Waldencroft Privacy & Cookie Policy

BACKGROUND:

We understand that your privacy is important to you and that you care about how your

personal data is used. We respect and value the privacy of everyone who visits our website https://waldencroft.com (“Our Website”) and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.

Please read this Privacy Policy carefully and ensure that you understand it. This policy relates to users of our services.

1. Definitions and Interpretation

In this Policy the following terms shall have the following meanings:

“Cookie”: means a small text file placed on your computer or device by Our Website when you visit certain parts of Our Website and/or when you use certain features of Our Website. Details of the Cookies used by Our Website are set out in Part 14, below; and

“Cookie Law”: means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;

2. Information About Us

Our Website is owned and operated by Waldencroft Ltd, a Scottish company SC520749.

Data Protection Officer: Dr Jacqueline Conway

Email address: [email protected]

Telephone number: 0131 564 1340

Postal address: Hudson House, 8 Albany Street, Edinburgh, EH1 3QB

3. What Does This Policy Cover?

This Privacy Policy relates only to your use of Our Website. Our Website may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.

4. What Is Personal Data?

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

5. What Are My Rights?

Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:

  1. The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 15.
  2. The right to access the personal data we hold about you. Part 13 will tell you how to do this.
  3. The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 15 to find out more.
  4. The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we Please contact us using the details in Part 15 to find out more.
    1. The right to restrict (i.e. prevent) the processing of your personal data.
    2. The right to object to us using your personal data for a particular purpose or purposes.
    3. The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
    4. The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask usfor a copy of that personal data to re-use with another service or business in many cases.

For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 15.

It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us in first instance, using the details in Part 15.

6. What Data Do You Collect and How?

Depending upon your use of Our Website, we may collect and hold some or all of the personal non-personal data set out in the table below, using the methods also set out in the table. Please also see Part 14 for more information about our use of Cookies and similar technologies.

Data Collected

  • Identity data including first name, last name, title, company name when you send us queries or contact us using our Contact Us form on our website.
  • Contact data including email and telephone numbers when you send us queries or contact us using our Contact Us form on our website.
  • Financial data including bank account details, payment card details when you communicate with us about anything relating to your account with us.
  • Marketing and Communications data including your preferences in receiving marketing from us and your communication preferences when you request marketing to be sent to you, give us feedback or communicate with us about anything else by post, phone, email or otherwise.

 

7. How Do You Use My Personal Data?

Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes how we will use your personal data, and our lawful bases for doing so:

What we do

To respond to any query you make via our website using our Contact form.

What data we use

  • Identity data (name, business name)
  • Contact data (email address, phone number)
  • Additional information may be processed if you provide it

Our lawful basis

Necessary for our legitimate interest (for running our business, providing our services

What we do

To respond to any query you make via email.

What data we use

  • Identity data (name, business name)
  • Contact data (email address, phone number)
  • Additional information may be processed if you provide it

Our lawful basis

Necessary for our legitimate interest (for running our business, providing our services.

What we do

To respond to a request by you to be informed about our events and services.

What data we use

  • Identity data (name, business name)
  • Contact data (email address, phone number)
  • Additional information may be processed if you provide it

Our lawful basis

Necessary for our legitimate interest (for running our business, providing our services

What we do

To use data analytics to improve our website, services or marketing.

What data we use

  • Technical data include IP address
  • Usage data (information about how you use our website)

Our lawful basis

  • Necessary for our legitimate interest (to keep our website updated and relevant (essential cookies) Consent (non-essential cookie)
  • Please see our Cookie Policy for further information

What we do

  • To manage our relationship with you which will include notifying you about changes to our terms or privacy policy.

What data we use

  • Identity data (name, business name)
  • Contact data (email address, phone number)
  • Usage data (information about how you use our website)

Our lawful basis

  • Necessary to company with a legal obligation.

With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email with information, news, and offers on our products and/or services. You will not be sent any unlawful marketing or spam. You can ask us to stop sending you marketing messages at any time. The unsubscribe option will be in every marketing email that you receive, or you can update your marketing preferences by contacting us.

Our 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 privacy statements. Please refer to Part 14 for more information on controlling cookies and we advise you to check the privacy policies of any such third parties.

We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 15.

If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis that allows us to do so.

In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.

8. How Long Will You Keep My Personal Data?

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 unauthorized use or disclosure of your personal data, the purpose for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

9. How and Where Do You Store or Transfer My Personal Data?

Some of our external third parties are based outside the European Union (EU) so their processing of your personal data will involve a transfer of data outside the EU.

