- Our details
- How we collect or obtain personal information about you
- Personal information we collect or obtain about you
- How we use your personal information
- How long we retain your personal information
- How we secure your personal information
- Your rights in relation to your personal information
- Your right to object to the processing of your personal information for certain purposes
- Consequences of not providing your personal information to us
- Changes to your information
- Children’s Privacy
- California Do Not Track Disclosures
- Copyright, credit and logo
- Data controller: David Knight
- How we collect or obtain your information:
- when you provide it to us (e.g. by contacting us, completing a checkout process, placing an order on our website, signing up to our newsletter, )
- from your use of our website, using cookies
- Personal information we collect: name, contact details, information about your computer (e.g. your IP address and browser type), payment information (e.g. your credit or debit card details when making payment through our website), information about how you use our website (e.g. which pages you have viewed, the time you viewed them, and what you clicked on), information about your mobile device (such as your geographical location).
- How we use your personal information: for administrative and business purposes (particularly to contact you and process orders you place on our website), to improve our business and website, for advertising and analytical purposes, in connection with our legal rights and obligations and for certain additional purposes only with your explicit consent.
- Disclosure of your personal information to third parties: only to the extent necessary to run our business, fulfil any contracts we enter into with you, where required by law or to enforce our legal rights.
- Do we sell personal information to third parties: No
- How long we retain your personal information: for no longer than necessary, taking into account any legal obligations we have (e.g. to maintain records for tax purposes) and any other legal basis we have for using your personal information e.g. your consent, performance of a contract with you or our legitimate interests as a business.
- How we secure your personal information: using appropriate technical and organisational measures such as storing your personal information on secure servers.
- Transfers of your personal information outside the European Economic Area: we will not transfer your personal information outside of the European Economic Area.
- Your rights in relation to your personal information
- to access your personal information and to be informed about its use
- to correct your personal information
- to have your personal information deleted
- to restrict the use of your personal information
- to object to the use of your personal information
- to complain to a supervisory authority
- to withdraw your consent to the use of your personal information
- to use appropriate technical and organisational measures such as storing personal information on secure servers
- only granting access to personal information where necessary
- using a non-standard URL for logging in to the content management system
How we collect or obtain personal information about you
Information collected from you
We collect personal data about you. This means any information about an individual from which that person can be identified. This data is only collected from you when you provide it to us, such as through your use of our website and its features, when you contact us directly by email, phone, in writing, or via social media, when you order goods and services, when you use any of our other websites or applications or any other means by which you provide personal information to us.
Information received about you from third parties
We may receive information about you from third parties such as our affiliates, business partners, (where authorised or permitted by law) credit and fraud checking agencies, as well as third parties with whom we have had no prior contact.
Information collected from your use of our website
Personal information we collect or obtain about you
The type of information we collect about you includes information such as:
- your name;
- your email address;
- your address;
- your phone number;
- your payment information (e.g. your credit or debit card details);
- your IP address;
- information about your device (e.g. device and browser type);
- information about how you use our website (e.g. which pages you have viewed, the time you viewed them and what you clicked on);
- information about your mobile device (such as your geographical location);
Information received from you
When you contact us by email, the information we collect about you will be your name and email address and any other information you provide to us. When you contact us using the contact form on our website, we will collect:
- your name
- email address
We also collect any other information you provide to us, including any optional information.
Information received from third parties
- you already have the information;
- providing you with the information would prove impossible or would involve a disproportionate effort;
- we are under an EU or EU member state law obligation to obtain or disclose the information which provides appropriate measures to protect your legitimate interests; or
- we are obliged to keep the information confidential as a result of an obligation of professional secrecy regulated by EU or EU member state law.
- if we intend to use your personal information to communicate with you, at the point when we first communicate with you;
- if we envisage that we will disclose your personal information to a third party, when we disclose your personal information to that third party (at the latest); and
- in any other circumstances, within a reasonable period after obtaining your personal information (and in any event within one month at the latest), taking into account the specific circumstances in which we use your personal information.
