Varcurn's Privacy
Policy
1. Introduction
1.1 We
are committed to safeguarding the privacy of [our website visitors and service
users].
1.2 This
policy applies where we are acting as a data controller with respect to the
personal data of [our website visitors and service users]; in other words,
where we determine the purposes and means of the processing of that personal
data.
1.3 We
use cookies on our website. Insofar as those cookies are not strictly necessary
for the provision of [our website and services], we will ask you to consent to
our use of cookies when you first visit our website.
1.4 Our
website incorporates privacy controls which affect how we will process your
personal data. By using the privacy controls, you can [specify whether you
would like to receive direct marketing communications and limit the publication
of your information]. You can access the privacy controls via [URL].
1.5 In
this policy, "we", "us" and "our" refer to [Varcurn
& Varcurn Marble Ltd].
[ For more information about us, see
Section 13.]
2. Credit
2.1 This
document was created using a template from SEQ Legal (https://seqlegal.com/free-legal-documents/privacy-policy).
3. How we use your personal data
3.1 In
this Section 3 we have set out:
(a) the
general categories of personal data that we may process;
(b) [in
the case of personal data that we did not obtain directly from you, the source
and specific categories of that data];
(c) the
purposes for which we may process personal data; and
(d) the
legal bases of the processing.
3.2 We
may process [data about your use of our website and services] ("usage
data"). The usage data may include [your IP address, geographical
location, browser type and version, operating system, referral source, length
of visit, page views and website navigation paths, as well as information about
the timing, frequency and pattern of your service use]. The source of the usage
data is [our analytics tracking system]. This usage data may be processed [for
the purposes of analysing the use of the website and services]. The legal basis
for this processing is [consent] OR [our legitimate interests, namely
[monitoring and improving our website and services]].
3.3 We
may process [your website user account data] ("account data").[The
account data may [include your name and email address].][ The source of the
account data is [you or your employer].] The account data may be processed [for
the purposes of operating our website, providing our services, ensuring the
security of our website and services, maintaining back-ups of our databases and
communicating with you.] The legal basis for this processing is [consent] OR
[our legitimate interests, namely [the proper administration of our website and
business]] OR [the performance of a contract between you and us and/or taking
steps, at your request, to enter into such a contract].
3.4 We
may process [information that you post for publication on our website or
through our services] ("publication data"). The publication
data may be processed [for the purposes of enabling such publication and
administering our website and services]. The legal basis for this processing is
[consent] OR [our legitimate interests, namely [the proper administration of
our website and business]] OR [the performance of a contract between you and us
and/or taking steps, at your request, to enter into such a contract].
3.5 We
may process [information contained in any enquiry you submit to us regarding
goods and/or services] ("enquiry data"). The enquiry data may
be processed [for the purposes of offering, marketing and selling relevant
goods and/or services to you]. The legal basis for this processing is [consent]
OR [our legitimate interests, namely [the proper administration of our website
and business]] OR [the performance of a contract between you and us and/or the
taking steps, at your request, to enter into such a contract].
3.6 We
may process [information relating to transactions, including purchases of goods
and/or services, that you enter into with us and/or through our website]
("transaction data").[ The transaction data may include [your
contact details, your card details and the transaction details].][ The source
of the transaction data is [you and/or our payment services provider].] The
transaction data may be processed [for the purpose of supplying the purchased
goods and/or services and keeping proper records of those transactions]. The legal
basis for this processing is [the performance of a contract between you and us
and/or taking steps, at your request, to enter into such a contract; providing
that, if you are not the person contracting with us, the legal basis for this
processing is our legitimate interests, namely [the proper administration of
our website and business]].
3.7 We
may 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 legal basis for this processing
is [consent] OR [our legitimate interests, namely [communications with our
website visitors and service users]] OR [the performance of a contract between
you and us and/or taking steps, at your request, to enter into such a contract].
3.8 We
may process your data and as above and the legal basis for this
processing is [consent] OR [our legitimate interests, OR [the performance of a
contract between you and us and/or taking steps, at your request, to enter into
such a contract].
3.9 We
may process [any of your personal data identified in 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
legal basis for this processing is our legitimate interests, namely [the
protection and assertion of our legal rights, your legal rights and the legal
rights of others].
3.10 We
may process [any of your personal data identified in this policy] where
necessary for [the purposes of obtaining or maintaining insurance coverage,
managing risks, or obtaining professional advice]. The legal basis for this processing
is our legitimate interests, namely [the proper protection of our business
against risks].
3.11 In
addition to the specific purposes for which we may process your personal data
set out in this Section 3, we may also process [any of your personal data]
where such processing is necessary [for compliance with a legal obligation to
which we are subject, or] in order to protect your vital interests or the vital
interests of another natural person.
3.12 Please
do not supply any other person's personal data to us, unless we prompt you to
do so.
4. Providing your personal data to others
4.1 We
may disclose [your personal data] to [our insurers and/or professional
advisers] insofar as reasonably necessary for the purposes of [obtaining or
maintaining insurance coverage, managing risks, obtaining professional advice,
or the establishment, exercise or defence of legal claims, whether in court
proceedings or in an administrative or out-of-court procedure].
