PRIVACY STATEMENT
GDPR Privacy Policy and Notice
Throughout this notice ‘Cobblers and Keys Limited’ (to be referred in this document as the company) and also trades as the following:
• Katies Custom Gifts
• CK Locksmiths
• Trophysuperstore
WHAT IS THE PURPOSE OF THIS DOCUMENT?
Cobblers and Keys Limited’ is committed to protecting the privacy and security of your personal information.
This privacy notice describes how we collect and use personal information about you during and after your working relationship with us, in accordance with the General Data Protection Regulation (GDPR).
Cobblers and Keys Limited’ is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.
This notice applies to current and former customers. This notice does not form part of a contract to provide services. We may update this notice at any time.
It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you so that you are aware of how and why we are using such information.
DATA PROTECTION PRINCIPLES
We will comply with data protection law. This says that the personal information we hold about you must be:
• Used lawfully, fairly and in a transparent way.
• Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
• Relevant to the purposes we have told you about and limited only to those purposes. • Accurate and kept up to date.
• Kept only as long as necessary for the purposes we have told you about. • Kept securely.
THE KIND OF INFORMATION WE HOLD ABOUT YOU
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).
There are “special categories” of more sensitive personal data which require a higher level of protection, but we will not collect, store or use such data.
We may collect, store, and use the following categories of personal information about you:
• Name
• Address
• Contact Numbers
• Email Address
• Bank Details
HOW IS YOUR PERSONAL INFORMATION COLLECTED?
We typically collect personal information about customers through the request for sales activity. We may sometimes collect additional information from third parties when requesting credit references.
HOW WE WILL USE INFORMATION ABOUT YOU
We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
• Where we need to perform the contract, we have entered into with you. • Where we need to comply with a legal obligation.
• 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.
Situations in which we will use your personal information
We need all the categories of information in the list above (see earlier paragraph) primarily to allow us to perform our contract with you, and to enable us to comply with legal obligations. We will also use your personal information to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests. The situations in which we will process your personal information are listed below.
• To set up your account for invoicing
• Process your orders
• Manage your account and provide customer services to you.
WHO WE SHARE YOUR INFORMATION WITH AND WHY
Delivery Partners
In order for you to receive your goods, we work with a number of delivery partners. We will only pass limited information to them in order to ensure delivery of your items.
IT Companies
We work with businesses who support our website and other business systems.
Payment Processing
We work with trusted third party payment processing providers in order to take and manage payments securely.
Credit References
If you are applying for a credit account with us, we will share your details with any referees you may have provided us with.
Debt Recovery
We work with a trusted third party in order to perform debt collection services securely. DATA SHARING
We may have to share your data with third parties, including third-party service providers and other entities in the company.
We require third parties to respect the security of your data and to treat it in accordance with the law.
We may transfer your personal information outside the EU.
If we do, you can expect a similar degree of protection in respect of your personal information. Why might you share my personal information with third parties?
We may share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so.
Which third-party service providers process my personal information?
”Third parties” includes third-party service providers (including contractors and designated agents) and other entities within the company.
How secure is my information with third-party service providers and other entities in our company?
All our third-party service providers and other entities in the company are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
When might you share my personal information with other entities in the company?
We will share your personal information with other entities in our company as part of our regular reporting activities on company performance, in the context of a business reorganisation or company restructuring exercise, for system maintenance support and hosting of data.
What about other third parties?
We may share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal information with a regulator or to otherwise comply with the law.
Links to other websites
Our website contains links to other websites. Once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting
such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.
DATA SECURITY
We have put in place measures to protect the security of your information. Details of these measures are available upon request.
Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions, and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
COOKIES
Cookies are not used on our website.
DATA RETENTION
How long will you use my information for?
We will only retain your personal information 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. 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.
RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RESTRICTION
Your duty to inform us of changes
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.
Your data protection rights
Under data protection law, you have rights including:
Your right of access - You have the right to ask us for copies of your personal information.
Your right to rectification - You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
Your right to erasure - You have the right to ask us to erase your personal information in certain circumstances.
Your right to restriction of processing - You have the right to ask us to restrict the processing of your personal information in certain circumstances.
Your right to object to processing - You have the the right to object to the processing of your personal information in certain circumstances.
Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.
You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.
Please contact us if you wish to make a request.
Our contact details
Name: Michael Evans Address: 11 Borehamgate Precinct, King Street, Sudbury, Suffolk. CO10 2EG Phone Number:07756316719 E-mail:mike@cobblersandkeysltd.co.uk
No fee usually required
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances. We will respond to your request to access your personal information within one month of receiving the request.
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 the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
RIGHT TO WITHDRAW CONSENT
In the limited circumstances where you may have provided your consent to the collection, processing, and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please email mike@cobblersandkeysltd.co.uk. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
RIGHT TO COMPLAIN
You have a right to lodge a complaint with a data protection regulator in Europe, in particular in a country you work or live or where your legal rights have been infringed. The contact details for the Information Commissioner’s Office (ICO), the data protection regulator in the UK, are available on the ICO website www.ico.org.uk, however, we would encourage you to contact us before
making a complaint and we will seek to resolve any issues or concerns you may have. CHANGES TO THIS PRIVACY NOTICE
We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.
If you have any questions about this privacy notice, please contact the following:
Name: Michael Evans Address: 11 Borehamgate Precinct, King Street, Sudbury, Suffolk. CO10 2EG Phone Number:07756316719 E-mail:mike@cobblersandkeysltd.co.uk