Privacy & Cookies Policy
1. Introduction1.1 Weare committed to safeguarding the privacy of our website visitors andcustomers; in this policy we explain how we will handle your personaldata.
1.2 By using our website and agreeing to this policy, you consent to our use of cookies in accordance with the terms of this policy.
1.3 Ourwebsite incorporates privacy controls which affect how we willprocess your personal data. By using the privacy controls, you canspecify whether you would like to receive direct marketingcommunications and limit the publication of your information. You canaccess the privacy controls within the customer account area of ourwebsite.
2. How we use your “personal data”
2.1 Inthis Section 2 we have set out:
(a) thegeneral categories of personal data that we may process;
(b) inthe case of personal data that we did not obtain directly from you,the source and specific categories of that data;
(c) thepurposes for which we may process personal data; and
(d) thelegal bases of the processing.
2.2 Wemay process data about your use of our website and services ("usagedata"). The usage data may include your IP address,geographical location, browser type and version, operating system,referral source, length of visit, page views and website navigationpaths, as well as information about the timing, frequency and patternof your service use. The source of the usage data is our analyticstracking system. This usage data may be processed for the purposes ofanalysing the use of the website and services. The legal basis forthis processing is our legitimate interests, namely monitoring andimproving our website and services.
2.3 Wemay process your account data ("account data"). Theaccount data may include your name, email address, telephone number,fax number, newsletter subscription preference and postal address.The account data may be processed for the purposes of operating ourwebsite, providing our services, ensuring the security of our websiteand services, maintaining back-ups of our databases and communicatingwith you. The legal basis for this processing is our legitimateinterests, namely the proper administration of our website andbusiness and/or the performance of a contract between you and usand/or taking steps, at your request, to enter into such a contract.
2.4 Wemay process information that you post for publication on our websiteor through our services ("publication data"). Thepublication data may be processed for the purposes of enabling suchpublication and administering our website and services. The legalbasis for this processing is our legitimate interests, namely theproper administration of our website and business and/or theperformance of a contract between you and us and/or taking steps, atyour request, to enter into such a contract.
2.5 Wemay process information contained in any enquiry you submit to usregarding goods and/or services ("enquiry data").The enquiry data may be processed for the purposes of offering,marketing and selling relevant goods and/or services to you.
2.6 Wemay process information relating to transactions, including purchasesof goods and services, that you enter into with us and/or through ourwebsite ("transaction data"). The transaction datamay include your contact details, select payment details and thetransaction details. The transaction data may be processed for thepurpose of supplying the purchased goods and services and keepingproper records of those transactions. The legal basis for thisprocessing is the performance of a contract between you and us and/ortaking steps, at your request, to enter into such a contract and ourlegitimate interests, namely our interest in the properadministration of our website and business.
2.7 Wemay process information that you provide to us for the purpose ofsubscribing to our email notifications and/or newsletters("notification data"). The notification data may beprocessed for the purposes of sending you the relevant notificationsand/or newsletters. The legal basis for this processing is theperformance of a contract between you and us and/or taking steps, atyour request, to enter into such a contract.
2.8 Wemay process information contained in or relating to any communicationthat you send to us ("correspondence data"). Thecorrespondence data may include the communication content andmetadata associated with the communication. Our website will generatethe metadata associated with communications made using the websitecontact forms. The correspondence data may be processed for thepurposes of communicating with you and record-keeping. The legalbasis for this processing is our legitimate interests, namely theproper administration of our website and business and communicationswith users.
2.9 Wemay process any of your personal data identified in this policy wherenecessary for the establishment, exercise or defence of legal claims,whether in court proceedings or in an administrative or out-of-courtprocedure. The legal basis for this processing is our legitimateinterests, namely the protection and assertion of our legal rights,your legal rights and the legal rights of others.
2.10 Wemay process any of your personal data identified in this policy wherenecessary for the purposes of obtaining or maintaining insurancecoverage, managing risks, or obtaining professional advice. The legalbasis for this processing is our legitimate interests, namely theproper protection of our business against risks.
2.11 Inaddition to the specific purposes for which we may process yourpersonal data set out in this Section 2, we may also process any ofyour personal data where such processing is necessary for compliancewith a legal obligation to which we are subject, or in order toprotect your vital interests or the vital interests of anothernatural person.
3. Providing your personal data to others
3.1 Wemay disclose your personal data to any member of our group ofcompanies this means our subsidiaries, our ultimate holding companyand all its subsidiaries insofar as reasonably necessary for thepurposes, and on the legal bases, set out in this policy.
3.2 Wemay disclose your personal data to our insurers and/or professionaladvisers insofar as reasonably necessary for the purposes ofobtaining or maintaining insurance coverage, managing risks,obtaining professional advice, or the establishment, exercise ordefence of legal claims, whether in court proceedings or in anadministrative or out-of-court procedure.
