Privacy & Cookies | Gushlow and Cole
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PRIVACY POLICY 

Your rights to privacy are important to us.

We will only use the information that we collect about you lawfully and in accordance with the Data Protection Act 2018 and the new General Data Protection Regulation which the Act implements.

We have therefore put in place appropriate technical and organisational measures to protect against unauthorised or unlawful processing of your personal information and against accidental loss or destruction of, or damage to it.

PLEASE READ THE TERMS OF THIS POLICY CAREFULLY BEFORE USING THE SITE

1. By using our site you accept these terms
Your access to and use of this website is subject to the terms of this policy, our Online Terms of Business and any other legal notices and statements contained on this website.  By using this website, you agree to be subject to the following terms. If you do not agree to these terms, you must not use our site or order goods from us. We recommend that you print a copy of these terms for future reference.

2. Where to find terms that may apply to you
This Privacy Policy should be read with the following documents that will all apply to you. Click on the links below to go straight to more information on each area:

2.1. Our Website Terms of Use

2.2. This Privacy Policy.

2.3. Our Cookies Policy, which sets out information about the cookies on our site: see below.

2.4. If you are a consumer, our Online Terms of Business (B2C)

3. Why do we have a privacy policy?
Gushlow & Cole Limited is committed to protecting and respecting your privacy and will comply with the obligations imposed on us by the applicable Data Protection legislation, including the UK Data Protection Act 2018, the General Data Protection Regulation ((EU) 2016/679) (GDPR) and any other national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK and any successor legislation to the GDPR or the Data Protection Act 2018 (the Data Protection Legislation). 

4. We shall use personal information provided by you in accordance with the provisions of our Online Terms of Business and in accordance with this policy. 

5. Your use of this website constitutes acceptance of the terms of this policy.

6. Our Privacy Policy will be reviewed from time to time to take account of new laws and technology and any changes to our operational processes and any amendments to this policy will be incorporated in an updated version. Your subsequent use of the website constitutes acceptance of those changes. Any information we hold will be governed by our most recent Privacy Policy.

7. What Personal Information do we collect and how do we use it?
7.1. Gushlow & Cole Limited needs to collect certain personal information to be able to offer its range of products to its customers.

7.2. We will collect and maintain most personal information from customer use of this website or when you correspond with us by phone, e-mail or otherwise. This may be through opening an account with us, filling in forms and registering to use our website and through active use of the website to order products from us.

8. The information we will collect includes (but is not limited to):
8.1. information given when ordering our products or enquiring about or requesting further products;

8.2. information when you report a problem with our website;

8.3. your name, address, delivery address, telephone numbers, email addresses and other contact information, areas of the website used and visited and links to and from third party websites;

8.4. information automatically collected when you use our website including:

8.4.1.3 technical information, the internet protocol (IP) address used to connect your computer to the internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;

8.4.2. information about your visit, including the full Uniform Resource Locators (URL’s), clickstream to, through and from our site (including date and time), products you have viewed and searched for, page response times, download errors, lengths of visits to certain pages, page interaction information (such as scrolling, clicks and mouse-overs), methods used to browse away from the page and any phone number used to call our customer service number. 

8.5. We may also need to collect and maintain information from external sources such as credit references and credit authorisations, and identity verification agencies. We will notify you when we receive information from them and the purposes for which we intend to use that information.

8.6. Periodically we may ask you to voluntarily complete surveys to provide us with information for our marketing or research purposes, although you do not have to respond to them.

9. How will we use your information?
9.1 Gushlow & Cole Limited will use your information for the following purposes:

9.1.1. to open and maintain your customer account/s with us;

9.1.2. to confirm your identity;

9.1.3. to perform and administer any contract we enter into with you in accordance with our Terms of Business;

9.1.4. to process payments from you and, where applicable, to you;

9.1.5. to ensure that content from our website is presented in the most effective manner for you and for your computer;

9.1.6. to provide you with information, products or services that you request from us or which we feel may be of interest to you, where you have consented to be contacted for such purposes;

9.1.7. to audit the usage of our website including:

9.1.7.1. to administer our website for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;

9.1.7.2. to improve our site to ensure that content is presented in the most effective manner for you and for your computer;

9.1.7.3. as part of our efforts to keep our site safe and secure;

9.1.7.4. to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;

9.1.7.5. to make suggestions and recommendations to you and other users of our site about products or services that may interest you or them;

9.1.7.6. to enable us to provide you with the products that you have requested from us and otherwise to perform our legal obligations to you;

9.1.7.7. for training purposes, quality assurance or to record details about the products you order from us;

9.1.7.8. to satisfy and meet our legal and regulatory requirements; and

9.1.7.9. to notify you about changes to our products.