How we use your personal information
We will only use your personal information when the law allows us. Most commonly, we will use your personal data in the following circumstances:
Administrative and business purposes
- Improving our website and business, including personalising our website and services for you and other customers. This is necessary for our legitimate interest of better understanding our customers’ and potential customers’ preferences and tailoring our website, products and services to their needs, preferences and desires.
- Providing you with offers relating to our products and services which are similar to the products and services which you purchased from us or were in negotiations to purchase from us (provided that you did not opt-out from receiving such communications either at the time or subsequently). This is necessary for our legitimate interest of direct marketing and advertising our products and services.
- Protecting our business and our business interests, including for the purposes of credit and background checks, fraud and website misuse prevention and debt recovery. This is necessary for our legitimate interests of preventing criminal activity such as fraud or money laundering, for ensuring that our website and services are not misused. Where we carry out credit and background checks, we will only carry out such checks to the extent that we are permitted or authorised by law to do so and to the minimum extent necessary.
- Communicating with our business advisors and legal representatives. This is necessary for our legitimate interests of obtaining legal or professional business advice. In such circumstances, we will only share your personal information where it is necessary to do so, to the minimum extent necessary, subject to appropriate confidentiality restrictions and on an anonymised basis wherever possible.
- Sharing your personal information with third parties, including service providers and data processors, which are either related to or associated with the running of our business (including to third parties within our corporate group from time to time), such as our business partners, insurers, accountants, affiliates, associates, suppliers, independent contractors, email providers, IT and web development service providers, . We will share your personal information with these third parties where it is necessary for our legitimate interest of running and managing our business effectively, fulfilling our contractual obligations (e.g. to our insurers) or for our own direct marketing purposes. Where you purchase goods or services from us or request that we take steps to do so, we may also need to share your personal information with such third parties in order to perform a contract which we have entered into with you or to take steps, at your request, to enter into a contract with you. Where we share your personal information with such third parties, we will do so strictly on a need-to-know basis, subject to appropriate confidentiality restrictions, on an anonymised basis as far as possible and only to the extent strictly necessary for any of these purposes.
- Ensuring physical, network and information security and integrity. This is necessary for our legitimate interest of ensuring that our IT systems and networks are secure and uncompromised, including, for example, preventing malware, viruses, bugs or other harmful code, preventing unauthorised access to our systems, and any form of attack on, or damage to, our IT systems and networks.
- In connection with disclosure requests and in the case of a business or share sale or sale or purchase of a business and/or assets, whether actual or potential. This is necessary for our legitimate interests of selling and/or ensuring and promoting the success of our business. Where we share your personal information with a prospective purchaser or seller, we will do so on a strictly need-to-know basis, subject to appropriate confidentiality restrictions, on an anonymised basis as far as possible and only to the extent strictly necessary for any of these purposes.
Advertising and analytical purposes
- Providing statistical information to third parties such as Google Analytics, . This is necessary for our and third parties’ legitimate interests of processing personal information for research purposes, including market research, better understanding our respective customers, and tailoring our respective products and services to their needs.
- Displaying advertisements to you and analysing the information we receive in relation to those advertisements. This is necessary for our own and for third parties’ legitimate interests in direct marketing and advertising our and their products and services respectively, and for market research purposes.
Legal and enforcement of legal rights
- Enforcing our legal rights. This is necessary for our legitimate interest of protecting our business and enforcing our contractual and other legal rights.
- Indicating possible criminal acts or threats to public security to a competent authority. This is necessary for our legitimate interest of preventing crime, for compliance with a legal obligation to which we are subject, in the general public interest or for the legitimate interests of governmental bodies and competent authorities that prevent crime.
- In connection with any legal or potential legal dispute or proceedings. This is necessary for our legitimate interest of resolving disputes and making such disclosures as are required by law or which we consider, acting reasonably, are required by law.