3.3 Financialtransactions relating to our website and services may be handled byour payment services providers as listed within our checkout pages.We will share transaction data with our payment services providersonly to the extent necessary for the purposes of processing yourpayments, refunding such payments and dealing with complaints andqueries relating to such payments and refunds. You can findinformation about the payment services providers' privacy policiesand practices on their own company websites.
3.4 Wemay disclose your enquiry data to one or more of those selected thirdparty suppliers of goods and services identified on our website forthe purpose of enabling them to contact you so that they can offer,market and sell to you relevant goods and/or services. Each suchthird party will act as a data controller in relation to the enquirydata that we supply to it; and upon contacting you, each such thirdparty will supply to you a copy of its own privacy policy, which willgovern that third party's use of your personal data.
3.5 Inaddition to the specific disclosures of personal data set out in thisSection 3, we may disclose your personal data where such disclosureis necessary for compliance with a legal obligation to which we aresubject, or in order to protect your vital interests or the vitalinterests of another natural person. We may also disclose yourpersonal data where such disclosure is necessary for theestablishment, exercise or defence of legal claims, whether in courtproceedings or in an administrative or out-of-court procedure.
4. International transfers of your personal data
4.1 Inthis Section 4, we provide information about the circumstances inwhich your personal data may be transferred to countries outside theEuropean Economic Area (EEA).
4.2 Weand our other group companies have offices and facilities in theUnited Kingdom. The European Commission has made an "adequacydecision" with respect to the data protection laws of each ofthese countries. Transfers to each of these countries will beprotected by appropriate safeguards, namely the use of standard dataprotection clauses adopted or approved by the European Commission, acopy of which can be obtained from the Information Commissioner'sOffice.
4.3 Thehosting facilities for our website are situated in the UnitedKingdom. The European Commission has made an "adequacy decision"with respect to the data protection laws of each of these countries.Transfers to each of these countries will be protected by appropriatesafeguards, namely the use of standard data protection clausesadopted or approved by the European Commission, a copy of which youcan obtain from the Information Commissioner's Office.
4.4 Youacknowledge that personal data that you submit for publicationthrough our website or services may be available, via the internet,around the world. We cannot prevent the use (or misuse) of suchpersonal data by others.
5. Retaining and deleting personal data
5.1 ThisSection 5 sets out our data retention policies and procedure, whichare designed to help ensure that we comply with our legal obligationsin relation to the retention and deletion of personal data.
5.2 Personaldata that we process for any purpose or purposes shall not be keptfor longer than is necessary for that purpose or those purposes.
5.3 Wewill retain your personal data for a minimum period of 30 daysfollowing its provision.
5.4 Insome cases it is not possible for us to specify in advance theperiods for which your personal data will be retained. In such cases,we will determine the period of retention based on its necessity forthe proper administration of our website and business and/or theperformance of a contract between you and us and/or taking steps, atyour request, to enter into such a contract.
5.5 Notwithstandingthe other provisions of this Section 5, we may retain your personaldata where such retention is necessary for compliance with a legalobligation to which we are subject, or in order to protect your vitalinterests or the vital interests of another natural person.
6. Amendments
6.1 Wemay update this policy from time to time by publishing a new versionon our website.
6.2 Youshould check this page occasionally to ensure you are happy with anychanges to this policy.
6.3 Wemay notify you of changes to this policy by email or other means ofcommunication.
7. Your rights
7.1 Inthis Section 7, we have summarised the rights that you have underdata protection law. Some of the rights are complex, and not all ofthe details have been included in our summaries. Accordingly, youshould read the relevant laws and guidance from the regulatoryauthorities for a full explanation of these rights.
7.2 Yourprincipal rights under data protection law are:
(a) theright to access;
(b) theright to rectification;
(c) theright to erasure;
(d) theright to restrict processing;
(e) theright to object to processing;
(f) theright to data portability;
(g) theright to complain to a supervisory authority; and
(h) theright to withdraw consent.
7.3 Youhave the right to confirmation as to whether or not we process yourpersonal data and, where we do, access to the personal data, togetherwith certain additional information. That additional informationincludes details of the purposes of the processing, the categories ofpersonal data concerned and the recipients of the personal data.Providing the rights and freedoms of others are not affected, we willsupply to you a copy of your personal data. The first copy will beprovided free of charge, but additional copies may be subject to areasonable fee. You can request a copy of the personal data we holdby contacting us. Please note that we may in return request copies ofvalid identification.
7.4 Youhave the right to have any inaccurate personal data about yourectified and, taking into account the purposes of the processing, tohave any incomplete personal data about you completed.
