GDPR DATA PRIVACY NOTICE
This is privacy notice of CWMNI CURIAD CYF, trading as
CYHOEDDIADAU CURIAD..
We respect your privacy and are determined to protect your
personal data. The purpose of this privacy notice is to inform you as to how we
look after your personal data when you visit our website (regardless of where
you visit it from). We’ll also tell you about your privacy rights and how the
data protection law protects you.
This privacy notice is provided in a layered format so you
can click through to the specific areas set out below.
1. WHO WE ARE AND
IMPORTANT INFORMATION
2. THE PERSONAL DATA
WE COLLECT ABOUT YOU
3. HOW WE COLLECT
YOUR PERSONAL DATA
4. HOW WE USE YOUR
PERSONAL DATA
5. WHO WE SHARE YOUR
PERSONAL DATA WITH
6. INTERNATIONAL
TRANSFERS
7. DATA SECURITY
8. DATA RETENTION
9. YOUR LEGAL RIGHTS
10. CHANGES TO THIS NOTICE AND YOUR DUTY TO
INFORM US OF CHANGES
11. QUERIES, REQUESTS
OR CONCERNS
1. WHO WE ARE AND
IMPORTANT INFORMATION
What is the
purpose of this privacy notice?
This privacy notice aims to give you information on how we
collect and process your personal data through your use of this website,
including any data you may provide through this website when you purchase a
product or service, sign up to our mailing list or newsletter.
This website is not intended for children and we do not
knowingly collect data relating to children.
You must read this privacy notice together with any other
privacy notice we may provide on specific occasions when we are collecting or
processing personal data about you so that you are fully aware of how and why
we are using your data. This privacy notice supplements the other notices and
is not intended to override them.
Data controller(s)
Curiad is the controller and responsible for your personal
data (collectively referred to as Cyhoeddiadau Curiad, "we",
"us" or "our" in this privacy notice). Our contact details
are Uned 2 & 6, Capel Salem, Talysarn, Gwynedd LL54 6AB, 01286 882166,
email - curiad@curiad.co.uk. For all data
matters contact Curiad.
Third-party links
outside of our control
This website may include links to third-party websites,
plug-ins and applications. Clicking on those links or enabling those
connections may allow third parties to collect or share data about you. We do
not control these third-party websites and are not responsible for their
privacy statements.
When you leave our website, we encourage you to read the
privacy notice of every website you visit.
2. THE PERSONAL DATA
WE COLLECT ABOUT YOU
Personal data, or personal information, means any
information about an individual from which that person can be identified. You
can find out more about personal data from the
Information
Commissioners Office
.
We may collect, use, store and transfer different kinds of
personal data about you which we have grouped together follows :
●
Identity
Data
includes Title, First and last name, Username.
●
Contact
Data
includes Billing address, delivery address, email address,
telephone number
.
●
Financial
Data
includes Bank account and payment card details.
●
Transaction
Data
includes details of payments to and from you and other details of
products and services you have purchased from us.
●
Technical
data
includes IP address, your login data, browser type and version,
location, operating system and platform and other technology on the devices you
use to access the website.
●
Profile
data
includes your username and password, purchases or orders made by you,
your interests, preferences and feedback.
●
Usage
data
includes information about how you use our website, products and
services.
●
Marketing
and Communications Data
includes your preferences in receiving marketing
from us and our third parties, and your communication preferences.
We do not collect any Special Categories of Personal Data about you (this includes
details about your race or ethnicity, religious or philosophical beliefs, sex
life, sexual orientation, political opinions, trade union membership,
information about your health and genetic and biometric data). Nor do we
collect any information about criminal convictions and offences.
If you fail to
provide personal data
Where we need to collect your personal data by law, or under
the terms of a contract we have with you and you fail to provide that data when
requested, we may not be able to perform the contract we have or are trying to
enter into with you (for example, to provide you with goods or services). In
this case, we may have to cancel a product or service you have with us but we
will notify you if this is the case at the time.
3. HOW WE COLLECT
YOUR PERSONAL DATA
We use different methods to collect data from and about you
including through:
●
Directly. You may give us your
name, contact details and bank details by filling in forms or by corresponding
with us by post, phone, email or otherwise. This includes personal data you
provide when you :
●
Order and purchase our goods or services;
●
Create an account on our website;
●
Subscribe to our service or publications;
●
Request marketing to be sent to you.
Automated
technologies or interactions.
As you interact with our website, we may
automatically collect Technical Data about your equipment, browsing actions and
patterns. We collect this personal data by using cookies and other similar
technologies. Please see our
cookie policy for further details.
Third parties or
publicly available sources.