- Complying with laws, regulations and other legal requirements. We may need to use and process your personal information in order to comply with legal obligations to which we are subject. For example, we may require your personal information pursuant to a statutory obligation to conduct anti-money-laundering checks or to disclose your information to a court following receipt of a court order or subpoena. We may also need your personal information to comply with ongoing legal obligations, such as tax laws and regulations to which we are subject (where you have placed an order for goods or services with us for example).
The processing of your personal information to comply with legal obligations to which we are subject applies to legal obligations of other countries where they have been integrated into the legal framework of the United Kingdom, for example in the form of an international agreement which the United Kingdom has signed. Where the legal obligations of another country have not been so integrated, we will process your information to comply with such obligations where it is in our legitimate interest to do so.
Use of your personal information only where we have your consent
We will process your personal information for one or more of the following purpose(s) only where we have obtained your consent to do so:
- To provide you with offers relating to goods and services we offer from time to time.
Opting Out Where we process your personal information on the basis of your consent, you can withdraw your consent to such processing at any time by emailing us at email@example.com or writing to us at The Commercial Branch Ltd, 6 Ormond Terrace, Regent Street, Cheltenham, Gloucestershire, GL50 1HR.
How long we retain your personal information
In general, we will retain your information for no longer than necessary, taking into account the following:
- the purpose(s) for which we are processing your personal information, such as whether it is necessary to continue to store that information in order to continue to perform our obligations under a contract with you or for our legitimate interests;
- whether we have any legal obligation to continue to process your information, such as any record-keeping obligations imposed by applicable law; and
- whether we have any legal basis to continue to process your personal information, such as your consent.
Where you contact us with an enquiry, we will retain your information for as long as it takes to respond to and resolve your enquiry, and for 1 further month(s), after which point we will delete your information.
How we secure your personal information
We take appropriate technical and organisational measures to secure your personal information and to protect it against unauthorised or unlawful use or processing as well as against the accidental loss or destruction of, or damage to, your personal information, including:
- only sharing and providing access to your personal information to the minimum extent necessary, subject to confidentiality restrictions where appropriate, and on an anonymised basis wherever possible;
- using secure servers to store your personal information;
- verifying the identity of any individual who requests access to personal information prior to granting them access to personal information;
- only transferring your personal information via closed system or encrypted data transfers;
Transmission of information (including personal information) over the internet is not entirely secure, and if you submit any information to us over the internet (whether by email, via our website or any other means), you do so entirely at your own risk. We cannot be responsible for any costs, expenses, loss of profits, harm to reputation, damages, liabilities or any other form of loss or damage suffered by you as a result of your decision to transmit information to us by such means.
Your legal rights in relation to your personal information
You have the following rights in relation to your personal information, which you can exercise by writing to the following address: The Commercial Branch Ltd, 6 Ormond Terrace, Regent Street, Cheltenham, Gloucestershire, GL50 1HR or sending an email to firstname.lastname@example.org:
- to request access to your personal information and information related to our use and processing of your personal information;
- to request the correction or deletion of your personal information;
- to request that we restrict our use of your personal information;
- to receive personal information which you have provided to us in a structured, commonly used and machine-readable format (e.g. a CSV file) and the right to have that personal information transferred to another Data Controller (including a third party Data Controller);
- to object to the processing of your personal information for certain purposes (for further information, see the section below entitled ‘Your right to object to the processing of your personal information for certain purposes’); and
- to withdraw your consent to our use of your personal information at any time where we rely on your consent to use or process that personal information. If you withdraw your consent, this will not affect the lawfulness of our use and processing of your personal information on the basis of your consent before the point in time when you withdraw your consent.
