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Privacy Policy

Last Updated: 18.05.2018

1. Introduction

This Privacy Notice explains in detail the types of personal data we may collect about you when you interact with us. It also explains how we’ll store and handle that data and keep it safe.

We know that there’s a lot of information here, but we want you to be fully informed about your rights, and how Ceramic Import and Manufacturing Company (CIMC)uses your data. We will explain things such as our credit checking procedure, and how we combine data across CIMC to build a picture of you.

We hope the following sections will answer any questions you have but if not, please do get in touch with us.

When you are using the CIMC website, CIMC is the data controller.

2. What is CIMC Home?

Ceramic Import and Manufacturing Company– which we’ll refer to as ‘the Company’ in this document.

CIMC’s Registered office is Murraysgate Industrial Estate Whitburn West Lothian EH47 0LE and our company registration number is 113315(Scotland)

For simplicity throughout this notice, ‘we’ and ‘us’ means CIMC.

3. Explaining the legal bases we rely on

The law on data protection sets out a number of different reasons for which a company may collect and process your personal data, including:

When you place an order with us, we collect the following mandatory information: name, email address, phone number, billing address, delivery address, company name, VAT number (if applicable).

If you do not provide this information, You will not be able to purchase from/enter into a contract with us.

Legal basis for processing: Processing is necessary to perform a contract (Article 6(1)(b) of the General Data Protection Regulation).

The reason why it is necessary to perform a contract: other than phone number, we need the mandatory information collected by us to establish who the contract is with and to contact you to fulfil our obligations under the contract, including sending you receipts and order confirmations, invoices, statements etc.

Legal basis for processing: compliance with a legal obligation (Article 6(1)(c) of the General Data Protection Regulation).

Complying with a legal obligation: Once you have ordered from us, we have a legal obligation to issue you with an invoice for the goods and services you purchased from us at the location where you are VAT registered. For this we require the mandatory information collected by our checkout form for this purpose.

Legal basis for processing: Legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate Interest(s); We collect your phone number for our legitimate interest of more easily and effectively contacting you in relation to your order and your account.

4. When do we collect your personal data?

  • When you visit our website, and use your account to buy products, from the Company over the phone, at trade shows, when our sales manager visits customers premises
  • When you make an online purchase.
  • When you open an account with us.
  • When you engage with us on social media.
  • When you join our mailing list.
  • When you contact us by any means with queries, complaints etc.
  • When you ask us to email you information about a product.
  • When you book any kind of appointment with us or book to attend an event, for example to visit our showroom.
  • When you choose to complete any surveys that we send to you.
  • When you comment on or review our products and services.
  • Any individual may access personal data related to them, including opinions. So, if your comment or review includes information about a company who provided that service, it may be passed on to them if requested.
  • When you fill in any forms we may collect your personal data.
  • When you’ve given a third-party permission to share with us the information they hold about you.
  • We collect data from publicly-available sources, when you have given your consent to share information or where the information is made public as a matter of law.

5. What sort of personal data do we collect?

  • If you have a web account with us: your name, gender, date of birth, billing/delivery address, orders and receipts, email and telephone numbers are gathered.
  • Details of your interactions with us through online, emailing or by phoning us are collected.
For example, we collect notes from our conversations with you, details of any complaints or comments you make, details of purchases you made, items viewed or added to your basket, brands you show interest in, web pages you visit and how and when you contact us.
  • If you have a trade account with us-proforma or credit account.
  • Details of your shopping preferences.
For example, details of your visits to our website, and which site you came from to ours.
  • Information gathered by the use of cookies and similar technology in your web browser.
  • Personal details which help us to recommend items of interest
For example, you might tell us what items you like or sell, which we’ll use to guide our suggested items.
  • We’ll only ask for and use your personal data collected for recommending items of interest and to tailor your ordering experience with us. Of course, it’s always your choice whether you share such details with us.
  • Payment card information and bank details for issuing refunds.
  • Your comments and product reviews.
  • To deliver the best possible web experience, we collect technical information about your internet connection and browser as well as the country and telephone code where your computer is located, the web pages viewed during your visit, the advertisements you clicked on, and any search terms you entered.

6. How and why do we use your personal data?

We want to give you the best possible customer experience. One way to achieve this is to get the richest picture we can of who you are by combining the data we have about you.

We then use this to offer you promotions, products and services that are most likely to interest you.

We hope the following sections will answer any questions you have but if not, please do get in touch with us.

