Cambio Privacy Statement
last modified: May 2018
Introduction
Welcome to Cambio Limited's (referred to as Cambio throughout) privacy
notice.
Cambio respects your privacy and is committed to protecting your
personal data. This privacy notice will inform you as to how we look after your
personal data when you visit our website (regardless of where you visit it
from) and tell you about your privacy rights and how the law protects you.
1. IMPORTANT INFORMATION
AND WHO WE ARE
2. THE DATA WE COLLECT
ABOUT YOU
3. HOW IS YOUR PERSONAL
DATA COLLECTED
4. HOW WE USE YOUR
PERSONAL DATA
5. DISCLOSURES OF YOUR
PERSONAL DATA
6. INTERNATIONAL
TRANSFERS
7. DATA SECURITY
8. DATA RETENTION
9. YOUR LEGAL RIGHTS
10. GLOSSARY
1. Important information and who we are
Purpose of this privacy notice
This privacy notice aims to give you information on how Cambio collects
and processes your personal data through your use of this website, including
any data you may provide through this website when you sign up to our
newsletter, technical notes, or to receive other product information, purchase
a product or service or take part in a competition.
This website is not intended for children and we do not knowingly
collect data relating to children.
It is important that you read this privacy notice together with
any other privacy notice or fair processing notice we may provide on specific
occasions when we are collecting or processing personal data about you so that
you are fully aware of how and why we are using your data. This privacy notice
supplements the other notices and is not intended to override them.
Controller
Cambio Limited is the controller and responsible for your personal
data (referred to as "Cambio", "we", "us" or "our" in this privacy notice).
If you have any questions about this privacy notice, including any
requests to exercise your legal rights, please contact Cambio using the details
set out below.
Contact details
Our full details are:
Full name of legal entity: Cambio Limited
Email address: privacy@cambio.co.uk
Postal address: 1 The Irwin Centre, Scotland Road, Dry
Drayton, Cambridge CB23 8AR.
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.
Changes to the privacy notice and your duty to inform us of
changes
This version was last updated on 8th May 2018 and we
reserve the right to update this privacy notice at any time.
The data protection law in the UK will change on 25 May 2018.
Although this privacy notice sets out most of your rights under the new laws,
we may not yet be able to respond to some of your requests (for example, a
request for the transfer of your personal data) until May 2018 as we are still
working towards getting our systems ready for some of these changes.
It is important that the personal data we hold about you is
accurate and current. Please keep us informed if your personal data changes
during your relationship with us.
Third-party links
This website may include links to third-party websites, plug-ins
and applications. Clicking on those links or enabling those connections may
allow third parties to collect or share data about you. We do not control these
third-party websites and are not responsible for their privacy statements. When
you leave our website, we encourage you to read the privacy notice of every
website you visit.
2.
The data 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, use, store and transfer different kinds of
personal data about you which we have grouped together follows:
-
Identity Data may include first name, last name, username or similar identifier,
title, and gender.
-
Contact Data may include billing address, delivery address, email address and
telephone numbers.
-
Financial Data may include bank account and payment card details.
-
Transaction Data may include details
about payments to and from you and other details of products and services you
have purchased from us.
-
Technical Data may include 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.
-
Profile Data may include your username and password, purchases or
orders made by you, your interests, preferences, feedback and survey
responses.
-
Usage Data may include information about
how you use our website, products and services.
-
Marketing and Communications Data may include your preferences in
receiving marketing from us and our third parties and your communication
preferences.
We also collect, use and share 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. However, if we combine or connect Aggregated Data with your personal
data 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.
If you fail to provide personal data
Where we need to collect personal
data by law, or under the terms of a contract we have with you and you fail to
provide that data when requested, we may not be able to perform the contract we
have or are trying to enter into with you (for
example, to provide you with goods or services). In this case, we may have to
cancel a product or service you have with us but we
will notify you if this is the case at the time.
3.
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
otherwise. This includes personal data you provide when you:
- apply for our products or services;
- create an account on our website;
- subscribe to our service or publications;
- request marketing to be sent to you;
- enter a competition, promotion or survey; or
- give us some feedback.
-
Automated technologies or interactions.
As you interact with our website, we may automatically collect Technical Data
about your equipment, browsing actions and patterns. We collect this personal
data by using cookies, and other similar technologies. We may also receive
Technical Data about you if you visit other websites employing our cookies.
