We may collect, store, and use the following categories of your personal information:

• Personal contact details such as name, title, address, telephone numbers, and personal email addresses.
• Company/business details such as name and address.
• Account number.
• Credit check results and credit limit.
• Telephone call information, including call recordings, phone number and length of call.

We collect information about you during the course of initial enquiries and during our account set-up process, either directly from you, or sometimes from other sources, such as credit reference agencies.

We will collect additional information about you during the course of our trading relationship.

The situations in which we will process your personal information are listed below:

• Handling and considering Trade Account Application Forms.
• Handling enquiries from potential Trade Accounts.
• Setting Trade Accounts up on our internal systems.
• Storing signed contracts with Trade Accounts.
• To determine and manage credit limits of Trade Accounts.
• Honouring our obligations under any contract with a Trade Account and working alongside Trade Account’s as required for the purposes of the contract.
• Managing Stockist Program benefits.
• Displaying your information within the ‘Store Finder’ section of our website.
• Invoicing, maintaining payment records, and pursuing late payments.
• Maintaining records of goods supplied to a Trade Account.
• Analysis of Trade Account performance.
• Handling and resolving disputes
• Training of staff.

Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it such as (i) for the purpose of performing our obligations under our contract with a Trade Account (or to take steps prior to entering into a contract with a Trade Account), (ii) to enable us to comply with our legal obligations, or (iii) where the processing is in our legitimate interests and not overridden by your rights.

If we collect and use your personal information in reliance on our legitimate interests (or those of any third party), this interest will normally be for our legitimate commercial interest, for sales performance analytics and strategy, and the management of credit risk. We may have other legitimate interests and if appropriate we will make clear to you at the relevant time what those legitimate interests are.

If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us (section 13).

If you fail to provide certain information when requested we may not be able to perform any contract we have entered into with you, or we may be prevented from complying with our legal obligations.

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

Please note that we may process your personal information without your knowledge or consent where this is required or permitted by law.

We have put in place appropriate technical and organisational measures to prevent your personal information from being accidentally lost, used, accessed, altered or disclosed. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information and include:

• Site access controls – only authorised personnel are able to gain access to premises, buildings and rooms where your information is being processed.
• IT access controls – only authorised personnel are able to gain access to your information stored electronically within our IT systems.
• IT security controls – use of appropriate technology and security measures to ensure secure storage of your information.
• Policies & procedures – comprehensive data protection and IT security policies and procedures setting out the way in which your information must be handled by staff.
• Training – delivery of ongoing data protection and IT security training to all staff handling your information.

We may share your personal information in the situations detailed below:

• Service providers

We share your personal information with third parties who provide services to us. The following activities all involve the processing of personal information and are carried out by third party service providers: website hosting, credit reference searches, hosting and maintenance of Customer Relationship Management platform, mail and distribution services, database and mailing list management services, management services, maintenance of call recording system, IT service providers, document and information collaboration and sharing, legal advisers. Further details in respect of our third party service providers are available on request. Please contact us (section 13) for further information.

All service providers are required to take appropriate security measures to protect your personal information. We do not allow third party service providers to use your personal information for their own purposes. We only permit them to process your personal data for specified purposes in accordance with our instructions.

• Games Workshop group

We may share your personal information with other entities in our group of companies as part of regular reporting activities on company performance, in the context of business reorganisation or group restructuring, or for system maintenance support.

• Sale or restructure

We may share your personal information in the context of the possible sale or restructuring of the business provided that we inform the buyer it must use your personal information only for the purposes disclosed in this notice.

• Law, legal rights and vital interests

We may also need to share your information with a law enforcement body, regulator, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any person.

We may transfer your personal information outside the European Economic Area (EEA). We will only transfer your personal information outside the EEA if adequate protection measures are in place.  To ensure that your personal information does receive an adequate level of protection outside the EEA we use the following protection measures:

• Transferring to countries approved by the European Commission
• Using model contractual clauses approved by the European Commission
• Requiring companies we transfer information to in the United States to be signed up to the EU/US Privacy Shield Framework

Further details in respect of protective measures used outside of the EEA are available on request. Please contact us (section 13) for further information.

We only retain your information for as long as necessary for the purposes described above, including for the purposes of satisfying any legal, accounting, or reporting requirements.

For much of your information, this will be for the length of any contract with us and then for a period of 6 years thereafter.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

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 it has been processed, and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.

Under certain circumstances, by law you have the right to:

• Request access to a copy of the personal information we hold about you
• Request correction of any incomplete or inaccurate information we hold about you
• Request erasure of information where there is no good reason for continued processing
• Object to processing of your information where we are relying on a legitimate interest to process your information.
• Where we are processing your information for a particular purpose based on your consent, you have the right to withdraw your consent at any time.
• Request restriction to suspend our processing of your personal information.
• Request transfer of your personal information to another party which you have provided to us.

If you want to exercise any of these rights please contact us (section 13).

You will not have to pay a fee to exercise any of your rights, however we may charge a reasonable fee if your request is unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

Please note that we may need to request information from you to confirm your identity and establish your entitlement to these rights.

If you are not satisfied with our processing of your personal information, you also have the right to make a complaint to the relevant supervisory authority. Please see here for the relevant contact details.

It is important that the personal information we hold about you is accurate and current. Please inform us immediately of any changes to the personal information which we hold about you.

We may update this notice from time to time. When we update this notice, we will take appropriate measures to inform you, consistent with the significance of the changes.  We will obtain your consent to any material changes if and where this is required by law.

You can see when this notice was last updated by checking the date displayed at the top of this notice.

This notice is overseen by the Data Protection Manager of the Games Workshop group.  If you have any questions, complaints or requests please make contact with our Data Protection Manager by email: privacy@gwplc.com.