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Privacy Policy

1. Introduction

1.1 We are committed to safeguarding the privacy of our website visitors; in this policy we explain how we will treat your personal information.

1.2 By using our website (https://www.cxcommerce.co.uk) and agreeing to this policy, you consent to our use of cookies in accordance with the terms of this policy.

2. Credit

2.1 This document was created using a template from SEQ Legal (http://www.seqlegal.com).

3. Collecting personal information

3.1 We may collect, store and use the following kinds of personal information:

(a) Information about your computer and about your visits to and use of this website (including your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths).

(b) Information that you provide to us when registering with our website and completing our contact form, including your name, telephone number and email address, as well as any metadata associated with the communication and any other personal information that you choose to send us.

(c) Information that you provide to us when using the services on our website, or that is generated in the course of the use of those services (including the timing, frequency and pattern of service use).

(d) Information relating to any enquiry that you make with us (including your name, address, telephone number, email address and any further personal information which has been provided with relevance to the enquiry). Information may be collected via a webform, an online chat service, telephone, email or any other means of communication.

(e) Information that you provide to us when signing up to our newsletter, including your name and email address.

(f) Information that you provide to us when reviewing our services.

3.2 Before you disclose to us the personal information of another person, you must obtain that person’s consent to both the disclosure and the processing of that personal information in accordance with this policy.

4. Using personal information

4.1 Personal information submitted to us through our website will be used for the purposes specified in this policy or on the relevant pages of the website.

4.2 We may use your personal information to:

(a) Administer our website and business.

(b) Supply to you services purchased; please note that we do engage carefully selected third parties who will also have access to any data required in order to carry out such outsourced services. Further details on third parties are included below.

(c) Send statements, invoices and payment reminders to you, and collect payments from you.

(d) Send you non-marketing commercial communications.

(e) Send you email notifications that you have specifically requested.

(f) Send you our email newsletter (you can inform us at any time if you no longer require the newsletter).

(g) Send you marketing communications relating to our business or the businesses of carefully-selected third parties, which we think may be of interest to you, by email or similar technology (you can inform us at any time if you no longer require marketing communications).

(h) Provide third parties with statistical information about our users (but those third parties will not be able to identify any individual user from that information).

(i) Deal with enquiries and complaints made by or about you relating to our website.

(j) Keep our website secure and prevent fraud.

(k) Verify compliance with the terms and conditions governing the use of our website.

4.3 If you submit personal information for publication on our website, we will publish and otherwise use that information in accordance with the licence you grant to us.

4.4 We will not, without your express consent, supply your personal information to any third party for the purpose of their or any other third party’s direct marketing.

5. Disclosing personal information

5.1 We may disclose your personal information to; any of our employees, officers, insurers, professional advisers, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes set out in this policy.

5.2 We may disclose your personal information to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes set out in this policy.

5.3 We may disclose your personal information:

(a) To the extent that we are required to do so by law.

(b) In connection with any ongoing or prospective legal proceedings.

(c) In order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).

(d) To the purchaser (or prospective purchaser) of any business or asset that we are (or are contemplating) selling.

(e) To any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.

5.4 In order to deliver the following services, we will share your personal information with carefully selected third parties:

(a) To maintain an accurate CRM system and mailing list

(b) To maintain an accurate payments system (including invoicing and direct debits) and accounting records.

(c) To carry out UX services, we may engage a subcontractor.

(d) To manage HR requirements, such as staff pension scheme.

(e) To manage recruitment.

6. International data transfers

6.1 The Data that we collect may be stored and processed in and transferred between any of the countries in which we, or our third parties or suppliers operate in order to enable us to provide our services to you and use the data in accordance with this privacy policy.

6.2 Information that we collect may be transferred to the following countries which do not have data protection laws equivalent to those in force in the European Economic Area (these include, but are not limited to: the United States of America, Russia, Japan, China, India, Ukraine, Argentina and Vietnam). In these scenarios, we have ensured that adequate agreements and/or legislation is in place for the protection of your data, for example ‘Privacy Shield’ is a certification programme which US organisations can participate in in order to demonstrate their compliance with Data Protection regulations in the EU, including

(i) ensuring that the transfer is to a country approved by the European Commission as providing adequate protection pursuant to Article 45 GDPR, for example to the USA under the Privacy Shield;

(ii) there are appropriate safeguards in place pursuant to Article 46 GDPR; or

(iii) one of the specific situations in Article 49 GDPR applies to the transfer.

6.3 When a subcontractor based outside of the European Economic Area has been engaged, we ensure that service agreements include a provision for how they handle and store your data. They will only keep your data or access to your data for as long as they are required in order to carry out the work that they have been instructed to on our behalf.

