WHAT PERSONAL DATA & WHY?
Who we are and how to contact us
www.ceuk-intl.com is a site operated by Cutting-Edge UK Ltd (“we”). Company registered number is 06971631. Company registered office at Unit 4E, Wymondham Business Centre, Eleven Mile Lane, Suton, Wymondham, Norfolk, NR18 9JL, UK. VAT number is GB977219283.
To contact us, please use our website contact form, or email to firstname.lastname@example.org, or by telephone on 03330 119978, or write to us at the above mentioned registered address.
Purpose of this privacy notice
This privacy notice aims to give you information on how we collect and process your personal data through your use of our site, including any data you may provide through our site when you sign up to our newsletter, purchase a product or register an account with us.
Our site is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy 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 notice supplements the other notices and is not intended to override them.
Cutting-Edge UK Ltd is the controller and responsible for your personal data (collectively referred to as “we”, “us” or “our” in this privacy notice).
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).
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.
Our site 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 site, we encourage you to read the privacy notice of every website you visit.
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 that you give us through our site or by using our applications, corresponding with us by phone, e-mail or otherwise about you which we have grouped together as follows:
- Identity Data includes first name, middle name, maiden name, last name, username or similar identifier.
- Contact Data includes billing address, delivery address, email address and telephone numbers.
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments to and from you and other details of products you have purchased from us.
- 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 sits.
- Profile Data includes your username and password, purchases or orders made by you.
- Usage Data includes information about how you use our sites, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
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 site 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 notice.
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 health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
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). In this case, we may be unable to process an order for a product or we may have to cancel a product you have ordered with us but we will notify you if this is the case at the time.
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 and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you;
- place an order for our products;
- return any products or request a refund;
- receive and/or rely on any warranty we or our suppliers provide to you;
- submit a comment on our sites;
- interact with us on our social media;
- submit an enquiry to us regarding our products;
- create an account on our sites;
- subscribe to our newsletters;
- request marketing to be sent to you;
- if you apply for a job with us; or
- give us some feedback.
- Automated technologies or interactions. As you interact with our site, 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.
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 or have entered 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; and
- to the purchaser (or prospective purchaser) of any business or asset that we are (or are contemplating) selling.
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. You have the right to withdraw consent to marketing at any time by contacting us.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
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 and offers may be relevant for you (we call this marketing). If you have requested information from us or purchased goods from us prior to the 1st October 2020, we will rely on our legitimate interests to market to you in relation to similar goods and information on our offers and news.
For any new customers after the 1st October 2020, we will request your consent to provide you with our marketing communications and, if you do not consent, we will not send you this information.
You will receive marketing communications from us if you have consented to join our email database, requested information from us or purchased goods from us (prior to 1st October 2020) and, in each case, you have not opted out of receiving that marketing.
We will not share your information with any third parties for marketing purposes.
Interacting with Cutting-Edge UK Ltd on social media
If you have mentioned one of our brands in a social media post by tagging @CEuk_intl on Instagram, Facebook or Twitter or by using our brand hashtag #CEuk in a comment you may have received a request from us which asks permission to use the image which you have posted and/or commented on our product pages.
If you reply as stated in the comment and accept that we will use the image on our product pages we will feature it on our website product pages. We will not share the image with any other third parties, it will only be re-posted on the relevant product pages on our website.
Usage of tagged images from social media
If you have actively tagged an image with our social media profile @CEuk_intl on Instagram, and/or Facebook and/or Twitter in a post then we will accept this as permission to re-post the tagged image on our product pages. We will not share the image with any other third parties, it will only be re-posted on the relevant product page on our website.
Usage of hashtags from social media
If you have actively mentioned one of our brands #CEuk_intl on Instagram, and/or Facebook and/or Twitter in a post then we will accept this as permission to re-post the tagged image on our product pages. We will not share the image with any other third parties, it will only be re-posted on the relevant product page on our website.
You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product purchase, warranty registration, product experience or other transactions.
Business to Business Communications
We do not collect personal data for our business customers, beyond business emails and a telephone number of you or your employees, as well as recording a history of contact.
