PRIVACY POLICY
Last Updated: 04/11/2025
This Privacy Policy (“Privacy Policy“) sets out how The Sub Center Ltd (““our”, “us” or “we”) process your personal data when you visit our website at https://thesubcenter.co.uk (our “Website“), purchase products or services from us or otherwise deal with us.
Your access to and use of our Website, including your account page and any secure area, is subject at all times to our Terms of Use. If you purchase products or services from our Website, your purchase will also be subject to our Terms of Use.
This Privacy Policy specifically applies to the processing of personal data of individuals we interact with during the day-to-day provision of our products and services to the extent such processing is caught by the requirements of the UK Data Protection Act 2018 and/or the General Data Protection Regulation (“UK GDPR”).
Please use the Glossary below to understand the meaning of some of the terms used in this Privacy Policy.
- Important information and who we are
- The data we collect about you
- How is your personal data collected?
- How we use your personal data
- Sharing of your personal data
- International transfers
- Data security
- Data retention
- Your legal rights
- Glossary
Important information and who we are
Purpose of this Privacy Policy
This Privacy Policy explains our approach to any personal data that we might collect from you or which we have obtained about you from a third party, and the purposes for which we process your personal data.
This Privacy Policy is intended to assist you in making informed decisions when using our Website or otherwise dealing with us. Please take a moment to read and understand it. It should be read in conjunction with our Terms of Use, and our Cookie Policy.
The Website is not intended for children, and we do not knowingly collect data relating to children.
Who we are
We are The Sub Center Ltd, a company established under the laws of England and Wales with company number 13167586. We are a data controller, which means that we are responsible for, and control the processing of, your personal data.
Contact details
If you have any questions about this Privacy Policy or want to exercise your rights as a data subject, as set out in this Privacy Policy, you can contact us as follows:
- in writing at 3-5 William Street, Herne Bay, Kent, CT6 5EW; or
- by email at support@thesubcenter.co.uk.
Third-party links
Our Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you.
We also have a social media presence for the purpose of engaging with you.
If you enable such connections or choose to communicate your personal data to us via third-party websites or social media, please remember that we do not control these third-party websites and are not responsible for their privacy statements. When you leave our Website, or interact with us on social media, we encourage you to read the privacy policy of each website or forum that you visit or use.
Changes to the Privacy Policy
If this Privacy Policy changes, the revised policy will include a new “last updated” date and will be posted on this page. We may notify you by email of any significant changes to this Privacy Policy, but please check back regularly to keep informed of updates.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where our ability to identify that person has been removed (anonymous data).
We may collect and process different types of personal data about you for different processing purposes. The types of personal data we collect depends on who you are and how you interact with us. We set out the categories of data that we collect and process, as follows:
- Identity Data which is your first name, last name, title.
- Contact Data which is your billing address, delivery address, email address, telephone number.
- Transaction Data which are details about payments to and from you, details of products you have purchased from us, details of returns.
- Correspondence Data which is the content of any correspondence you have with us, including interactions with our chat feature on our Website, to the extent that it includes personal data.
- Review Data which is information that you choose to provide to us concerning your review of our products and services such as the item reviewed and your comments.
- Technical Data which is your internet protocol (IP) address, information about your device, browser, or network connection, and other unique identifiers assigned to a device.
- Profile Data which is your account username, password, answers to any security questions, wish-list items, preferences and settings, whether you have participated in any promotions or competitions, feedback and survey responses.
- Usage Data which is information about how you use our website and services, data relating to your browsing activity or interaction with our emails.
- Marketing and Communications Data which is your marketing preferences and service communication preferences.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, 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.
How is your personal data collected?
We use different methods to collect data from and about you including through:
- Your direct interactions with us. You may give us your personal data directly, for example when you purchase products from our Website, contact us with enquiries, complete forms on our Website, subscribe to receive our marketing communications or provide feedback to us.
- Automated technologies or interactions. As you interact with our Website, we will automatically collect certain Technical and Usage Data about your device, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our Cookie Policy for further details.
How we use your personal data
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:
- Performance of a contract with you. Where we need to perform the contract we are about to enter into or have entered into with you.
- Legitimate interests. 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.
- Legal obligation. Where we need to comply with a legal obligation.
See the Glossary below to find out more about the types of lawful basis that we will rely on to process your personal data.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us using the details set out above.
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, depending on your relationship to us, 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 us using the details set out above 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. If we wish to make any changes to these purposes, or if we wish to use your personal data for any purpose that is not listed in this section, we will notify you using the contact details we hold for you.
