PRIVACY POLICY

1. Introduction
2. What personal information do we collect?
3. Who do we share your information with?
4. Data Security
5. Careers
6. CCTV
7. Cookies
8. Your rights
9. Changes to this Privacy Policy

Introduction

Colwick (“we” or “us”) values its users’ privacy and we strive to protect the privacy of all personally identifiable information collected during the course of providing services and it’s important to know how we process your data. This Policy sets out what information we might collect from a registered user or other visitor (“you”) and what we will do with it. By using our services or providing us with information, you consent to the collection, use and transfer of your information under the terms of this policy and also agree to be bound by our Terms and Conditions.
Please note that this privacy policy does not govern the collection and use of information by companies that Colwick Ltd does not control, nor by individuals not employed or managed by us. If you visit a website that we mention or link to, be sure to review its privacy policy before providing the site with information.

What Personal Information do we collect?

We may collect and process the following data:
• Information you provide to us by filling in forms on our web site / customer portal
• Information collected through correspondence with our Sales and/or Customer Relations teams
• Information you provide for loyalty purposes
• Information you provide to us through the recruitment process
• Information you provide to us in order to register for alerts
• Social Media interaction
• CCTV on our site
• Statistical data about your browsing actions and patterns for the administration of your application for employment with Colwick Ltd.
We may require you to submit personally identifiable information in order for you to make use of our services. Personally Identifiable Information (“PII”) means any information that can be used to identify you as an individual, such as, for example;
• Your name, company, email address, phone number, billing address and shipping address;
• Your Smart Vault user ID and password
• Credit / Debit card information;
• Account preference information that you provide;
• Your computer’s domain name and IP address, indicating where your computer is located on the internet
• Session data for your login session.
You confirm that any information you enter will be true. We will only request and collect information which is necessary or reasonable in order to provide you with your requested services and to improve the services that we provide. It will not be a requirement to provide any additional information which is not needed to provide the services.
If you elect not to provide PII to us, we reserve the right not to register you as a user and may not be able to provide you with our products or services.

Use of information collected

The personal information you provide is used for operational purposes only, for example, producing invoices, processing payments or confirming orders, collection or delivery purposes, and to personalise your customer experience and to make recommendations to you about products and services that we think may be of interest to you.
We and/or our authorised third parties may also use your personal information: (a) for internal market research and analysis purposes; (b) to carry out survey related activities with you, and (c) dealing with any complaints, refunds and other collection or delivery issues.

Who do we share your information with?

The information you provide to us may be accessed by our staff, business partners and carefully selected third parties in the course of providing services. We may also use information in aggregate, where personally identifiable information is removed, for marketing and strategic development to improve and support our business.
Some of your information may be transferred out of the European Economic Area (EEA), where data protection laws are not as strong. We will however make every effort to ensure that third parties comply with this policy and the Data Protection Act as much as possible.
The Company will not share or distribute any of the information you provide to us to unaffiliated third parties without receiving your consent, unless required to do so by Law.

Data Security

We employ administrative, electronic and physical security measures to ensure that the information that we collect about you is protected from access by unauthorised persons and protected against unlawful processing, accidental loss, destruction and damage. We do this by having in place a range of appropriate technical and organisational measures to deal with any security breaches.
By using our website and/or services you acknowledge and agree that, except to the extent required by the Data Protection laws, we shall not be responsible for any unauthorised use, distribution, damage or destruction of personal data. We will only retain your information for a reasonable period or as long as is required by law.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of the data transmitted to our site; any transmission is at your own risk. However, we promise to notify the relevant authorities of data breaches and will notify you if there are any threats to your rights or interests.
If you have an account with us, note that you must keep your username and password secret.

Careers

Some of the information you provide to us when applying for vacancies through our careers service may be sensitive personal data which requires your explicit consent to permit us to process it. If you do not tick the box on the application form confirming that you accept the declaration then we will not be able to accept your application.
We will only use this data:
1. for confirming your suitability for the work that you carry out, including any checks that are required by us or any other body to be made with the Criminal Records Bureau which may result in us retaining information about criminal convictions;
2. in connection with your health including screening and making decisions based on any health records which may be collected by, or transferred to us;
3. for any statutory requirements relating to you or your application;
4. for monitoring our selection processes;
5. to transfer to your employee file if your application is successful;
6. for retention following the outcome of any unsuccessful application.

CCTV

We employ CCTV at our site in order to:
• prevent, deter and detect crime
• apprehend and prosecute offenders, and provide evidence to take civil action in the courts
• help provide a safer environment for our staff
• protect public safety
• help to provide improved customer service, for example by enabling staff to see customers requiring assistance
• monitor operational and safety related incidents
• assist with the verification of claims
You have the right to make a Subject Access Request for CCTV images of yourself and to ask for a copy of them. We are entitled by law to charge an administrative fee for this and you will need to complete an application form provided by us in order for us to establish your identity as the person in the pictures and assist us in finding the images in our system.
Such requests should be directed to info@colwick.org
We reserve the right to withhold information where permissible by the Data Protection Act and we will only retain CCTV images for a reasonable period or as long as is required by law. In certain circumstances we may need to disclose CCTV images for legal reasons. When this is done there is a requirement for the organisation that has received the images to adhere to the Data Protection Act.

