1.1 This policy applies to all the activities of CDC, including our website the Hanger Store. We are committed to safeguarding the privacy of our website visitors and service users.
1.2 This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.
1.4 In this policy, “we”, “us” and “our” refer to Curry’s Distribution Co. Ltd t/a CDC. For more information about us, see Section 13.
2.1 This document was created using a template from SEQ Legal (https://seqlegal.com).
- How we use your personal data
3.1 In this Section 3 we have set out:
(a) the general categories of personal data that we may process;
(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
(c) the purposes for which we may process personal data; and
(d) the legal bases of the processing.
3.2 We may process data about your use of our website and services (“usage data“). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.
3.3 We may process your information included in your personal profile on our website (“profile data“). The profile data may include your name, address, telephone number, email address and gender. The source of profile data is you or your organization. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.
3.4 We may process your account data (“account data“) and service data (“service data”). The account data and service data may include your name, address, phone number, email address, sales and order history and any preferences you have expressed about how you would like us to deliver our services to you. The source of the account and service data is you or your organisation. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.
3.5 We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website (“transaction data“). The transaction data may include your contact details, your card details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract; and our legitimate interests, namely the proper administration of our website and business.
3.6 We may process information that you post for publication on our website (“publication data“). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.
3.7 We may process information contained in any enquiry you submit to us regarding goods and/or services (“enquiry data“). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.
3.8 We may process information relating to our customer relationships, including customer contact information (“customer relationship data“). The customer relationship data may include your name, your organisation, your job title or role, your contact details, details of goods and services you have purchased and information contained in communications between us and you or your organisation. The source of the customer relationship data is you or your organisation. The customer relationship data may be processed for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications and promoting our products and services to customers. The legal basis for this processing is our legitimate interests, namely the proper management of our customer relationships and the effective organisation of our business. NB you can ask us to stop contacting you for this purpose and/or ask for your details to be deleted at any time.
3.9 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data“). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent.
3.10 We may process information contained in or relating to any communication that you send to us (“correspondence data“). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
3.11 We may process publicly-available information about our customers and potential customers (companies or corporate bodies whom we think may be interested in our goods and services). This data may include website address, contact details (e-mail, phone and/or postal), details of products that you sell, visual merchandising products that you use in the course of selling your goods and services. The source of this data is your website, sales outlets, other information publicly available on the Internet, or you or your organisation. This data may be processed to enable us to contact existing and potential customers with information about goods and services in which you may be interested. The legal basis for this processing is our legitimate interests, namely our interest in developing our business and publicising our products. NB you can ask us to stop contacting you for this purpose and/or ask for your details to be deleted at any time.
3.12 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
3.13 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
3.14 In addition to the specific purposes for which we may process your personal data set out in this Section 3, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
3.15 Please do not supply:
- a) any other person’s personal data to us, unless we prompt you to do so;
- b) any information about a person under 18 years of age;
- c) sensitive personal data about anyone (including yourself).
- Providing your personal data to others
4.1 We may disclose your personal data to any member of staff within CDC (including the Hanger Store) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.
4.2 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
Delivery data, including your name, organization and address, to our couriers:
Parcelforce (Royal Mail Group) – https://www.parcelforce.com/privacy
UK Mail (DHL) – https://www.ukmail.com/privacy-and-cookies
Palletline – https://www.palletline.co.uk/privacy-policy
Pallex – https://www.pallex.co.uk/privacy-policy/
United Pallets – https://u-p-n.co.uk/
PL Logistics – http://www.pllogistics.co.uk/
Davis Turner – https://www.daviesturner.com/contentfiles/PrivacyPolicyDaviesTurner.pdf
Newsletter/marketing data, including name, organization and e-mail address, which can be withdrawn for this purpose or unsubscribed by you at any time:
Mail Chimp – https://mailchimp.com/legal/privacy/
4.4 In addition, although we would not specifically disclose data to them, the following suppliers/contractors might have access to personal data during the course of their work in supporting our IT functions:
IT Positive (IT system support and maintenance) –
Boxed-Up Media (order data placed on website) – https://www.boxedupmedia.co.uk/privacy/
Sage (general account data) – https://www.sage.co.uk/uk/hrpayrollhero/privacy-policy
4.5 Financial transactions relating to our website and services are handled by our payment services providers, listed below. They are responsible for handling card transactions and do not pass this information to CDC.
