Blues & Twos Credit Union
Eden Products Ltd (“We”) 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 policy only applies to our site. If you leave our site, 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.
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.
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
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. 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 consent or our legitimate interests, namely the proper administration of our business and websites.
2.2 We may control and process data about your use of our services and website (“usage data”). The usage data may include records of your enquiries, sample requests, orders, invoices, other relevant communications your IP address, length of visit on website, page views and website navigation paths. The sources of the usage data are you and your organisation and our website monitoring process. This usage data may be processed for the purposes of managing our transactions with you and keeping a record of them for future reference as well as analysing the use of the website and services. The lawful basis for this processing is our legitimate interests, namely recording, monitoring and improving our services and website.
2.3 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 consent.
2.4 We may control and process information relating to transactions, including purchases of goods and services or supply of same, that you enter into with us and/or through our website (“transaction data”). The transaction data may include your business contact details, your banking details for payment purposes, your card details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The lawful 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 and our legitimate interests, namely our interest in the proper administration of our business and website.
2.5 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.
2.6 We may control and process information contained in or relating to any communication that you send to us (“correspondence data”). The correspondence data may include the communication content and metadata associated with the communication. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The lawful basis for this processing is our legitimate interests, namely the proper administration of our business and communications with clients, suppliers, partners and website users.
2.7 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.
2.8 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 our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
2.9 We may control and process information supplied to us from Google Analytics. The lawful basis for this processing is our legitimate interest, namely monitoring activity on our website
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 and Orderwise. 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.
4.1 Some of our suppliers are situated in the United States. Transfers to this country will be protected by appropriate safeguards, namely the EU-U.S. Privacy Shield Framework.
5.1 This Section 5 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.
5.2 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.
5.3 We will retain and delete your personal data as follows:
(a) Personal data collected for core business processes (business transactions, customer and supplier surveys, website sign-up) will be deleted if it has been unused for more than 2 years.
(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 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.
5.4 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.
6.1 We may update this policy from time to time by publishing a new version on our website.
6.2 You should check this policy occasionally to ensure you are happy with any changes to it.
6.3 We may notify you of changes to this policy by email.
7.1 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 of the details have been included here. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
7.2 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.
7.3 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. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
7.4 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.
7.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are certain general exclusions of the right to erasure. Those general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
7.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
7.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the lawful basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
7.8 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.
7.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
7.10 To the extent that the lawful basis for our processing of your personal data is consent, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
7.11 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.
7.12 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
(b) using our website contact forms;
(c) by telephone, on 01606 835757 or
(d) by email, using email@example.com
7.13 You may exercise any of your rights in relation to your personal data by contacting us using any of the means above.
8.1 Our website includes 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.
9.1 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.
10.1 Please let us know if the personal information that we hold about you needs to be corrected or updated.
11.1 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.
11.2 Our principal place of business is at:
Eden Products Ltd
11.3 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 firstname.lastname@example.org
12.1 Our data protection officer is Simon Thompstone whose contact details are:
Eden Products Ltd
14 .1 If you have a complaint about us, or the treatment of your data, you can contact us or the UK Information Commissioner.