The Washing Machine Project Privacy Policy
Last updated 11th April 2022
Introduction
We are The Washing Machine Project (TWMP). We are a company registered in England and Wales with company number 12113634. Our registered office is at 92 Mansell Road, Greenford, UB6 9EL.
In this privacy notice we will refer to ourselves as ‘we,’ ‘us’ or ‘our’.
We take the privacy, including the security, of personal information we hold about you seriously. This privacy notice is designed to inform you about how we collect personal information about you, and how we use that personal information. You should read this privacy notice carefully so that you know and can understand why and how we use the personal information we collect and hold about you.
If you have questions about this privacy notice or issues arising from it, then you should contact Akash Ghavalkar at akash@thewashingmachineproject.org. They are responsible for matters in this privacy notice.
We may update this privacy policy from time to time. This version was last updated on April 10, 2022.
1: Key Definitions
The key terms that we use throughout this privacy notice are defined below, for ease:
Data Controller: under UK data protection law, this is the organisation or person responsible for deciding how personal information is collected and stored and how it is used.
Data Processor: a Data Controller may appoint another organisation or person to carry out certain tasks in relation to the personal information on behalf of, and on the written instructions of, the Data Controller. (This might be the hosting of a site containing personal data, for example, or providing an email marketing service that facilitates mass distribution of marketing material to a Data Controller’s customer-base).
Personal Information: in this privacy notice we refer to your personal data as ‘personal information’. ‘Personal information’ means any information from which a living individual can be identified. It does not apply to information which has been anonymized.
2: Details of Personal Information which we collect and hold about you
2.1 Set out below are the general categories of data, and in each category, the types of personal information which we may collect, use and hold about you:
General Category — Types of Personal Information in that category
Identity Information — This is information relating to your identity such as your name (including any previous names and any titles which you use), gender, date of birth, and company name.
Contact Information — This is information relating to your contact details such as e-mail address, addresses, and telephone numbers.
Payment Information — This is information relating to the methods by which you provide payment to us such as [bank account details, credit or debit card details] and details of any payments (including amounts and dates) which are made between us.
Transaction Information — This is information relating to transactions between us such as details of the goods, services and/or digital content provided to you and any returns details.
Survey Information — This is information which we have collected from you or which you have provided to us in respect of surveys and feedback.
Marketing Information — This is information relating to your marketing and communications preferences.
Website, Device and Technical Information — This is information about your use of our website and technical data which we collect (including your IP address, the type of browser you are using and the version, the operating system you are using, details about the time zone and location settings on the device and other information we receive about your device). As per UK data law, TWMP will hold and use Personal Information (the Data) only as long as is necessary, or to comply with applicable laws. When TWMP no longer needs the Data, which will generally be 6 years after the Data is provided, TWMP will remove it from its systems. If TWMP keeps the Data longer, it would be to satisfy legal or regulatory obligations.
3: Details of Special Information which we collect and hold about you
3.1 We do not collect or hold any special information about you, including race, ethnic origin, political belief, religion, genetics, health information or biometric information.
3.2 We do not collect information from you relating to criminal convictions or offences.
4: Details of how and why we use Personal Information
4.1 We are only able to use your Personal Information for certain legal reasons set out in data protection law. There are other legal reasons for using your Personal Information under data protection law, other than those listed below, but in most cases we will use your information for the following reasons:
Contract Reason: this is in order to perform our obligations to you under a contract we have entered into with you;
Legitimate Interests Reason: this is where the use of your Personal Information is necessary for our (or a third party’s) legitimate interests, so long as that legitimate interest does not override your fundamental rights, freedoms or interests;
Legal Obligation Reason: this is where we have to use your Personal Information in order to perform a legal obligation by which we are bound; and
Consent Reason: this is where you have given us your consent to use your Personal Information for a specific reason or specific reasons. For example, we require your Personal Information in order to provide the products and services you request from us.
4.2 So that we are able to provide you with goods and services, we will need your Personal Information. If you do not provide us with the required Personal Information, we may be prevented from supplying the goods and services to you.
4.3 It is important that you keep your Personal Information up to date. If any of your Personal Information changes, please contact us as soon as possible to let us know. If you do not do this then we may be prevented from supplying you goods and services.
