This Privacy Notice sets out how we, Hugh Crane (Cleaning Equipment) Ltd, collect, store and use (in other words, “process”) personal data or information about you when you interact with us and where we obtain or collect personal information about you. This Privacy Notice is effective from 25/05/2018 and also covers activities carried out by the company under the “Commando” and “Cask Force” brands.
This section summarises how we obtain, store, keep secure, and use personal information about you. It is intended to provide a very general overview only. It is not complete in itself and must be read in conjunction with the corresponding full sections of this Privacy Notice.
- Data controller:
Hugh Crane (Cleaning Equipment) Ltd, of South Walsham Rd, Acle, Norwich, NR13 3ES and of 148, Station Rd, Whittlesey, PE7 1UF.
- How we collect or obtain information about you:
when you provide it to us by contacting us, placing an order on our website, completing our online enquiry form.
from your use of our website, using cookies and tracking beacons.
from publicly available sources
- Information we collect includes:
name, contact details, payment details including last 4 digits of card, IP address, information from cookies, information about your computer (device, browser type), information from cookies, information about how you use the website (which pages have been viewed), the time when you view them and what you clicked on, the geographical location from which you accessed our website (based on your IP address), the company name or business name (if applicable.
- How we use your information:
for administrative and business purposes (particularly to contact you and process orders on our website), electronic and postal marketing, to improve our business and website functionality and processes, to fulfil our contractual and legal obligations, to advertise our goods and services, to analyse your use on our website and in connection with our legal rights and obligations.
- Our legal basis for the processing of personal data: :
is assessed and determined in all cases
- Disclosure of your information to third parties:
only to the extent necessary to run our business, to our service providers, to fulfil any contracts we enter into with you, where required by law, or to enforce our legal rights.
- Do we sell your information to third parties (other than in the course of a business sale or purchase or similar event)? :
- How long we retain your information:
for no longer than necessary, taking into account any legal obligations we have (e.g. to maintain records for tax purposes), any other legal basis we have for using your information (e.g. your consent, performance of a contract with you or our legitimate interests as a business).
- How we secure your data:
Security of your data is recognised by us as being of paramount importance. We achieve this by using appropriate technical and organisational measures such as
storing your information on secure servers, encrypting transfers of data to or from our servers using Secure Socket Layer (SSL) technology, encrypting payments you make on or via our website using Secure Socket Layer (SSL) technology, only granting access to your information where necessary.
- Transfers of your information outside the European Economic Area (EEA):
We do not sell your personal data. Personal data we collect from you may be transferred to and stored at a destination outside the EEA, as may be data handled by one of our service providers who have appropriate protection measures in place to make sure data remains adequately protected.
- Use of automated decision making and profiling:
we may use automated decision making via web analytics, cookies and targeting cookies to display advertisements to people who visit our website on other websites and around the internet
- Your rights in relation to your information: :
- Sensitive personal information:
we do not knowingly or intentionally collect what is commonly referred to as ‘sensitive personal information’. Please do not submit sensitive personal information about you to us.
- This notice is available :
via our website and by specific written request to the company
Legal basis for processing personal data
In each situation where we collect, control and process personal data, we have considered and assessed the legal basis for doing so which will generally be one or more of the following:
(Article 6(1)(a) of the General Data Protection Regulations) – where clear consent has been given in respect of processing personal data for a specific purpose
(Article 6(1)(b) of the General Data Protection Regulations) – where the data processing is necessary for a contract we hold or to fulfil specific steps prior to entering in to a contract.
- Legal obligation:
(Article 6(1)(c) of the General Data Protection Regulations) – where the data processing is necessary for purposes of legal compliance
- Legitimate interests:
(Article 6(1)(f) of the General Data Protection Regulation) – where the processing is necessary for your or our legitimate interests or the legitimate interests of a third party, unless there is good reason to protect the individual’s personal data which overrides those legitimate interests.
