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Privacy Policy

Websites Privacy Notice
Cuts Ice – Website
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 visiting our websites, 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 websites 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

Website

http://www.cutsice.com/

Address

Unit 2 Origin Business Park, Rainsford Road, Park Royal
London, NW10 7FW

Telephone

+44 208 960 6974

Email

privacy@cutsice.com

3. What information do we collect about you, and for what purpose?
We may collect, use, store and/or transfer technical data and usage information about you if you interact with our websites, including:

  • IP Address and approximate location information;
  • Browser connection string;
  • Browser type;
  • Platform or system type;
  • Usage information (pages visited, length of time spent, referral location).

We may also collect, use, store and/or transfer information about your identity, contact details and profile if you use our “contact us” forms, for example:

  • Name;
  • Email address;
  • Telephone Number;
  • Any other information that you share in the message body.

If you make a purchase from our websites or create an account with us we may collect, use, store and/or transfer information about your identity, contact details, transaction data, profile data and marketing & communications preferences, such as your:

  • Name;
  • Email address;
  • Telephone Number;
  • Address (billing and shipping);
  • Password (which is stored securely if you create an account);
  • Transaction information such as details about payments from you (although your financial data, such as payment card details, will be captured by our payment service providers and not by us directly);
  • Preferences in receiving marketing from us and our third parties and your communication preferences.

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.

Please be aware that our websites 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.

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 your identity, contact and financial data when you fill in our contact forms, make a purchase from any of our websites or create an account with us.
  • Information we automatically collect about you. We may automatically collect technical data about your equipment, browsing actions and patterns as you interact with our websites. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy for further details.
  • 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:
    • technical data from analytics providers;
    • contact, financial and transaction data from providers of technical, payment and delivery services; and
    • identity and contact data from selected business partners, data brokers or aggregators.

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • where we need to perform a contract we are about to enter into, or have entered into with you;
  • 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; or
  • where we need to comply with a legal or regulatory obligation.

 

Generally, we do not rely on consent as a legal basis for processing your personal information other than in relation to sending direct marketing communications to you by electronic means or permitting our selected third parties to do so. You have the right to withdraw consent to marketing at any time by contacting 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 purposes set out below. We have identified our legitimate interests where appropriate.


Your information

Purpose

Legal basis

Your data collected as part of access to our site and the platform it resides upon (e.g. technical data).

Detection and prevention of crime, improvement of the site based on access methods, availability and capacity planning of our website, to deliver relevant website content and advertisements and to make suggestions about goods and/or services that may interest you.

We need this information for our legitimate interests as the controller of this data (for running our business, provision of IT and administration services, network security, growing our business and informing our marketing strategy).

The data you share with us as part of the contact us form (e.g. information about your identity, profile and your contact details).

To be able to answer queries and respond to your requests that you make to us.

Necessary for our legitimate interests (to run our business, manage our relationship with you and keep our records updated).

You have also agreed for us to process your data in this manner to answer the query that you have, in the first instance.

Our basis for processing your data might also include performance of a contract with you, if we are bound by contract and your query relates to a purchase you have made.

The data you give us if you create an account or purchase something from us (e.g. information about your identity, contact details, financial and transaction details and marketing & communications preferences).

To be able to give you access to our site, allow us to fulfil your purchases that you have made from us and to manage our relationship with you, including notifying you about changes to our terms and privacy policy.

We need this information to be able to fulfil the contract that you have engaged us to perform.

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 may be unable to use our website and will not be able to request our assistance. 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 buy anything from us) 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:


Google

Google Analytics privacy policy can be found at: https://support.google.com/analytics/answer/6004245?hl=en

Microsoft

Microsoft provide our email service and when you use our contact us forms these will be
https://products.office.com/en-us/business/office-365-trust-center-privacy

Hosting providers

These provide the physical devices that we use to host the website and provide the connectivity so that you can access it.

PayPal / 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.

Mail and courier companies

If you buy something from us we will need to post / deliver this to you so we need to share information with these companies to fulfil your request.

We may also need to share your personal information with the following in limited circumstances:

  • IT security providers;
  • Insurers;
  • 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 2 above.

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:

 

Your information

Retention Period

Your data collected as part of access to our site and the platform it resides upon

We will retain the analytics data for twenty-six (26) months.  At which point the data will be anonymised or removed.

