Blues & Twos Credit Union
Eden Products Ltd (“We”) act as the controller of your data and are committed to protecting and respecting your privacy. This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. We keep certain basic information when you visit our website and recognise the importance of keeping that information secure and letting you know what we will do with it.
We ensure that the provisions and obligations imposed by the Data Protection Act 2018, together with any subsequent re-enactment or amendment thereof in storing and processing data, are complied with at all times.
This notice applies to our company wide processing including that of our website. If you leave our website, you will be subject to the policy of that website provider. We have no control over that policy or the terms of the website and you should check their policy before continuing to access the site.
1. Introduction
We are committed to safeguarding the privacy of our clients, partners, suppliers and website visitors. In this policy, we explain how we will handle your personal data.
2. How we use your personal data
Here we set out:
(a) the general categories of personal data that we may control and process
(b) the purposes for which we may control and process personal data
(c) the lawful bases of the controlling and processing
We receive this data via face to face, telephone, email and postal communications.
2.1 We may control and process your account data (“account data”). The account data may include your name, job title, email address and direct or switch phone number including past transactions and correspondence. The source of the account data is you and your company or organisation. The account data may be processed for the purposes of managing smooth transactions with you, providing our services and/or receiving yours, operating our website, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The lawful basis for this processing is “performance of a contract”.
2.2 We may control and process information contained in any enquiry you submit to us regarding products and/or services (“enquiry data”). The enquiry data may be processed for the purposes of offering, marketing and selling relevant products and/or services to you. The lawful basis for this processing is “performance of a contract” unless you have consented to us sending marketing material.
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2.3 We may control and process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data”). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The lawful basis for this processing is consent unless you are already a client, in which case we use “legitimate interests”
2.4 We may control and process information captured by our CCTV security system (“security data”). This may be processed for the purposes of identifying physical security incursions into the company’s premises and supplying these to the police in order to facilitate prosecution of any criminal case that may arise. The lawful basis for this processing is our legitimate interests, namely the proper securing of our premises, our property and all those who work for the company, carry out subcontracted works on site or visit for business purposes.
2.5 We may control and process any of your personal data identified in the other provisions of this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The lawful basis for this processing is “legal obligation”, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
2.6 We may control and process information supplied to us from Google Analytics. We rely on your consent for this, via our cookie consent tool.
3. Providing your personal data to others
3.1 We will never disclose your personal data to any party or any organisation outside our company’s business unless such disclosure is necessary for legitimate completion of our transactions with you, compliance with a legal obligation to which we are subject, or in order to protect our or your vital interests or the vital interests of another natural person.
3.2 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining and maintaining insurance coverage, managing risks, obtaining professional advice and managing legal disputes.
3.3 We may disclose your business contact and delivery details to our suppliers or subcontractors insofar as reasonably necessary for delivery and efficient transaction.
3.4 Financial transactions relating to our products and services are handled via our accounts and order processing services providers, Sage. We will share transaction data with these providers only to the extent necessary for the purposes of processing your orders, payments, refunding such payments and dealing with queries relating to such payments and refunds.
3.5 In addition to the specific disclosures of personal data set out in this Section 3, we may also disclose your personal data where such disclosure is necessary for compliance with any legal obligation to which we are subject, or in order to protect our or your vital interests or the vital interests of another natural person.
4. International transfers of your personal data
4.1 Some of our suppliers are situated in the United States. Transfers to this country will be protected by appropriate safeguards and where appropriate Transfer Impact Assessments (TIA’s) have been completed.
5. Retaining and deleting personal data
This Section sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
5.1 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
5.2 We will retain and delete your personal data as follows:
(a) Personal data collected for core business processes (i.e. business transactions) will be deleted if it has been unused for more than 7 years, as we are obligated to keep these records for tax reasons (legal obligation)
(b) Personal data collected for email marketing will be retained while you are a subscriber. An unsubscribe link will be provided on our email newsletters and you can unsubscribe at any time. The suppressed data of unsubscribed users will be retained only to ensure we have a record of your preferences, so we know to not contact you with that method. You have the right to withdraw consent at any time.
5.3 Notwithstanding the other provisions of this Section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect our or your vital interests or the vital interests of another natural person.
6. Amendments
6.1 We may update this policy from time to time by publishing a new version on our website.
7. Your rights
In this Section 7, we have set out the rights that you have under data protection law. Some of the rights are complex, and not all the details have been included here.
7.1 Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
7.2 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. The first copy will be provided free of charge, but excessive requests may be subject to a reasonable fee.
7.3 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.
7.4 In some circumstances you have the right to the erasure of your personal data without undue delay.
7.5 In some circumstances you have the right to restrict the processing of your personal data.
7.6 You have the right to object to our processing of your personal data for direct marketing purposes. If you make such an objection, we will cease to process your personal data for this purpose.
7.7 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
7.8 To the extent that the lawful 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 can withdraw your consent:
(a) by post,
Eden Products Ltd
Millbrook Court
Midpoint 18
Middlewich
Cheshire
CW10 0GE
(b) using our website contact forms;
(c) by telephone, on 01606 835757 or
(d) by email, using info@edenproductsltd.co.uk
Please address any correspondence to the Data Protection Representative
7.9 You may exercise any of your rights in relation to your personal data by contacting us using any of the means above.
8. Third party websites
8.1 Our website may include hyperlinks to, and details of, third party websites.
8.2 We have no control over, and are not responsible for, the privacy policies and practices of third parties.
8.3 This privacy notice only governs our websites and we are not responsible for the privacy policies that govern third party websites even where we have provided links to them. If you use any link on our website, we recommend you read the privacy policy of that website before sharing any personal or financial data
8.4 We operate a number of social media pages (including Facebook, Twitter, YouTube and Instagram). Although this policy covers how we will use any data collected from those pages it does not cover how the providers of social media websites will use your information. Please ensure you read the privacy policy of the social media website before sharing data and make use of the privacy settings and reporting mechanisms to control how your data is used. These companies act as joint controllers who determine their own purposes. We do not share your data with them.
9. Personal data of children
9.1 We do not promote our business to children. Our website is targeted at persons over the age of 16.
9.2 If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.
10. Security
We undertake specific security measures to protect your data. These include encryption and network security
11. Special Category Data
We do not knowingly process any type of Special Category Data (Race, Religion etc)
12. Profiling
We do not carry out any profiling of you or your data
13. Our details
13.1 We are registered as a private, limited company registration number 5514788, and our registered office is at Millbrook Court, Midpoint 18, Middlewich, Cheshire, CW10 0GE.
13.2 Our principal place of business is at:
Eden Products Ltd
Millbrook Court
Midpoint 18
Middlewich
Cheshire
CW10 0GE
13.3 You can contact us:
(a) by post, using the postal address given above;
(b) using our website contact forms;
(c) by telephone, on 01606 835757 or
(d) by email, using info@edenproductsltd.co.uk
14. Data protection Representative
14.1 Our data protection representative is Simon Thompstone whose contact details are:
info@edenproductsltd.co.uk
01606 835757
Eden Products Ltd
Millbrook Court
Midpoint 18
Middlewich
Cheshire
CW10 0GE
15. Complaints
15 .1 If you have a complaint about us, or the treatment of your data, you can contact us or the UK Information Commissioner at www.ico.org.uk
They do not publish an email address, but you can use the contact form on their website
ICO Telephone No. 0303 123 1113
Date – 19th November 2021
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