4.4 Where we rely on consent for a specific purpose as the legal reason for processing your Personal Information, you have the right under data protection law to withdraw your consent at any time. If you do wish to withdraw your consent, please contact us using the details set out at the beginning of this notice. If we receive a request from you withdrawing your consent to a specific purpose, we will stop processing your Personal Information for that purpose, unless we have another legal reason for processing your Personal Information, in which case, we will confirm that reason to you.
4.5 We have explained below the different purposes for which we use your Personal Information and, in each case, the legal reason(s) allowing us to use your Personal Information. Please also note the following:
if we use the Legitimate Interests Reason as the legal reason for which we can use your personal information, we have also explained what that legitimate interest is; and
for some of the purposes we may have listed more than one legal reason on which we can use your Personal Information, because the legal reason may be different in different circumstances. If you need confirmation of the specific legal reason that we are relying on to use your personal data for that purpose, please contact us using the contact details set out at the start of this privacy notice.
Purpose — Legal Reason(s) for using the Personal Information
To enrol you as a customer and facilitate pre-orders. — Contract Reason; Legitimate Interests Reason (in order to offer you goods and/or services).
To process your order, which includes taking payment from you, advising you of any updates in relation to your order or any enforcement action against you to recover payment. — Contract Reason; Legitimate Interests Reason (in order to recover money which you owe us).
To manage our contract with you and to notify you of any changes. — Contract Reason; Legal Obligation Reason.
To comply with audit and accounting matters. — Legal Obligation Reason.
For record keeping, including in relation to any guarantees or warranties provided as part of the sale of goods and/or services. — Contract Reason; Legal Obligation Reason.
To improve the goods and/or services which we supply. — Legitimate Interests Reason (in order to improve the goods and/or services for future customers and to grow our business).
To recommend and send communications to you about goods and/or services that you may be interested in. More details about marketing are set out in section 10 below. — Legitimate Interests Reason (in order to grow our business); Consent Reason.
To ensure the smooth running and correct operation of our website. — Legitimate Interests Reason (to ensure our website runs correctly).
To understand how customers and visitors to our website use the website and interact with it via data analysis. — Legitimate Interests Reason (to improve and grow our business, including our website, and to understand our customer’s needs, desires and requirements).
To respond to any of your questions and concerns submitted through the ‘Contact Us’ form. — Consent Reason.
To gather information about distributors and how many machines they can procure for us. — Contract Reason; Legitimate Interests Reason (in order to offer you goods and/or services).
4.6 Sometimes we may anonymise personal information so that you can no longer be identified from it and use this for our own purposes. In addition, sometimes we may use some of your personal information together with other people’s personal information to give us statistical information for our own purposes. Because this is grouped together with other personal information and you are not identifiable from combined data, we are able to use this.
4.7 Under data protection laws, we can only use your personal information for the purposes we have told you about, unless we consider that the new purpose is compatible with the purpose(s) which we told you about. If we want to use your personal information for a different purpose which we do not think is compatible with the purpose(s) which we have told you about, then we will contact you to explain this, and what legal reasons are in in place to allow us to do this.
5: Details of how we collect Personal Information
5.1 We usually collect Identity Information, Contact Information, Payment Information, Transaction Information, Survey Information, and/or Marketing Information directly from you when you fill out a form, contact us by email, contact us through the website’s ‘Contact Us’ form, fill out a survey or questionnaire, or pre-order goods from us. This includes the Personal Information which you provide to us when you subscribe to our newsletter.
5.2 We may also receive Website, Device and Technical Information automatically from technologies such as cookies which are installed on our website. To find out more about these please see our cookie policy.
6: Details about who personal information may be shared with
6.1 We may need to share your Personal Information with other organisations or people. These organisations include:
Third parties. These may include:
Suppliers.
Manufacturers.
Delivery agencies.
Government bodies and regulatory bodies: such as HMRC and fraud prevention agencies.
Our advisors: such as lawyers, accountants, auditors, and insurance companies.
Any organisations which propose to purchase our business and assets, in which case we may disclose your Personal Information to the potential purchaser.