Data will be maintained on our servers including your IP address for 1 year from date of collection.

The data you share with us as part of the contact us form

This will be retained for as long as the relationship between us to answer your query.

If your query relates to a purchase you have made then we will keep this for six (6) years in relation to the purchase you made and our business record requirements.

If you create an account or purchase something from us

Your account information will be retained for the lifetime of the relationship between 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;
  • 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. 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.

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.

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

Website

https://ico.org.uk/concerns/

Address

Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, United Kingdom

Telephone

0303 123 1113

Email

https://ico.org.uk/global/contact-us/email/

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.

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

Website

http://www.cutsice.com/

Address

Unit 2 Origin Business Park, Rainsford Road, Park Royal
London, NW10 7FW

Telephone

+44 208 960 6974

Email

privacy@cutsice.com

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:

  • Name;
  • 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:

  • Name;
  • 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:

  • Name;
  • 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:
    • technical data from analytics providers;
    • contact, financial and transaction data from providers of technical, payment and delivery services; and
    • 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:


Your information

Purpose

Legal basis

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 25th 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.

The data you provide if you purchase something from us at an event e.g. identity, contact details, financial and/or transaction data and marketing & communications preferences.

To be able to fulfil your purchases that you have made from us and to manage our relationship with you, including notifying you about changes to our terms and privacy policy.

We need this information to be able to fulfil the contract that you have engaged us to perform.

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:


Google

Google Analytics privacy policy can be found at: https://support.google.com/analytics/answer/6004245?hl=en

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

Mailchimp

We use Mailchimp to send our marketing emails from all of our brand sites.  Their privacy policy can be found here: https://mailchimp.com/legal/privacy/

Facebook

If you interact with us through Facebook then you will be subject to their privacy policy that can be found here: https://www.facebook.com/legal/FB_Work_Privacy

Twitter

If you interact with us through Twitter then you will be subject to their privacy policy that can be found here: https://twitter.com/en/privacy#update and you can change your preferences here: https://twitter.com/personalization

Instagram

If you interact with us through Instagram then you will be subject to their privacy policy that can be found here: https://help.instagram.com/519522125107875?helpref=page_content

You Tube

If you interact with us through our You Tube channels then you will be subject to their privacy policy that can be found here: https://policies.google.com/privacy?hl=en-GB&gl=uk

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;
  • Insurers;
  • 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:


Your information

Retention Period

  • 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

Website

https://ico.org.uk/concerns/

Address

Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, United Kingdom

Telephone

0303 123 1113

Email

https://ico.org.uk/global/contact-us/email/

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.

Sales and Services Privacy Notice
Cuts Ice – Sales and Services
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 entering into a contract (or trying to) with us, 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

Website

http://www.cutsice.com/

Address

Unit 2 Origin Business Park, Rainsford Road, Park Royal
London, NW10 7FW

Telephone

+44 208 960 6974

Email

privacy@cutsice.com

3. What information do we collect about you, and for what purpose?
If you contact us then we may collect, use, store and/or transfer information about your identity and contact details to be able to service your requirements, including:

  • Representatives’ Names;
  • Representatives’ business addresses;
  • Representatives’ telephone numbers (mobile or landline);
  • Representatives’ email addresses.

If you do business with us then we may collect, use, store and/or transfer information about your identity, contact details and financial and/or transaction data to be able to trade with you, for example:

  • Representatives’ Names;
  • Representatives’ business addresses;
  • Representatives’ telephone numbers (mobile or landline);
  • Representatives’ email addresses;
  • You may also share bank details if we are setting up direct debits or standing orders or need to refer to a credit reference agency.

If we are given your contact details or you have made them public and we need to contact you, we may collect, use, store and/or transfer information such as:

  • Representatives’ Names;
  • Representatives’ business addresses;
  • Representatives’ telephone numbers (mobile or landline);
  • Representatives’ email addresses.

We may also collect, use and share aggregated data such as statistical or demographic data for any purpose if you (or your representatives) 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 or your representatives (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 if you do business with us.
  • Information we receive from other sources. We may receive personal data about you from various third parties and public sources. For example, we may collect contact data from your website or from selected business partners.

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 be instances where we are provided your information in relation to a contract with another party.  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 your data at this point.  We may also use your information if you have made this public, on your website, via Linked-in or other public means.

