We at In Phase International Ltd understand that you care how your information is used and shared, and we appreciate your trust in us to do that carefully and sensibly. This privacy notice will inform you as to how we look after your personal data when you visit one of our UK stores, place an order by telephone or visit our website (regardless of where you visit it from), and tell you about your privacy rights and how the law protects you.
This privacy notice is provided in a layered drop-down format so you can click through to the specific sections set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.

PURPOSE OF THIS PRIVACY NOTICE 

This privacy notice aims to give you information on how In Phase International collects and processes your personal data when you visit one of our stores or one of our websites, place an order with us online or by phone, make an in-store purchase, save your information with us online, contact us with a query or concern, or participate in a contest, promotion or survey. 

Our website is not intended for children and we do not knowingly collect data relating to children under the age of 16. 

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them. 

CONTROLLER 

In Phase International Ltd is the controller and responsible for your personal data (collectively referred to as “In Phase International”, “we”, “us” or “our” in this privacy notice. 

We have appointed a data protection manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data protection manager or customer services using the details set out below. 

CONTACT DETAILS 

Our full details are: 

In Phase International Ltd 

DB House 

Unit 3 Rani Drive 

Nottingham

NG5 1RF 

Company registration no. 04158516 

Data Protection Manager: Chris Dunsmuir 

Email address: sales@ipiltd.net 

Tel: Customer Services 0115 875 8600 

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance. 

CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES 

We keep our privacy policy under regular review, and we will place any changes and / or updates on our websites. This privacy policy was last updated on January 4th 2023 and sets out your rights under the GDPR and other UK associated Data Protection laws. Historic versions of this privacy policy can be obtained by contacting us as per the details set out above. 

It is important that the personal data we hold about you is accurate and current. Please kindly keep us informed if your personal data changes during your relationship with us. You can contact us with your up-to-date details and we will update them for you. 

THIRD-PARTY LINKS 

Our websites may include links to third-party websites. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit. 

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). 

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows: 

Identity Data includes first name, last name and title. 

Contact Data includes billing address, delivery address, email address and telephone numbers. 

Financial Data includes bank account and payment card details. 

Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us. 

Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our website. 

Profile Data, purchases or orders made by you, your interests, preferences, feedback and survey responses. 

Usage Data includes information about how you use our website, products and services. 

Marketing and Communications Data includes your preferences in receiving marketing from us. 

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice. 

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. 

IF YOU FAIL TO PROVIDE PERSONAL DATA 

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time. 

We use different methods to collect data from and about you, including through: 

Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, and email or otherwise. This includes personal data you provide when you: 

• apply for our products or services; 
• make a purchase in-store, by phone or on one of our websites; 
• create an account on our websites; 
• subscribe to our newsletters; 
• request marketing to be sent to you; 
• enter a competition, prize draw, promotion or survey; or 
• give us some feedback. 

Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy below for further details. 

Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:

(a) analytics providers such as Google Analytics based outside the EU; 

(b) customer review providers such as Trustpilot based in the EU. 

Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Opayo/Sagepay Merchant Services based in the EU.

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances: 

Where we need to perform the contract we are about to enter into or have entered into with you. 

Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. 

Where we need to comply with a legal or regulatory obligation. 

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by clicking on the unsubscribe link provided at the end of each marketing communication or by contacting Customer Services on 0115 975 8600. 

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA 

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. 

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact our Data Protection Manager if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below. 

MARKETING 

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You may opt out of receiving marketing at any time or, if you prefer, you may change the frequency of your mailings or remove 1 or more of our company brands by telephoning customer services on 0115 975 8600, or by simply clicking the unsubscribe link or change my preference link at the end of each e-communication received. 

CROSS BRAND SHARING

Personal data maybe shared between the InPhase International Ltd group of companies, currently including, but not limited to:

• Road Angel Group (www.roadangelgroup.com), 
• Car Audio Centre (www.caraudicentre.co.uk), 
• Superfi Ltd (www.superfi.co.uk) 
• Snooper (www.snooper.eu), 
• Nottingham Hifi (www.nottinghamhifi.co.uk), 
• In Phase (www.inphaseinternational.co.uk), 
• Juice (www.juice.co.uk)
• Retro Scents (www.retroscents.co.uk)
• DB Audio (www.dbaudio.com)
• Co-Pilot (www.copilotgps.com)

for the purposes outlined above

PROMOTIONAL OFFERS FROM US 

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this In Phase predictive marketing). If you have opted into our marketing communications, we may also use your Identity, Contact and Transaction Data to provide additional marketing from other brands within our group of companies.

You will receive marketing communications from our other brands if you have requested information from us or provided us with your details when you made a purchase on one of our websites, entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing. 

OPTING OUT 

You can ask us to stop sending you marketing messages at any time by contacting customer services on 0115 975 8600 or by following the opt-out links on any marketing message sent to you. 

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product / service purchase, warranty registration, product / service experience or other transactions.

