Privacy Policy

Introduction

Welcome to Castle & Gregory’s privacy notice. 

Castle & Gregory respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) or buy or use any of our products/services and will tell you about your privacy rights and how the law protects you. 

Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice. 

1. Important Information and Who We Are 

Purpose of this Privacy Notice 

This privacy notice aims to give you information on how Castle & Gregory collects and processes your personal data through your use of our website at www.castleandgregory.co.uk, or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you place an order, request a quote, subscribe to our marketing, search for a product, browse our website, create an online account, add products to your online cart, participate in discussion boards or other social media functions on our website, use or post on bulletin boards on our website, take part in a competition, prize draw, promotion or survey, register for one of our events, use the form on our website to contact us or report a problem with our website. 

This website 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. 

Controller 

Castle and Gregory Limited is the controller and responsible for your personal data (collectively referred to as “we”, “us” or “our” in this privacy notice).

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacynotice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below. 

Contact Details 


Full name of legal entity:
Castle and Gregory Limited

We have a Data Privacy Manager to help make sure we’re transparent and fair about how we use your data and comply with any law that may affect your privacy. 

If you have any questions, comments, or concerns about how we handle your personal data, then you may contact us at:

Data Privacy Manager

c/o Customer Services Team

Castle and Gregory Ltd

Keys Road 

Alfreton 

Derbyshire DE55 7FQ 

customercare@castleandgregory.co.uk 

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). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance. 

Changes to the Privacy Notice and Your Duty To Inform Us of Changes


This version was last updated on 25thMay 2018 and historic versions can be obtained by contacting us.

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. 

Third-Party Links

This website 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 privacystatements. When you leave our website, we encourage you to read the privacy notice of every website you visit. 

2. 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 about you which we have grouped together follows: 

Identity Data includes first name, last name, username or similar identifier, title, proof of residency / identity. 

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 and services you have requested, purchased from us or wish to purchase 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 website. 

Profile Data includes your username and password, purchases or orders made by you (including any cancelled or returned purchases or orders), purchases or orders under consideration by you (including requests for custom made goods, quotes and incomplete website orders) your interests, preferences, feedback and survey responses. 

Usage Data includes information about how you use our website, products and services (see our Cookie Policy for further details).


Marketing and Communications Data includes your preferences in receiving marketing from us 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 website 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 or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time. 

3. 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, Profile, Marketing and Communications and Financial Data by filling in forms (on our website or in person) or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

    • request a quote; 
    • contact us with a query;
    • create an account on our website; 
    • request our marketing be sent to you;

    • enter a competition, promotion or survey; or
    • give us some feedback.

Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy for further details. 

• Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below: 

    • Technical Data from analytics providers, advertising networks and search information providers such as Google, based outside the EU.
    • Identity and Contact Data from data brokers or aggregators such as Royal Mail Group, based inside the EU. 
    • Identity and Contact Data from publicly availably sources such as the Electoral Register, based inside the EU.
    • Your reviews of our products and services from review sites such as Trustpilot, based inside the EU.

 

4. 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 into or have entered into 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. 

• Where we have your consent. 

See the table below to find out more about the types of lawful basis that we will rely on to process your personal data. 

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you if you are not a previous customer (you are a previous customer if you have placed an order or quote request for our products, services or samples). You have the right to withdraw consent to marketing at any time by Contacting us

Purposes For Which We Will Use Your Personal Data 

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. 

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please Contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below. 

Purpose/Activity 

Our Reasons (Legal Basis)

Basis of Our Legitimate Interests (if applicable)

To register you as a website account holder

Legitimate interests

For process efficiency

To respond to queries raised prior to placing an order 

Legitimate interests

To provide you with the best service, to build our relationship and grow our business

To process and provide a quote

Fulfil a contract

n/a

To provide assistance prior to placing an order, including items placed in cart and checkout process not completed

Legitimate interests

To provide you with the best service, to build our relationship and grow our business

To process and deliver your order including to: 

(a)   confirm order received;

(b)   confirm order accepted;

(c)   process your order; 

(d)   provide products / services; and 

(e)   for billing purposes, to manage payments, fees and charges

 

Fulfil a contract

 

n/a

To manage our relationship with you, which may include a request to:


(a)    review/update contact details;

(b)    undertake customer satisfaction surveys;

(c)    provide product/service reviews;

(d)    feedback on our products, services and your experience.

 

 

Legitimate interests

To provide you with the best service and understand how we can improve our products and services based on your experience.

To enable you to take part in a prize draw or competition

Fulfil a contract

Legitimate interests

 

To develop our products and services and grow our business 

To allow you to participate in interactive features of our service, when you choose to do so

Legitimate interests

To develop our products and services and grow our business

To provide ‘customer service’ assistance 

Fulfil a contract

Legitimate interests

To develop our products and services and grow our business

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) 

Legitimate interests

For running our business, provision of administration and IT services, network security, maintaining and improving services, to prevent fraud

 

To detect, investigate and report financial crime (e.g. Fraud)

Legitimate interests

Legal obligation

To protect our business, employees and customers, and to make service and process improvements.