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 purposes set out below. We have identified our legitimate interests where appropriate.


Your information

Purpose

Legal basis

Your contact details.

These are processed for you to be able to take out a contract for our services.  These are then processed to enable us to provide payment terms and discuss matters with relevant personnel to be able to fulfil the contracted services agreed.  These will then need to be used for billing purposes.

We need this information to be able to be able to enter into a contract with you, and to be able to fulfil our obligations under it.

It is also necessary for our legitimate interests (to recover any debts due to us, manage our relationship with you and keep our records updated).

The data you share as part of our contract e.g. contact details and financial and/or transaction data.

To allow access to data exchanged between the disclosing and receiving parties to fulfil contractual obligations between the parties.

We need this information to be able to fulfil the contract that you have engaged us to perform.

It is also necessary for our legitimate interests (to run our business, recover any debts due to us, manage our relationship with you and keep our records updated).

If your data has been shared with us, but is outside of contract or if you have made your data public and we contact you.

To allow us to contact if we have been provided your information in relation to our services or you have made your data public and we have an interest in contact you in relation to our services.

We have a legitimate interest in contacting you in relation to our services (to develop our business)

6. What if you do not want to provide your personal information?
You do not have to provide your personal information to us. However, 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 buy anything from us) 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 provision of these services 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 and IT solution companies

To be able to provide these services to you we need to have appropriate IT solutions in place.  We purchase these from both Microsoft and other companies as needed to fulfil our obligations to you.  Where feasible and technically possible we will encrypt the data so that the provider does not have access to it.

Credit reference agencies

If you are a sole trader then your details may be provided directly, otherwise it will be that data of your organisation.  This allows us to check the credit worthiness of your organisation for us to be able to provide payment terms.  These companies will not have access to any report information as this is held under non-disclosure agreements between us.

Our bank

To be able to collect payments by direct debit or standing order if this has been agreed with us.  If you have provided bank details then this will need to be shared with our bank to be able to process payments.  These companies will not have access to any report information as this is held under non-disclosure agreements between us.

Payment service provider / Bank

If you purchase something from one of our e-liquid brand sites then to process your payment we will 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.

Mail and courier companies

If you buy something from us we will need to post / deliver this to you so we need to share information with these companies to fulfil your request.

We may also need to share your personal information with the following in limited circumstances:

  • IT security providers;
  • Insurers;
  • 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.

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:


Your information

Retention Period

Your contact details.

This will be retained for the lifetime of the contract between us and if possible, this will be removed at the end of the contract.  However, if this is part of product information that has been provided to you or us this will be retained for the lifetime of the contract plus six years to be able to defend any insurance claims against us.

The data you share as part of our contract.

This will be retained for the lifetime of the contract between us plus six years to be able to defend any insurance claims against us.

If your data has been shared with us, but is outside of contract or if you have made your data public and we contact you.

This will be retained while we have a legitimate interest in the data, or until:

  • We form a contact between us;
  • Or you have asked us not to process your data.

 

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;
  • 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. 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.

Out partners use automated decision making for the following reasons:

  • To review if we can give you credit facilities;
  • 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.

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 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

Website

https://ico.org.uk/concerns/

Address

Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, United Kingdom

Telephone

0303 123 1113

Email

https://ico.org.uk/global/contact-us/email/

14. Changes to this Privacy Notice
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.

Cookie Privacy Notice
Cuts Ice – Website cookies
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 visiting our websites, 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 websites 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

Website

http://www.cutsice.com/

Address

Unit 2 Origin Business Park, Rainsford Road, Park Royal
London, NW10 7FW

Telephone

+44 208 960 6974

Email

privacy@cutsice.com

3. What information do we collect about you, and for what purpose?
Cookies are a standard feature of websites that allow us to store small amounts of data on your computer about your visit to the website. Cookies help us to learn which areas of our websites are useful and which areas need improvement.  We also use these files to provide access to marketing and re-marketing information.  These files contain a unique code to you and can be considered personal data under the GDPR.

