Privacy Notice and Consent Policy

Version:  2.0

Date:  04/01/2022

Author:  Ian Bellingham

Stored at:  CPP Ltd

Privacy Statement

We take your privacy seriously and will only use your personal information to administer your account and to provide the products and services you have requested from us. We will never sell, share, or use your personal or business information other than as described here.

About this privacy policy

This policy sets out how we will use and share the information that you give us.  This policy describes your relationship with CPP Ltd.

The Data Protection Act 1998 (DPA) and General Data Protection Regulation (GDPR) describes how organisations must collect, handle, process and store personal information.

These rules apply regardless of whether data is stored electronically, on paper or on other materials.
To comply with the law, personal information must be collected and used fairly, stored safely and not disclosed unlawfully. GDPR is underpinned by eight important principals. These say that personal data must:

1. 1. Be processed fairly and lawfully.
   2. Be obtained only for specific, lawful purposes.
   3. Be adequate, relevant and not excessive.
   4. Be accurate and kept up to date.
   5. Not be held for any longer than is necessary.
   6. Processed in accordance with the rights of the data subjects.
   7. Be protected in appropriate ways
   8. Not be transferred outside the European Economic Area unless that country or territory also ensures an adequate level of protection.

We are serious about our responsibilities and this document describes our approach to data protection.

This policy helps to protect us from data security risks, including:

• Breaches of confidentiality. For instance, information being given out inappropriately;
• Failing to offer choice. For instance, all individuals should be free to choose how the company uses data relating to them; and
• Reputational damage. For instance, the company could suffer if hackers successfully gained access to sensitive data.

Who are we and how to contact us

Corrugated Plastic Products (CPP Ltd) is registered in England and is registered with the Information Commissioner’s Office under the Data Protection Act 1998. The Data Controller is Ian Bellingham.  You can get in touch with us in any of the following ways:

Email: office@cppltd.com

Tel: 01425 470249 – Mon-Fri      0830 – 1700

Post: Ian Bellingham, CPP Ltd, Unit 21, Hightown Industrial Estate, Crow Arch Lane, Ringwood, BH241ND

How to change your preferences

You can contact us at office@cppltd.com to change your preferences at any time. You can also call us using the above contact number.

How we operate

We operate in line with EU GDPR [May 2018] Data Protection guidelines.  We are committed to maintaining your rights and allow all users to change or withdraw their opt-in options at any time. We will also advise you on how to complain to the relevant authorities, namely the Information Commissioners Office – https://ico.org.uk/

Who this privacy policy applies to

This policy relates to any relationship that CPP Ltd may have on a Business to Business level (B2B). The processing of your data and how we store it is required for us to operate within a business framework. This policy applies to individuals and organisations that we interface with on a regular basis as either a customer, supplier, administrator, or in any other capacity within the B2B framework.

What this policy applies to

This section describes the lawful basis for processing your data and applies to the information about yourself that you choose to provide us with or that you allow us to collect.

The lawful basis for processing any data for the purposes of B2B is based upon Consent and Legitimate Interests and we are committed to conducting and recording legitimate interest assessments where necessary and ensuring business data supplied by our customers and suppliers have the option for consent or not.  This includes:

As a Customer and Supplier:

• information you provide during the initial contact process;
• information you provide for the purposes of engaging in business with CPP Ltd;
• information we collect about how you have used our website or any other medium;
• information relating to purchases and other transactions; and
• information given and stored as part of our ongoing relationship.

Scope of Consent

By submitting your personal data on with us, you are affirming your explicit consent for such information to be used in accordance with this Privacy Policy. You will be able to withdraw that consent at any time by the methods described.

Opting out

Once you have given your consent to use any information for the purposes of B2B, you can amend or withdraw your consent at any time.  You can also choose to object to the processing of any specific data we use at any time.  We respect all user rights as defined in GDPR.  If you have any comments or wish to complain please contact us office@cppltd.com

How we store and process your data

Your account data will be collected stored and processes in the UK only and is not externally facing. Your data will be stored for as long as we continue to have a Business relationship with you. We use recognised procedures and utilise Banking best practices to take payment, manage our company accounts, and provide banking services. We will store transaction, payment, and order data for up to 7 years or for as long as required by UK financial and company regulations.

Our obligations.

We are a data controller.  In relation to the information that you provide to us, we are legally responsible for how that information is handled. We will comply with the Data Protection Act 1998 and the GDPR (2018) in the way we use and share your personal data.  Among other things, this means that we will only use your personal data:

• Fairly and lawfully;
• As set out in the legislation and this policy;
• To the extent necessary for these purposes; and
• We will take steps to ensure your data is accurate and rectify data as necessary.

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:

• 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; and
• Right to withdraw consent.

You can see more about these rights at:

https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

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.

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.

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.

Third Parties

We may have to share your personal data with the parties set out below for the purposes described in this document:

• Service providers who provide IT and system administration services;
• Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, credit scoring, banking, legal, fraud protection, insurance and accounting services;
• HM Revenue & Customs, regulators and other authorities based in the United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances; and
• Third parties to whom we sell, transfer, or merge parts of our business or our assets.

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

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. 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 such data. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We will report any breaches or potential breaches to the appropriate authorities within 24 hours and to anyone affected by a breach within 72 hours.  If you have any queries or concerns about your data usage, please contact us.

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

Cookies

A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added, and the cookie helps analyse web traffic or lets you know when you visit a specific site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences. We use traffic log cookies to identify which pages are being used. This helps us analyse data about webpage traffic and improve our website to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

Overall, cookies help us provide you with a better website by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.

As well as your ability to accept or reject cookies, we also require your permission to store cookies on your machine, which is why when you visit our site, you are presented with the ability to accept our terms of use, including the storage of cookies on your machine. Should you not accept then you are free to leave our website, at any time.

Legitimate Interests

Under the Data Protection Act, we are also permitted to share some information with third parties who use such data for non-marketing purposes (including credit and risk assessment and management, identification and fraud prevention, debt collection and returning assets to you).

Contacting us, exercising your information rights and Complaints

If you any questions or comments about this Privacy Policy, wish to exercise your information rights in connection with the personal data you have shared with us or wish to complain, please contact: The Data Protection Officer at CPP Ltd.  We will process Subject Access Requests (SARs) within 30 days, SAR responses are usually at no cost, but we reserve the right to charge for excessive or unfounded requests. We fully comply with Data Protection legislation and will assist in any investigation or request made by the appropriate authorities.

The General Data Protection Regulation (GDPR) includes strict rules on giving privacy information to data subjects. These are more detailed and specific than in the Data Protection Act and place an emphasis on making privacy notices more transparent, and accessible.

If you remain dissatisfied, then you have the right to apply directly to the Information Commissioner for a decision.  The Information Commissioner can be contacted at:

Information Commissioner’s Office

Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

www.ico.org.uk