 

To deliver relevant website content and online advertisements to you and measure or understand the effectiveness of the advertising we serve to you 

Legitimate interests

To study how customers use our products and services, to develop them, to grow our business and to inform our marketing strategy

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences 

 

 Legitimate interests

To define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy

Marketing communications to inform you of special offers, promotions, news and events.

 

Legitimate interests

Consent (where you are not a previous customer)

For direct marketing, to build our relationship and grow our business

 

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms: 

  • 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, services and offers may be relevant for you (we call this marketing). 

You will receive marketing communications from us if you have requested information from us or placed an order for goods or services from us and, in each case, you have not opted out of receiving that marketing. 

  • Third-Party Meeting 

We will get your express opt-in consent before we share your personal data with any other company for their own marketing purposes. 

  • Opting Out 

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by Contacting us at any time. 

Where you opt out of receiving these marketing messages, we will retain any personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions. 

  • Cookies 

Our website uses cookies to distinguish you from other users of the website. This helps us to provide you with a good experience when you browse the website and also allows us to improve the website. 

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.

  • 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. 

5. Disclosures of Your Personal Data 

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above. 

  • Internal Third Parties as set out in the Glossary.

  • External Third Parties as set out in the Glossary.

  • 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 share only the minimum amount of personal data needed. 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. 

6. International Transfers 

Primarily we store all of our data within the European Economic Area (“EEA”) however the personal data that we collect from you may be transferred to, and stored outside the EEA. 

Whenever we transfer your personal data out of the EEA, we will put in place an appropriate contractual provisions to ensure that there are strict rules regarding both the confidentiality and security of your information. To find out more please Contact us.

7. Data Security 

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, for example:

• information you provide to us is stored on our secure servers; 

• online payment transactions are encrypted using SSL technology;

• access to your personal data which is not stored electronically is locked with limited access by key; 

 

In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who 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. 

Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website, you are responsible for keeping this password confidential. You must not share this password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

We have put in place procedures to deal with any suspectedpersonal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. 

8. Data Retention 

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. 

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see Request erasure[link to section 9] below for further information. 

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. 

9. Your Legal Rights 

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please visit the 'Your Legal Rights' section to find more information about these.

  • Request access to your personal data.

  • Request correction of your personal data.

  • Request erasure of your personal data.

  • Object to processing of your personal data.

  • Request restriction of processing your personal data
  • Request transfer of your personal data
  • Right to withdraw consent.


If you wish to exercise any of the rights set out above, please Contact us. 

No Fee Usually Required 

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. 

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. 

10. Glossary

Lawful Basis

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by Contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. 

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to. 

Third Parties 

Internal third parties 

There are no Internal Third Parties. 

External third parties 

• Service providers acting as processors based in the EU who provide services for the performance of any contract we enter into with them or you such as IT and system administration services, website and marketing agencies, delivery services, print and mailing services, data services. 

• Payment processors / service providers such as Paymentsense, Paypal and Hitachi, acting data as controllers and who are based in the EU.

• Guardsman, acting as controllers based in the EU who provide furniture protection plans.

• Professional advisers and service providers acting as processors including lawyers, bankers, accountants, auditors and insurers based in the EU who provide consultancy, banking, legal, insurance and accounting services. 

• HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances. 

• Advertisers and advertising networks such as Google and Facebook, based outside the EU, that require the data to select and serve relevant adverts to you and others.  Information disclosed to our advertisers and advertising networks is anonymised so that information by which individuals would be identifiable would not be disclosed; 

• Review sites such as Trustpilot based in the EU (acting as processors and controllers at different stages of the process), to collect feedback from you on our behalf;

• Analytics and search engine providers that assist us in the improvement and optimisation of our website;

• Market researchers, acting as processors or controllers (depending on the research being undertaken) based in the EU.

• Organisations that we may partner with in connection with prize draws or competitions, in which case your personal data will be shared only as necessary for fulfilment/delivery/arrangement of the prize, unless otherwise stated in the advertised terms of the specific competition / prize draw.

• Named third party partners in a competition / prize draw for their marketing purposes where you have consented to this during the course of entry into the competition / prize draw, in which case your personal data will be held by the named third party partner subject to their privacy policy, which you should familiarise yourself with.

We may also need to share your personal information with a regulator or to otherwise comply with the law, or in order to enforce or apply our Website Terms of Use or Terms and Conditions of sale and other agreements; or to protect the rights, property or safety of Castle and Gregory Limited, our customers, employees or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

Your Legal Rights 

You have the right to: 

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. 

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. 

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. 

Object to processing of 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. 

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. 

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. 

Withdraw 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.