-
Third parties or publicly available sources.
We may receive personal data about you from various third parties and public
sources as set out:
- Technical Data from the following parties:
- (a) analytics
providers
- (b) advertising
networks
- (c) search
information providers
- (d)
our suppliers.
4.
How we use your personal
data
We will only use your personal data in keeping with prevailing
regulations in the UK. Most commonly, we will use your personal data in the
following circumstances:
-
Where we need to perform the 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.
For
the avoidance of doubt, legitimate interests means the
interest of our business in conducting and managing our business to enable us
to give you the best service/product and the best and most secure experience.
We make sure we consider and balance any potential impact on you (both positive
and negative) and your rights before we process your personal data for our
legitimate interests. We do not use your personal data for activities where our
interests are overridden by the impact on you (unless we have your consent or
are otherwise required or permitted to by law). You can obtain further
information about how we assess our legitimate interests against any potential
impact on you in respect of specific activities by contacting us.
-
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 data other than in relation to sending third party
direct marketing communications to you via email or text message for which we
encourage you to visit our Opt-in page.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the
ways we plan to use your personal data, and which of the legal bases we rely on
to do so. We have also identified what our legitimate interests are where
appropriate.
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. Please contact us if you need details about
the specific legal ground we are relying on to process your personal data where
more than one ground has been set out in the table below.
|
Purpose/Activity
|
Type of data
|
Lawful basis for processing including basis of legitimate interest
|
|
To register you as a new customer
|
(a) Identity
(b) Contact
|
Performance of a contract with
you
|
|
To process and deliver your order
including:
(a) Manage payments, fees and
charges
(b) Collect and recover money
owed to us
|
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e)
Marketing and Communications
|
(a) Performance of a contract
with you
(b) Necessary for our legitimate
interests (to recover debts due to us)
|
|
To manage our relationship with
you which will include:
(a) Notifying you about changes
to our terms or privacy policy
(b) Asking you to leave a review
or take a survey
|
(a) Identity
(b) Contact
(c) Profile
(d)
Marketing and Communications
|
(a) Performance of a contract
with you
(b) Necessary to comply with a
legal obligation
(c) Necessary for our legitimate
interests (to keep our records updated and to study how customers use our
products/services)
|
|
To enable you to partake in a
prize draw, competition or complete a survey
|
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
|
(a) Performance of a contract
with you
(b) Necessary for our legitimate
interests (to study how customers use our products/services, to develop them
and grow our business)
|
|
To administer and protect our
business and this website (including troubleshooting, data analysis, testing,
system maintenance, support, reporting and hosting of data)
|
(a) Identity
(b) Contact
(c) Technical
|
(a) 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)
(b) Necessary to comply with a
legal obligation
|
|
To deliver relevant website
content and advertisements to you and measure or understand the effectiveness
of the advertising we serve to you
|
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical
|
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)
|
|
To use data analytics to improve
our website, products/services, marketing, customer relationships and
experiences
|
(a) Technical
(b) Usage
|
Necessary for our legitimate
interests (to define types of customers for our products and services, to
keep our website updated and relevant, to develop our business and to inform
our marketing strategy)
|
|
To make suggestions and
recommendations to you about goods or services that may be of interest to you
|
(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
|
Necessary for our legitimate
interests (to develop our products/services and grow our business)
|
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data
to form a view on what we think you may want or need, or what may be of
interest to you. This is how we decide which products, services and offers may
be relevant for you.
You will receive marketing communications from us if you have
requested information from us or purchased goods or services from us or if you
provided us with your details when you entered a competition or registered for
a promotion and, in each case, you have opted in for receiving such marketing
material.
Third-party marketing
We will get your express opt-in
consent before we share your personal data with any company outside of Cambio for
marketing purposes.
Cookies
Cambio
Ltd uses cookies only when necessary to provide a better service on our
website. Cookies allow us to recognize you when you pay a repeat visit to our
website and let us personalize your experience based on your preferences.
Cookies
- Cookies technology enables web sites to store small bits of information on
your computer and retrieve that information at a later time.
A cookie is a string of characters stored in a text file that is sent to your
hard drive, where your Internet browser files are kept.