9.2. If you have provided your explicit consent and unless and until you advise us to the contrary, we will also communicate with you about relevant information and opportunities relating to existing and new products which we consider suitable for you.  You have the right to withdraw your consent at any time (see paragraph 16) and, should you wish to do so, please contact info@gushlowandcole.com. Withdrawing your consent is very likely to impact and possibly to prevent the supply of goods and services to you. 

10. Disclosure of Information
10.1. In the standard operation of our business, to answer your enquiries, to perform and administer the contract we enter into with you in accordance with our Terms of Business and to process payments, we may disclose your personal information to the following (who may be within or outside the European Economic Area):
10.1.2. our associated businesses;
10.1.3. our third party service providers, delivery agents, suppliers and professional advisors;
10.1.4. credit agencies;
10.1.5. successors in title to our business;
10.1.6. any organisation or person expressly instructed by you;
10.1.7. any relevant regulatory, governmental or law enforcement authority as required by law;
10.1.8. third parties necessary to provide the products requested by you or necessary to protect the rights, property, or safety of our other customers, our employees, agents, consultants, suppliers or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction; advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers, but we will provide them with aggregate information about our users (for example, we may inform them that 500 women aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in SW1). We may make use of the personal data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience.

10.2. We will endeavour to ensure that any transfer outside the EEA is lawful and that appropriate security arrangements apply.

10.3. In order to transfer personal information to third parties in territories that do not yet retain adequate privacy laws, we will look to enter into agreements with the parties to whom we may there transfer your personal information ensuring appropriate and suitable safeguards that would be accepted as adequate within the European Community.

10.4. We require that organisations outside of our business who handle or obtain personal information as service providers acknowledge the confidentiality of this information, undertake to respect any individual’s right to privacy and comply with the Data Protection Legislation and this policy.

11. Security of Information
11.1. We take the safeguarding of your data very seriously. All personal information in our possession is held securely. We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

11.2. All information you provide to us is stored on secure servers. Any payment transactions are encrypted (using SSL technology). In accordance with our Website Terms of Use, where we have given you (or where you have chosen) a username and password which enables you to open an account and/or to access certain parts of our site, you are responsible for keeping this information confidential. We ask you not to share a password with anyone.

11.3. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. Details of these measures may be obtained from info@gushlowandcole.com

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

12. Your duty to inform us of changes
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.

13. Data Retention
13.1. We will only retain your personal information 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. We will keep under regular review the length of time we need to retain personal data and have put in place internal procedures for this purpose.

13.2. In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer a customer of Gushlow & Cole Limited we will retain and securely destroy your personal information in accordance with applicable laws and regulations.

14. Your rights of access, correction, erasure, and restriction

14.1. Under certain circumstances, by law you have the right to:
14.1.1. Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.

14.1.2. Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.

14.1.3. Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).

14.1.4. Object to processing of your personal information 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. You also have the right to object where we are improperly processing your personal information for direct marketing purposes.

14.1.5. Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.

14.1.6. Request the transfer of your personal information to another party. 

14.1.7. If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact info@gushlowandcole.com in writing.

14.2 No fee usually required
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

15. 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 the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

16. Right to withdraw consent
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact info@gushlowandcole.com. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law. Please note however that withdrawing your consent is very likely to impact the services we can provide to you.

17. Questions, Comments and Complaints
If you have any questions concerning our Privacy Policy, or you would like to change your personal information, or you would like to make a complaint concerning any action of ours which you consider is in breach of our policy please contact our Compliance Department directly. We have appointed a data privacy manager to oversee compliance with this Privacy Policy who can be contacted at info@gushlowandcole.com 

We would hope to be able to deal with any complaint you may have to your satisfaction, but you have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), at https://ico.org.uk/. The ICO is the UK supervisory authority for data protection issues. Our ICO registration number is ZA476923.

18. How we collect your data during website use
Personal Information may be submitted on our website when you open an account with us. You must use a password to enter your account. A “session cookie” is used to enable you to leave and re-enter our website without re-entering your password. Our web server will record the pages you visit within our website. To ensure a good quality of service we may monitor and record any communication you have with us whether in writing, by phone or by electronic mail. E-mail is not encrypted to/from either the public or private areas of this website.

