privacy policy - version 1
1.
Introduction and Terms
[SC Dogs Distillery T/A Carron Farm] (“We” or “us”) are
committed to protecting and respecting your personal data and privacy.
This privacy policy relates to how we use and collect personal data from
you through your use of this website or when you purchase a product or service
from us. It also relates to our use of any personal information you provide to
us by telephone, in written correspondence (including letter and email), by SMS
and in person. Please note that this website and our services are not intended
for children under the age of 18 and we do not knowingly collect data relating
to children.
Whenever you provide personal data, we are legally obliged to use your information in line with all applicable laws concerning the protection of such information; including the Data Protection Act 1998 and 2018 (DPA), and The General Data Protection Regulation 2016 (GDPR) together, and with other subsequent laws “Data Protection Laws”.
This privacy policy also forms part of our terms of business and is not intended to override them. This policy may be amended or updated from time to time and any revisions will be posted to this page.
2.
WHO WE
ARE AND How to contact us
For the purpose of the Data Protection Laws, the data controller is [Julia Walder & Hannah Walder] [trading as Julia Walder & Hannah Walder]. If you want to request more information about our privacy policy or information regarding data protection you should contact us using the details provided below:
FAO: Privacy Officer
Carron Farm
Highertown
St Martins
Isles of Scilly
TR25 0QL
Email: info@carronfarm.co.uk
Telephone: 01720 422893
and
ask to speak to the Privacy Officer.
3.
The
data we collect about you
3.1
We
collect and process personal data. Typically the
personal data we collect and process will include identity, contract,
financial, transactional, technical, profile, usage and marketing and
communications data such as:
3.1.1 Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, gender and images.
3.1.2 Contact Data includes billing address, delivery address, email address and telephone numbers.
3.1.3 Financial Data includes bank account and payment card details.
3.1.4 Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
3.1.5 Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
3.1.6 Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
3.1.7 Usage Data includes information about how you use our website, products and services.
3.1.8 Marketing and Communications data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
Please note that we may collect and/or process other personal data from
time to time.
3.2
We also
collect, use and share aggregated data, such as statistical or demographic data
for any purpose. Aggregated data could be derived from your personal data, but
is not considered to be personal data in law as it will not directly or
indirectly reveal your identity. For example, we may aggregate your usage data
to calculate a percentage of users accessing a specific feature of our
services. However, if we combine or connect your aggregated data with your
personal data so that it can directly or indirectly identify you, we treat the
combined data as personal data which will be used solely in accordance with
this policy.
3.3
We do
not collect the following special categories of personal data about you:
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.
3.4
We only
collect data from you directly or via third parties (see the section Third Parties below).
4.
if you
fail to provide personal data
Where we need to collect 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 our 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.
5.1
We use
information held about you to:
5.1.1
carry
out our obligations arising from any contracts entered into between you and us
and provide our services;
5.1.2
carry
out feedback and research on our services; and
5.1.3
notify
you about changes to our services.
5.2 We never sell your data to third parties or allow third parties to contact you without your permission.
5.3 We share your data with third parties where there is a legal obligation for us to do so or we have identified a valid lawful basis as set out in the table below (please also see clause 7 below, lawful basis). We may process your personal data without your knowledge or consent where this is required or permitted by law.
5.4 You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you.
5.5 We have set out below in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. 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 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 user and customer |
Identity Contact |
Performance of a contract with you |
|
To process and deliver your order including: Manage payments, fees and charges Collect and recover money owed to us |
Identity Contact Financial Transaction Marketing and Communications |
Performance of a contract with you Necessary for our legitimate interests (to recover debts due to us) |
|
To manage our relationship with you which will include: Notifying you about changes to our terms or privacy policy Asking you to leave a review or take a survey |
Identity Contact Profile Marketing and Communications |
Performance of a contract with you Necessary to comply with a legal obligation Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) |
|
To enable you to partake in a prize draw, competition or complete a survey |
Identity Contact Profile Usage Marketing and Communications |
Performance of a contract with you Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) |
|
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data). |
Identity Contact Technical |
Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) Necessary to comply with a legal obligation |
|
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you |
Identity Contact Profile Usage Marketing and Communications Technical |
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) |
|
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences |
Technical Usage |
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
|
To make suggestions and recommendations to you about goods or services that may be of interest to you |
Identity Contact Technical Usage Profile Marketing and Communications |
Necessary for our legitimate interests (to develop our products/services and grow our business) |
6.
lawful
basis for processing
6.1 We only process your data (which may include providing it to a third party) where we have identified a valid lawful basis to do so. These are as follows:
6.1.1
Contractual
obligation – Where processing is necessary to comply with our obligations arising
out of a contract, for example, where you have bought products from us we will use the personal data you provide to fulfil our
contractual obligations e.g. taking payment /shipping.