THIRD-PARTY MARKETING 

We will not share your personal data with any company outside the In Phase International Ltd group of companies for third party marketing purposes (without first of all obtaining your express opt-in consent before doing so). 

COOKIES 

Our websites use cookies. A cookie is a small file of letters and numbers we put on your computer if you agree. These cookies allow us to distinguish you from other users of our website by recording information about your online preferences, remember information about you when you visit our site and compile statistical reports on website activity. These help us provide you with a good experience when you browse our websites and allow us to improve our websites. Some cookies used are essential in order to provide our services to you. Most web browsers will accept cookies, but if you would rather that we did not collect data in this way you can choose to accept all or some or reject cookies in the preference centre in the Cookie Policy section. 

For more information on our Cookie Policy please see the section below. 

CHANGE OF PURPOSE 

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact the Data Protection Manager. 

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. 

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law. 

Information about our customers is an important part of our business and we are not in the business of selling it to others. 

We only share your personal data with our owned and operated brands and the parties set out below for the purposes set out in the table in section 4 above. 

Third Party Service Providers: We employ other companies and individuals to perform functions on our behalf. Examples include delivering packages, sending postal mail and email, providing IT and system administration, providing marketing assistance, providing search results and links, technical services, logistical services, repair services, installation services, insurance provision, processing credit card payments, and the provision of legal, accountancy, banking and other professional services. 

Fraud Protection: In processing your order we may send your details to, and also use information from credit reference agencies and fraud prevention agencies. We ensure that your personal data will not be disclosed to government institutions and authorities except if required or allowed by law (for example where reporting of processing activities in certain circumstances). 

Finance: We offer customers finance on certain products subject to eligibility criteria. In respect of the provisions of any such finance we use credit reference agencies for the purposes of assessing your credit score and we act as a credit intermediary where we work with our Finance Partners with whom we may share your information (either with your express consent or to the extent relevant for providing or assessing your suitability for credit). 

Other instances: Your information may also be transferred to another company (based in the European Union or in a country ensuring an adequate level of protection) in the event of a sale of our company to a third party or we sell the business and assets of our company. Any disclosure in such circumstances will only be to the prospective buyer and their professional advisors who will be subject to obligations of confidentiality. In that event we will endeavour to ensure that your rights in respect of the processing of personal data are adequately and appropriately protected in accordance with all Data Protection Laws. We may also disclose your information if we are under a duty or legal obligation to share your personal data or to protect the rights, property or safety of In Phase International Ltd, its group companies and customers or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction. 

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. 

Please contact us if you require further details of any of the third parties detailed above.

A minority of our third-party service providers are based outside the European Economic Area (EEA) so their processing of your personal data may involve a transfer of data outside the EEA. Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented: 

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries. 

Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield. 

Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries. 

Please contact the Data Protection Manager should you want further information on the specific mechanism used by us when transferring your personal data out of the EEA. 

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. 

We work to protect the security of your information during transmission by using Secure Sockets Layer (SSL) software, which encrypts information you input. 

All the personal information collected via our website and in-store is recorded in a secure database located within the European Union. We maintain physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of personally identifiable customer information. Our security procedures mean that we may occasionally request proof of identity before we disclose personal information to you. 

All In Phase International' employees and data processors, who have access to or are associated with the processing of personal information, are obliged to respect the confidentiality of that information and comply with all applicable Data Protection legislation. 

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. 

It is important for you to protect against unauthorised access to your password and to your computer. Be sure to sign off when you finish using a shared computer. 

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. 

HOW LONG WILL YOU USE MY PERSONAL DATA FOR? 

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. A copy of our Retention Policy can be obtained by contacting the Data Protection Manager. 

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. 

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers, for tax purposes. 

In some circumstances you can ask us to delete your data: see Your Legal Rights / Request erasure below for further information. 

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you. 

Under certain circumstances, you have the following rights under data protection laws in relation to your personal data. 

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. 

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.; 

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. 

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. 

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. 

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. 

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. 

If you wish to exercise any of the rights set out above, please contact the Data Protection Manager. 

NO FEE USUALLY REQUIRED 

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. 

WHAT WE MAY NEED FROM YOU 

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. 

TIME LIMIT TO RESPOND 

We try to respond to all legitimate requests within 28 days from confirmation of requester’s ID. Occasionally it may take us longer than 28 days if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

LAWFUL BASIS 

Legitimate Interest means the interest of our businesses in conducting and managing our business to enable us to give you the best service / product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests.

We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting our Data Protection Manager or customer services on 0115 975 8600. 

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. 

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to. 

In order to be able to offer you Klarna’s payment options, we will pass to Klarna certain aspects of your personal information, such as contact and order details, in order for Klarna to assess whether you qualify for their payment options and to tailor the payment options for you.

General information on Klarna you can find here. Your personal data is handled in accordance with applicable data protection law and accordance with the information in Klarna’s privacy policy.