6.2 Depending on the circumstances, the organisations or people who we share your Personal Information with will be acting as either Data Processors or Data Controllers. Where we share your personal information with a Data Processor, we will ensure that we have in place contracts, which set out the responsibilities and obligations of us and them, including in respect of security of personal information.
6.3 We do not sell or trade any of the personal information which you have provided to us.
7: Details about transfers to countries outside of the EEA (European Economic Area).
7.1 Your Personal Information may be shared with suppliers, manufacturers and delivery agencies outside of the EEA. If any Personal Information is transferred outside of the EEA then we will ensure that safeguards are in place to ensure that a similar degree of protection is given to your personal information, as is given to it within the EEA, and that the transfer is made in compliance with data protection laws.
8: Details about how long we will hold your personal information
8.1 As per UK data law, TWMP will hold and use Personal Information (the Data) only as long as is necessary, or to comply with applicable laws. When TWMP no longer needs the Data, which will generally be 6 years after the Data is provided, TWMP will remove it from its systems. If TWMP keeps the Data longer, it would be to satisfy legal or regulatory obligations.
8.2 How long is necessary will depend upon the purposes for which we collected the personal information (see section 4 above) and whether we are under any legal obligation to keep the personal information (such as in relation to accounting or auditing records or for tax reasons). We may also need to keep personal information in case of any legal claims, including in relation to any guarantees or warranties which we have provided.
9: Your rights under Data Protection Law
9.1 Under data protection laws you have certain rights in relation to your personal information, as follows:
Right to request access: (this is often called ‘subject access’). This is the right to obtain from us a copy of the personal information which we hold about you. We must also provide you with certain other information in response to these requests to help you understand how your personal information is being used.
Right to correction: this is the right to request that any incorrect personal data is corrected and that any incomplete personal data is completed.
Right to erasure: (this is often called the “right to be forgotten”). This right only applies in certain circumstances. Where it does apply, you have the right to request us to erase all of your personal information.
Right to restrict processing: this right only applies in certain circumstances. Where it does apply, you have the right to request us to restrict the processing of your personal information.
Right to data portability: this right allows you to request us to transfer your personal information to someone else.
Right to object: you have the right to object to us processing your personal information for direct marketing purposes. You also have the right to object to us processing personal information where our legal reason for doing so is the Legitimate Interests Reason (see section 4 above) and there is something about your particular situation which means that you want to object to us processing your personal information. In certain circumstances you have the right to object to processing where such processing consists of profiling (including profiling for direct marketing).
9.2 In addition to the rights set out in section 9.1, where we rely on consent as the legal reason for using your personal information, you have the right to withdraw your consent. Further details about this are set out in section 4.
9.3 If you want to exercise any of the above rights in relation to your personal information, please contact us using the details set out at the beginning of this notice. If you do make a request then please note:
we may need certain information from you so that we can verify your identity;
we do not charge a fee for exercising your rights unless your request is unfounded or excessive; and
if your request is unfounded or excessive then we may refuse to deal with your request.
10: Marketing
10.1 You may receive marketing from us about similar goods and services, where either you have consented to this, or we have another legal reason by which we can contact you for marketing purposes.
10.2 However, we will give you the opportunity to manage how or if we market to you. In any e-mail which we send to you, we provide a link to either unsubscribe or opt-out, or to change your marketing preferences. To change your marketing preferences, and/or to request that we stop processing your personal information for marketing purposes , you can always contact us by the details set out at the beginning of this notice.
10.3 If you do request that we stop marketing to you, this will not prevent us from sending communications to you which are not to do with marketing (for example in relation to goods and/or services which you have purchased from us).
10.4 We do not pass your personal information on to any third parties for marketing purposes.
11: Complaints
11.1 If you are unhappy about the way that we have handled or used your personal information, you have the right to complain to the UK supervisory authority for data protection, which is the Information Commissioner’s Office (ICO). Please do contact us in the first instance if you wish to raise any queries or make a complaint in respect of our handling or use of your personal information, so that we have the opportunity to discuss this with you and to take steps to resolve the position. You can contact us using the details set out at the beginning of this privacy notice.
12: Third Party Websites
12.1 Our website may contain links to third party websites. If you click and follow those links then these will take you to the third party website. Those third-party websites may collect personal information from you and you will need to check their privacy notices to understand how your personal information is collected and used by them.