We may receive personal data about you from
various third parties (and public sources) as set out below:
●
Technical data from the following parties; (a)
Analytics providers such as Google; (b) Search information providers such as
Google.
●
Contact, Financial and Transaction Data from
providers of technical, payment and delivery services such as Worldpay and
Sagepay.
4. HOW WE USE YOUR
PERSONAL DATA
We will only use your personal data when the law allows us
to. Most commonly, we will use your personal data in the following
circumstances:
●
To register you as a new customer
●
To process and deliver your order
●
Performance of Contract this means
processing your data where it is necessary for the performance of a contract to
which you are a party or to take steps at your request before entering into
such a contract.
●
Manage payments, fees and charges.
●
Asking you to leave a review or take a survey.
●
Collect and recover money owed to us.
●
Legitimate Interest this
means the interest of our business in conducting and managing our business to
enable us to give you the best service/product and the most secure experience.
We make sure we consider and balance any potential impact on you (both positive
and negative) and your rights before we process your personal data for our
legitimate interests. We do not use your personal data for activities where our
interests are overridden by the impact on you (unless we have your consent or
are otherwise required or permitted to by law). You can obtain further
information about how we assess our legitimate interests against any potential
impact on you in respect of specific activities by contacting Curiad.
●
Comply with a legal or regulatory obligation this means processing your personal data where it is
necessary for compliance with a legal or regulatory obligation that we are
subject to.
GENERALLY WE DO NOT
RELY ON CONSENT AS A LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA OTHER THAN
IN RELATION TO SENDING THIRD PARTY DIRECT MARKETING COMMUNICATIONS TO YOU VIA
EMAIL OR TEXT MESSAGE. YOU HAVE THE RIGHT TO WITHDRAW CONSENT TO MARKETING AT
ANY TIME BY CONTACTING US AT CURIAD AND REQUESTING TO SPEAK WITH THE
DATA PROTECTION OFFICER OR DATA REPRESENTATIVE.
PURPOSES FOR WHICH WE
WILL USE YOUR PERSONAL DATA
We have set out below, in a table format, a description of
all the ways we plan to use your personal data, with the legal bases we rely on
to do so.
Note that we may process your personal data for more than
one lawful ground depending on the specific purpose for which we are using your
data. Please contact us at Curiad and request to speak with the Data
protection officer if you need details about the specific legal ground we are
relying on to process your personal data where more than one ground has been
set out in the table below.
Purpose/Activity | Type of data | Lawful basis for
processing including basis of legitimate interest
|
To register you as a new customer To process
and deliver your order
Marketing
and communication
| (a) Identity (b) Contact (a)Contact (b) Bank details (a) Identity (b) Contact (c) Preferences and previous purchases | Performance of a contract with you Performance of a contract with you Necessary for our legitimate interest to develop our
products and to grow our business.
|
Marketing
We strive to provide you with choices regarding certain
personal data uses, particularly around marketing and advertising.
[Promotional
offers from us
We may use your Identity, Contact, Technical, Usage and
Profile Data to form a view on what we think you may want or need, or what may
be of interest to you. This is how we decide which products, services and
offers may be relevant for you.
You will receive marketing communications from us if you
have requested information from us or purchased goods or services from us or if
you provided us with your details by filling in a form online or at a
conference or trade stand and, in each case, you have not opted out of
receiving that marketing.
Third-party
marketing
We will get your express opt-in consent before we share your
personal data with any company outside the Curiad group of companies for
marketing purposes.
Opting out
You can ask us or third parties to stop sending you
marketing messages at any time by logging into the website and checking or
unchecking relevant boxes to adjust your marketing preferences.Where you opt
out of receiving these marketing messages, this will not apply to personal data
provided to us as a result of a product/service purchase or other transaction.
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see cookie policy
Change of purpose
We will only use your personal data 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 you
wish to get an explanation as to how the processing for the new purpose is
compatible with the original purpose, please contact Curiad and request to
speak to the Data Protection Officer.
If we need to use your personal data for an unrelated
purpose, we will notify you and we will explain the legal basis which allows us
to do so.
Please note that we may process your personal data without
your knowledge or consent, in compliance with the above rules, where this is
required or permitted by law.
5. WHO WE SHARE YOUR
PERSONAL DATA WITH
We may have to share your personal data with the parties set
out below for the purposes set out in the table in paragraph 4 above.
●
Internal
Third Parties who deal with processing orders and dispatching.
●
External
Third Parties Service
●
Providers acting as processors based in the
United Kingdom who provide IT and system administration services.
●
Professional advisers acting as processors,
including lawyers, bankers, auditors and insurers based in the United Kingdom
who provide banking, legal, insurance and accounting services.
