Bettys & Taylors Privacy & Cookies Notice
Version 17th May 2018
Welcome to the Cone Exchange privacy & cookies notice.
The Cone Exchange respects your privacy and is committed to protecting your personal data. This privacy & cookies notice will inform you as to how we look after your personal data when you visit our website www.coneexchange.org (the “Website”), regardless of where you visit it from and tell you about your privacy rights and how the law protects you.
This privacy & cookies 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 & cookies notice.
- Important information and who we are
- The data we collect about you
- How is your personal data collected?
- How we use your personal data
- Disclosures of your personal data
- International transfers
- Data security
- Data retention
- Your legal rights
- Cookies Policy
1. Important information and who we are
Purpose of this privacy & cookies notice
This privacy & cookies notice aims to give you information on how the Cone Exchange collects and processes your personal data through your use of our Website and/or contacting us over the telephone, and/or face-to-face, including any data you may provide when you contact us, set up an exchange account with us, or apply to volunteer at the Cone Exchange.
This Website is not intended for children and we do not knowingly collect data relating to children via the Website.
It’s important that you read this privacy & cookies notice together with any other privacy & cookies notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy & cookies notice supplements the other notices and is not intended to override them.
Bettys & Taylors of Harrogate Ltd is the controller and responsible for your personal data (collectively referred to as “The Cone Exchange”, “we”, “us” or “our” in this privacy & cookies notice).
If you have any questions about this privacy & cookies notice, including any requests to exercise your legal rights (as detailed below), please contact our Customer Service team using the details set out below.
Our full details are
Full name of legal entity: Bettys & Taylors of Harrogate Ltd (a company registered in England and Wales)
Email address: firstname.lastname@example.org
Postal address: The Cone Exchange, Hookstone Park, Harrogate, North Yorkshire, HG2 7DB, UK
Telephone: 01423 814000 / 07515 061721
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to the privacy & cookies notice and your duty to inform us of changes
This version was last updated on 17th 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.
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 are not responsible for their privacy statements. When you leave our Website, we encourage you to read the privacy & cookies notice of every website you visit.
2. 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 follows:
- Identity Data includes first name, last name and title.
- Contact Data includes postal address, email address and telephone number.
- Financial Data includes bank account and payment card details.
- Technical Data includes internet protocol (IP) address, your login data, 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 our Website.
- Usage Data includes information about how you use our Website, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
- Special Category Data includes only data relating to your health, which we ask you for when you apply to volunteer with us.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy & cookies notice.
With the exception of data relating to your health, which are collected for the purpose of ensuring your safety as a Cone Exchange Volunteer, we do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your genetic and biometric data).
Information about criminal convictions
If you apply to volunteer with us, because of the nature of the volunteer work, it is likely that we will need to carry out disclosure and barring service (“DBS”) checks on you. We will only use information relating to criminal convictions where the law allows us to do so. This will usually be where such processing is necessary to carry out our legal obligations. We have an appropriate DBS policy and appropriate safeguards in place in relation to this type of processing.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity, Contact, Financial and Special Category Data by filling in forms or by corresponding with us by post, phone, email, face-to-face, or otherwise. This includes personal data you provide when you:
- contact us;
- apply to volunteer with us;
- give us some feedback;
- set up an exchange account with us;
- request marketing to be sent to you; or
- enter a competition, promotion or survey.
- 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, and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our Cookies Policy for further details.
- Technical Data from analytics providers, such as Google Analytics.
4. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- 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.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message.
If on occasion we do require your consent for any particular type of processing (for example if we need to obtain health information from you when you apply to volunteer with us), we will ensure that we have obtained your consent as required by law. You have the right to withdraw consent at any time by contacting us.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|1. Purpose/Activity||2. Type of data||3. Lawful basis for processing including basis of legitimate interest||4. Period we retain the data for||5. Is the data transferred to an External Third Party?|
|To manage our relationship with you which will include:
(b) Asking you to give us feedback or take a survey
(c) Responding to your queries and/or complaints
(d) Asking you to complete our standard forms for volunteering and our visitor’s induction form
(d) Marketing and Communications
(e) Special Category Data
|(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
(d) Necessary to carry out our obligations under employment and social protection law
|Three years maximum||(i) This information is processed using a website platform and database provided and maintained by third-party business partners.|
|To administer and protect our business and the Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity
|(a) 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)
(b) Necessary to comply with a legal obligation
|seven years||(ii) Your data may be processed by the third party business partners who provide us with systems support, hosting and security services, strictly for the purposes of providing those services.|
|To use data analytics to improve our Website, products/services, marketing, customer relationships and experiences||(a) Technical
|Necessary for our legitimate interests (to define types of customers for our products and services, to keep our Website updated and relevant, to develop our business and to inform our marketing strategy)||seven years||(iii) Your data will be processed by a third-party business partner who provides data analytics services.|
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You may receive marketing communications from us if you have requested information from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
We will obtain your consent and advise you of how to opt-out of receiving such communications where we are required to do so in accordance with applicable law.