6.4 Personal information that you publish on our website or submit for publication on our website may be available, via the internet, around the world. We cannot prevent and are not liable for the use or misuse of such information by others.

6.5 You expressly agree to the transfers of personal information described in this Section 6.

7. Retaining personal information

7.1 This Section 7 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 information.

7.2 Personal information that we process for any purpose or purposes shall not be kept for longer than 7 years, or than is necessary for that purpose or those purposes. For a detailed breakdown of our data retention policy, please contact us.

7.3 Notwithstanding the other provisions of this Section 7, we will retain documents (including electronic documents) containing personal data:

(a) to the extent that we are required to do so by law;

(b) if we believe that the documents may be relevant to any ongoing or prospective legal proceedings; and

(c) in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).

(d) in order to deliver agreed upon services to you.

8. Security of personal information

8.1 We will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information.

8.2 We will store all the personal information you provide on our secure (password- and firewall-protected) servers.

8.3 You acknowledge that the transmission of information over the internet is inherently insecure and despite putting in place several security measures, we cannot guarantee the security of data sent over the internet.

8.4 You are responsible for keeping the password you use for accessing your website confidential.

9. Amendments

9.1 We may update this policy from time to time by publishing a new version on our website.

9.2 You should check this page occasionally to ensure you are happy with any changes to this policy.

10. Your rights

10.1 You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to:

(a) the supply of appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address).

10.2 We may withhold personal information that you request to the extent permitted by law.

10.3 You may exercise your right to object to our processing of your personal data at any point, this applies to data processed for marketing, for the performance of legal tasks, for legitimate interests and for any research purposes.

10.4 We will provide you with an opportunity to opt out of the use of your personal information for marketing purposes, usually by way of an ‘Unsubscribe’ button at the bottom of our regular newsletters.

11. Third party websites

11.1 Our website includes hyperlinks to, and details of, third party websites.

11.2 We have no control over, and are not responsible for, the privacy policies and practices of these third parties.

12. Updating information

12.1 Please let us know if the personal information that we hold about you needs to be corrected or updated.

13. Cookies

13.1 Our website uses cookies.

13.2 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

13.3 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

13.4 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

13.5 We use both session and persistent cookies on our website.

13.6 The names of the cookies that we use on our website, and the purposes for which they are used, are set out below:

  • _ga (2 year expiry)
    Used for statistics only and not personaly identifiable. Registers a unique ID that is used to generate statistical data on how the visitor uses the website.
  • _gat (expires after visit)
    Used for statistics only and not personaly identifiable. Used by Google Analytics to throttle request rate.
  • _gid (expires after visit)
    Used for statistics only and not personaly identifiable. Registers a unique ID that is used to generate statistical data on how the visitor uses the website.

13.7 Most browsers allow you to refuse to accept cookies; for example:

(a) in Internet Explorer (version 11) you can block cookies using the cookie handling override settings available by clicking “Tools”, “Internet Options”, “Privacy” and then “Advanced”;

(b) in Firefox (version 47) you can block all cookies by clicking “Tools”, “Options”, “Privacy”, selecting “Use custom settings for history” from the drop-down menu, and unticking “Accept cookies from sites”; and

(c) in Chrome (version 52), you can block all cookies by accessing the “Customise and control” menu, and clicking “Settings”, “Show advanced settings” and “Content settings”, and then selecting “Block sites from setting any data” under the “Cookies” heading.

13.8 Blocking all cookies will have a negative impact upon the usability of many websites.

13.9 If you block cookies, you will not be able to use all the features on our website.

13.10 You can delete cookies already stored on your computer; for example:

(a) in Internet Explorer (version 11), you must manually delete cookie files (you can find instructions for doing so at http://windows.microsoft.com/en-gb/internet-explorer/delete-manage-cookies#ie=ie-11);

(b) in Firefox (version 47), you can delete cookies by clicking “Tools”, “Options” and “Privacy”, then selecting “Use custom settings for history” from the drop-down menu, clicking “Show Cookies”, and then clicking “Remove All Cookies”; and

(c) in Chrome (version 52), you can delete all cookies by accessing the “Customise and control” menu, and clicking “Settings”, “Show advanced settings” and “Clear browsing data”, and then selecting “Cookies and other site and plug-in data” before clicking “Clear browsing data”.

13.11 Deleting cookies will have a negative impact on the usability of many websites.

14. Our details

14.1 This website is owned and operated by Limarah Crathorne.

14.2 For our business operating address please contact us.

14.3 You can contact us:

(a) By Email: limarah@cxcommerce.co.uk

(b) Using our website contact form in the website footer.

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