Privacy Policy
New regulations are coming into place on 25 May 2018 around how organisations record, store and use your personal data. This legislation is the General Data Protection Regulation (GDPR), which is designed to give you full control over your personal data. Shaftesbury Carnaby PLC (“Shaftesbury”) respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you. The Company Secretary is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the Company Secretary at shaftesbury@shaftesbury.co.uk. If you would like to update your marketing preferences, please contact contact@carnaby.co.uk. This privacy notice is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice. 1. [THE DATA WE COLLECT ABOUT YOU] 2. [HOW IS YOUR PERSONAL DATA COLLECTED] 3. [HOW WE USE YOUR PERSONAL DATA] 4. [DISCLOSURES OF YOUR PERSONAL DATA] 5. [INTERNATIONAL TRANSFERS] 6. [DATA SECURITY] 7. [DATA RETENTION] 8. [IMPORTANT INFORMATION AND WHO WE ARE] 9. [YOUR LEGAL RIGHTS] 10. [GLOSSARY] CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES This version was last updated on 29 May 2018 and historic versions can be obtained by contacting us. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us. We may change this policy from time to time by updating this page so please revisit and reread it periodically. THIRD-PARTY LINKS This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and we are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit. Please note that Shaftesbury does not warrant, represent, endorse or hold responsibility over any external sites that may be linked to and from this site. 1. THE DATA WE COLLECT ABOUT YOU Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:- Identity Data includes first name and last name.
- Contact Data includes email address and, for Neighbourhood cardholders only, company/residential address.
- Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
- Profile Data includesfeedback and survey responses.
- Usage Data includes information about how you use our website.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties.
- Direct interactions. You may give us your Identity, Contact and Marketing and Communications Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- subscribe to our newsletter;
- apply to become a member of the Neighbourhood Card scheme;
- request marketing to be sent to you;
- enter a prize draw, ballot, promotion or survey; or
- give us some feedback or ask us a question via our online contact form.
- Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, pixels, server logs and other similar technologies. Please see our Cookie Policy for further details.
- Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below.
- Technical Data from analytics providers such as Google based outside the EU.
- Where we need to perform the agreement we are about to enter into or have entered into with you.
- Where we have your consent.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
Purpose/Actvity | Type of data | Lawful basis for processing including basis of legitimate interest |
To register you as a member of our Neighbourhood Card scheme, and inform you via email of forthcoming offers and privileges relating to membership (if applicable) | IdentityContact | Consent |
To manage our relationship with you which will include: Notifying you about changes to our terms or privacy policyAsking you to take a survey | IdentityContact Profile Marketing and Communications | Necessary to comply with a legal obligation Necessary for our legitimate interests (to keep our records updated) |
To respond to any queries that you submit on our website | IdentityContact | Consent |
To provide a newsletter via email containing information about special offers, events, launches and other promotions | IdentityContact Marketing and Communications | Consent |
To enable you to partake in a prize draw or ballot or asking you to take a survey and administering the same | IdentityContact Profile Usage Marketing and Communications | Consent |
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | IdentityContact Technical | Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)Necessary to comply with a legal obligation |
To use data analytics to improve our website, services, and consumer experiences | TechnicalUsage | Necessary for our legitimate interests (to keep our website updated and relevant, to develop our business and to inform our marketing strategy). |
- Internal Third Parties as set out in the Glossary [Link to Glossary below].
- External Third Parties as set out in the Glossary [Link to Glossary below].
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
- Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Right to withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
- Service providers acting as processors based in the United Kingdom who provide IT and system administration services.
- Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors, PR advisors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance, PR and accounting services.
- HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.