Use of our Website
|
Purpose/Activity |
Type of data |
Lawful basis for processing including basis of legitimate interest |
|
To enable you to browse our Website |
Technical Data; Usage Data |
Necessary for our legitimate interests (to ensure that we provide access to our Website in a secure and effective way and so that we can make improvements to our Website). |
|
To register you as a customer and enable you to access your account on our Website |
Identity Data; Profile Data; Technical Data; Marketing and Communications Data |
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to ensure that we provide access to the Website and our products and services in a secure and effective way and so that we can make improvements to our Website) |
|
To process and deliver orders placed by you through our Website or in our store |
Identity Data; Contact Data; Profile Data; Transaction Data |
Performance of a contract with you |
|
To use data analytics to improve our website, products and services. |
Technical Data; Usage Data |
Necessary for our legitimate interests (to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
Customer service
|
Purpose/Activity |
Type of data |
Lawful basis for processing including basis of legitimate interest |
|
To respond to your general questions or if you need help with any issue concerning our Website, products and/or services. |
Identity Data; Contact Data; Profile Data; Transaction Data; Correspondence Data |
Necessary for our legitimate interests (to ensure that we are able to help you with your enquiry, provide a good standard of service and improve our customer services) |
Surveys and feedback.
|
Purpose/Activity |
Type of data |
Lawful basis for processing including basis of legitimate interest |
|
To enable you to complete our surveys, provide reviews and feedback on your experience of our Website, products and/or services |
Identity Data; Contact Data; Profile Data; Transaction Data; Review Data; Correspondence Data |
Necessary for our legitimate interests (so that we can improve our Website, products and services, and provide them in an effective way) |
Advertising and marketing activities.
|
Purpose/Activity |
Type of data |
Lawful basis for processing including basis of legitimate interest |
|
To send you notifications when a product that you have expressed an interest in becomes available |
Contact Data |
Consent |
|
To send you marketing communications by email and text |
Identity Data; Contact Data; Marketing and Communications Data; Profile Data; Transaction Data; |
Consent |
|
To carry out online personalised advertising |
Profile Data; Transactional Data; Technical Data. |
(a) Consent (b) Necessary for our legitimate interests (to promote our Website and our Services to you.) |
Business administration and legal compliance.
|
Purpose/Activity |
Type of data |
Lawful basis for processing including basis of legitimate interest |
|
To comply with our legal obligations or to administer and protect our business and our Website. |
All. |
(a) Necessary for our legitimate interests (in connection with a business transition, to enforce our legal rights or to protect the rights of third parties). (b) To comply with a legal obligation. |
If you fail to provide your personal data
Where we are required by law to collect your personal data, or we need to collect your personal data under the terms of a contract we have with you, and you fail to provide that personal data when we request it, we may not be able to perform the contract we have or are trying to enter into with you. This may apply where you do not provide the personal data we need in order to provide the products or services you have requested from us or to process an application to register an account. In these circumstances, we may have to cancel your order or the provision of the relevant product or service to you, in which case we will notify you.
Marketing
We will never send you marketing by email or text without your consent, and you can withdraw your consent at any time.
We do not share your personal data with third parties for direct marketing purposes, and do not send third party marketing on behalf of any other business.
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the Website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.
When processing your personal data, we may need to share it with third parties, as set out below. This list is non-exhaustive and there may be circumstances where we need to share personal data with other third parties.
- Third-party suppliers who support us in providing our Website and other third parties who perform services on our behalf (e.g. IT management, payment processing, data analytics, customer support, cloud storage, fulfilment and shipping).
- Our advertising partners including those set out in our Cookie Policy when you use our Website.
- Our auditors, lawyers, accountants and other professional advisers
- Law enforcement or other government and regulatory agencies and bodies as required by, and in accordance with, applicable law or regulation.
- Another corporate entity if we are involved in a business transition such as a merger, reorganisation, acquisition by another company, or sale of any of our assets.
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 any third-party service providers who are acting as processor for us 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.
If you require any further information about third parties with whom we may share your personal data, please contact us using the details set out above.
International transfers
Some of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.
Whenever we transfer your personal data out of the UK we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We may transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
- We may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.
Please contact us using the details set out above if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
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 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.
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in relation to which your personal data is relevant.
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, regulatory, tax, accounting or other requirements.
You have certain rights in relation to the personal data we hold about you. You have the right to:
- 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 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:
- If you want us to establish the data’s accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- 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.
- 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 your rights set out above, please contact us using the details set out above.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator 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 (using the details set out above) in the first instance.
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 could 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 a 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 one month. Occasionally it could take us longer than a month 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.
Legitimate Interest means the interest of our business 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 us using the using the details set out above.
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 obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.