- Soft opt-in:
, (under the Privacy and Electronic Communications Regulations) where we have obtained personal details directly from yourself during the course of a sale, or negotiations for a sale of a product or service; only in relation to our marketing of our own similar products and services; where you have been given a simple opportunity to refuse or opt-out both when collecting details and in all of our marketing communications after that; where all of our future communications give you the simple opportunity to opt-out of receiving further communications.
Personal information we collect when you visit our website
- Web server log information:
We use a third party server, located in the EU, to host our website
- Use of website server log information for IT security purposes:
We and our third party hosting provider collect(s) and store(s) server logs to ensure network and IT security and so that the server and website remain uncompromised. This includes analysing log files to help identify and prevent unauthorised access to our network, the distribution of malicious code, denial of services attacks and other cyber attacks, by detecting unusual or suspicious activity. Unless we are investigating suspicious or potential criminal activity, we do not make, nor do we allow our hosting provider to make any attempt to identify you from the information collected via server logs.
- Cookies and similar technologies:
Personal information we collect when you contact us:
We collect and use information from individuals who contact us in accordance with this section and the later section entitled “Disclosure and additional uses of your personal information”.
When you send an email to the email address displayed on our website we collect your email address and any other information you provide in that email (such as your name, telephone number and the information contained in any signature block in your email). We use a third party email provider to store the emails, which takes place within the EEA.
- Contact form:
When you contact us using our contact form, we collect name, email address and telephone number, IP address, plus your comments. We also collect any other information you provide to us when you complete the contact form. If you choose not to provide the mandatory information required by our contact form, you will not be able to submit the contact form and we will not receive your enquiry. If you choose not to supply the optional information required by our contact form we will not be able to respond to your enquiry by telephone or email. Messages you send us via our contact form will be stored on our third-party email and hosting provider’s servers within the EEA.
If you contact us by post, we will collect any information you provide to us in any postal communications you send us.
Personal information we collect when you interact with our website:
We collect and use information from individuals who interact with particular features of our website in accordance with this section and the later section entitled “Disclosure and additional uses of your personal information”.
- Registering on our website.:
When you register and create an account on our website, we collect the following information: first name, last name and email address. If you choose not to provide the mandatory information required by the registration form, you will not be able to register or create an account on our website. Information you submit to us via the registration form will be stored within the European Economic Area on our third party hosting provider’s servers.
Personal information we collect when you place an order on our website:
We collect and use information from individuals who place an order on our website in accordance with this section and the later section entitled “Disclosure and additional uses of your personal information”.
- Information collected when you place an order:
When you place an order for goods or services on our website, we collect your full name, email address, contact number, billing address, shipping address. If you do not provide this information, you will not be able to purchase goods or services from us on our website or enter into a contract with us. At checkout, we also provide you with the opportunity to give further (optional) information, such as company name, and ask for your consent if you would like to receive marketing communications from us. For further information see section on ‘Direct Marketing Communications’ below. If you choose not to provide this optional information, including giving your consent to receive further marketing information from us, we will not be able to contact you via these forms of communication. Each subsequent marketing communication we send you will have the means for you to easily opt out/unsubscribe.
- Processing your payment:
After you place an order on our website you will need to make payment for the goods or services you have ordered. In order to process your payment we use a third party processor Barclaycard. Your payment will be processed by Barclaycard via a payment gateway. Barclaycard collects, uses and processes your information, including payment information, in accordance with their privacy policies. You can access their privacy policies via the following link(s) www.barclaycard.co.uk/business/privacy-and-cookie-policy.Barclaycard is located in the UK. Information relating to the processing of your payment is stored with the European Economic Area on our third party payment processors servers located in the UK and Ireland.
