NEWNEW treats the privacy of its clients, customers and website (new-new.co.uk) users very seriously and we take appropriate security measures to safeguard your privacy. This Privacy Notice explains how we protect and manage your Personal Data you share with us and that we hold about you, including how we collect, process, protect and share that data.
Personal Data means any information that may be used to identify an individual, including but not limited to, a first and last name, a home or other physical address, a telephone number and an email address or other contact information, whether at work or at home.
Who we are
NEWNEW Limited trading as NEWNEW (“we”). We are registered in England and Wales under company number 12306332 and have our registered office situated in Milton Keynes.
We provide footwear valeting services to UK based individuals and entities. As part of conducting these services, you provide us with information about you to enable us to conduct these services.
In instances where you are not our client, for example where we are instructed by a UK institution or entity, they will be the ‘Controller’ of this information and we will be a ‘Processor’. In such cases, this Privacy Notice is therefore supplemental to the Privacy Notice provided by the UK institution or entity. We will be the ‘Controller’ of the personal data.
How we obtain your Personal Data – Information provided by you
When you decide to use our services you may provide us with your Personal Data via our Site, through email or text message, over the telephone or similar mediums. This Personal Data includes name, address, phone number and email address. We use this information in order to fulfil the agreed services that we provide to you.
We may also keep the information contained in any correspondence you may have with us by text message or email.
How we use your Personal Data
We use your Personal Data to fulfil the agreed services, to keep you informed and to keep a record of the services we provide you for example for accounting, payment and legal requirements. We endeavour, at all times to protect your Personal Data in a manner which is consistent with our requirements of the General Data Protection Regulation (GDPR) concerning data protection. We will also take reasonable security measures to protect your Personal Data in storage.
Do we use your Personal Data for marketing purposes?
Any information that you choose to give us for the provision of services will be used by us for that purpose only or to comply with associated legitimate interests (as described in the paragraph above) and will not be used for marketing purposes by us or third parties.
What is our Legal Basis for processing your information
The main legal basis for processing your information will be to perform the services as agreed between us and yourself. Therefore, the main reason for us processing your Personal Data will be for the performance of a contract between us or, for us to take steps at your request prior to entering into a contract with you.
We will also need to process your Personal Data for our own internal record keeping activities: in this instance, your Personal Data will be processed for keeping a record of what services we have provided to you, what payments we have requested from you and what payments you have made. In this instance, we will be processing your Personal Data on a legitimate interest basis.
Additionally, we may be required to obtain Personal Data from you in order to comply with our regulatory and legal obligations, for example, to comply with anti-money laundering legislation, accounting practices or legal requirements, court orders or conduct fraud prevention. In these instances, our legal basis for processing information will be to fulfil a legal obligation.
We will keep information about you confidential. In order to fulfil the performance of the contract, to carry out our legitimate interest or to satisfy a legal obligation we may be required to disclose your information to third parties. Examples of the types of third parties used include:
-Any legal or crime prevention agencies and/or to satisfy any regulatory request (including recognised practitioner bodies) if we have a duty to do so or if the law allows us to do so.
In the event that NEWNEW is sold or integrated with another business, your anonymised details may be disclosed to our advisers and any prospective purchasers’ advisers and your personal details will be passed on to the new owners of the business. We will notify you in such a case.
Transfer of your Personal Data outside of the European Economic Area (EEA)
We do not transfer your Personal Data outside the EEA.
How long do we keep this information about you
We retain your personal data as follows: we will keep your Personal Data for a period of six years after the last piece of work or service we have provided to you e.g. if we provided a service in 2019 to you then we would only retain your Personal Data until 2025. This retention period is in line with the length of time we need to keep your Personal Data in order to meet or take any legal action (e.g. debt collection, claim for breach of contract) for financial statutory or legal requirements and the handling of any insurance claims. In all cases our need to use your Personal Data will be reassessed on a regular basis and information which is no longer required will be disposed of.
What if I choose not to give you my personal information
If you do not wish us to process your Personal Data we will still be able to provide our services, but our communication will be limited.
Will you process my information for purposes I may not be aware of
If you use our Site, we may also use aggregate information and statistics for the purposes of monitoring Site usage and to help us develop our Site and our services, and may provide such aggregate information to third parties. These statistics will not include information that can be used to identify any individual.
We may use sign up form data to assist with providing downloads, newsletters and enrolling on events. Such use does not result in any personally identifiable data, other than contact details, being collected, stored or transferred to such agencies. We may contact you e-mail or telephone to ask you for your feedback and comments on our services. We will only do this with your consent that you can give on our Site.
