Marketing & Social Media Privacy Notice
Cuts Ice – Marketing & Social Media
This privacy notice was last updated on 24th May 2018.
1. What is the purpose of this Privacy Notice?
Your ‘personal data’ or ‘personal information’ is any piece of information that would allow us to identify you as an individual. The processing of personal data is governed by the EU General Data Protection Regulation (the “GDPR”) and national laws that implement the GDPR in each European Economic Area (“EEA”) country.
We take your privacy very seriously, and this document sets out what personal information we collect from you in relation to this service, how we intend to use it and what your rights in respect of that information are. By participating in our marketing activities and/or events and using our social media sites, you are accepting and consenting to the practices described in this Privacy Notice.
It is important that you read this Privacy Notice (together with any other privacy notice or fair processing notice we may provide you with on specific occasions when we are collecting or processing personal data about you) and we encourage you to keep copies of all such notices for your records.
Our products and/or services are not intended for children and we do not knowingly collect data relating to children.
2. Who controls your personal information, and how do you get in touch?
The controller of your personal information is Cuts Ice Limited, a company incorporated and registered in England and Wales under company number 07512911 (“we”, “us”, “our”). Cuts Ice Limited is a member of the Cuts Ice group comprising many different legal entities. This Privacy Notice is issued on behalf of all companies in the Cuts Ice group. The Cuts Ice group owns many different brands, as follows, which you may interact with us through:
Should you have any query in respect of this Privacy Notice (including details of the group companies) or your personal information, you can contact us at the following:
|Data controller||Cuts Ice Limited|
|Address||Unit 2 Origin Business Park, Rainsford Road, Park Royal
London, NW10 7FW
|Telephone||+44 208 960 6974|
3. What information do we collect about you, and for what purpose?
We may collect, use, store and/or transfer information about your identity, contact details and marketing & communications preferences if you sign up for one of our newsletters (on the website or in person) or enter one of our competitions, including:
- Email address;
We may also collect, use, store and/or transfer information about your identity, contact details and profile the if you use our social media sites, or interact with us on social media:
- Email address;
· Details you share with your social media platform and allow us to have access to.
If you come to an event and interact with us on stand, or make a purchase from us at that event, we may collect, use, store and/or transfer information about your identity, contact details, financial and/or transaction data and marketing & communications preferences, such as your:
- Email address;
- Telephone Number;
- Address (billing and shipping);
· Transaction or financial information (although your financial data, such as payment card details, will be captured by our payment service providers and not by us directly);
We may also collect, use and share aggregated data such as statistical or demographic data for any purpose if you cannot be identified in any way. 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. However, if we combine or connect aggregated data with your personal information 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.
4. How do we collect and use your personal information?
We collect your personal information through different methods, including:
- Information you give us. You may give us information about your identity, contact details, financial and/or transaction data and marketing & communications preferences when you sign up to a newsletter, enter a competition, or purchase something from us at an event.
- Information we automatically collect about you. We may automatically collect information about your profile if you share certain details with your social media platform.
- Information we receive from other sources . We may receive personal data about you from various third parties and public sources. For example, we may receive:
o technical data from analytics providers;
o contact, financial and transaction data from providers of technical, payment and delivery services; and
o identity and contact data from selected business partners, data brokers or aggregators.
We may purchase lists of data from organisations, from time to time, that can provide data privacy records showing your consent for the use of this data by us. There may also be instances where people make purchases on your behalf and sign you up to our services. If this is the case then we will endeavour to contact you within thirty (30) days to let you know this has happened, and you can ask us to stop processing at this point. We may also use your information if you have made this public, are over 18 and may have interacted with us.
5. What is our legal basis for collecting and using your personal information?
We will use your personal information in the following ways and for the following purposes:
|The identity data, contact details and marketing & communications preferences you give us if:
· You sign up for a newsletter;
· Enter one of our competitions;
· Sign up at an event to receive information from us;
· Sign up for information via social media.
|To be able to supply you with information about our products, allow you to enter competitions, provide you with promotional codes, give you free product and generally interact with you about our e-liquids.||Necessary for our legitimate interests (to run our business, inform our marketing strategy, manage our relationship with you and keep our records updated).
If you have already given us your data prior to 25 th May 2018 then we will process this information for our legitimate interests as the controller of this data.
However, to give you more choice going forwards and to be more granular we will ask you to consent to us using your data for these purposes.
|Social media sites allow interaction with your personal data in many ways – generally based on the level of information that you decided to share (e.g. data about your identity, contact details and profile). Therefore, the amount of data you share with us, upon interaction, will be controlled by you and the privacy settings you select in each social media platform that you interact with us through.||To be able to interact with you on social media. This may include to supply you with information about our products, allow you to enter competitions, provide you with promotional codes, give you free product and generally interact with you about our e-liquids.
You may also private message us to answer queries you may have.
|You have consented to us using your data through the interaction that you have with us on these social media sites.
We also have a legitimate interest (growing our business and informing our marketing strategy) as you have made your data public and expressed an interest in our products.
It is also necessary for our legitimate interests (e.g. to recover debts due to us, manage our relationship with you and keep our records updated).
6. What if you do not want to provide your personal information?
You do not have to provide your personal information to us. However, should you choose not to provide it, you will be unable to receive our newsletters or other information from us, interact with us over social media. Where we need to collect personal data by law or under the terms of a contract we have with you (e.g. if you try to purchase anything from us at trade shows) and you fail to provide it when requested, we may not be able to perform the contract we have or are trying to enter into with you and may have to cancel the product and/or service you have with us (but we will notify you at the time if this is the case).