Personal information from third parties:
This section sets out how we obtain or collect information about you from third parties. In certain circumstances (for example, to verify the information we hold about you or obtain missing information we require to provide you with a service) we may obtain information about you from publicly accessible sources, both EU and non-EU, such as the electoral register, companies house, online customer databases, business directories, social medial and websites, including your own if you have one. For example, where you ask us to send you information by email, we may obtain and/or verify your email address from your website or from a directory to confirm that we have recorded your email address correctly. Otherwise, we do not normally solicit or receive other information about you from third parties. Were this to occur it would be for a legitimate business reason. It is also possible that third parties with whom we have had no prior contact may provide us with unsolicited information about you. Information we obtain from third parties will generally be your name and contact details, but may include any additional information about you which they provide to us.
- If we receive information about you in error:
If we receive information about you from a third party in error and/or we do not have a legal basis for processing that information, we will delete that information.
Electronic and postal
We may process your data and contact you directly for electronic marketing purposes regarding our own products and services. We will not contact you on behalf of third parties unless they are a supplier of products or services to us which we then market to you or unless there is some contractual or legal reason for doing so. In all such cases we will only do so where we have assessed there is a legitimate reason which may be in the interests of either or both of us, which will generally be on one or more of the following bases:
- If you are an individual working for a “corporate body”, such as a company, limited liability partnership or an official organisation with whom we have an existing business relationship covering similar products and services, we will process your data and continue to contact you electronically on the basis of legitimate interests (Article 6(1)(f) of the General Data Protection Regulation), and where we always provide you with the opportunity to easily opt out of receiving similar future marketing communications.
- If you are a sole trader, individual or partner in a small enterprise who is an existing customer where we have obtained your details direct from you during the course of a previous sale or negotiations for a sale; we are marketing similar products; and where you have had the opportunity to easily opt out, we will process your data and continue to contact you electronically on the basis of “Soft opt-in” (under the Privacy and Electronic Communications Regulations) and where we always provide you with the opportunity to easily opt out of receiving similar future marketing communications.
- If you are an individual working for a corporate body, or are a sole trader, individual, or a partner in a small enterprise who does not meet the criteria for legitimate interest or soft opt-in, we will only contact you electronically where you have specifically given us your consent (Article 6(1)(a) of the General Data Protection Regulations) and where we always provide you with the opportunity to easily opt out of receiving similar future marketing communications. You may give consent in a number of ways, for example if you contact us verbally or in writing to request marketing information or if you complete and submit an online enquiry to us via our website or other means.
We use a third party service to administer our mailing list. Information you submit will be stored on our third party mailing list provider’s servers within the European Economic Area or in the USA
In respect of postal marketing, we may contact you, or continue to contact you, provided that we have obtained your contact details legally and that we provide you with a simple opt out from future marketing communications.
Disclosure and additional uses of your personal information:
This section sets out the circumstances in which will disclose information about you to third parties and any additional purposes for which we use your information.
- In connection with the normal and effective operation of our business.:
We will only disclose personal information to third party service providers or others who are necessary to run our business or suppliers of products and services to us and from whom we have obtained satisfactory information regarding their data processing and data security via their own privacy information. These providers may be located in the UK, EEA or USA. Your information will be only shared with these service providers to the extent necessary to enable the effective operation of our business and to provide you with the service you have requested, whether that is accessing our website or ordering goods and services from us. Information may also be shared in the event of an actual, or potential, business asset sale, purchase or similar business sale or combination event.
- Disclosure and use of your information for legal reasons:
If we suspect that criminal or potential criminal conduct has been occurred, we may in certain circumstances need to contact an appropriate authority, such as the police or other official body. This could be the case, for instance, if we suspect that fraud or a cyber-crime has been committed or if we receive threats or malicious communications towards us or third parties. We may also use and process your information in order to comply with legal obligations to which we are subject. For example, we may need to disclose your information pursuant to a court order or subpoena if we receive one. We will generally only need to process your information for this purpose if you were involved in or affected by such an incident in some way.
- In connection with other or potential legal rights, disputes or proceedings:
We may use your information in connection with the enforcement or potential enforcement of our legal rights, including, for example, sharing information with debt collection agencies if you do not pay amounts owed to us when you are contractually obliged to do so. Our legal rights may be contractual (where we have entered into a contract with you) or non-contractual (such as legal rights that we have under copyright law or tort law). We may also need to use your information if we are involved in a dispute with you or a third party for example, either to resolve the dispute or as part of any mediation, arbitration or court resolution or similar process.
