Privacy Notice

Cotswold Hose & Fittings Limited are committed to complying with the General Data Protection Regulation and the Data Protection Act 2018.

We have published this notice to help you understand;

• how and why Cotswold Hose & Fittings collects information from you;

• who we share your information with, why and on what basis; and

• what your rights are.

If we make changes to this notice this will be updated on our website. Cotswold Hose & Fittings Limited will be what is known as the ‘Data Controller’ of the personal data you provide to us, and we will sometimes refer to ourselves in this notice as “we” or “us”. By Data Controller, this means Cotswold Hose & Fittings Limited determines the purposes and way in which any personal data is, or will be, processed.

Should you need to contact us please write to:

Cotswold Hose & Fittings Limited, 3 Wilkinson Road, Cirencester GL7 1YT

or via accounts@chf-ltd.co.uk, with the subject ‘My Data Enquiry’.

This privacy notice was last updated on 21st May 2018.

What information will we collect when you engage with us and why?

When you buy products or obtain services from us, you are entering into a contract with us. If you need to set up an account with us before you enter into this contract, we will ask you to provide information to us, such as;

• full name

• business name

• business address

• contact numbers

• email addresses

• invoicing information

As an existing customer if you have provided this information to us or we have taken these details to deliver services to you, we have securely collected and stored this information.

In order to undertake website personalisation, we will also gather information about the devices you use to access our sites (desktop and mobile), and this may include IP addresses. For further information on our use of cookies and tracking please see our Cookie Notice.

How do we use your information?

Data Protection says that we are allowed to use and share your personal data only where we have an appropriate reason to do so. The law says we must have one or more of these reasons and these are:

• Contract – your personal information is processed in order to fulfil a contractual arrangement e.g. in order to deliver services as part of your package agreement

• Consent – where you agree to us using your information in this way e.g. for storing your details or contacting 3rd parties involved in your marketing activity

• Legitimate Interests – this means the interests of Cotswold Hose & Fittings Ltd in managing our business to allow us to provide you with the best products and service in the most secure and appropriate way e.g. to transfer your data to certain 3rd parties such as graphic designers, web designers and others involved in marketing activity

• Legal Obligation – where there is statutory or other legal requirement to share the information e.g. when we have to share your information for law enforcement purposes.

Here is a list of the ways that we may use your personal information, and which of the reasons described above we rely on to do so. Where we list legitimate interests as a reason, we also describe below what we believe these legitimate interests are.

Set up your Cotswold Hose & Fittings Limited account

• Legitimate interest & Consent Process efficiency in dealing with such activity.

Storing payment cards • Consent N/A

Process your requests • Fulfilling a contract N/A

Notify you of your order or delivery progress • Legitimate interests

Process efficiency in dealing with such activity, and to make improvements to your experience.

Manage your account/ provide customer services to you. • Legal obligation/ Legitimate interests (depending on nature of services) Keeping our records up to date, handling our customer contact efficiently and effectively, working out which of our products and services may interest you and telling you about them.

To detect, investigate and report financial crime (e.g. Fraud) • Legal Obligation / legitimate interests Developing and improving how we deal with financial crime. Complying with any regulations that apply to us. Process efficiency in dealing with such activity, and to make service and process improvements.

Undertake website personalisation and administration. • Legitimate interests Developing products, services, applications and designs that attract and retain customers. Improving customer interaction with our site. Defining types of customers for new products or services.

Marketing communications to inform you of special offers, promotions, helpful information & marketing tips. Provide you with online advertising. • Legitimate interests Developing products, services, applications and designs that attract and retain customers. Improving customer interaction with our site.

Notifying you about enhancements to our services, such as changes to the website and new services that may be of interest to you. • Legitimate interests Developing products, services, applications and designs that attract and retain customers. Improving customer interaction with our site.

Contact you to undertake customer satisfaction surveys, invite you to provide service/product reviews or for market research. • Legitimate interests Developing products, services, applications and designs that attract and retain customers. Improving customer interaction with our site.

Maintaining network and data security. • Legitimate interests To maintain the security of our network. This in turns helps us to maintain the safety and confidentiality of your information.

Planning, demand forecasting, management information and research • Legitimate interests We use information about habits, services used and volumes, to help us to respond to demand and to ensure the right products & services get to the right areas and to help us plan our ranges.