We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers’ privacy policies and practices as follows:
Sagepay (handles card payments on our website) – https://www.sagepay.co.uk/policies/privacy-policy
Paypal (handles Paypal payments on our website and in our Ebay shop) – https://www.paypal.com/uk/webapps/mpp/ua/privacy-prev
Amazon (handles card payments in our Amazon shop) – https://www.amazon.co.uk/gp/help/customer/display.html?nodeId=502584
Global Payments (handles card payments made through our office payment terminal) – https://www.resources.globalpaymentsinc.co.uk/en/privacy-statement
HSBC (our bankers – they handle personal data only where requested by us to make payments to suppliers or customers, using details supplied to us by the customer or supplier) – https://www.hsbc.co.uk/content/dam/hsbc/gb/pdf/privacy-notice.pdf.
4.6 We do not disclose any other data to third parties outside CDC, unless specifically requested to do so by the data subject.
4.7 In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
- International transfers of your personal data
5.1 In this Section 5, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).
5.2 The hosting facilities for our website are situated in the UK.
5.3 We do not intend to transfer your personal data to countries outside the EEA, except in relation to the standard practice of the following sub-contractors:
Mailchimp – this company applies the EU-U.S. Privacy Shield Framework in data is transferred to/stored in the United States of America (USA)
Sage – Sage may transfer data to other Sage group servers outside the EEA. If so, ‘such transfers are made in accordance with the requirements of Regulations (EU) 2016/679 (the General Data Protection Regulations or “GDPR”) and may be based on the use of the European Commission’s Standard Model Clauses for transfers of personal data outside the EEA’. (Sage Privacy Notice, Section 9).
Amazon – Amazon.com, Inc. participates in the EU-US and Swiss-US Privacy Shield frameworks. Its Privacy Notice states: Whenever we (Amazon) transfer personal information to countries outside of the European Economic Area in the course of sharing information …, we will ensure that the information is transferred in accordance with this Privacy Notice and as permitted by the applicable laws on data protection.’
Global Payments – In the event that personal data is shared with affiliates or third parties outside the EEA, its Policy Statement states: ‘The relevant Global Payments companies will take the necessary measures to ensure protection of your personal data collected through this website in accordance with applicable data privacy laws.’
HSBC – Data may be processed or transferred where necessary outside the EEA. ‘However, whether it is processed in the UK or overseas, customer information will be protected by a strict code of secrecy and security applying to all members of the HSBC Group, their staff and third parties holding information on their behalf’ (HSBC Privacy Notice, page 4).
5.4 You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
- Retaining and deleting personal data
6.1 This Section 6 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
6.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
6.3 We will retain your personal data as follows:
(a) Usage, account, service, transaction (insofar as it is held by CDC) and correspondence data will be retained for a minimum period of 7 years following the end of the financial year in question, and for a maximum period of 10 years following the end of the financial year in question.
(b) Profile, publication, enquiry, customer relationship, notification and publicly-available data will be deleted within 7 years of creation or 7 years after your last order, whichever is later.
6.4 Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
7.1 We may update this policy from time to time by publishing a new version on our website.
7.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
- Your rights
8.1 In this Section 8, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
8.2 Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
8.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee
8.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
8.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing, including processing for direct marketing purposes; you object to the processing under certain rules of applicable data protection law; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
8.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
8.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
8.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
8.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
8.10 To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,
and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
8.11 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
8.12 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
8.13 You may exercise any of your rights in relation to your personal data by written notice to us.
- About cookies
9.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
9.2 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
(a) authentication – to identify you when you visit our website and as you navigate our website;
(b) status – to help us to determine if you are logged into our website
(c) personalisation – to store information about your preferences and to personalise the website for you;
(d) security – as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally;
(e) advertising – to help us to display advertisements that will be relevant to you;
(f) analysis – to help us to analyse the use and performance of our website and services; and
- Cookies used by our service providers
- Managing cookies
11.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies from your browser provider.
11.2 Blocking all cookies will have a negative impact upon the usability of many websites. If you block cookies, you will not be able to use all the features on our website.
- Our details
12.1 This website is owned and operated by Curry’s Distribution Co. Ltd t/a CDC.
12.2 We are registered in England and Wales under registration number 3697978. Our registered office and our principal place of business are at 18 Baynes Place, Off Waterhouse Lane, Chelmsford, Essex, CM1 2 QX, UK.
12.3 You can contact us:
(a) by post, to the postal address given above;
(b) using our website contact form;
(c) by telephone, on +44 (0)1245 253420; or +44 (0)1245 253434
- Data Protection Officer
13.1 Our data protection officer’s contact details are:
The Data Protection Officer
18 Baynes Place
Off Waterhouse Lane
Or contact via the phone or e-mail addresses above.
May 2018; amended September 2018.