Visitors
who are concerned about the use of cookie technology may opt to enable a
feature in their browser software that will erase cookies, block all cookies,
or warn the user before cookies are stored or exchanged, however, please note
that some parts of our site may not function or may be considerably slower if
you do so.
Change of purpose
We will only use your personal data for the purposes for which we
collected it, unless we reasonably consider that we need to use it for another
reason and that reason is compatible with the original purpose. If you wish to
get an explanation as to how the processing for the new purpose is compatible
with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we
will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your
knowledge or consent, in compliance with the above rules, where this is
required or permitted by law.
5.
Disclosures of your
personal data
We may have to share your personal data with the parties set out
below for the purposes set out in the table in paragraph 4 above.
-
Internal Third Parties – Cambio employees and
consultants.
-
External Third Parties – suppliers, distributors,
auditors, consultants and third parties that we are legally required to contact
as a company based in the UK.
-
Third parties to whom we may choose to sell,
transfer, or merge parts of our business or our 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.
-
We require all third parties 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.
6.
International transfers
We may need to share your personal data with our suppliers and distributors.
This might involve transferring your data outside the European Economic Area (EEA).
Whenever we transfer your personal data out of the EEA, we ensure
a similar degree of protection is afforded to it by ensuring at least one of
the following safeguards is implemented:
-
We will only transfer your personal data to
countries that have been deemed to provide an adequate level of protection for
personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of
personal data in non-EU countries.
-
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. For further details, see European Commission: Model contracts for the transfer of
personal data to third countries.
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. For further details, see European Commission: EU-US
Privacy Shield.
Please contact us if you want
further information on the specific mechanism used by us when transferring your
personal data out of the EEA.
7.
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.
8.
Data retention
How long will you use my personal data for?
We will only retain 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.
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.
9.
Your legal rights
Under certain circumstances, you have rights under data protection
laws in relation to your personal data.
YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal data (commonly known as a
"data subject access request"). This enables you to receive a copy of
the personal data we hold about you and to check that we are lawfully
processing it.
Request correction of the personal data that we hold about
you. This enables you to have any incomplete or inaccurate data we hold about
you corrected, though we may need to verify the accuracy of the new data you
provide to us.
Request erasure of your personal data. This enables you to
ask us to delete or remove personal data where there is no good reason for us
continuing to process it. You also have the right to ask us to delete or remove
your personal data where you have successfully exercised your right to object
to processing (see below), where we may have processed your information
unlawfully or where we are required to erase your personal data to comply with
local law. Note, however, that we may not always be able to comply with your
request of erasure for specific legal reasons which will be notified to you, if
applicable, at the time of your request.
Object to processing of your personal data where we are
relying on a legitimate interest (or those of a third party) and there is
something about your particular situation which makes you want to object to
processing on this ground as you feel it impacts on your fundamental rights and
freedoms. You also have the right to object where we are processing your
personal data for direct marketing purposes. In some cases, we may demonstrate
that we have compelling legitimate grounds to process your information which
override your rights and freedoms.
Request restriction of processing of your personal data.
This enables you to ask us to suspend the processing of your personal data in
the following scenarios: (a) if you want us to establish the data's accuracy;
(b) where our use of the data is unlawful but you do not want us to erase it;
(c) where you need us to hold the data even if we no longer require it as you
need it to establish, exercise or defend legal claims; or (d) you have objected
to our use of your data but we need to verify whether we have overriding
legitimate grounds to use it.
Request the transfer of your personal data to you or to a
third party. We will provide to you, or a third party you have chosen, your
personal data in a structured, commonly used, machine-readable format. Note
that this right only applies to automated information which you initially
provided consent for us to use or where we used the information to perform a
contract with you.
Withdraw consent at any time where we are relying on
consent to process your personal data. However, this will not affect the
lawfulness of any processing carried out before you withdraw your consent. If
you withdraw your consent, we may not be able to provide certain products or
services to you. We will advise you if this is the case at the time you
withdraw your consent.
If you would like to exercise any
of these rights please contact us using the details set out in this privacy
notice.
No fee usually required
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.
What we may need from you
We may need to request specific information from you to help us
confirm your identity and ensure your right to access 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.
Time limit to respond
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.
GDPR and Europe
Please note that our European representative is the European Data Protection Office, Avenue Huart Hamoir, 71, 1030 Brussels, Belgium. Email info@edpo.com
