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Privacy Policy

1.0 OUR CORE BELIEFS REGARDING USER PRIVACY AND DATA PROTECTION

• User privacy and data protection are human rights

• We have a duty of care to the people within our data

• Data is a liability, it should only be collected and processed when absolutely necessary

• We loathe spam as much as you do!

• We will never sell, rent or otherwise distribute or make public your personal information


2.0 RELEVANT LEGISLATION

Along with our business and internal computer systems, this website is designed to comply with the following national and international legislation with regards to data protection and user privacy:• UK Data Protection Act 1988 (DPA)• EU Data Protection Directive 1995 (DPD)• EU General Data Protection Regulation 2018 (GDPR)This site’s compliance with the above legislation, all of which are stringent in nature, means that this site is likely compliant with the data protection and user privacy legislation set out by many other countries and territories as well. If you are unsure about whether this site is compliant with your own country of residences’ specific data protection and user privacy legislation you should contact our data protection officer (details of whom can be found in section 9.0 below) for clarification.


3.0 PERSONAL INFORMATION THAT THIS WEBSITE COLLECTS AND WHY WE COLLECT IT

This website collects and uses personal information for the following reasons:

3.1 Site visitation tracking

Like most websites, this site uses Google Analytics (GA) and Google Search Console (GSC) to track user interaction. We use this data to determine the number of people using our site, to better understand how they find and use our web pages and to see their journey through the website.

Although GA & GSC record data such as your geographical location, device, internet browser and operating system, none of this information personally identifies you to us. GA also records your computer’s IP address which could be used to personally identify you but Google do not grant us access to this. We consider Google to be a third party data processor (see section 6.0 below).

GA makes use of cookies, details of which can be found on Google’s developer guides. FYI our website uses the Global site tag (gtag.js) implementation of GA.

Disabling cookies on your internet browser will stop GA from tracking any part of your visit to pages within this website. In addition to Google Analytics, this website may collect* information (held in the public domain) attributed to the IP address of the computer or device that is being used to access it.

3.2 Sales

We use the Opencart ecommerce platform that is cookie based to allow tracking of products added to the basket to the completion of the order.

We collect various types of information depending upon how you use our site. We will not disclose your personal details to third parties. When you purchase with us, we collect some personal information from you including your name, billing address, delivery address, email address, phone number(s) and credit card number (with expiration date – with a third party - WorldPay). In addition, if you are a registered user and have signed in when you enter this information, it will automatically be saved in your “my account” area for ease of reference. We do not save your credit card information as this is processed through Worldpay direct. When you become a registered user, we collect information from you including your name, mailing address, email address and password.

This information is gathered to make your shopping experience as a registered user as quick and easy as possible. Additionally, we collect certain personal information if you choose to opt-in to our email newsletters. Our primary goal in collecting personal information - including your first name, last name, purchase history, phone number(s), valid email and residential address and credit card data (through WorldPay) - is to provide you with a smooth, efficient, customised shopping experience and to let you know about offers that may be of interest to you.


3.3 Cookies

Our ecommerce site uses cookies. A cookie is a small file which asks permission to be placed on your computer's hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual such as tracking what you add to your basket and allows the process to go to payment. We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us. You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website. Data collected from this website will also help us work towards improving our website content and for internal marketing analysis and promotional purposes. We will not disclose your personal details to third parties.


3.4 Our blog

Should you choose to add a comment to any posts that we have published on our blog, the name and email address you enter with your comment will be saved to this website’s database, along with your computer’s IP address and the time and date that you submitted the comment. This information is only used to identify you as a contributor to the comment section of the respective blog post and is not passed on to any of the third party data processors detailed below. Only your name will be shown on the public-facing website although if the supplied email address is linked to a Gravatar account, your Gravatar photo will also be displayed.Your comment and it’s associated personal data will remain on this site until we see fit to either

1.) remove the comment or

2.) remove the blog post.

Should you wish to have the comment and it’s associated personal data deleted, please email us using the email address that you commented with.If you are under 16 years of age you MUST obtain parental consent before posting a comment on our blog. NOTE: You should avoid entering personally identifiable information to the actual comment field of any blog post comments that you submit on this website.


3.5 Contact forms and email links

Should you choose to contact us using the contact form on our Contact Us page or an email link like this one (link here), none of the data that you supply will be stored by this website or passed to / be processed by any of the third party data processors defined in section 6.0. Instead the data will be collated into an email and sent to us over the Simple Mail Transfer Protocol (SMTP). Our SMTP servers are protected by TLS (sometimes known as SSL) meaning that the email content is encrypted using SHA-2, 256-bit cryptography before being sent across the internet. The email content is then decrypted by our local computers and devices.3.6 Email newsletter. If you choose to join our email newsletter, the email address that you submit to us will be forwarded to either MailChimp or Colourmedia’s own dedicated email server hosted with CWCS who provide us with email marketing services. We consider MailChimp and Colourmedia’s own email server to be a third party data processor (see section 6.0 below).

The email address that you submit will not be stored within this website’s own database or in any of our internal computer systems.Your email address will remain within MailChimp’s or Colourmedia’s email server database for as long as we continue to use MailChimp’s or Colourmedia’s services for email marketing or until you specifically request removal from the list. You can do this by unsubscribing using the unsubscribe links contained in any email newsletters that we send you or by requesting removal via email. When requesting removal via email, please send your email to us using the email account that is subscribed to the mailing list.If you are under 16 years of age you MUST obtain parental consent before joining our email newsletter.While your email address remains within the MailChimp or Colourmedia’s email database, you will receive periodic newsletter-style emails from us.


4.0 HOW WE STORE YOUR PERSONAL INFORMATION

As detailed in section 3.2 above, if you submit a comment to a blog post published on this website some personal information will be stored within this website’s database. This is currently the only occasion where personal data will be stored on this website. This data is currently stored in an identifiable fashion; a limitation of the content management system that this website is build on and our ecommerce solution. In the near future we aim to change the storage of this data to a pseudonymous fashion meaning that the data would require additional processing using a separately stored ‘key’ before it could be used to identify an individual.Pseudonymisation is a recent requirement of the GDPR which many web application developers are currently working to fully implement. We are committed to keeping it as a high priority and will implement it on this website as soon as we are able to.


5.0 ABOUT THIS WEBSITE’S SERVER

This website is hosted by CWCS within a UK data centre located just outside London and Nottingham.Full details of CWCS Hosting’s data centre can be found here.All traffic (transferral of files) between this website and your browser is encrypted and delivered over HTTPS.


6.0 OUR THIRD PARTY DATA PROCESSORS

We use a number of third parties to process personal data on our behalf. These third parties have been carefully chosen and all of them comply with the legislation set out in section2.

All 3 of these third parties are based in the USA and are EU-U.S Privacy Shield compliant.

• Google (Privacy policy)

• Mailchimp (Privacy policy)

• Gravatar (Privacy policy)

• Payment Processor – WorldPay Hosted (Privacy Policy)


7.0 DATA BREACHES

We will report any unlawful data breach of this website’s database or the database(s) of any of our third party data processors to any and all relevant persons and authorities within 72 hours of the breach if it is apparent that personal data stored in an identifiable manner has been stolen.


8.0 CHANGES TO OUR PRIVACY POLICY

This privacy policy may change from time to time inline with legislation or industry developments. We will not explicitly inform our clients or website users of these changes. Instead, we recommend that you check this page occasionally for any policy changes. Specific policy changes and updates are mentioned in the change log below.

8.1 Change log10/05/2018

Change log18/11/2019 Google analytics version updated and some typographical errors corrected.