The Box Group

Equality Statement

Diversity fuels the Box group spirit. Our commitment to inclusion across race, gender, age, religion, identity, and experience drives us forward every day.

General Privacy Notice

The Purpose of this privacy statement is to explain how Floorbox Ltd trading as The Box Group referred to as TBG hereafter, processes personal data to fulfil its data protection responsibilities. Specific privacy notices for clients and third parties will be provided when necessary.

The Role of TBG in data protection terms is that of a data controller where it determines the purpose and use of personal data collected. Once received it becomes the responsibility of the TBG privacy manager (PM) contactable using info@thebox-group.co.uk. The PM ensures that all processing accords with the latest UK data protection legislation.

The sort of personal data collected by TBG will be basic contact details sufficient to be able to respond to general enquiries and for sales purposes. 

TBG’s duty of confidentiality means that TBG staff will treat your personal data with due respect and in confidence. It is only disclosed to those that need to know it. We expect the same duty of confidentiality from all third parties with whom TBG shares personal data. Data processing agreements are in place when required.

TBG processes personal data against a lawful basis and such instances are described below:

• We will pursue our legitimate interests to respond to your general enquiries and stay in touch with you for marketing purposes
• To comply with our legal obligations
• When it is necessary for the performance of a contract and its prior preparation, typically when preparing for a sale and the subsequent delivery
• When processing for a pre-defined purpose for which your consent will be sought prior to the processing commencing – please note that consent can be withdrawn at any time by contacting the PM

In all cases the processing of personal data by TBG shall be done in accordance with the principles of data protection.

TBG will share personal data, on a ‘need to know’ basis with some or all of the following:

• The Inland Revenue (HMRC) for invoice purposes
• A virtual assistant who is subject to a data processing agreement
• An IT support company that is subject to a data processing agreement
• Accountants appointed by TBG for payment handling and related record keeping
• Third-party suppliers when needed to deliver products directly to our customers
• Unspecified recipients but only when compelled to do so for legal reasons

TBG will process your personal data in the UK and the EU and all business data, including email, are backed up using a replicated systems based in the UK and the EU. TBG uses appropriate technical and organisational measures to safeguard all personal data.

TBG follows a retention schedule to determine the length of time it holds different types of personal data. The retention schedule is shown below:

• Routine correspondence for casual and contract related business in hard copy or in emails will be stored for 2 years
• Contact data is stored indefinitely unless a valid request to erasure is received from the interested data subject
• For former customers, we will retain your details for 7 years after the conclusion of our contractual obligations to you or our last contact with you, whichever is the later
• Invoice related information will be retained for 6 years after the tax year in which they were created
• By exception, documentation that includes personal data may be retained by TBG beyond the schedule, but only for a specific purpose and only when TBG believes it has a legitimate interest or a legal obligation to do so

At the end of the retention schedule TBG will either return, destroy or delete your personal data and any associated emails or relevant documentation. If it is technically impractical to delete electronic copies of personal data, it will put it beyond operational use. It should be noted that TBG allows up to 3 months after the retention schedule to complete the action.

The TBG website does not use non-essential cookies and no personal data is held on the website server. Enquiries made via the website are received in the form of an email.

The UK General Data Protection Regulation defines the rights that you have, although these do not apply in all situations. For convenience, these rights are shown below:

• Right to be informed as to how TBG is processing your personal data – this is done through this statement or separate TBG privacy notices
• Right to access your personal data held by us which is done by making a ‘Data Subject Access Request’ (DSAR) to the PM
• Right to rectification of your personal data if you believe we have collected it incorrectly or it needs to be updated
• Right to erasure of your personal data for which we no longer have a legitimate purpose to process
• Right to restrict processing under certain circumstances, during which time your personal data but will be out of operational use until the related matter is resolved
• Right to data portability of your personal data in a machine-readable version, but this only applies to data that has been provided with consent or under contract
• Right to object to TBG processing your personal data for which it does not have a legal or contractual obligation
• Rights related to automated decision making and profiling (although we do not use these techniques in its decision making)

Further details on data subjects’ rights can be found on the Information Commissioner’s Office (ICO) website: https://ico.org.uk.

Raising concerns, exercising rights or making queries about our processing of your personal data can be done by contacting the PM. Be aware that we will need to verify your identity before responding fully. This may involve asking you for documentary proof that, in context, will enable us to confirm your identity. Alternatively, you may contact the ICO directly without referring to us first, although naturally we would welcome the first opportunity to address your concerns or queries.

v1.0

January 2023