Privacy Policy
INTRODUCTION
The Cambridge VA respects your privacy and is committed to protecting your personal data. This privacy policy is to inform you of how we look after your personal data when you visit our website, and to tell you about your privacy rights and how the law can protect you.
OUR CONTACT DETAILS
| Business Name | The Cambridge VA |
| Name of Data Privacy Manager | Jenny Turnbull |
| Email Address | jenny@thecambridgeva.com |
TYPES OF PERSONAL INFORMATION WE MAY COLLECT
| Identity Data | includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender |
| Contact Data | includes billing address, delivery address, email address and telephone numbers |
| Financial Data | includes bank account and payment card details |
| Transaction Data | includes details about payments to and from you and other details of products and services you have purchased from us |
| 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 |
| Profile Data | includesyour username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses |
| 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 |
HOW WE GET THE PERSONAL INFORMATION AND WHY WE HAVE IT
Most of the personal information we process is provided to us directly by you for one of the following reasons:
| Direct interactions | You may give us your Identity, Contact, Financial, Transaction, Profile and Marketing and Communications Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you: apply for or purchase our products or services; sign up for free services or offerings; subscribe to our service or publications; request marketing to be sent to you; enter a competition, promotion or survey; or give us some feedback. |
| 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: analytics providers such as Google; advertising networks; and search information providers. Contact, Financial and Transaction Data from providers of technical, payment and delivery services. Identity and Contact Data from publicly availably sources such as Companies House. |
HOW WE USE YOUR PERSONAL DATA
Under UK General Data Protection Regulation (GDPR), we will only use your personal data when the law allows us to do so. This includes:
- when you have consented for us to do so. You are able to remove your consent at any time and can do so by contacting jenny@thecambridgeva.com
- where there is a contractual obligation
- where there is a legal or regulatory obligation
- where we need it to perform a public task
- where it is necessary
REASONS FOR COLLECTING YOUR PERSONAL DATA
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
| To register you as a new customer. | (a) Identity (b) Contact | Performance of a contract with you. |
| To provide our free or paid services or offerings. | (a) Identity (b) Contact (c) Transaction (d) Profile (e) Usage (f) Marketing and Communications | (a) Performance of a contract with you. (b) 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 process and deliver your order including: (a) manage payments, fees and charges; (b) collect and recover money owed to us. | (a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications | (a) Performance of a contract with you. (b) Necessary for our legitimate interests (to recover debts due to us). |
| To manage our relationship with you which will include: (a) notifying you about changes to our Terms or Privacy Policy; (b) asking you to leave a review or take a survey. | (a) Identity (b) Contact (c) Profile (d) Marketing and Communications | (a) Performance of a contract with you. (b) Necessary to comply with a legal obligation. (c) 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. | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications | (a) Performance of a contract with you. (b) 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). | (a) Identity (b) Contact (c) Technical | (a) 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). (b) 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. | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) 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. | (a) Technical (b) Usage | Necessary for our legitimate interests (to define types of customers for our products/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 products/services that may be of interest to you. | (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile | Necessary for our legitimate interests (to develop our products/services and grow our business). |
DISCLOSURE OF YOUR PERSONAL DATA
We may need to share your information. We will get your express opt-in consent before sharing personal data with any companies for third-party marketing purposes. We may also share your personal data with service providers who we engage with, which includes but is not limited to those providing IT support, administrative support and professional services such as legal and financial advisers.
HOW WE STORE YOUR PERSONAL INFORMATION
Your information is securely stored. We will only keep your personal data for as long as necessary to fulfil the purposes it was collected for. To determine the appropriate retention period, we will consider:
- the amount
- nature
- sensitivity
- potential risk of harm from unauthorised use or disclosure
- purposes for which it is processed
- applicable legal requirements
By law we are required to keep basic information about our customers (eg. Contact, identity, financial and transactional data) for six (6) years after they cease being customers for tax purposes.
In some circumstances we may anonymise your personal data so that it can no longer be associated with you.
In some circumstances you can request for your data to be deleted.
Data will be disposed of by deleting any electronic data relevant to you / your business as applicable. Any necessary physical copies of data will be confidentially destroyed.
YOUR DATA PROTECTION RIGHTS
Under data protection law, you have rights including:
- Your right of access – You have the right to ask us for copies of your personal information.
- Your right to rectification – You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
- Your right to erasure – You have the right to ask us to erase your personal information in certain circumstances.
- Your right to restriction of processing – You have the right to ask us to restrict the processing of your personal information in certain circumstances.
- Your right to object to processing – You have the the right to object to the processing of your personal information in certain circumstances.
- Your right to data portability – You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.
You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.
Please contact us at jenny@thecambridgeva.com if you wish to make a request.
HOW TO COMPLAIN
If you have any concerns about our use of your personal information, you can make a complaint to us at jenny@thecambridgeva.com
You can also complain to the ICO if you are unhappy with how we have used your data.
The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk
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