You also have the right to lodge a complaint with a supervisory authority, which, for the purposes of the UK, is the Information Commissioner’s Office (ICO), the contact details of which are available here: https://ico.org.uk/global/contact-us/
Further information on your rights in relation to your personal data as an individual
For further information about your rights in relation to your personal information, including certain limitations which apply to some of those rights, please visit the following pages on the ICO’s website:
- https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/; and
You can also find out further information about your rights, as well as information on any limitations which apply to those rights, by reading the underlying legislation contained in Articles 12 to 22 and 34 of the General Data Protection Regulation (GDPR), which is available here: http://ec.europa.eu/justice/data-protection/reform/files/regulation_oj_en.pdf
Verifying your identity where you request access to personal information
Where you request access to personal information, we are required by law to use all reasonable measures to verify your identity before doing so. Where we possess appropriate information about you on file, we will attempt to verify your identity using that information. If it is not possible to identity you from such information, or if we have insufficient information about you, we may require original or certified copies of certain documentation in order to be able to verify your identity before we are able to provide you with access to your personal information. These steps are necessary to verify your identity in order to reduce the risk of identity fraud or identity theft by persons other than yourself asking for access to your personal information.
Your right to object to the processing of your personal information for certain purposes
You have the following rights in relation to your personal information, which you may exercise in the same way as you may exercise the rights in the preceding section (Your rights in relation to your personal information):
- to object to us using or processing your personal information where we use or process it in order to carry out a task in the public interest or for our legitimate interests, including ‘profiling’ (i.e. predicting your behaviour based on your personal information) based on any of these purposes; and
- to object to us using or processing your personal information for direct marketing purposes (including any automated evaluation we make about you or any of your characteristics as a person, to the extent that it is related to such direct marketing).
You may also exercise your right to object to us using or processing your personal information for direct marketing purposes by:
- clicking the unsubscribe link contained at the bottom of any marketing email we send to you and following the instructions which appear in your browser following your clicking on that link;
- sending an SMS message containing only the words “OPT OUT” in reply to any marketing communication we send by text message; or
- sending an email to email@example.com, asking that we stop sending you marketing communications or by including the words “OPT OUT”.
Whenever you object to direct marketing from us by a different communication method to that of the marketing communications you have received from us, you must provide us with your name and sufficient information to enable us to identify you in relation to the communications you have received (for example, if you have received text messages from us and you wish to unsubscribe by email, we may need you to provide us with your phone number in that email).
Consequences of not providing your personal information to us
Where you wish to purchase products or services from us, we require your personal information in order to enter into a contract with you. We may also require your personal information pursuant to a statutory obligation (in order to be able to send you an invoice for products and services you wish to order from us, for example). If you do not provide your personal information, we will not be able to enter into a contract with you or to provide you with those products or services.
Changes to your information
Please inform us of any changes to any information (including personal information) which we hold about you so we can keep the information we hold about you accurate and up-to-date.
Because we care about the safety and privacy of children online, we comply with the Children’s Online Privacy Protection Act of 1998 (COPPA). COPPA and its accompanying regulations protect the privacy of children using the internet. We do not knowingly contact or collect personal information from children under the age of 13. The website is not intended to solicit information of any kind from children under the age of 13. It is possible that we may receive information pertaining to children under the age of 13 by fraud or deception. If we are notified of this, as soon as we verify the information, we will immediately obtain the appropriate parental consent to use that information or, if we are unable to obtain such parental consent, we will delete the information from our servers. If you would like to notify us of our receipt of information about children under the age of 13, please do so by sending an email to firstname.lastname@example.org.
California Do Not Track Disclosures
“Do Not Track” is a privacy preference that users can set in their web browsers. When a user turns on a Do Not Track signal in their browser, the browser sends a message to websites requesting that they do not track the user. For information about Do Not Track, please visit www.allaboutdnt.org At this time, we do not respond to Do Not Track browser settings or signals. In addition, we may use other technology that is standard to the internet, such as pixel tags, web beacons, and other similar technologies, to track visitors to the website, or one of the affiliated pages. Those tools may be used by us and by third parties to collect information about you and your internet activity, even if you have turned on the Do Not Track signal.
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