Data Subject Rights
Right to be informed
You, the Data Subject, shall have the right to be informed of how your Personal Data is used. This Privacy Notice provides you with this explanation in relation to the information processed by us when providing services to you.
Subject access requests
The General Data Protection Regulation (GDPR) grants you (the Data Subject) the right to access particular Personal Data that we hold about you. This is referred to as a subject access request. We shall respond promptly, and certainly within one month from the point of receiving the request and all necessary information from you. Our formal response shall include details of the Personal Data we hold about you.
You may also request the following:
Sources from which we acquired the information;
The purposes for processing the information; and
Persons or entities with whom we are sharing the information.
Right to rectification
You, the Data Subject, shall have the right to obtain from us, without undue delay, the rectification of inaccurate Personal Data we hold concerning you. Taking into account the purposes of the processing, you, the Data Subject, shall have the right to have incomplete Personal Data completed, including by means of providing a supplementary statement.
Right to erasure
You, the Data Subject, shall have the right to obtain from us the erasure of Personal Data concerning you without undue delay.
This right does not apply if processing is necessary:
for the exercise of the right of freedom of expression and information;
For compliance with a Union or Member State legal obligation;
For the performance of a public interest task or exercise of official authority:
For public health reasons; for archival, research or statistical purposes (if any relevant conditions for this type of processing are met); or if required for the establishment, exercise or defence of legal claims.
Right to restriction of processing
You, the data subject, shall have the right to obtain from us a restriction of processing where one of the following applies:
the accuracy of the Personal Data is contested by you, the data subject, and is restricted until the accuracy of the data has been verified;
the processing is unlawful and you, the data subject, oppose the erasure of the Personal Data and instead request the restriction in its use;
we no longer need the Personal Data for the purposes of processing, but it is required by you, the data subject, for the establishment, exercise or defence of legal claims;
you, the data subject, have objected to processing of your Personal Data pending the verification of whether there are legitimate grounds for us to override these objections.
The right will not apply where the processing is necessary for:
the establishment of legal claims
the protection of another; or
reasons of important public interest
Notification obligation regarding rectification or erasure of Personal Data or restriction of processing
We shall communicate any rectification or erasure of Personal Data or restriction of processing as described above to each recipient to whom the Personal Data has been disclosed unless this proves impossible or involves a disproportionate effort. We shall provide you, the data subject, with information about those recipients if you request it.
Right to data portability
You, the data subject, shall have the right to receive your Personal Data, which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit this data to another controller, without hindrance from us.
Right to object
You, the data subject, shall have the right to object, on grounds relating to your particular situation, at any time to the processing of Personal Data concerning you, including any personal profiling; unless this relates to processing that is necessary for the performance of a task carried out in the public interest or an exercise of official authority vested in us. We shall no longer process the Personal Data unless we can demonstrate compelling legitimate grounds for the processing, which overrides the interests, rights and freedoms of you, the data subject, or for the establishment, exercise or defence of legal claims.
Right to not be subject to decisions based solely on automated processing.
We do not carry out any automated processing, which may lead to an automated decision based on your Personal Data.
Invoking your rights
If you would like to invoke any of the above data subject rights with us, please submit a written request to firstname.lastname@example.org
Accuracy of information
In order to provide the highest level of customer service possible, we need to keep accurate Personal Data about you. We take reasonable steps to ensure the accuracy of any Personal Data we obtain. We ensure that the source of any Personal Data is clear and we carefully consider any challenges to the accuracy of the information. We also consider when it is necessary to update the information, such as name or address changes and you can help us by informing us of these changes when they occur.
Questions and queries
If you have any questions or queries which are not answered by this Privacy Notice or have any potential concerns about how we may use the Personal Data we hold, please email us on email@example.com .
If you have a complaint
If you have a complaint regarding the use of your Personal Data, then please contact us on email firstname.lastname@example.org and we will do our best to help you.
If your complaint is not resolved to your satisfaction and you wish to make a formal complaint to the Information Commissioner’s Office (ICO), you can contact them on 01625 545745 or 0303 123 1113. You also have the right to a judicial remedy against a legally binding decision of the ICO where you consider that your rights under this regulation have been infringed as a result of the processing of your Personal Data. You have the right to appoint a third party to lodge the complaint on your behalf and exercise your right to seek compensation.