The Cheese Tasting Company Privacy & Data Protection Policy
The Cheese Tasting Company respects your privacy and is committed to protecting your personal data.
2. Our website
Our website at sells goods and services which are aimed at private and business customers. CTC is the Data Controller responsible for this website and any handling of personal data carried out by or on our behalf.
3. Personal data which 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 a variety of information about our customers and visitors to the CTC website. This personal data falls into these categories (not all categories are currently collected:
Identity Data includes title, first name, last name, username or similar identifier and an encrypted version of your login/password. If you interact with us through social media, this may include your social media user name.
Contact Data includes billing address, delivery address, email address and telephone numbers.
Financial Data includes payment card details.
Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
Profile Data includes your username and password, purchases or orders made by you, preferences, feedback and survey responses, as well as any profile data which we have added (for example, using analytics and profiling).
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 this website.
Usage Data includes information about how you use our website, products and services.
Tracking Data includes information we or others collect about you from cookies and similar tracking technologies, such as web beacons, pixels, and mobile identifiers.
Marketing and Communications Data includes your preferences in receiving direct marketing from us and our third parties and your communication preferences.
We may also collect and use 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.
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.
Remember, if you choose not to share personal data with us, or refuse certain contact permissions, we might not be able to provide the products and services you’ve asked for.
4. 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 and Financial Data by filling in forms or by corresponding with us by post, phone, email or through chat or social media. This includes personal data you provide when you:
Sign up to receive a CTC newsletter.
Make enquiries or request information be sent to you.
Order our products or services.
Ask for marketing to be sent to you.
Engage with us on social media.
Enter a competition, promotion or survey.
Contact customer services.
Leave comments or reviews on our products or services.
Automated technologies or interactions. As you interact with us, including via the CTC website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We may also collect Tracking Data when you use our website, or when you click on one of our adverts (including those shown on third party websites).
Third parties or publicly available sources. We may receive personal data about you from various types of third parties, including:
Technical Data and/or Tracking Data from analytics providers, advertising networks and search information providers.
Contact, Financial and Transaction Data from providers of payment and fraud prevention services.
Identity and Contact Data from data partners.
Data from any third parties who are permitted by law or have your permission to share your personal data with us, such as via social media or review sites.
We will only use your personal data when the law allows us to.
5. How we use your personal data
Where we need to perform the contract, we are about to enter into, or have entered into with you. For example, when you purchase our products.
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. For example, when we carry out fraud screening as part of the check-out process.
Where we need to comply with a legal or regulatory obligation. For example, keeping records of our sales for tax compliance.
Generally, we do not rely on consent as a legal basis for processing your personal data other than where the law requires it, for example in relation to sending certain direct marketing communications. Where our legal basis is consent, you have the right to withdraw consent any time.
See ‘Legal basis we rely on to process personal data’ to find out more about the types of lawful basis that we will rely on to process your personal data.
6. Legal basis we rely on to process personal data
The table below shows you a description of all the ways we plan to use personal data, and which of the legal basis we rely on to do so. We have also identified what our legitimate interests are where appropriate.
6.1. To register you as a new customer.
Type of data: Identity, Contact
Lawful basis for processing: Performance of a contract with you.
6.2. To process and deliver your order including: Manage payments, fees and charges; and Collect and recover money owed to us.
Type of data: Identity, Contact, Financial, Transaction, Marketing and Communications.
Lawful basis for processing: Performance of a contract with you. Necessary for our legitimate interests (including to recover debts due to us).
Type of data: Identity, Contact, Profile, Marketing and Communications.
Lawful basis for processing: Performance of a contract with you. Necessary to comply with a legal obligation. Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services).
6.4. To deliver direct marketing to you.
Type of data: Identity, Contact, Profile, Usage, Marketing and Communications, Tracking, Technical.
Lawful basis for processing: For most direct marketing communications, we rely on consent, however there are situations in which it is in our legitimate interests to use your personal data in this way (Please see Advertising, marketing and your communications preferences below).
6.5. To enable you to take part in a prize draw, competition or complete a survey.
Type of data: Identity, Contact, Profile, Usage, Marketing and Communications.
Lawful basis for processing: Performance of a contract with you. Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business).
6.6. To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).
Type of data: Identity, Contact, Technical, Tracking.
Lawful basis for processing: Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise). Necessary to comply with a legal obligation.
6.7. To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.
Type of data: Identity, Contact, Profile, Usage, Marketing and Communications, Technical, Tracking.
Lawful basis for processing: Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy).
6.8. To use data analytics to improve our website, products/services, marketing, customer relationships and experiences.
Type of data: Identity, Contact, Technical, Usage, Profile.
Lawful basis for processing: Necessary for our legitimate interests (to develop our products/services and grow our business).
6.9. To prevent and detect unlawful acts.
Type of data: Identity, Contact, Financial, Transaction, Technical, Tracking.
Lawful basis for processing: Necessary for our legitimate interests (to protect our business and our customers by way of undertaking fraud monitoring and suspicious transaction monitoring). Necessary to comply with a legal or contractual obligation to share personal data for the purposes of law enforcement.
6.10. Purpose/Activity: To resolve legal claims or disputes involving you or us.
Type of data: All relevant data categories, depending on the nature of the
allegation or claim.
Lawful basis for processing: Necessary to bring or defend a claim.
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.
We do not carry out any automated decision making.
If you ever have any questions about this, just ask. See ‘Contact CTC about privacy’ below.