Retention of personal information:
We only intend to retain personal data for the minimum time necessary to fulfil any associated requirement, including actual or potential contractual, legal or other business reasons. We take appropriate technical and organisational measures to secure your information and to protect it against unauthorised or unlawful use and accidental loss or destruction, including:
- only sharing and providing access to your information to third parties as previously described and to the minimum extent necessary, subject to confidentiality restrictions where appropriate, and on an anonymised basis wherever possible;using secure servers to store your information.
- verifying the identity of any individual who requests access to information prior to granting them access to information;
- using Secure Socket Layer (SSL) software to encrypt any information you submit to us via any forms on our website and any payment transactions you make on or via our website.
- only transferring you information via closed system or encrypted data transfers.
Transmission of information by email:
Transmission of information over the internet is not entirely secure, and if you submit any information to us over the internet (whether by email, via our website or any other means), you do so entirely at your own risk. Equally we cannot guarantee the security of any email sent by us to you. We cannot be responsible for any data loss, costs, expenses, loss of profits, harm to reputation, damages, liabilities or any other form of loss or damage suffered by you as a result of your email communication to us or our email communication to you.
Your rights in relation to your personal information and subject access requests:
Subject to certain limitations, you have the following rights in relation to your information, which you can exercise by writing to us or sending an email to [email protected]. Should you initially make such request verbally, you will be asked to confirm this in writing (electronically or hard copy) before we consider it further. We will also ask you to take reasonable steps to verify your identity before we respond.
To request access to your information and information related to our use and processing of your information; to request the correction or deletion of your information; to request that we restrict our use of your information; to receive information which you have provided to us in a structured, commonly used and machine-readable format and the right to have that information transferred to another data; to object to the processing of your information for certain purposes; to withdraw your consent to our use of your information at any time where we rely on your consent to use or process that information. Please note that if you withdraw your consent, this will not affect the lawfulness of our use and processing of your information on the basis of your consent before the point in time when you withdraw your consent; the right not to be subject to a decision based on automated processing, including profiling which produces legal affects concerning you or similarly significantly affects you.
All requests will be considered where we will initially determine whether to accept the request or refuse the request. If the request is accepted we will respond to you within 1 month of receipt of your request. If your request is refused we will inform you of the reasons for refusal within 1 month of receipt of your request. These reasons could include requests that we consider are manifestly unfounded or excessive. In the event of refusal you have the right to lodge a complaint with the supervisory authority, the ICO, and to a judicial remedy if applicable.
Your right to object to the processing of your personal information for certain purposes:
You have the following rights in relation to your information, which you may exercise in the same way as described in item 15 above by writing to us or sending an email to [email protected]
To object to us using or processing your information where we use or process it in order to carry out a task in the public interest or for our legitimate interests, including ‘profiling’ (i.e. analysing or predicting your behaviour based on your information) based on any of these purposes; and to object to us using or processing your information for direct marketing purposes (including any profiling we engage in that is related to such direct marketing). See also the section on Direct Marketing communications above.
Sensitive Personal Information:
We do not knowingly or intentionally collect or require sensitive personal information from individuals, and you must not submit sensitive personal information to us. If, however, you inadvertently or intentionally transmit sensitive personal information to us, you will be considered to have explicitly consented to us processing that sensitive personal information under Article 9(2)(a) of the General Data Protection Regulations. We will use and process your sensitive personal information for the purposes of deleting it.
Anyone becoming aware of any data breach in respect of personal information held or processed by Hugh Crane Cleaning equipment is asked to immediately inform the company either verbally or by email to [email protected]
Changes to our Privacy Notice:
We may update and amend our Privacy Notice from time to time. Please take the time to check our website periodically to keep abreast of such updates.