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Camrosa Equestrian Limited

Privacy Policy

 

How we use and store your data Who we share it with Your Rights

 

SUMMARY

In this notice, "we", "us" and "our" refer to Camrosa Equestrian Limited (a limited company with registered place of business at Ladymeads Farm, Wadhurst, East Sussex, TN5 6HH, U.K., and company registration number 2365553).

We are committed to safeguarding the privacy of our website visitors and people who we conduct business with (“our customers”). For the purpose of the General Data Protection Regulation (EU Regulation 2016/679, when applicable, the “GDPR”), and the EU Data Protection Directive (Directive 95/46/EC), this notice applies where we are acting as a data controller with respect to our customers where we determine the purposes and means of the processing of that personal data.

 

1. USAGE AND STORAGE OF YOUR PERSONAL DATA

In this section we have set out the general categories of personal data that we may process (Website Usage Data, Sales Enquiries, Newsletter Sign-ups, Customer Order Information, and Employee Data for Payroll), the purposes and legal basis for which we may process this data, as well as our data retention policy.

Your personal data that we process for any purpose shall not be kept for longer than is necessary and is explained below. It may be necessary to keep your data longer than the stated period to comply 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 have classified your personal data you share with us as follows:

+ Website Use

+ Sales Enquiries

+ Newsletter Sign-ups

+ Customer Order Information

+ Employee Data

We may process any of your personal data identified in this notice 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. Please do not supply any other person's personal data to us, unless we prompt you, and you have their explicit permission to do so.

 

2. PERSONAL DATA SHARING WITH OTHERS

Your personal data may be shared with companies who help us run our business (our “processors”), subject to appropriate organizational and technical safeguards. Click here to see the details of these processors.

In addition, we may disclose your personal data to our insurers and/or professional advisers only 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.

In addition to the specific disclosures of personal data set out in this section, 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.

Notwithstanding these protections, you acknowledge that personal data that you submit for the provision of services may be available, via the internet, around the world. Whilst we attempt to keep this information secure, we cannot guarantee against the use (or misuse) of such personal data by others.

 

3. Your Rights

When applicable, you (the Data Subject) have the following rights regarding the processing of your personal information under General Data Protection Regulation (EU Regulation 2016/679, Chapter 3, Articles 12-23). These rights are summarized below (for a more detailed explanation, please refer to the UK's Information Commissioner's website).

 

The Right to be Informed

You have a right to be provided with information regarding our processing of your personal information. This includes: our purposes for processing your personal data, our retention periods for that personal data, and who we shared with. We call this ‘privacy information’ and it is contained in this privacy policy. 

 

The Right of Access

You have the right to confirmation as to whether 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 £15 fee.

 

The Right to Rectification

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.

 

The Right to Erasure

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
  • you object to the processing under certain rules of applicable data protection law
  • the processing is for direct marketing purposes, 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 defense of legal claims).

 

The Right to Restrict Processing

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 defense of legal claims
  • 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 defense of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

 

The Right to Data Portability

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.

 

The Right to Object to Processing

You have the right to object to our processing of your personal data on grounds relating to your 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 defense of legal claims.

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.

 

Rights Related to Automated Decision Making & Profiling

Article 22 provides you with specific rights regarding any automated decision making or profiling that we may carry out. In particular, it says that we must:

  • give you information about that processing
  • introduce simple ways for you to request human intervention or challenge a decision
  • carry out regular checks to make sure that your systems are working as intended.

We have determined that we do not perform any form of automated decision making or profiling under Article 22.

 

Right to complain to a statutory authority

If you have any questions about our use of your personal data, please let us know so we can help. Notwithstanding that, if you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with the ICO.

  • Right to withdraw consent
  • 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.

 

You may exercise any of your rights in relation to your personal data by written notice to us, either by mail, email (privacy@camrosa.co.uk), or telephone. 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 UK’s GDPR regulatory authority (the Information Commissioner’s Office) for a full explanation of these rights.

 

4. AMENDMENTS

We may update this notice from time to time by publishing a new version on our website. You should check this page occasionally to ensure you are happy with any changes to this notice. We may notify you of significant changes to this notice by email.