7. How is your personal information protected?
We maintain strong physical, electronic and procedural safeguards to protect the confidentiality, integrity and availability of your personal information. We have taken appropriate security measures against illegal and/or unauthorised access to your personal information, and against the accidental loss of, or damage to, it.
8. Do we share your personal information with anyone?
Data is shared as part of the usage of the website with several parties outside of Cuts Ice that allow us to process your data. These parties, and the purposes for sharing the data, are set out below:
|Microsoft||Microsoft provide our email service and when you email us this will be controlled under: https://products.office.com/en-us/business/office-365-trust-center-privacy|
|Payment service provider / Bank||If you purchase something from one of our e-liquid brand sites then to process your payment we may need to share information with our partners to process this payment.|
|Address / Age verification service||As our services are aimed at over 18’s we have a requirement to verify your address and age. We will share information with our provider to ensure that you are eligible to purchase our products.|
We may also need to share your personal information with the following in limited circumstances:
- IT security providers;
· External advisors (for example solicitors or auditors); and
- Public authorities or law enforcement.
If we sell or buy (or plan to sell or buy) any business or assets or seek investment from a third-party investor, we may disclose your personal data to the investor or prospective seller or buyer of such business or 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.
Any time we provide access to your personal information to someone else, we will ensure that it is adequately secured to protect your privacy and that they comply with the requirements of the applicable data protection legislation.
9. Will your personal information be transferred outside of the EEA?
If you are a resident of a country in the EEA, we may need to transfer your personal information outside of the EEA, for example where our data storage facilities or processing locations are in another country.
Whenever we transfer your personal data outside of the EEA, we ensure a similar degree of protection is afforded to it by putting adequate, legally-approved safeguards in place, including at least one of the following:
· we will only transfer your personal information to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission;
· where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe; and
· where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.
If you would like more information about our safeguards, please contact us using the details inserted in Section two (2) above.
Please note that some of the social media companies that we interact with may share your data outside of the EEA. We have no control over this as it is bound by their data privacy notices to you. Please see section eight (8) above and review their data privacy notices carefully.
10. How long do we keep your personal information?
We will only retain your personal data for as long as necessary to fulfil the purposes we hold it for, including for the purposes of satisfying any legal, accounting or reporting requirements. In general, we will need to keep the information that we collect from you for the following periods of time:
|· If you sign up for a newsletter.
· Enter one of our competitions.
· Sign up at an event to receive information from us.
· Sign up for information via social media.
|We will retain this information for the lifetime of the relationship between us. You have the right to withdraw consent or ask us to stop processing your data at any time for these services.
If you ask us to stop processing your data we will only retain enough information to ensure that we can comply with your requirements, to ensure that we do not contact you again.
|Interact with us via social media.||We will retain this information for the lifetime of the relationship between us. You have the right to withdraw consent or ask us to stop processing your data at any time for these services.
Information shared in social media will be retained based on the settings that you have selected in the social media platform. More information can be found on this in section eight (8) above.
|Your data may be collected as part of analytics that we use to monitor usage of social media interaction.||We will retain the analytics data for twenty-six (26) months. At which point the data will be anonymised or removed.|
|If you purchase something from us.||Your transactional information will be maintained for six (6) years in line with Cuts Ice standard business records
Your payment card information will be maintained for twenty-three (23) months as required by the card schemes under a contract that we hold with them.
We may sometimes need to keep a copy of your personal information for a longer period, for example in the event of an incident, to investigate a data breach or to comply with legal requirements. We will never keep your personal information for longer than we consider necessary.
In all cases, your personal information will be securely destroyed once the retention periods described above expire.
11. What are your rights in respect of your personal information?
You have rights in respect of the personal information we hold on you, including the right to ask us to:
- inform you on how we collect and use it (this Privacy Notice is designed to do that);
- rectify it if you believe that it is incorrect;
- delete it (only to the extent you consented to us using it);
- provide you with a copy of any information we hold on you in a portable data format that we agree;
- request the transfer of it to you or a third party;
- tell you about automated decision-making solutions that we use; and
- restrict the processing of it e.g. stop processing or using it temporarily.
You can also object to our use of your personal information for our legitimate purposes at any time.
Should you want to exercise any of those rights, please contact us using the details set out in Section 2 above.
Out partners use automated decision making for the following reasons:
· To decide if you are over 18 and able to purchase our products;
· To process your payment card for your purchase to be approved.
Cuts Ice does not handle these processes directly and they are provided to us. If you would like to know more about these processes and which companies to contact to find out how this data is processed then please contact us using the details set out in Section 2 above. 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 several requests. In this case, we will notify you and keep you updated.
12. Will we do anything else with your information in the future?
Where we need to use your personal data for another reason, other than for the purpose for which we collected it, we will only use your personal data where that reason is compatible with the original purpose.
Should it be necessary to use your personal data for a new, unrelated purpose, we will endeavour to notify you and communicate the legal basis which allows us to do so before starting any new processing.
The exception to this is where use of the personal information is required or permitted by law e.g. to a recall of any of our products, updated allergy advice or for another legal reason that may require us to contact you. In this case, we may process your personal information without your knowledge or consent.
13. You have the right to complain to us or our supervisory authority
You also have the right to lodge a complaint with our supervisory authority, the Information Commissioner’s Office, which can be contacted at the following:
|Supervisory Authority||UK Information Commissioner’s Office|
|Address||Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, United Kingdom|
|Telephone||0303 123 1113|
14. Changes to this Privacy Notice and your duty to inform us of changes
We may need to make changes to this Privacy Notice in the future (for example, to comply with new legal requirements).
Where that is the case, we will provide you with a revised Privacy Notice on our website, which you will be able to access. If required by law, we will seek your prior approval before revising this Privacy Notice.
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.