. These personal data are stored by Google in the United States of America. Google may pass these personal data collected through the technical procedure to third parties.
7. The data subject may, as stated above, prevent the setting of cookies through our website at any time by means of a corresponding adjustment of the web browser used and thus permanently deny the setting of cookies. Such an adjustment to the Internet browser used would also prevent Google Analytics from setting a cookie on the information technology system of the data subject. In addition, cookies already in use by Google Analytics may be deleted at any time via a web browser or other software programs.
8. In addition, the data subject has the possibility of objecting to a collection of data that are generated by Google Analytics, which is related to the use of this website, as well as the processing of this data by Google and the chance to preclude any such. For this purpose, the data subject must download a browser add-on under the link https://tools.google.com/dlpage/gaoptout and install it. This browser add-on tells Google Analytics through a JavaScript, that any data and information about the visits of Internet pages may not be transmitted to Google Analytics. The installation of the browser add-ons is considered an objection by Google. If the information technology system of the data subject is later deleted, formatted, or newly installed, then the data subject must reinstall the browser add-ons to disable Google Analytics. If the browser add-on was uninstalled by the data subject or any other person who is attributable to their sphere of competence, or is disabled, it is possible to execute the reinstallation or reactivation of the browser add-ons.
9. Further information and the applicable data protection provisions of Google may be retrieved under https://www.google.com/intl/en/policies/privacy/ and under http://www.google.com/analytics/terms/us.html. Google Analytics is further explained under the following Link https://www.google.com/analytics/.

Data protection provisions about the application and use of Google+

1. On this website, the controller has integrated components of Google+. Google+ is a social network.
2. A social network is a place for social meetings on the Internet, an online community, which usually allows users to communicate with each other and interact in a virtual space. A social network may serve as a platform for the exchange of opinions and experiences, or enable the Internet community to provide personal or business-related information. Google+ allows social network users to include the creation of private profiles, upload photos, and network through friend requests.
3. The operator of the Google+ is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, United States.
4. With each call-up to one of the individual pages of this Internet site, which is operated by the controller and on which a Google+ component (Google+ button) was integrated, the Internet browser on the information technology system of the data subject is automatically prompted to the download of a display of the corresponding Google+ component of Google+. During the course of this technical procedure, Google+ becomes aware of what specific sub-page of our website was visited by the data subject.
5. If the data subject is logged in at the same time on Google+, Google+ detects with every call-up to our website by the data subject—and for the entire duration of their stay on our Internet site—which specific sub-page of our Internet page was visited by the data subject. This information is collected through the Google+ component and is associated with the respective Google+ account of the data subject. If the data subject clicks on one of the Google+ buttons integrated on our website, then Google+ matches this information with the personal Google+ user account of the data subject and stores the personal data.
6. Google+ receives information via the Google+ component that the data subject has visited our website provided that the data subject is logged in at Google+ at the time of the call to our website. This occurs regardless of whether the person clicks on the Google+ button or not. If such a transmission of information to Google+ is not desirable for the data subject, then he or she can prevent this by logging off from their Google+ account before a call-up to our website is made.
7. Further information and the applicable data protection provisions of Google+ may be retrieved under https://www.google.com/+/policy/content.html

Data protection provisions about the application and use of Pinterest

1. On this website, the controller has integrated components of the service Pinterest. Pinterest is a service that may be qualified as an audio-visual platform, which allows users to share photos, as well as disseminate such data in other social networks.
2. The operating company of the services offered by Pinterest is Pinterest Inc. at 651 Brannan Street, San Francisco, CA 94103, USA.
3. With each call-up to one of the individual pages of this Internet site, which is operated by the controller and on which a Pinterest component (Pinterest button) was integrated, the Internet browser on the information technology system of the data subject is automatically prompted to the download of a display of the corresponding Pinterest component of Pinterest. During the course of this technical procedure, Pinterest becomes aware of what specific sub-page of our website was visited by the data subject.
4. If the data subject is logged in at the same time on Pinterest, Pinterest detects with every call-up to our website by the data subject—and for the entire duration of their stay on our Internet site—which specific sub-page of our Internet page was visited by the data subject. This information is collected through the Pinterest component and is associated with the respective Pinterest account of the data subject. If the data subject clicks on one of the Pinterest buttons integrated on our website, then Pinterest matches this information with the personal Pinterest user account of the data subject and stores the personal data.
5. Pinterest receives information via the Pinterest component that the data subject has visited our website provided that the data subject is logged in at Pinterest at the time of the call to our website. This occurs regardless of whether the person clicks on the Pinterest button or not. If such a transmission of information to Pinterest is not desirable for the data subject, then he or she can prevent this by logging off from their Pinterest account before a call-up to our website is made.
6. Further information and the applicable data protection provisions of Pinterest may be retrieved under https://policy.pinterest.com/en-gb/privacy-policy