Your rights

One of the GDPR main objectives is to protect and clarify the rights of individuals with regards to data privacy. This means that you retain various rights in respect of your data, even when you have given it to us.
Data Subject Access Request (DSARS)
You have the right to request to see the personal information that we hold on you, as well as request that inaccurate information be corrected and you have the right to withdraw your consent. We will not charge you for this unless your request is ‘unfounded or excessive’. We may apply a small administration fee for any duplicate copies requested.
Any request to update incorrect information or to opt-out of any communications that you initially agreed to receive should be directed to info@colwick.org.
To get in touch about these rights:
• We may require proof of your identity before we supply the information to you.
• We will seek to deal with your request without undue delay and in any event within one month (subject to any extensions we are required by law).
• Please note that we will keep a record of your communications to help us deal with your query.
Right to Object:
This right enables you to object to us processing your personal data where we do so for one of the following four reasons:
1. Our legitimate interests; (mostly applicable to our web users, suppliers and clients)
2. To enable us to perform a task in the public interest;
3. To send you direct marketing materials; and (mostly applicable to our web users, suppliers and clients)
4. For scientific, historical research or statistical purposes
Upon your request to object, we will cease the activity in question unless we can show that;
• We have compelling legitimate grounds for processing which overrides your interests; or
• We are processing your data for the establishment, exercise of defence of a legal claim
• If your objection relates to direct marketing, then we must act on your objection and cease this activity.
Right to Withdraw Consent:
• Where we have gained your consent to process your personal data for certain activities, for example for marketing activities, you may withdraw this consent at any time and we must act on your request to withdraw consent and cease this activity. Should we consider that there is an alternative reason to justify our continued processing of your data for this purpose, in which case we will inform you of this condition.
Right to Erasure:
• You have the right to request that we erase your personal data in certain circumstances, normally the information must meet one of the following criteria;
– The data is no longer necessary for the purpose in which we originally collected and processed it;
– Where previously given, you have withdrawn your consent to us processing your data, and there is no other valid reason for us to continue processing.
– The data has been processed unlawfully (not compliant with the GDPR)
– If we believe we have a legitimate interest and we are unable to demonstrate any overriding legitimate reason to continue processing
Right to Restrict Processing:
In certain circumstances, you can request that we restrict processing of your personal data, such as where data is inaccurate (until rectified), object to our legitimate interests (until verification). This means that we can only store data and we will not be able to continue with processing activity until resolution, you consent, or is necessary for legal reasons.
We will ensure that 3rd Parties are informed of any restrictions, rectifications, withdrawal of consent, and erasures.

Children

We do not intend to collect or knowingly collect information from children. We do not target children with our services.

Cookies and other Technologies we use

We use cookies and/or similar technologies to analyse customer behaviour, administer the website, track users’ movements, and to collect information about users. This is done in order to personalise and enhance your experience with us.
A cookie is a tiny text file stored on your computer. Cookies store information that is used to help make sites work. Only we can access the cookies created by our website. You can control your cookies at the browser level. Choosing to disable cookies may hinder your use of certain functions.
We use cookies for the following purposes:
• Necessary cookies – these cookies are required for you to be able to use some important features on our website, such as logging in. These cookies don’t collect any personal information.
• Functionality cookies – these cookies provide functionality that makes using our service more convenient and makes providing more personalised features possible. For example, they might remember your name and e-mail in comment forms so you don’t have to re-enter this information next time when commenting.
• Analytics cookies – these cookies are used to track the use and performance of our website and services
• Advertising cookies – these cookies are used to deliver advertisements that are relevant to you and to your interests. In addition, they are used to limit the number of times you see an advertisement. They are usually placed to the website by advertising networks with the website operator’s permission. These cookies remember that you have visited a website and this information is shared with other organisations such as advertisers. Often targeting or advertising cookies will be linked to site functionality provided by the other organisation.
You can remove cookies stored in your computer via your browser settings. Alternatively, you can control some 3rd party cookies by using a privacy enhancement platform such as optout.aboutads.info or youronlinechoices.com. For more information about cookies, visit allaboutcookies.org.
We use Google Analytics to measure traffic on our website. Google has their own Privacy Policy which you can review here. If you’d like to opt out of tracking by Google Analytics, visit the Google Analytics opt-out page.

Changes to this Privacy Policy

We reserve the right to update and amend the Privacy Policy. All such developments will be notified to you by updating this Privacy Policy.
This policy was last updated on 15/05/2018