4. How do we collect your personal information?
We collect your personal information through different methods, including:

  • Information you give us. You may give us your identity, contact and financial data when you fill in our contact forms, make a purchase from any of our websites or create an account with us.  We may store some or all information in encrypted format in a cookie on your computer.
  • Information we automatically collect about you. We may automatically collect technical data about your equipment, browsing actions and patterns as you interact with our websites. We collect this personal data by using cookies and other similar technologies.
  • 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:
    • technical data from analytics providers;
    • cookies that allow third party review or interaction with our website that have been saved on your computer from other websites you have visited; and
    • identity and contact data from selected business partners, data brokers or aggregators.

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.
Please be aware that our websites 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.
Generally, we do not rely on consent as a legal basis for processing your personal information other than in relation to sending direct marketing communications to you by electronic means or permitting our selected third parties to do so. You have the right to withdraw consent to marketing at any time by contacting us.

5. What is our legal basis for collecting and using your personal information?
We will use your personal information (i.e. the cookie) for different purposes depending on the cookie that we set on your system.  Each will be broken down to be clear on their purposes.
Essential / Session Cookies.   Essential cookies enable you to navigate our websites and to use its services and features.  Without these cookies our website will not perform as smoothly and you may lose connectivity to it, and we may not be able to provide our websites or certain services or features.  These cookies are:


Cookie name

Purpose

1st / 3rd Party Cookie

Legal basis

PHPSESSID

To store a simple message when a form is submitted that can be displayed on a different page.

For example, if an enquiry form is completed incorrectly, a message will be stored and presented to the user to indicate the errors in the submission.

1st Party

We need this information for our legitimate interests as the controller of this data as it allows us to provide a functional site to you

ageverification

To allow us to indicate if you are over 18 years old and eligible to use our websites and able to purchase products from us.

1st Party

We need this information for our legitimate interests as the controller of this data as it allows us to indicate if you are over 18 and eligible to purchase our products

FRONTEND_CID

Information relating to the customer including cached information that has previously been used on the website

1st Party

We need this information for our legitimate interests as the controller of this data as it allows us to provide a functional site to you

FRONTEND

The customer's session ID.

1st Party

We need this information for our legitimate interests as the controller of this data as it allows us to provide a functional site to you

verify

This cookie helps make sure that no other user can log in with your information. It’s also used to hold information regarding your session, including when you started your session, and other variable relevant to your choices.

1st Party

We need this information for our legitimate interests as the controller of this data as it allows us to provide a functional and secure site to you

3b900130939669
ee0f2656102bc9f0f5

The customer's session ID.

1st Party

We need this information for our legitimate interests as the controller of this data as it allows us to provide a functional site to you

Preference Cookies.  Preference cookies collect information about your choices and preferences, and allow us to remember location, language, screen reader or other local settings you have set in your system so that we can automatically adapt our websites to your preferences.  These cookies are:


Cookie name

Purpose

1st / 3rd Party Cookie

Legal basis

EXTERNAL_NO_CACHE

Indicates if caching is disabled or enabled.

1st Party

We need this information for our legitimate interests as the controller of this data to optimise our websites for your enjoyment.

persistent_shopping_cart

A link to information about the shopper's cart and viewing history.

1st Party

We need this information for our legitimate interests as the controller of this data to optimise our websites for your enjoyment.

Analytics Cookies.  Analytics cookies collect information about your use of our websites, and enable us to improve the way it works.  Analytics allow us to see which are the most frequently visited pages, how you use the site, or record any difficulties you may have.  We use the information to improve the site and optimise it for most users that we have.  It also allows us to ensure that there is enough capacity in the system to service your needs.  These cookies are:


Cookie name

Purpose

1st / 3rd Party Cookie

Legal basis

_gat

This is used by Google Analytics to be able to throttle request rates

3rd Party

We need this information for our legitimate interests as the controller of this data to perform analytics on our websites

_ga

This is used by Google Analytics to be able to distinguish users from each other

3rd Party

We need this information for our legitimate interests as the controller of this data to perform analytics on our websites

_gid

This is used by Google Analytics to be able to distinguish users from each other

3rd Party

We need this information for our legitimate interests as the controller of this data to perform analytics on our websites

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 may be unable to use our website and will not be able to request our assistance. 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 buy anything from us) 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).
You can choose whether to accept cookies by changing the settings in your internet browser.  Information about the procedure to enable or disable cookies can be found on your Internet browser provider’s website via its help menu or further information can be found at: http://www.allaboutcookies.org/manage-cookies/index.html.  However, if you disable this function, your experience on our websites may be reduced and some features may not work as intended.