●
HM Revenue & Customs, regulators and other
authorities acting as processors or joint controllers based in the United
Kingdom who require reporting of processing activities in certain
circumstances.
●
Third
parties to whom we may choose to sell, transfer, or merge parts of our business
or our assets. Alternatively, we may seek to acquire other businesses or merge
with them. If a change happens to our business, then the new owners may use
your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your
personal data and to treat it in accordance with the law. We do not allow our
third-party service providers to use your personal data for their own purposes
and only permit them to process your personal data for specified purposes and
in accordance with our instructions.
6. INTERNATIONAL
TRANSFERS
We share your personal data with Mailchimp who have servers
that are US based but can lawfully receive EU data.
7. DATA SECURITY
We have put in place appropriate security measures to
prevent your personal data from being accidentally lost, used or accessed in an
unauthorised way, altered or disclosed. In addition, we limit access to your
personal data to those employees, agents, contractors and other third parties
who have a business need to know. They will only process your personal data on
our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected
personal data breach and will notify you and any applicable regulator of a
breach where we are legally required to do so.
8. DATA RETENTION
We will only retain your personal data 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.
In some circumstances you can ask us to delete your data:
see
Your legal rights below for
further information.
In some circumstances we may anonymise your personal data
(so that it can no longer be associated with you) for research or statistical
purposes in which case we may use this information indefinitely without further
notice to you.
9. YOUR LEGAL RIGHTS
Unless
subject to an exemption under the data protection laws, you have the following
rights with respect to your personal data:
●
The right to request a
copy of the personal data which we hold about you;
●
The right to request
that we correct any personal data if it is found to be inaccurate or out of
date;
●
The right to request
your personal data is erased where it is no longer necessary to retain such
data;
●
The right to withdraw
your consent to the processing at any time, where consent was the lawful basis
for processing your data;
●
The right to request
that we provide you with your personal data and where possible, to transmit
that data directly to another data controller, (known as the right to data
portability), where applicable 9i.e. where our processing is based on consent
or is necessary for the performance of our contract with you or where we
process your data by automated means);
●
The right, where there
is a dispute in relation to the accuracy or processing of your personal data,
to request a restriction is placed on further processing;
●
The right to object to
our processing of personal data, where applicable i.e. where processing is
based on our legitimate interests (or in performance of a task in the public
interest/exercise of official authority); direct marketing or processing for the
purposes of scientific/historical research and statistics).
If you wish to exercise any of the rights set out above,
please contact Curiad and request to speak with the Data protection
officer.
No fee required –
with some exceptions
You will not have to pay a fee to access your personal data
(or to exercise any of the other rights). However, we may charge a reasonable
admin fee if your request is clearly unfounded, repetitive or excessive.
Alternatively, we may refuse to comply with your request in these circumstances.
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 your personal data (or
to exercise any of your other rights). This is a security measure to ensure
that personal data is not disclosed to any person who has no right to receive
it. We may also contact you to ask you for further information in relation to
your request to speed up our response.
Time limit to
respond
We try to respond to all legitimate requests within one
month. Occasionally it may take us longer than a month if your request is
particularly complex or you have made a number of requests. In this case, we
will notify you and keep you updated.
10. CHANGES TO THIS NOTICE AND YOUR DUTY TO
INFORM US OF CHANGES
THis version was last updated on December 8 2018. Please
keep us informed if your personal data changes during your relationship with
us. It is important that the personal data we hold about you is accurate and
current.
11. QUERIES, REQUESTS OR CONCERNS
To exercise all relevant rights, queries or complaints in
relation to this policy or any other data protection matter between you and us,
please in the first instance contact our Data protection officer. If this does
not resolve your complaint to your satisfaction, you have the right to lodge a
complaint with the
Information
Commissioners Office
on 03031231113 or via email https://ico.org.uk/global/contact-us/email/
or at the Information Commissioner's Office, Wycliffe House, Water Lane,
Wilmslow, Cheshire, SK9 5AF, England, UK.
Please note - LHS
Solicitors owns the copyright in this document. You must not use this
document in any way that infringes the intellectual property rights in
it. You may download and print this document which you may then use, copy
or reproduce for your own
internal non-profit making purposes. However,
under no circumstances are you permitted to use, copy or reproduce this
document with a view to profit or gain. In addition, you must not sell or
distribute this document to third parties who are not members of your
organisation, whether for monetary payment or otherwise.
The content of this document has been written with best
practices in mind, however this is not a substitute for taking legal advice on
your circumstances. If you do require specific advice, get in touch with us and
we’ll be happy to assist you.