4.2 [Your
personal data held in our website database] OR [on our office p.c’s]
will be stored on the servers of our hosting services providers [identified at [URL]].
4.3 We
may disclose [specify personal data category or categories] to [our
suppliers or subcontractors][identified at [URL]] insofar as reasonably
necessary.
4.4 In
addition to the specific disclosures of personal data set out in this Section
4, we may disclose your personal data where such disclosure is necessary for
compliance with a legal obligation to which we are subject, or in order to
protect your vital interests or the vital interests of another natural person.[
We may also disclose your personal data where such disclosure is necessary for
the establishment, exercise or defence of legal claims, whether in court
proceedings or in an administrative or out-of-court procedure.]
5. International transfers of your personal
data
5.1 In
this Section 5, we provide information about the circumstances in which your
personal data may be transferred to [countries outside the European Economic
Area (EEA)].
5.2 The
hosting facilities for our website are situated in the UK. [The European
Commission has made an "adequacy decision" with respect to [the data
protection laws of the UK and will be protected by appropriate safeguards,
namely [the use of standard data protection clauses adopted or approved by the
European Commission, a copy of which you can obtain from the European
Commission website.
5.3 Some
of our tile manufacturers and stone manufacturers are situated within Europe
and South America. [The European Commission has made an "adequacy
decision" with respect to [the data protection laws of each of these
countries].][Transfers to each of these countries will be protected by
appropriate safeguards, namely [the use of standard data protection clauses
adopted or approved by the European Commission, a copy of which can be obtained
from the European Commission.
5.4 You
acknowledge that [personal data that you submit for publication through our
website or services] may be available, via the internet, around the world. We
cannot prevent the use (or misuse) of such personal data by others.
6. Retaining and deleting personal data
6.1 This
Section 6 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.
6.2 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.
6.3 We
will retain your personal data as follows:
(a) [usage
data will be retained for a minimum period of 48 months following the
date of collection, and for a maximum period of 3 months thereafter;
(b) [account
data will be retained for a minimum period of 12 months following the
date of closure of the relevant account, and for a maximum period of 3
months period following that date;
(c) [publication
data will be retained for a minimum period of 12 months following the
date when the relevant publication ceases to be published on our website or
through our services, and for a maximum period of 3 months following that
date];
(d) [enquiry
data will be retained for a minimum period of 48 months period following
the date of the enquiry, and for a maximum period of 3 months following
that date];
(e) [transaction
data will be retained for a minimum period of 3 months following the
date of the transaction, and for a maximum period of 3 months following
that date]; and
(f) [notification
data will be retained for a minimum period of 3 months following the
date that we are instructed to cease sending the notifications, and for a
maximum period of 3 months following that date (providing that we will
retain notification data insofar as necessary to fulfil any request you make to
actively suppress notifications)].
6.4 Notwithstanding
the other provisions of this Section 6, 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 your vital interests or the vital interests
of another natural person.
7. Your rights
7.1 In
this Section 7, we have listed the rights that you have under data protection
law.
7.2 Your
principal rights under data protection law are:
(a) the
right to access - you can ask for copies of your personal data;
(b) the
right to rectification - you can ask us to rectify inaccurate personal data and
to complete incomplete personal data;
(c) the
right to erasure - you can ask us to erase your personal data;
(d) the
right to restrict processing - you can ask use to restrict the processing of
your personal data;
(e) the
right to object to processing - you can object to the processing of your
personal data;
(f) the
right to data portability - you can ask that we transfer your personal data to
another organisation or to you;
(g) the
right to complain to a supervisory authority - you can complain about our
processing of your personal data; and
(h) the
right to withdraw consent - to the extent that the legal basis of our
processing of your personal data is consent, you can withdraw that consent.
7.3 These
rights are subject to certain limitations and exceptions. You can learn more
about the rights of data subjects by visiting https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.
7.4 You
may exercise any of your rights in relation to your personal data [by written
notice to us, using the contact details set out below.
8 Amendments
8.1 We
may update this policy from time to time by publishing a new version on our
website.
8.2 You
should check this page occasionally to ensure you are happy with any changes to
this policy.
8.3 We
[may] OR [will] notify you of [changes] OR [significant changes] to this policy
[by email].
9. Our details
9.1 This
website is owned and operated by Varcurn Marble Limited.
9.2 We
are registered in [England and Wales] under registration number [5222520],
and our registered office is at [Zenith House, Dudnance Lane, Pool, Redruth,
Cornwall, TR15 3QY].
9.3 Our
principal place of business is at [Zenith House, Dudnance Lane, Pool,
Redruth, Cornwall, TR15 3QY].
9.4 You
can contact us:
(a) [by
post, to [the postal address given above]];
(b) [using
our website contact form];
(c) [by
telephone, on [the contact number published on our website]]; or
(d) [by
email, using [the email address published on our website]].