6.1.2 Legitimate Interest - Where we use legitimate interests we will record our decision on making this decision. We rely on legitimate interest where processing of the data we hold on you does not, in our opinion, affect your rights or freedoms and is proportionate to our interests e.g. keeping you up to date with our latest products or obtaining your feedback on our service.
6.1.3 Consent – We will seek to obtain your consent to process your data outside our contractual obligations (see above) unless we have identified a Legitimate Interest (see above).
7.
THIRD
PARTIES and sharing information
7.1
We will
keep your information within the organisation except where disclosure is
required or permitted by law or when we use third party service providers (data
processors) to supply and support our services to you. We have contracts in place with our data
processors. This means that they cannot do anything with your personal data
unless we have instructed them to do so. They will not share your personal data
with any organisation apart from us. They will hold it securely and retain it
for the period we instruct.
7.2
Please
see below the list which sets out the categories of recipients of personal
data.
|
SERVICE PROVIDERS WHO MAY RECEIVE YOUR PERSONAL DATA |
|
IT Support Services |
|
Email Provider |
|
Website Provider |
|
Secure document disposal service |
|
Banks |
|
Online payment providers |
|
Accountants |
|
Solicitors |
|
Accounting Software Provider |
|
Feedback
aggregators and collectors |
|
Couriers
|
|
Marketing
Agencies |
7.3
In addition third parties may provide us with personal data and
they should only do so where the law allows them to.
Your data is stored by us and our processors in the UK or EEA. Where
your personal data is transferred outside of the UK or the EAA, we have ensured
that:
8.1.1 an adequacy decision has been made by the European Commission permitting the transfer of data to that country; or
8.1.2 standard contractual clauses (SCCs) are in place and we have received assurances that an adequate level of protection of the personal data is achieved (based on a case by case assessment of the circumstances of the transfer), including adequate technical and operational measures in place to protect the personal data.
9.
APPLICATIONS
to work for us
If you apply to work for us (directly or indirectly) in any role we may
receive data about you from third parties. In addition, we will keep the
details of your application and any additional information provided to us by
you or others during your application so that we can keep you informed of
future opportunities that you may be interested in. If you do not wish for us
to keep your details for this reason, please let us know by contacting us using
the details provided in this policy.
Our data retention policy is dictated by the Data Protection Laws and is
available for inspection by submitting a written request using the contact
details provided in this policy.
11.1 Under the Data Protection Laws your rights are:
11.1.1
To be
informed – We must make this privacy policy (sometimes referred to as a
privacy notice) available with the emphasis on transparency over how we process
your data.
11.1.2 Access – You are entitled to find out what details we may hold about you and why. We strive to be as open as we can be in terms of giving people access to their personal data. Individuals can find out if we hold any of their Personal Data by making a formal request under the Data Protection Laws. Such requests should be in writing to the contact details provided in this policy. If we do not hold information about you we will confirm this in writing at the earliest opportunity. If we do hold your personal data we will respond in writing within one calendar month of your request (where that request was submitted in accordance with this policy). The information we supply will:
(a) confirm that your data is being processed;
(b) verify the lawfulness and the purpose of the processing;
(c) confirm the categories of personal data being processed;
(d) confirm the type of recipient to whom the personal data have been or will be disclosed; and
(e) let you have a copy of the data in format we deem suitable or as reasonably required by you.
11.1.3 Rectification – We are obliged to correct or update your details. We will correct or update your data without delay provided you make the request in writing to the contact details provided in this policy, clearly specifying which data is incorrect or out of date.
11.1.4
Erasure –
This is also known as the request to be forgotten. Under Data Protection Laws
you have the right to erasure under specific circumstances. A request for your
personal data to be deleted will be decided on a case by case
basis and should be submitted in writing to the contact details provided in
this policy.
11.1.5 Restrict processing – You have the right to ‘block’ or suppress the processing by us of your personal data.
11.1.6 Portability – You have the right to obtain and reuse your personal data that you have provided to us.
11.1.7 Object – You have the right to object to us processing your data in relation to direct marketing and or profiling.
11.1.8
Rights in
relation to automated decision making and profiling – We do not use
automatic decision making or profiling.
11.2
Please
note that you may need to provide identification in order to prove who you are
if you wish to invoke any of your rights as provided by the Data Protection
Laws and as summarised above.
11.3
If you
agree, we will try to deal with your request informally, for example by providing
you with the specific information you need over the telephone.
We keep our privacy policy under regular review and you should check
back regularly to ensure you are aware of changes to it. We may display this
notice to you from time to time to help ensure you are aware of its contents.
You have the right to complain about the processing of your personal
data. Please contact us using the details provided above. If you are still
unsatisfied you have the right to complain to the Information Commissioners Office.