Candlebury understands that your privacy is important to you and that you care about how your personal data is used. I respect and value the privacy of everyone who visits this website, www.candlebury.co.uk and our subsidiary sites My Sites”) and will only collect and use personal data in ways that are described here, and in a way that is consistent with my obligations and your rights under the law.
- Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
|“Account”||means an account required to access and/or use certain areas and features of My Site;|
|“Cookie”||means a small text file placed on your computer or device by My Site when you visit certain parts My Site and/or when you use certain features of My Site. Details of the Cookies used by My Site are set out in Part 14, below; and|
|[“Cookie Law”||means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;]|
- Information About Me
My Site is owned and operated by Candlebury, a Sole Trader in in England.
Address: Technology House, Western Way, Bury St Edmunds, IP33 3SP.].
Data Protection Officer: Warren Short.
Email address: [email protected].
Postal Address: Technology House, Western Way, Bury St Edmunds, IP33 3SP]
- What Does This Policy Cover?
- What is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
- What Are My Rights?
Under the GDPR, you have the following rights, which I will always work to uphold:
- The right to access the personal data I hold about you. Part 13 will tell you how to do this.
- The right to have your personal data rectified if any of your personal data held by me is inaccurate or incomplete. Please contact me using the details in Part 15 to find out more.
- The right to be forgotten, i.e. the right to ask me to delete or otherwise dispose of any of your personal data that I have. Please contact me using the details in Part 15 to find out more.
- The right to restrict (i.e. prevent) the processing of your personal data.
- The right to object to me using your personal data for a particular purpose or purposes.
- The right to data portability. This means that, if you have provided personal data to me directly, I am using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask me for a copy of that personal data to re-use with another service or business in many cases.
- Rights relating to automated decision-making and profiling.
- For more information about my use of your personal data or exercising your rights as outlined above, please contact me using the details provided in Part 15.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about my use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
- What Data Do We Collect?
- [Date of birth;]
- [Email address;]
- [Telephone number;]
- [Information about your preferences and interests;]
- [IP address];
- [Web browser type and version;]
- [Operating system;]
- [A list of URLs starting with a referring site, your activity on My Site, and the site you exit to;]
- How Do You Use My Personal Data?
Under the GDPR, I must always have a lawful basis for using personal data. This may be because the data is necessary for my performance of a contract with you, because you have consented to my use of your personal data, or because it is in my legitimate business interests to use it. Your personal data may be used for [one of] the following purposes:
- [Providing and managing your Account;]
- [Providing and managing your access to My Sites;]
- [Personalising and tailoring your experience on my Site;]
- [Supplying my [products] AND/OR [services] to you. Your personal details are required in order for me to enter into a contract with you.]
- [Personalising and tailoring my products AND/OR [services] for you.]
- [Communicating with you. This may include responding to emails, sms, post or calls from you.]
- [Supplying you with information by email, sms, post and telephone that you have opted-in to (you may unsubscribe or opt-out at any time by emailing [email protected]).]
- [Analysing your use of my Site [and gathering feedback] to enable me to continually improve my Site and your user experience.]
With your permission and/or where permitted by law, I may also use your personal data for marketing purposes, which may include contacting you by [email] AND/OR [telephone] AND/OR [text message] AND/OR [post] with information, news, and offers on my products AND/OR [services]. You will not be sent any unlawful marketing or spam. I will always work to fully protect your rights and comply with my obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.]
Third Parties (including google analytics) whose content appears on My Site may use third-party Cookies, as detailed below in Part 14. Please refer to Part 14 for more information on controlling cookies. Please note that I do not control the activities of such third parties, nor the data that they collect and use themselves, and I advise you to check the privacy policies of any such third parties.
- How Long Will You Keep My Personal Data?
I will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):
- No fixed period;
- Will not be used when unsubscribed.
- How and Where Do You Store or Transfer My Personal Data?
I may store or transfer some or all of your personal data in countries that are not part of the European Economic Area (the “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein). These are known as “third countries” and may not have data protection laws that are as strong as those in the UK and/or the EEA. This means that I will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR as follows.
I share your data within the group of companies of which I am a part. Where this involves the transfer of personal data outside the EEA, my group ensures that personal data is protected by requiring all companies within the group to follow the same rules with respect to personal data usage. These are known as “binding corporate rules”. More information on binding corporate rules is available from the European Commission.]
- Do You Share My Personal Data?