 

 

COOKIES POLICY 

PLEASE READ THE TERMS OF THIS POLICY CAREFULLY BEFORE USING THE SITE

 

  • By using our site you accept these terms 

Your access to and use of this website is subject to the terms of this cookies policy, our Terms of Business and any other legal notices and statements contained on this website.  By using this website, you agree to be subject to the following terms. If you do not agree to these terms, you must not use our site. We recommend that you print a copy of these terms for future reference.

 

  • Where to find terms that may apply to you

 

This Cookies Policy should be read with the following documents that will all apply to you. Click on the links below to go straight to more information on each area:

      1. Our Website Terms of Use: [insert link];
      2. Our Privacy Policy: [insert link];
      3. This Cookies Policy;
      4. If you are a consumer, our Online Terms of Business (B2C): [insert link]; and

 

  • What is a cookie?

 

A cookie is a small file stored on your computer that helps us anonymously to identify your browser from page to page and from visit to visit to improve your experience on a particular website. It assists and can speed up your use and navigation through our site. It stores your preferences and allows the site to remember you. If you do not know what cookies are, or how to control or delete them, then we recommend you visit http://www.aboutcookies.org for detailed guidance.  Alternatively, you can search the internet for other independent information on cookies.

 

  • How do they work?

 

The first time you visit a site which uses cookies, a cookie is downloaded to your device. This can contain a variety of information to improve your visit on the site, such as language preferences, etc. The next time you go back to that website, your browser checks for a stored cookie and sends information back to the website if there is one stored. The website then tailors content appropriately (for example, to display the UK version of the site).

 

  • [Explicit Consent

 

By clicking the Cookies Consent, you have provided explicit consent for us to put cookies onto your computer. If you change your mind, then you should either not use this site, or you should delete our cookies having visited the site, or you should browse the site using your browser’s anonymous usage setting (such as  “Incognito” in Chrome, “InPrivate” in Internet Explorer, “Private Browsing” in Firefox and Safari). You can also change your browser settings to disable cookies or to be advised when cookies are sent to your computer. However this may impair your use of and access to our website and will inevitably impact the services we are able to provide for you, including as to the supply and delivery of goods, so if you hope to be able to order goods from us we advise that you leave cookies enabled.]

 

  • How we use Cookies

 

    1. The following information describes the cookies we use on this site and what they are used for:  
      1. Persistent Cookies for Site Analytics and Performance

Google Analytics

We use this to understand how the site is being used in order to improve the user experience. User data is all anonymous. 

You can find out more about Google’s position on privacy as regards its analytics service at http://www.google.co.uk/intl/en/analytics/privacyoverview.html

      1. Remarketing 

Google AdWords and Bing AdWords

Our website may use Google AdWords and Bing AdWords remarketing to advertise on third party websites to previous visitors to the website. Targeted advertising could be in the form of an advertisement on the Google or Bing search results pages or another website in the relevant display network. Third-party vendors use cookies to serve ads based on someone’s past visits to our website. Of course, any data collected will be used in accordance with our own privacy policy and Google’s or Bing’s (as applicable) own privacy policies.

You can set preferences for how Google and Bing advertise to you using their respective Preferences pages, or you can opt out of their use of cookies by visiting the respective Settings pages. You can find out more generally about Google and Bing’s policies and principles as regards advertising at, respectively:

http://www.google.com/policies/privacy/ads/ 

and 

https://help.bingads.microsoft.com/apex/index/3/en-us/52023

      1. Cookies to Share the Contents of our Website Through Social Media

By using the correct buttons, you can share the content on our website through social media. These buttons are controlled by social media cookies that are installed by the social media parties, so they are able to recognise you when you would like to share content.

These cookies enable logged-in users of selected social media to instantly share content that is available on our website.

Please refer to the privacy and cookies policies that these social media parties have published on their own websites. Beware that these policies may regularly change. We have no influence or control over these third parties or what they do with the data they collect.

In respect of Gushlow & Cole Limited, the social media parties concerned are:

  • Facebook 
  • Instagram
  • Twitter 
  • Pinterest
      1. These cookies are classed by the Information Commissioner’s Office (ICO) as ‘minimally intrusive’. 

 

  • Third Party Content

 

We occasionally provide content through third parties who may implement cookies of their own. This includes trusted third party content providers.

We recommend you set your browser to not accept third party cookies if you do not wish to have these third party services place cookies on your machine. We have little control over what they do with the data they collect.