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:


Google

Google Analytics privacy policy can be found at: https://support.google.com/analytics/answer/6004245?hl=en

Microsoft

Microsoft provide our email service and when you use our contact us forms these will be
https://products.office.com/en-us/business/office-365-trust-center-privacy

Hosting providers

These provide the physical devices that we use to host the website and provide the connectivity so that you can access it.

PayPal / 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;
  • Insurers;
  • 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 2 above.
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:


Cookie Name

Retention period

Third party data privacy notice

PHPSESSID

24 hours

1st party so covered by this data privacy notice

ageverification

24 hours

1st party so covered by this data privacy notice

FRONTEND_CID

24 hours

1st party so covered by this data privacy notice

FRONTEND

24 hours

1st party so covered by this data privacy notice

verify

24 hours

1st party so covered by this data privacy notice

3b900130939669
ee0f2656102bc9f0f5

24 hours

1st party so covered by this data privacy notice

EXTERNAL_NO_CACHE

24 hours

1st party so covered by this data privacy notice

persistent_shopping_cart

24 hours

1st party so covered by this data privacy notice

_gat

1 minute

https://goog.le/cookies and https://goog.le/privacy

_ga

2 years

https://goog.le/cookies and https://goog.le/privacy

_gid

24 hours

https://goog.le/cookies and https://goog.le/privacy

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;
  • 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. 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.

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.

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

Website

https://ico.org.uk/concerns/

Address

Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, United Kingdom

Telephone

0303 123 1113

Email

https://ico.org.uk/global/contact-us/email/

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.

CCTV Privacy Notice
Cuts Ice – CCTV
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 visiting our premises, 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 work sites 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

Website

http://www.cutsice.com/

Address

Unit 2 Origin Business Park, Rainsford Road, Park Royal
London, NW10 7FW

Telephone

+44 208 960 6974

Email

privacy@cutsice.com

3. What information do we collect about you, and for what purpose?
We collect the following information from you to ensure your safety and that of our staff, as well as protect our offices from damage:

  • Your face and other identifying features in the video footage we record.

We do not collect any special categories of personal data about you or your representatives (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 your personal information?
We collect your personal information through different methods, including:

  • Information you give us. When you enter one of our premises and are seen on the CCTV systems.
  • Information we automatically collect about you. We may automatically collect information if you walk / drive past our premises within an open public area that is covered by our CCTV cameras around our premises.

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 purposes set out below. We have identified our legitimate interests where appropriate.


Your information

Purpose

Legal basis

Your face and other identifying features in the video footage we record

Protecting your safety and that of our staff, as well as detecting and preventing crime

We need this information for our legitimate interests as the controller of this data (for the detection and prevention of crime, or health and safety on our premises)

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 may be unable to visit or use our premises.

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 CCTV system 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:


CCTV solution provider

These companies provide the equipment and maintenance for the CCTV equipment that we use

CCTV Monitoring company

These companies have remote viewing capabilities of our cameras and ensure that they are monitored when we are not here.

We may also need to share your personal information with the following in limited circumstances:

  • IT security providers;
  • Insurers;
  • 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 2 above.

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:


Your information

Retention Period

Your face and other identifying features in the video footage we record

The information will be retained for eight (8) weeks.  All CCTV operations are conducted in line with the recommendations from the information commissioner under its CCTV code of practice, and under the Protection of Freedoms Act 2012.

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);
  • provide you with a copy of any information we hold on you
  • request the transfer of it to you or a third party; and

 

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. 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.

Where a person makes an access requests and there are other data subjects such as people or number plates on the same footage or images, the requested footage or images will be subject to a blurring process to ensure the rights to privacy of the other person.  Restrictions of access do apply where the blurring process of the data cannot hide CCTV footage of the other subjects the data will not be released to ensure the protection of the other person’s right to privacy.

12. Will we do anything else with your information in the future?
We may use your image for the prevention of crime within all our sites and provide this to the security company that protects our sites to be able to identify you if we do not wish to allow you access to our premises.

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

Website

https://ico.org.uk/concerns/

Address

Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, United Kingdom

Telephone

0303 123 1113

Email

https://ico.org.uk/global/contact-us/email/

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.