Who we share your information with and why

Cotswold Hose & Fittings Limited works with a number of trusted suppliers, agencies and businesses in order to provide you the high quality services you expect from us such as delivery companies, credit reference agencies, fraud prevention agencies, staff visiting your commercial site and market research companies amongst others.

Some examples of the categories of third parties with whom we share your data are:

Supplier Partners

Cotswold Hose & Fittings Limited works with a number of trusted partners who supply products and services on our behalf. All partners are subject to thorough checks and will only hold the minimum amount of personal information needed in order to fulfil or provide a service on our behalf.

Delivery Partners

In order for you to receive your goods & services, Cotswold Hose & Fittings works with a number of delivery partners. Again, we only pass limited information to them in order to ensure delivery to your chosen address.

IT Companies

Cotswold Hose & Fittings works with businesses who support our website and other business systems.

Payment Collection & Management

Cotswold Hose & Fittings works with trusted third party financial & software providers in order to securely receive and manage payments.

Credit Reference Agencies

When you apply for an account with us we will carry out searches about your business with credit reference agencies when necessary. We do this to make sure customers are not committing fraud by providing false or inaccurate information.

In order to set up an account and provide products to you we will supply your personal information to credit reference agencies (CRA’s) when necessary and they will give us information about your business, such as financial history. We do this to assess your account suitability, check your identity, manage your account, and prevent criminal activity. These checks will not show against your business and are for our internal checks only.

Your Rights

Your personal data is protected by legal rights, which include your rights to object to our processing of your personal data; request that your personal data is erased or corrected; request access to your personal data.

For more information or to exercise your data protection rights, please contact us using the contact details above. You also have a right to complain to the Information Commissioner’s Office, which regulates the processing of personal data.

Keeping in touch with you

We want to keep you up to date with information about special offers, news and updates to the products and services available to you. When you set your account up, we will ask you if you want to receive this type of marketing information.

Cotswold Hose & Fittings Limited will not share your information with any third parties for any purposes not outlined in the examples above.

If you decide you do not want to receive this marketing information you can request that we stop by writing to the Data Protection Officer at the address provided above, emailing accounts@chf-ltd.co.uk, by calling us on 01285 700480 or by clicking the unsubscribe link within the email.

Your request will be processed & completed within 48 working hours, you may receive emails during this processing time.

How long we keep your information

If we collect your personal information, the length of time we retain it is determined by a number of factors including the purpose for which we use that information and our obligations under other laws.

We may need your personal information to establish, bring or defend legal claims. For this purpose, we will always retain your personal information for 7 years after the date it is no longer needed by us for any of the purposes listed under ‘How we use your information’ above. The only exceptions to this are where:

• the law requires us to hold your personal information for a longer period, or delete it sooner;

• you exercise your right to have the information erased (where it applies) and we do not need to hold it in connection with any of the reasons permitted or required under the law;

• we bring or defend a legal claim or other proceedings during the period we retain your personal information, in which case we will retain your personal information until those proceedings have concluded and no further appeals are possible; or

• in limited cases, existing or future law or a court or regulator requires us to keep your personal information for a longer or shorter period.

What are your rights

You are entitled to request the following from Cotswold Hose & Fittings, these are called your Data Subject Rights and there is more information on these on the Information Commissioners website www.ico.org.uk

• Right of access –to request access to your personal information and information about how we process it

• Right to rectification –to have your personal information corrected if it is inaccurate and to have incomplete personal information completed

• Right to erasure (also known as the Right to be Forgotten) – to have your personal information erased.

• Right to restriction of processing – to restrict processing of your personal information

• Right to data portability – to electronically move, copy or transfer your personal information in a standard form

• Right to object – to object to processing of your personal information

• Rights with regards to automated individual decision making, including profiling –rights relating to automated decision making.

If you have any general questions about your rights or want to exercise your rights please accounts@chf-ltd.co.uk.

You have the right to lodge a complaint with a data protection regulator in Europe, in particular in a country you work or live or where your legal rights have been infringed. The contact details for the Information Commissioner’s Office (ICO), the data protection regulator in the UK, are available on the ICO website www.ico.org.uk. Where your personal information has or is being used in a way that you believe does not comply with data, however, we encourage you to contact us before making any complaint and we will seek to resolve any issues or concerns you may have.