Privacy Notice
1. INTRODUCTION
This privacy notice provides you with details of how we collect and process your personal data.
CPB Projects Ltd is the data controller and we are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).
The email address for our internal Data Controller is: caroline.thomas@cpbprojects.co.uk
Our postal address is: CPB Projects Ltd, PO Box 9883, Leicester LE9 0DA
If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.
It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at caroline.thomas@cpbprojects.co.uk or writing to us at CPB Projects Ltd, PO Box 9883, Leicester LE9 0DA.
Sensitive Data
We do not collect any Sensitive Data about you. Sensitive data refers to data that 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. We do not collect any information about criminal convictions and offences.
2. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when legally permitted. The most common uses of your personal data are:
– Where we need to perform the requirements of the contract between us when you make a purchase either from our website or in response to a direct mailing.
– Where it is necessary for our legitimate interests (or those of a third party such as HMRC) and your interests and fundamental rights do not override those interests.
– Where we need to comply with a legal or regulatory obligation.
Generally, we do not rely on consent as a legal ground for processing your personal data, other than in relation to sending marketing communications to you via post or email. You have the right to withdraw consent to marketing at any time by emailing us at caroline.thomas@cpbprojects.co.uk or writing to us at CPB Projects Ltd, PO Box 9883, Leicester LE9 0DA.
Purposes for processing your personal data
Set out below is a description of the ways we intend to use your personal data and the legal grounds on which we will process such data. We have also explained what our legitimate interests are where relevant.
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 email us at caroline.thomas@cpbprojects.co.uk or write to us at CPB Projects Ltd, PO Box 9883, Leicester LE9 0DA 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 below.
We may use your data to provide the following for the lawful basis as set out:
- Register you as a new customer to allow us to fulfil a contract with you (Data: ID and Contact details)
- To process and deliver your instructions to ensure our performance of a contract with you (Data: ID and Contact details; Financial; Marketing and Communications)
- To help manage our relationship with you, which may include notifying you about changes to our terms or privacy policy or asking you to provide a testimonial (Data: ID and Contact details; Marketing and Communications)
- To administer and protect our business and website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) to help run our business efficiently and to provide administration services and if necessary to comply with a legal obligation (Data: ID and Contact details; Technical)
- To use data analytics to improve our website, products or services, marketing, customer relationships and experiences to keep our site updated and relevant, to develop our business and inform you of our marketing strategy (Data: Technical; Usage)
- To make suggestions and recommendations to you about services or products that may be of interest to you in order to develop our products or services to grow our business (Data: ID and Contact details; Technical; Usage)
Marketing communications
You will receive marketing communications from us if you have:
- requested information from us or purchased services from us; or
- if you provided us with your details and ticked the box at the point of entry of your details for us to send you marketing communications; and
- in each case, you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by emailing us at caroline.thomas@cpbprojects.co.uk or writing to us at CPB Projects Ltd, PO Box 9883, Leicester LE9 0DA at any time.
Where you opt out of receiving our marketing communications, this will not apply to personal data provided to us as a result of a service purchase, or other transactions.
3. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 2 above:
– Service providers who provide IT and system administration services.
– Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
– HM Revenue & Customs, regulators and other authorities based in the United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances.
– Third parties to whom we may sell, transfer, or merge parts of our business or our assets in the future.
We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.
4. 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 such data. 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.
5. 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.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data where appropriate) for six years after they cease being customers for tax purposes. We do not retain any financial information whatsoever.
In some circumstances you can ask us to delete your data: see 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.
6. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:
– Request access to your personal data
– Request correction of your personal data
– Request erasure of your personal data
– Object to processing of your personal data
– Request restriction of processing your personal data
– Request transfer of your personal data
– Right to withdraw consent
You can see more about these rights at:
https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/ If you wish to exercise any of the rights set out above, please email us at caroline.thomas@cpbprojects.co.uk or write to us at CPB Projects Ltd, PO Box 9883, Leicester LE9 0DA.
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 fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
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.
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.