The data privacy law allows this as part of our legitimate interest in understanding our customers and providing the highest levels of service.

If you wish to change how we use your data, you’ll find details in the ‘What are my rights?’ section below.

Please note that if you choose not to share your personal data with us, or refuse certain contact permissions, we might not be able to provide some services you’ve asked for.

For example, if you’ve asked us to let you know when an item comes back into stock, we can’t do that if you’ve withdrawn your general consent to hear from us.

Here’s how we’ll use your personal data and why:

  • To process any orders that you place with us. If we don’t collect your personal data during checkout, we won’t be able to process your order and comply with our legal obligations.
For example, your details may need to be passed to a third party to supply or deliver the product or service that you ordered, and we may keep your details for a reasonable period afterwards in order to fulfil any contractual obligations such as refunds, and so on.
  • To respond to your queries, refund requests and complaints. Handling the information, you sent enables us to respond. We may also keep a record of these to inform any future communication with us and to demonstrate how we communicated with you throughout. We do this on the basis of our contractual obligations to you, our legal obligations and our legitimate interests in providing you with the best service and understanding how we can improve our service based on your experience.
  • To protect our business and your account from fraud and other illegal activities. This includes using your personal data to maintain, update and safeguard your account. We’ll also monitor your browsing activity with us to quickly identify and resolve any problems and protect the integrity of our websites. We’ll do all of this as part of our legitimate interest.
For example, by checking your password when you login and using automated monitoring of IP addresses to identify possible fraudulent log-ins from unexpected locations.
  • To protect our Staff, premises, assets from crime, we operate CCTV systems in our warehouse and car park which record images for security. We do this on the basis of our legitimate business interests.
  • To process payments and to prevent fraudulent transactions. We do this on the basis of our legitimate business interests. This also helps to protect our customers from fraud.
  • If we discover any criminal activity or alleged criminal activity through our use of CCTV, fraud monitoring and suspicious transaction monitoring, we will process this data for the purposes of preventing or detecting unlawful acts. Our aim is to protect the individuals we interact with from criminal activities.
  • With your consent, we will use your personal data, preferences and details of your transactions to keep you informed by email, web, text, telephone and social media about relevant products and services including tailored special offers, discounts, promotions, events, competitions and so on.

You are free to opt out of hearing from us by any of these channels at any time.

  • To send you relevant, personalised communications by post in relation to updates, offers, services and products. We’ll do this on the basis of our legitimate business interest.

You are free to opt out of hearing from us by post at any time.

  • To send you communications required by law or which are necessary to inform you about our changes to the services we provide you. For example, updates to this Privacy Notice, product recall notices, and legally required information relating to your orders. These service messages will not include any promotional content and do not require prior consent when sent by email or text message. If we do not use your personal data for these purposes, we would be unable to comply with our legal obligations.
  • To display the most interesting content to you on our website, we’ll use historical data about your favourite products. We do so on the basis of your consent to receive notifications and/or for our website to place cookies or similar technology on your device.
For example, we might display a list of items you’ve recently looked at or offer you recommendations based on your purchase history and any other data you’ve shared with us.
  • To develop, test and improve the systems, services and products we provide to you. We’ll do this on the basis of our legitimate business interests.
For example, we’ll record your browser’s Session ID to help us understand more when you leave us online feedback about any problems you’re having
  • To comply with our contractual or legal obligations to share data with law enforcement.
For example, when a court order is submitted to share data with law enforcement agencies or a court of law
  • To send you survey and feedback requests to help improve our services. These messages will not include any promotional content and do not require prior consent. We have a legitimate interest to do so as this helps make our products or services more relevant to you.

Of course, you are free to opt out of receiving these requests from us at any time by updating your preferences in your online account.

  • To build a rich picture of who you are and what you like, and to inform our business decisions, we’ll combine data captured from across CIMC, third parties and data from publicly-available lists as we have described in the section 'What Sort of Personal Data do we collect?' We’ll do this on the basis of our legitimate business interest.
For example, by combining this data, this will help us personalise your experience and decide which inspiration or content to share with you. We also use anonymised data from customer purchase histories to identify trends in different areas of the country. This may then guide which products we display at our Sales Shows.
  • For CIMC customers, to decide which information to show you, with the help of computer algorithms. We do so on the basis of your consent when you become a CIMC customer. If you don’t want to continue receiving CIMC offers, information, emails telephone call, letters. You will be unable to continue to be CIMC customer.
  • To process your order. Sometimes, we’ll need to share your details with a third party who is providing a service (such as delivery couriers). We do so to maintain our appointment with you. Without sharing your personal data, we’d be unable to fulfil your request.
  • Here’s more information on how we share personal data with third parties.

