Copper & Silk Ltd values our customers and their privacy, we understand that you entrust us with information that is personal to you and so we treat that information with the upmost respect. We have described how we will use your information below that is consistent with our obligations and your rights under the law.
1. INFORMATION ABOUT US
Copper & Silk ltd
Registered in England under company number 11206352.
Registered address: 23A Tontine Street, Folkestone, Kent, CT20 1JT
Main trading address: as above
VAT number: GB 294 8535 54
2. WHAT DOES THIS NOTICE COVER?
This Privacy Information explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.
3. WHAT IS PERSONAL DATA?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
The personal data that we use is set out in Part 5, below.
4. WHAT ARE YOUR RIGHTS?
Under the GDPR, you have the following rights, which we will always work to uphold:
· The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 11.
· The right to access the personal data we hold about you. Part 10 will tell you how to do this.
· The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 11 to find out more.
· The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Part 11 to find out more.
· The right to restrict (i.e. prevent) the processing of your personal data.
· The right to object to us using your personal data for a particular purpose or purposes.
· The right to data portability. This means that, if you have provided personal data to us directly, we am using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
· Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 11.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
5. WHAT PERSONAL DATA DO WE COLLECT?
We may collect some or all of the following personal data (this may vary according to your relationship with us):
· Email address;
· Telephone number;
· Business name;
· Job title;
· Payment information;
· Order and enquiry history.
We do not collect or hold sensitive information.
We mainly collect this data directly from our clients but in some cases we may supplement it through information we collect about you from publically available sources such as your website.
By providing your personal information to Copper & Silk ltd you agree that you would like to receive new product information and promotions. You are not obligated to provide Copper & Silk Ltd with any information or participate in any of the services we offer. As such, we will consider any information we collect directly from you as having been provided voluntarily.
6. HOW DO WE USE YOUR PERSONAL DATA?
Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data may be used for one of the following purposes:
· Providing and managing your account.
· Supplying our products to you. Your personal details are required in order for us to enter into a contract with you.
· Personalising and tailoring our products for you.
· Communicating with you. This may include responding to emails or calls from you.
· Supplying you with information by email and / or post that we believe may be of legitimate interest to you, and from which you may unsubscribe or opt-out at any time by clicking the unsubscribe link or by contacting us directly.
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email or telephone or post with information, news, and offers on our products and services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.
The legal bases for which we collect and store your personal information are as follows:
· Legitimate Interest. In most cases Copper & Silk Ltd will process your personal information in the legitimate interest of providing you with a sales and marketing service. We will hold, collect and process your personal information so long as it does not infringe nor impact your rights, freedom or interests.
· Contractual obligations. In certain circumstances, we may need your personal information to comply with our contractual obligations.
· Legal compliance. Where the law requires us to, we may need to collect, process and disclose your personal information to comply with a statutory or legal requirement.
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. The following factors will be used to determine how long your personal data is kept):
· Likely relevance to you and benefit to you of continuing to be in contact with us.
· Government and regulatory requirements, e.g. VAT records requirement
8. HOW AND WHERE DO WE STORE AND TRANSFER YOUR PERSONAL DATA?
We share your data with external third parties, as detailed below in Part 9, that are based outside of the EEA. The following safeguards are applied to such transfers:
We take appropriate steps to ensure your information is kept secure at all times. We have technology and organisational safeguards in place to protect against the loss, destruction, misuse, disclosure and unauthorised access to personal information under our control. Unfortunately, the transmission of information via the internet cannot be guaranteed secure. Whilst we will do our best to protect your personal information, we cannot guarantee the security of your information 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.
9. DO WE SHARE YOUR PERSONAL DATA?
We may sometimes contract with the following third parties to supply services to you on our behalf. These may include payment processing, delivery, and marketing. In some cases, those third parties may require access to some or all of your personal data that we hold.
· Barclays bank PLC for payment processing
· DPD for delivery
· Post office for delivery
· Freight forwarders if appropriate – we will let you know the name of the freight forwarder if we are using one
· Sales agents for sales and marketing
· Mailchimp for the creation of marketing campaigns
· Campaign Monitor for marketing
If any of your personal data is required by a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 8.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
We will never sell your information to third parties or use the information for purposes other than those outlined in this policy.
10. HOW CAN YOU ACCESS YOUR PERSONAL DATA?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 11. To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
11. HOW TO CONTACT US
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details (for the attention of Daniel Fosbery):
Email address: email@example.com
Telephone number: +44 (0) 20 8459 8772
Postal Address: 23A Tontine Street, Folkestone, Kent, CT20 1JT
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