We will get your express opt-in consent before we share your personal data with any company outside the Bettys & Taylors group of companies for marketing purposes.
Opting out of email marketing: You can ask us to stop sending you marketing messages by email at any time by contacting us at any time or by clicking on the “unsubscribe” link in any marketing emails that we send you.
Opting out of postal marketing (including catalogues/brochures): You can ask us to stop sending you postal marketing by contacting us at any time.
Where you opt out of receiving these marketing messages and/materials, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
- Internal Third Parties as set out in the Glossary.
- External Third Parties as set out in the Glossary.
- Specific third parties as set out in column 5 of the table in section 4 How we use your personal data above.
- 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 & cookies notice.
- Government authorities, law enforcement and regulatory authorities where required or permitted by law.
- Parties to whom you authorise Cone Exchange to release your personal information
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. International transfers
Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- 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 certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
- Where we use providers based in the USA, 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 the U.S. Department of Commerce’s EU-US Privacy Shield website (https://www.privacyshield.gov/welcome).
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
7. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Details of retention periods for different aspects of your personal data are set out in the table in paragraph 4 above.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for [six] years after they cease being customers for [tax] purposes.
In some circumstances you can ask us to delete your data: see Request erasure of your personal data below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
- Request access to your personal data.
- Request correction of the personal data that we hold about you.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing of your personal data.
- Request the transfer of your personal data.
- Withdraw consent.
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
10. Cookies Policy
Like many websites, when you visit our Website or click on an advert of ours on another website we issue ‘cookies’. The following paragraphs give you information on the cookies that we use on the Website and what we use them for.
What are cookies?
Cookies are small text files that websites send to your computer. They let the website know when the user has returned. This allows the website to bring up information relevant to that user, for example your name, past orders etc. Cookies only contain and transfer to the website as much information as you have disclosed to the website, nothing else.
What cookies do we use on the Website?
When you visit our Website, cookies are either sent directly by us, or by our third-party service providers. Details of the categories of cookies we use are as follows:
Necessary cookies: These cookies help make a website usable by enabling basic functions like page navigation and access to secure areas of the website. The website cannot function properly without these cookies.
Statistics cookies: These cookies help website owners to understand how visitors interact with websites by collecting and reporting information anonymously.
Marketing cookies: These cookies are used to track visitors across websites. The intention is to display ads that are relevant and engaging for the individual user and thereby more valuable for publishers and third-party advertisers.
For full details of the cookies we use, please click here to view our Cookies Page, or click on the “Cookies Page” link on the Website.
How can you opt-out of cookies from our Website?
Most web browsers automatically accept cookies, but your browser’s settings can be altered to prevent this. If you do this, you will not be able to shop from our Website as the functions of the Website are dependent on cookies. In addition, Cookies can be deleted from your hard-drive. How you do this will depend upon the Internet browser that you use. Please refer to your relevant Internet browser manufacturer’s website, where you should be able to get the information you need. Please note that cookies are computer specific, so if you log on to our Website from a different computer, the cookie settings on that computer will apply.
For further information about managing and disabling cookies on your computer, see the website www.allaboutcookies.org.
Find out how to manage cookies on popular browsers:
To opt out of being tracked by Google Analytics across all websites, visit http://tools.google.com/dlpage/gaoptout.
Your consent to Cookies
If you agree to cookies from our Website by clicking “OK”, by actively closing the cookies banner, or by continuing to use the Website, we will set cookies on your computer. If you wish to delete the cookies we have set on your computer, please refer to your browser ‘Help’ menu.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Consent: means obtaining your explicit, informed and freely given consent to the processing of your personal data by an unambiguous statement or clear affirmative action on your part.
Internal Third Parties
Other companies in the Bettys & Taylors Group acting as joint controllers or processors, who are based in the UK and carry out management, analysis, planning and decision making, including in relation to taking decisions regarding the expansion and promotion of our product and service offering, order or customer request fulfilment, or provide IT and system administration services.
External Third Parties
- Service providers acting as processors based in the United Kingdom and the USA who provide data analytics services.
- Service providers acting as processors based in the UK who may from time to time provide call centre services.
- Service providers acting as processors based in the United Kingdom who provide IT hosting and IT maintenance.
- 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 and insurers based in the United Kingdom, who provide consultancy, banking, legal, insurance 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.
YOUR LEGAL RIGHTS
You have the following legal rights:
(a) Request access to your personal data
You have the right to 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.
(b) Request correction of the personal data that we hold about you
You have the right to 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.
(c) Request erasure of your personal data
You have the right to 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.
(d) Object to processing of your personal data
You have the right to 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.
(e) Request restriction of processing of your personal data
You have the right to request restriction of processing of 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.
(f) Request the transfer of your personal data
You have the right to request the 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.
(g) Withdraw consent
You have the right to withdraw your 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.