Data protection provisions about the application and use of Twitter

1. On this website, the controller has integrated components of Twitter. Twitter is a multilingual, publicly-accessible microblogging service on which users may publish and spread so-called ‘tweets,’ e.g. short messages, which are limited to 280 characters. These short messages are available for everyone, including those who are not logged on to Twitter. The tweets are also displayed to so-called followers of the respective user. Followers are other Twitter users who follow a user's tweets. Furthermore, Twitter allows you to address a wide audience via hashtags, links or retweets.
2. The operating company of Twitter is Twitter, Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, UNITED STATES.
3. With each call-up to one of the individual pages of this Internet site, which is operated by the controller and on which a Twitter component (Twitter button) was integrated, the Internet browser on the information technology system of the data subject is automatically prompted to download a display of the corresponding Twitter component of Twitter. Further information about the Twitter buttons is available under https://about.twitter.com/de/resources/buttons. During the course of this technical procedure, Twitter gains knowledge of what specific sub-page of our website was visited by the data subject. The purpose of the integration of the Twitter component is a retransmission of the contents of this website to allow our users to introduce this web page to the digital world and increase our visitor numbers.
4. If the data subject is logged in at the same time on Twitter, Twitter detects with every call-up to our website by the data subject and for the entire duration of their stay on our Internet site which specific sub-page of our Internet page was visited by the data subject. This information is collected through the Twitter component and associated with the respective Twitter account of the data subject. If the data subject clicks on one of the Twitter buttons integrated on our website, then Twitter assigns this information to the personal Twitter user account of the data subject and stores the personal data.
5. Twitter receives information via the Twitter component that the data subject has visited our website, provided that the data subject is logged in on Twitter at the time of the call-up to our website. This occurs regardless of whether the person clicks on the Twitter component or not. If such a transmission of information to Twitter is not desirable for the data subject, then he or she may prevent this by logging off from their Twitter account before a call-up to our website is made.
6. The applicable data protection provisions of Twitter may be accessed under https://twitter.com/privacy?lang=en.

Data protection provisions about the application and use of Houzz

1. On this website, the controller has integrated components of the company Houzz. Houzz is a social network.
2. The Houzz Platform is an information and social network dedicated to homebuilding, renovation, and design. Houzz brings together professionals, service providers, products, homeowners, renters and design enthusiasts. Through the Houzz Platform, people can obtain and exchange, ideas, information, products, and services related to home remodelling and design.
3. The operating company of Houzz is a Delaware corporation, and Houzz Shop LLC, a Delaware limited liability company, which are headquartered in Palo Alto, California in the United States.
4. The data protection guideline published by Houzz, which is available at https://www.houzz.co.uk/privacyPolicy, provides information about the collection, processing and use of personal data by Houzz.

Data protection provisions about the application and use of MailChimp

1. For marketing communication, the controller has integrated/uses components of the company MailChimp. MailChimp is a marketing automation platform.
2. MailChimp is the world’s largest marketing automation platform. It’s like a second brain that helps millions of customers—from small e-commerce shops to big online retailers—find their audience, engage their customers, and build their brand.
3. The operating company of MailChimp is The Rocket Science Group, LLC, 675 Ponce de Leon Ave NE
   Suite 5000, Atlanta, GA 30308 USA.
4. The data protection guideline published by MailChimp, which is available at https://mailchimp.com/legal/privacy/, provides information about the collection, processing and use of personal data by MailChimp.

Existence of automated decision-making

1. We do not use automatic decision-making or profiling unless necessary for deciding on the correct marketing communications to send to specified contacts.

Security measures

1. London Stone will use commercially reasonable efforts to see that the recorded data, including the personal information, under its control is handled using appropriate security measures. London Stone regularly audits its system for possible vulnerabilities and attacks. However, since the internet is not a 100% secure environment, London Stone cannot ensure or warrant the security of information you transmit to London Stone. Emails sent via the Website are not encrypted, and London Stone therefore advises you not to communicate any confidential information through these means.

Changes in the privacy policy

1. London Stone may at any time and without notice make changes to its privacy policy with future effect. We will make an effort to provide reasonable advance notice of any such changes. London Stone shall inform the users of the Website of such changes when the users log on to the Website. You agree that the continued use of the Website after any posted modified version of the Privacy Policy is your acceptance of the modified Privacy Policy.