 

5. MANAGING COOKIES

We do not actively use cookies on our website other than those required by our service provider, Bubblegate (details of the Bubblegate cookie policy can be found in their Privacy Policy). These cookies are for security, performance and functionality and while Bubblegate may track visitor behavior, we do not use any of that data for any form of advertising. Details regarding how to manage these cookies with your browser settings can be found here.

 

6. OUR DETAILS

This website is owned and operated by Camrosa Equestrian Limited. Our registered office is at Ladymeads Farm, Wadhurst, East Sussex, TN5 6HH, U.K., and our company registration number 2365553.

You can contact us by post, to the postal address given above, by using our website contact form, by telephone on the contact number published on our website home page, or by email (privacy@Camrosa Equestrian Limited).

 

7. CREDITS

This document was created by Data Compliance Specialists and was last reviewed on the 8th Feb, 2019.

 

 


 

Website Use
 

Data we Collect

Business Purpose

Legal Basis for Collection

Retention Period

 

May include 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 (no tracking cookies are used).

Monitoring and improving our website and services.

Article 6(1)(a) - Consent

See Bubblegate (our website service provider) Privacy Policy

 


 

Sales Enquiries
 

Data we Collect

Business Purpose

Legal Basis for Collection

Retention Period

 
May include name, job title or role, employer, your contact details, information contained in communications between us (e.g. email and website metadata)

Responding to any enquiry you submit to us via email, telephone or our website for the purposes of offering, marketing and selling relevant goods and/or services to you, or for providing technical advice about our products or services.

Article 6(1)(a) - Consent

1-year (maybe withdrawn at any time) unless specifically agreed to be longer

 


 

Newsletter Sign-ups
 

Data we Collect

Business Purpose

Legal Basis for Collection

Retention Period

 
May include name and email address

For the provision of an email newsletter a 2-3 times a year.

Article 6(1)(a) - Consent

1-year

 


 

Employee data
 

Data we Collect

Business Purpose

Legal Basis for Collection

Retention Period

 
May include name, address, age, date of birth, National Insurance number and bank account data.

Legal requirement to furnish this information to HMRC for tax and national insurance purposes.

Article 6(1)(f) - Legitimate Interests

7 yrs. (IRS guidance)

 


 

Customer orders
 

Data we Collect

Business Purpose

Legal Basis for Collection

Retention Period

 
May include name, job title or role, employer, your contact details, information contained in communications between us (e.g. email and website metadata), credit card details.

For the provision of the goods or services that you request via our website, over the phone or via email.

Article 6(1)(b) – Contract

7 yrs. (IRS guidance)

 


 

Processors
 

Processor

Business Function

Location of Data

Safeguards

Policies

 

Bubblegate

Customer Orders & email Newsletter

EEA and United States

ISO 27001

Privacy Shield (US sub-processors)

Privacy Policy

Security Policy

 

eBay

Customer Orders

Various locations

Binding Corporate Rules (BCR’s), firewalls, data encryption, physical access controls to data centres, and information access authorization controls

Privacy Policy

Security Policy

 

Mustard

Payroll

Unknown

Unknown

Privacy Policy

 

Royal Mail (“Click and Drop”)

Order Fulfillment (shipping)

UK and non-EEA countries

Model contractual clauses and Privacy Shield

Privacy Notice

Mail Integrity Code of Practice

 

SagePay

Payment Processor

USA and non-EEA countries (transfers conform to GDPR and UK law)

Transaction security with 128-bit SSL certificates and MD5 hashing, 256-bit data-at-rest encryption, PCI compliant

Privacy Policy

Security Policy

 

PayPal

Payment Processor

UK & non-EEA countries

Binding Corporate Rules, firewalls, data encryption, physical access controls to our data centers, and information access authorization controls

Privacy Policy

 

PayZone

PoS (Point of Sale) Payment Processor

UK & non-EEA countries

PCI DSS compliant

Privacy Policy

Data Processing Agreement

 

 

 

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