7. Combining your data for personalised direct marketing

We want to bring you offers and promotions that are most relevant to your interests at particular times. To help us form a better, overall understanding of you as a customer, we combine your personal data gathered across CIMC as described above, for example your ordering history. For this purpose, we also combine the data that we collect directly from you with data that we obtain from third parties to whom you have given your consent to pass that data onto us.

8. How we protect your personal data

We know how much data security matters to all our customers. With this in mind we will treat your data with the utmost care and take all appropriate steps to protect it.

We secure access to all transactional areas of our website using ‘https’ technology.

Access to your personal data is password-protected, and sensitive data such as payment card information this is securely destroyed as soon as payment is processed.

We regularly monitor our system for possible vulnerabilities and attacks, and we carry out penetration testing to identify ways to further strengthen security.

9. How long will we keep your personal data?

Whenever we collect or process your personal data, we’ll only keep it for as long as is necessary for the purpose for which it was collected.

At the end of that retention period, your data will either be deleted completely or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning.

Some examples of customer data retention periods:

Orders
When you place an order, we’ll keep the personal data you give us for the statutory amount of time required so we can comply with our legal and contractual obligations.

10. Who do we share your personal data with?

We sometimes share your personal data with trusted third parties.

For example, delivery couriers, for fraud management, to handle complaints, to help us personalise our offers to you and so on.

Here’s the policy we apply to those organisations to keep your data safe and protect your privacy:

  • We provide only the information they need to perform their specific services.
  • They may only use your data for the exact purposes we specify in our contract with them.
  • We work closely with them to ensure that your privacy is respected and protected at all times.
  • If we stop using their services, any of your data held by them will either be deleted or rendered anonymous.

Examples of the kind of third parties we work with are:

IT companies who support our website and other business systems.

Operational companies such as delivery couriers.

Direct marketing companies who help us manage our electronic communications with you.

Google to show you products that might interest you while you’re browsing the internet. This is based on either your marketing consent or your acceptance of cookies on our websites.

Data insight companies to ensure your details are up to date and accurate.

Sharing your data with third parties for their own purposes:

We will only do this in very specific circumstances, for example:

  • With your consent, given at the time you supply your personal data, we may pass that data to a third party for Providing information to Google Inc.
  • Google collects information through our use of Google Analytics on our website. Google uses this information, including IP addresses and information from cookies, for a number of purposes, such as improving its Google Analytics service. Information is shared with Google on an aggregated and anonymised basis. To find out more about what information Google collects, how it uses this information and how to control the information sent to Google, please see the partners page of Google’s privacy policy
  • Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
  • Legitimate interest(s): meeting our contractual obligations to Google under our Google Analytics Terms of Service and allowing the Google Analytics to work on our website
  • Sharing your information with a prospective or actual purchaser or seller in the context of a business or asset sale or acquisition by us, a merger or similar business combination event, whether actual or potential
  • Legal basis for processing: legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
  • Legitimate interest(s): sharing your information with a prospective purchaser, seller or similar person in order to allow such a transaction to take place.
  • Sharing your information with third parties, which are either related to or associated with the running of our business, where it is necessary for us to do so. These third parties include our accountants, advisors, affiliates, business partners, independent contractors, and insurers

Further information on each of these third parties is set out below.

  • Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
  • Legitimate interest: running and managing our business efficiently.

Accountants

We share information with our accountants for tax purposes. For example, we share invoices we issue and receive with our accountants for the purpose of completing tax returns and our end of year accounts.

Advisors

Occasionally, we obtain advice from advisors, such as accountants, financial advisors, lawyers and other specialists. We will share your information with these third parties only where it is necessary to enable these third parties to be able to provide us with the relevant advice.

Affiliates

Affiliates are individuals or entities we work with to promote our business by various means, including advertising our services on their websites. Our affiliates can be in in any industry, sector or sub-sector. Affiliates will share information with us and we will share information with them where you have expressed an interest in our products or services.

Business partners

Business partners are businesses we work with which provide goods and services which are complementary to our own or which allow us to provide goods or services which we could not provide on our own. We share information with our business partners where you have requested services which they provide whether independently from, or in connection with or own services.