7. Advertising, marketing and your communications preferences
We may use your Identity, Contact, Technical, Tracking, Usage and Profile Data to form a picture of which products, services and offers may be relevant for you and tell you about them. We may carry out direct marketing by email, phone, text or post. For example, you might receive our email newsletter or promotion by post.
On our website, we always try hard to make it really clear what we are doing and what communications you will be sent, whether it’s you deciding to sign up to the CTC newsletter or as part of creating an account or the purchase journey – and you have a right at any time to change your mind and say no thank you and opt out. The easiest way to opt out is to use the unsubscribe link at the bottom of the communication.
You may see adverts for CTC out and about, and not all of these are based on using personal data – sometimes we just buy advertising space. If you see CTC’s adverts on websites and in social media, these may not be directed specifically at you, we might just have bid for the space. But here’s some things we may do that may be specifically directed at you:
Emails, for example the CTC newsletter.
Text messages, for example with discount codes.
Promotions by post, such as great money-off offers, or from our trusted retail partners.
Phone calls, to tell you something that might be relevant to you and your business.
We may work with partners to promote the reach of our adverts and use analytics and retargeting for this. We will use Tracking Data to deliver relevant online advertising, including via websites and social media.
Tracking Data, and in particular cookies, help us to deliver website and social advertising that we believe is most relevant to you and to potential new customers of CTC.
The cookies used for this purpose are often placed on our website by specialist organisations – and this is also why when you’ve been on our website, you might see an advert from us. This includes retargeting.
Cookies can also tell us if you have seen a specific advert, and how long it has been since you have seen it. This is helpful, because it means we can control the effectiveness of our adverts and control the number of times people might be shown our adverts. Cookies also help us understand if you’ve opened a marketing email because we don’t want to send you things you don’t read.
Almost all the cookies that relate to advertising are part of third party online advertising networks. We do not control cookies which are set by advertising networks.
Cookies help our website work more effectively and provide help in the background to make the process of being a CTC customer a lot easier.
Other cookies collect information about how visitors use CTC, for instance which pages visitors go to most often, and if they get error messages from web pages. These cookies don't collect information that identifies a visitor. All information these cookies collect is aggregated and used to improve how CTC works.
There are also cookies that allow CTC to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customise. They may also be used to provide services you have asked for such as watching a video or commenting on a blog.
There are cookies that collect information about your browsing habits to make advertising delivered to you more relevant to you and your interests (see Advertising, marketing and your communications preferences above). They are usually placed by advertising networks with our permission. They remember that you have visited a website and this information is shared with other organisations such as advertisers. Quite often targeting or advertising cookies will be linked to site functionality provided by the other organisation.
When you use our website, your device or browser may be sent cookies from third parties, for example when using embedded content and social network links. It's important for you to know that we have no access to or control over cookies used by these companies or third-party websites. We suggest you check the third-party websites for more information about their cookies and how to manage them.
9. Disclosures of your personal data
We may share personal data with the following categories third parties:
Suppliers and service providers (such as technology service providers, payment processing and fraud prevention providers, manufacturers and post and courier services).
Auditors and professional advisers like bankers, lawyers, accountants and insurers
Government, regulators and law enforcement.
Third parties are required to respect the security of your personal data and to treat it in accordance with the law.
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.
10. Payment information
Any online payments will be conducted in accordance with Payment Card Industry (PCI) data security standards, and your billing information (which is only used by these payment processors for the purpose of performing fraud protection) is encrypted before being communicated to them. Subject to the below exceptions, your credit card details are communicated directly from your browser to these payment processors.
11. International transfers
If we transfer your personal data out of the EEA, we will comply with applicable data protection law. Some of the mechanisms we may choose to use when undertaking an international transfer are:
The transfer of your personal data is to a country that has officially been deemed to provide an adequate level of protection for personal data by the European Commission.
We may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe (called the “EU Model Clauses”).
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 the Europe and the US. If the provider is not EU-US Privacy Shield certified, we may use the EU Model Clauses.
Some of our external third-party providers may be based outside the EEA, so their processing of your personal data will involve a transfer of data outside the EEA.
12. 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. 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.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
13. Third-party links
14. Data retention
We will only keep 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 must keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers for tax purposes.
In some circumstances you can ask us to delete your data; see ‘Your legal rights’ 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.
15. Your legal rights
If the General Data Protection Regulation (GDPR) applies to you because you are in the European Union, you have rights under data protection laws in relation to your personal data. GDPR includes eight core principle rights:
The right to be informed – that’s an obligation on us to inform you how we use your personal data.
The right of access – that’s a right to make what’s known as a ‘data subject access request’ for copy of the personal data we hold about you.
The right to rectification – that’s a right to make us correct personal data about you that may be incomplete or inaccurate.
The right to erasure – that’s also known as the ‘right to be forgotten’ where in certain circumstances you can ask us to delete the personal data we have about you (unless there’s an overriding legal reason we need to keep it).
The right to restrict processing – that’s a right for you in certain circumstances to ask us to suspend processing personal data.
The right to data portability – that’s a right for you to ask us for a copy of your personal data in a common format (for example, a .csv file).
The right to object – that’s a right for you to object to us processing your personal data (for example, if you object to us processing your data for direct marketing).
Rights in relation to automated decision making and profiling – that’s a right you have for us to be transparent about any profiling we do, or any automated decision making.
These rights are subject to certain rules around when you can exercise them. You can see a lot more information on them, on the UK Information Commissioner’s Office website.
If you wish to exercise any of the rights set out above, please contact us (see ‘Contact CTC’). 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.
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.
16. Contact CTC
© The Cheese Tasting Company 2019