We rely on legitimate interest to store and use this information, because we need to communicate with you in order to provide our products and perform our functions, as well as responding to requests for information and placing orders. We believe it is within your reasonable expectations that we will process this minimal contract information and this will not impact the legal rights and freedoms of you and/or your employees. We also provide the opportunity for you to opt out of any communications and you may exercise your data rights.
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.
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.
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.
Cookies can be used by web servers to identity and track users as they navigate different pages on a website and identify users returning to a website.
We use both session and persistent cookies on our sites.
The names of the cookies that we use on our sites, and the purposes for which they are used, are set out below.
We use Google Analytics to analyse the use of our sites.
Most browsers allow you to refuse to accept cookies; for example:
- in Internet Explorer (version 10) you can block cookies using the cookie handling override settings available by clicking “Tools”, “Internet Options”, “Privacy” and then “Advanced”;
- in Firefox (version 24) 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
- in Chrome (version 29), 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.
Blocking all cookies will have a negative impact upon the usability of many websites. If you block cookies, you will not be able to use all the features on our sites.
You can delete cookies already stored on your computer. Deleting cookies will have a negative impact on the usability of many websites.
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.
Disclosures of your personal data
We may have to share your personal data with the parties set out below:
- Internal third parties such as our employees or officers and legal entities within Cutting-Edge UK Ltd.
- External third parties including payment providers, specialist IT support, data analytics and technology providers, suppliers and sub-contractors, delivery courier services, for the management and taking of payments, performance of our sites and our applications, arranging delivery to you and to facilitate any contract we enter into with them or you.
- Professional advisers including lawyers, bankers, marketing agencies, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- Credit reference agencies, law enforcement and fraud prevention agencies to help us prevent and deal with fraud.
- HM Revenue & Customs, regulators and other authorities who require reporting or processing activities in certain circumstances.
- 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 notice.
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.
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 do not 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.
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.
Your personal customer data will be stored for no longer than 7 years from when you last purchased a product from us, or 2 weeks following a request for this information to be deleted, providing we have no other legal basis or requirement to retain it.
Record of sale data
Data relating to purchase(s) will be stored for no longer than 7 years from when you last purchased a product from us, or 2 weeks following a request for this information to be deleted, providing we have no other legal basis or requirement to retain it.
Email & Marketing data
If you have registered to receive communications from us as part of our mailing list, then we will keep your personal data for 2 years, at which time we will contact you to ensure you are happy to remain on the mailing list. If you do not want to continue to receive emails, we will no longer send you updates and will automatically delete your personal data at that time, providing we have no other legal basis or requirement to retain it.
For site users, we will usually keep data for 2 years.
For job applicants, we will usually keep data for 2 years.
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.
Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
Marketing – We will inform you (before collecting your data) if we intend to use your data for marketing purposes. We will only use your data for this if you have agreed in advance.
Correction Of Information – If you notify us that the personal data we hold is complete or inaccurate we will correct or complete the information as soon as possible.
Deletion Of Information – You have the right to request that your personal data be deleted; including if we no longer need it for the purpose we collected it, or you withdraw your consent.
Following such a request we will erase your personal data without undue delay unless continued retention is necessary and permitted by law. If we made the personal data public, we will take reasonable steps to inform other data controllers processing about your erasure request.
Object to processing – You have the right to object to us processing 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.
Restriction on processing – You have the right to request that we suspend processing your personal data, but hold it for you, in the event the personal data we hold is inaccurate, the processing is unlawful or we no longer need the personal data. Once the processing is restricted, we will only continue to process your personal data if you consent or we have another legal basis for doing so.
Access to information – You have the right to access information held about you and any access request will usually be free of charge. We will endeavour to provide information in a format requested, but we may charge you a reasonable fee for additional copies.
Data portability – You have the right to receive a copy of your personal data which you gave to us. The copy will be provided in a commonly used and machine-readable format. You can also have it transmitted directly from us to another data controller, where technically possible.
If you wish to exercise any of the rights set out above, please contact us. 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.
Withdraw consent at any time
You may 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.
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.