Independent contractors

Occasionally, we use independent contractors in our business. Your information will be shared with independent contractors only where it is necessary for them to perform the function we have hired them to perform in relation to our business.

Insurers

We will share your information with our insurers where it is necessary to do so, for example in relation to a claim or potential claim we receive or make or under our general disclosure obligations under our insurance contract with them.

  • For fraud management, we may share information about fraudulent or potentially fraudulent activity in our premises or systems. This may include sharing data about individuals with law enforcement bodies.
  • We may also be required to disclose your personal data to the police or other enforcement, regulatory or Government body, in your country of origin or elsewhere, upon a valid request to do so. These requests are assessed on a case-by-case basis and take the privacy of our customers into consideration.

11. Where your personal data may be processed

Sometimes we will need to share your personal data with third parties and suppliers outside the European Economic Area (EEA), such as placing direct container orders to our supplier outside EEA.

International orders

If you are based outside the UK and place an order with us, we will transfer the personal data that we collect from you to CIMC in the UK.

Protecting your data outside the EEA

The EEA includes all EU Member countries as well as Iceland, Liechtenstein and Norway. We may transfer personal data that we collect from you to third-party data processors in countries that are outside the EEA.

For example, this might be required in order to fulfil your order and provide support services.

If we do this, we have procedures in place to ensure your data receives the same protection as if it were being processed inside the EEA.

Any transfer of your personal data will follow applicable laws and we will treat the information under the guiding principles of this Privacy Notice.

12. What are your rights over your personal data?

An overview of your different rights

You have the right to request:

  • Access to the personal data we hold about you, free of charge in most cases.
  • The correction of your personal data when incorrect, out of date or incomplete.
For example, when you withdraw consent, or object and we have no legitimate overriding interest, or once the purpose for which we hold the data has come to an end (such as the end of a warranty).
  • That we stop using your personal data for direct marketing (either through specific channels, or all channels).
  • That we stop any consent-based processing of your personal data after you withdraw that consent.
  • Review by CIMC of any decision made based solely on automatic processing of your data (i.e. where no human has yet reviewed the outcome and criteria for the decision).

You have the right to request a copy of any information about you that CIMC holds at any time, and also to have that information corrected if it is inaccurate. To ask for your information, please contact CIMC Murraysgate Industrial Estate Whitburn West Lothian EH47 0LE To ask for your information to be amended, please update your online account, or contact our Customer Services team.

If we choose not to action your request, we will explain to you the reasons for our refusal.

Your right to withdraw consent

Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent.

Where we rely on our legitimate interest

In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.

Direct marketing

You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels

Checking your identity

To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Notice. If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.

13. How can you stop the use of your personal data for direct marketing?

There are several ways you can stop direct marketing communications from us:

  • Write to CIMC Murraysgate Industrial Estate Whitburn West Lothian EH47 0LE
  • Email CIMC online@cimc-lighting.co.uk
  • Telephone;-0116 287 5288

Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated.

14. Contacting the Regulator

If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests that you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.

You can contact them by calling 0303 123 1113.

Or go online to www.ico.org.uk/concerns (opens in a new window; please note we can't be responsible for the content of external websites)

If you are based outside the UK, you have the right to lodge your complaint with the relevant data protection regulator in your country of residence. Details can be found in Section 15.

15. If you live outside the UK

For all non-UK customers

By using our services or providing your personal data to us, you expressly consent to the processing of your personal data by us or on our behalf. Of course, you still have the right to ask us not to process your data in certain ways, and if you do so, we will respect your wishes.

Sometimes we’ll need to transfer your personal data between countries to enable us to supply the goods or services you’ve requested. In the ordinary course of business, we may transfer your personal data from your country of residence to ourselves and to third parties located in the UK.

By dealing with us, you are giving your consent to this overseas use, transfer and disclosure of your personal data outside your country of residence for our ordinary business purposes.

This may occur because our information technology storage facilities and servers are located outside your country of residence and could include storage of your personal data on servers in the UK.

We’ll ensure that reasonable steps are taken to prevent third parties outside your country of residence using your personal data in any way that’s not set out in this Privacy Notice. We’ll also make sure that we adequately protect the confidentiality and privacy of your personal data.

16. Any questions?

We hope this Privacy Notice has been helpful in setting out the way we handle your personal data and your rights to control it.

If you have any questions that haven’t been covered, please contact us :-

Email us at online@cimc-lighting.co.uk

Or write to us at CIMC Murraysgate Industrial Estate Whitburn West Lothian Scotland EH47 0LE