If any part of the work we undertake for you requires it, we may transfer your personal data to a country outside the EU provided that one of the following conditions applies:

  • The country to which the personal data are transferred ensures an adequate level of protection for the data subjects’ rights and freedoms.
  • The transfer takes place in accordance with binding corporate rules authorized by the relevant data protection authority or other safeguards set out in Article 4 of the GDPR.
  • You have given consent.
  • The transfer is necessary for one of the reasons set out in the GDPR, including the performance of a contract between us, or to protect your vital interests.
  • The transfer is legally required on important public interest grounds or for the establishment, exercise or defence of legal claims.
  • The transfer is authorised by the relevant data protection authority where we have adduced adequate safeguards with respect to the protection of the data subjects’ privacy, their fundamental rights and freedoms, and the exercise of their rights.
  • Where we use providers based in the US, we may transfer them if they are part of the Privacy Shield which requires them to provide a similar protection to personal data shared between the EU and the US.

10. Do You Share My Personal Data?

We will not share any of your personal data with any third parties for any purposes, subject to the following exceptions.

In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

We may sometimes contract with the following third parties to supply certain products and/or services.

  • Mailchimp
  • SurveyMonkey

If any of your personal data is shared with a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 9.

In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

11. How Can I Control My Personal Data?

In addition to your rights under the Data Protection Legislation, set out in Part 5, when you submit personal data via Our Website, you may be given options to restrict our use of your personal data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails.

12. Can I Withhold Information?

You may access certain areas of Our Website and Website without providing any personal data at all. However, to use all features and functions available on Our Website and Website you may be required to submit or allow for the collection of certain data.

You may restrict our use of Cookies. For more information, see Part 14.

13. How Can I Access My Personal Data?

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 15. There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We will respond to your subject access request within one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

14. How Do You Use Cookies?

Our Website may place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by us and are used only by us. We use Cookies to facilitate and improve your experience of Our Website and to provide and improve our products and/or services. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.

By using Our Website, you may also receive certain third-party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, and/or parties other than us. Third-party Cookies are used on Our Website to enhance performance. For more details, please refer to the table below. These Cookies are not integral to the functioning of Our Website and your use and experience of Our Website will not be impaired by refusing consent to them.

All Cookies used by and on Our Website are used in accordance with current Cookie Law.

Before Cookies are placed on your computer or device, you will be shown a prompt requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling us to provide our service to you. Our Website depends on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown in the table below. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below, but please be aware that Our Website may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.

You can choose to accept or decline the following cookies by saving your options below.

The following first-party Cookies may be placed on your computer or device:

PHPSESSID cookie (strictly necessary)

A session cookie is integral to the PHP that runs the content management system. It only lasts for the duration of the users using the website. Your web browser will normally delete this session cookie once you close your browser.

privacy_embeds (strictly necessary)

This cookie is used to store your cookie preference selection made from the options above.

Google Analytics cookies (performance)

Our Website uses analytics services provided by Google Analytics. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling us to better understand how Our Website is used. This, in turn, enables us to improve Our Website and the products and/or services offered through it.

The analytics services used by Our Website uses Cookies to gather the required information. You do not have to allow us to use these Cookies, however whilst our use of them does not pose any risk to your privacy or your safe use of Our Website, it does enable us to continually improve Our Website, making it a better and more useful experience for you.

The analytics services used by Our Website uses the following Cookies:

Name of Cookie: _ga

First/third party: Third

Provider: Google analytics

Purpose: Used to distinguish users

Name of Cookie: _gid

First/third party: Third

Provider: Google analytics

Purpose: Used to distinguish users

Name of Cookie: _gat

First/third party: Third

Provider: Google analytics

Purpose: Used to throttle request rate. If Google Analytics is deployed via Google Tag Manager, this cookie will be named _dc_gtm_.

Name of Cookie: AMP_TOKEN

First/third party: Third

Provider: Google analytics

Purpose: Contains a token that can be used to retrieve a Client ID from AMP Client ID service. Other possible values indicate opt-out, inflight request or an error retrieving a Client ID from AMP Client ID service.

Name of Cookie: _gac_

First/third party: Third

Provider: Google analytics

Purpose: Contains campaign related information for the user. If you have linked your Google Analytics and Google Ads accounts, Google Ads website conversion tags will read this cookie unless you opt-out.

Name of Cookie: CONSENT

First/third party: Third

Provider: Google analytics

Purpose: This cookie is used by Google Analytics to analyse how visitors find our website, how often they visit it, and which pages are the most popular.

In addition to the controls that we provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.

You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Website more quickly and efficiently including, but not limited to, login and personalisation settings.

It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.

15. How Do I Contact You?

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details (for the attention of Dr Jacqueline Conway):

Email address: [email protected]

Telephone number: 0131 564 1340

Postal address: Hudson House, 8 Albany Street, Edinburgh, EH1 3QB

16. Changes to this Privacy Policy

We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if wechange our business in a way that affects personal data protection.

Any changes will be immediately posted on Our Website and Website and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Website and Website following the alterations. We recommend that you check this page regularly to keep up-to-date.

This Privacy Policy was last updated on 10 April 2021.