[ I may share your personal data with other companies in my group for marketing purposes. This includes subsidiaries AND/OR my holding company and its subsidiaries.] [ I may sometimes contract with the following third parties to supply certain products AND/OR [services]. These may include payment processing, delivery, and marketing. In some cases, those third parties may require access to some or all of your personal data that I hold.
If any of your personal data is required by a third party, as described above, I will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, my obligations, and the third party’s obligations under the law, as described above in Part 9.] [If any personal data is transferred outside of the EEA, I will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR, as explained above in Part 9.]
In some limited circumstances, I may be legally required to share certain personal data, which might include yours, if I am involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.]
- How Can I Control My Personal Data?
- In addition to your rights under the GDPR, set out in Part 5, when you submit personal data via My Site, you may be given options to restrict my use of your personal data. In particular, I aim to give you strong controls on my use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from me which you may do by unsubscribing using the links provided in my emails [and at the point of providing your details and by managing your Account).
- You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
- Can I Withhold Information?
You may access certain areas of My Site without providing any personal data at all. [However, to use all features and functions available on My Site you may be required to submit or allow for the collection of certain data.]
- How Can I Access My Personal Data?
If you want to know what personal data I have about you, you can ask me for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 15. [To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell me everything I need to know to respond to your request as quickly as possible.]
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover my administrative costs in responding.
I will respond to your subject access request within [28 days and, in any case, not more than] one month of receiving it. Normally, I aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date I receive your request. You will be kept fully informed of my progress.
By using My Site, you may also receive certain third-party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, and/or parties other than me. Third-party Cookies are used on My Site for marketing and analytics. For more details, please refer to the table below. These Cookies are not integral to the functioning of My Site and your use and experience of My Site will not be impaired by refusing consent to them.
All Cookies used by and on My Site are used in accordance with current Cookie Law.
Before Cookies are placed on your computer or device, you will be shown a banner requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling me to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of My Site may not function fully or as intended. [You will be given the opportunity to allow only first-party Cookies and block third-party Cookies.]
[Certain features of My Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown in the table below. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below, but please be aware that My Site may not work properly if you do so. I have taken great care to ensure that your privacy is not at risk by allowing them.]
The following first-party Cookies may be placed on your computer or device:
|Name of Cookie||Purpose||Strictly Necessary|
gtag.js and analytics.js
|When the newer ga.js library launched, developers were encouraged to migrate to the new library. For sites that have not completed the migration, urchin.js sets cookies identically to what is set in ga.js.||Yes|
|Used to determine a user’s inclusion in an experiment.||No|
|Used to determine the expiry of experiments a user has been included in.||No|
|Used to determine a user’s inclusion in an experiment and the expiry of experiments a user has been included in.||No|
My Site uses analytics services provided by google analytics. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling me to better understand how My Site is used. This, in turn, enables me to improve My Site and the [products] AND/OR [services] offered through it.
The analytics service(s) used by My Site use(s) Cookies to gather the required information. You do not have to allow me to use these Cookies, however my use of them does not pose any risk to your privacy or your safe use of My Site, it does enable me to continually improve My Site, making it a better and more useful experience for you.
The analytics service(s) used by My Site use(s) the following Cookies:
|Name of cookie||First / third party cookie||Provider||Purpose|
|_ga||First||Google Analytics||Used to distinguish users.|
|_gid||First||Google Analytics||Used to distinguish users.|
|_gat||First||Google Analytics||Used to throttle request rate. If Google Analytics is deployed via Google Tag Manager, this cookie will be named
|__utmt||First||Google Analytics||Used to throttle request rate.|
|__utmc||First||Google Analytics||Not used in ga.js. Set for interoperability with urchin.js. Historically, this cookie operated in conjunction with the
|__utmv||First||Google Analytics||Used to store visitor-level custom variable data. This cookie is created when a developer uses the
|__utmxx||First||Google Analytics||Used to determine the expiry of experiments a user has been included in.|
|_gaexp||First||Google Analytics||Used to determine a user’s inclusion in an experiment and the expiry of experiments a user has been included in.|
In addition to the controls that I provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.
It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.]
- How Do I Contact You?
To contact me about anything to do with your personal data and data protection, including to make a subject access request, please use the following details [(for the attention of Warren Short)]:
Email address: [email protected]
Postal Address: Technology House, Western Way, Bury St Edmunds, IP33 3SP .
I may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if I change my business in a way that affects personal data protection.