7.5 Insome circumstances you have the right to the erasure of your personaldata without undue delay. Those circumstances include: the personaldata are no longer necessary in relation to the purposes for whichthey were collected or otherwise processed; you withdraw consent toconsent-based processing; you object to the processing under certainrules of applicable data protection law; the processing is for directmarketing purposes; and the personal data have been unlawfullyprocessed. However, there are exclusions of the right to erasure. Thegeneral exclusions include where processing is necessary: forexercising the right of freedom of expression and information; forcompliance with a legal obligation; or for the establishment,exercise or defence of legal claims.
7.6 Insome circumstances you have the right to restrict the processing ofyour personal data. Those circumstances are: you contest the accuracyof the personal data; processing is unlawful but you oppose erasure;we no longer need the personal data for the purposes of ourprocessing, but you require personal data for the establishment,exercise or defence of legal claims; and you have objected toprocessing, pending the verification of that objection. Whereprocessing has been restricted on this basis, we may continue tostore your personal data. However, we will only otherwise process it:with your consent; for the establishment, exercise or defence oflegal claims; for the protection of the rights of another natural orlegal person; or for reasons of important public interest.
7.7 Youhave the right to object to our processing of your personal data ongrounds relating to your particular situation, but only to the extentthat the legal basis for the processing is that the processing isnecessary for: the performance of a task carried out in the publicinterest or in the exercise of any official authority vested in us;or the purposes of the legitimate interests pursued by us or by athird party. If you make such an objection, we will cease to processthe personal information unless we can demonstrate compellinglegitimate grounds for the processing which override your interests,rights and freedoms, or the processing is for the establishment,exercise or defence of legal claims.
7.8 Youhave the right to object to our processing of your personal data fordirect marketing purposes (including profiling for direct marketingpurposes). If you make such an objection, we will cease to processyour personal data for this purpose.
7.9 Youhave the right to object to our processing of your personal data forscientific or historical research purposes or statistical purposes ongrounds relating to your particular situation, unless the processingis necessary for the performance of a task carried out for reasons ofpublic interest.
7.10 Tothe extent that the legal basis for our processing of your personaldata is:
(a) consent;or
(b) thatthe processing is necessary for the performance of a contract towhich you are party or in order to take steps at your request priorto entering into a contract,
andsuch processing is carried out by automated means, you have the rightto receive your personal data from us in a structured, commonly usedand machine-readable format. However, this right does not apply whereit would adversely affect the rights and freedoms of others.
7.11 Ifyou consider that our processing of your personal informationinfringes data protection laws, you have a legal right to lodge acomplaint with a supervisory authority responsible for dataprotection. You may do so in the EU member state of your habitualresidence, your place of work or the place of the allegedinfringement.
7.12 Tothe extent that the legal basis for our processing of your personalinformation is consent, you have the right to withdraw that consentat any time. Withdrawal will not affect the lawfulness of processingbefore the withdrawal.
7.13 Youmay exercise any of your rights in relation to your personal data bywritten notice to us, in addition to the other methods specified inthis Section 7.
8. Third party websites
8.1 Ourwebsite includes hyperlinks to, and details of, third party websites.
8.2 Wehave no control over, and are not responsible for, the privacypolicies and practices of third parties.
9. Personal data of children
9.1 Ourwebsite and services are targeted at persons over the age of 16.
9.2 Ifwe have reason to believe that we hold personal data of a personunder that age in our databases, we will delete that personal data.
10. Updating information
10.1 Pleaselet us know if the personal information that we hold about you needsto be corrected or updated.
11. About cookies
11.1 Acookie is a file containing an identifier (a string of letters andnumbers) that is sent by a web server to a web browser and is storedby the browser. The identifier is then sent back to the server eachtime the browser requests a page from the server.
11.2 Cookiesmay be either "persistent" cookies or "session"cookies: a persistent cookie will be stored by a web browser and willremain valid until its set expiry date, unless deleted by the userbefore the expiry date; a session cookie, on the other hand, willexpire at the end of the user session, when the web browser isclosed.
11.3 Cookiesdo not typically contain any information that personally identifies auser, but personal information that we store about you may be linkedto the information stored in and obtained from cookies.
12. Cookies that we use
12.1 Weuse cookies for the following purposes:
(a) authentication- we use cookies to identify you when you visit our website and asyou navigate our website.
(b) status- we use cookies to help us to determine if you are logged into ourwebsite.
(c) shoppingcart - we use cookies to maintain the state of your shopping cart asyou navigate our website.
(d) personalisation- we use cookies to store information about your preferences and topersonalise our website for you.
(e) security- we use cookies as an element of the security measures used toprotect user accounts, including preventing fraudulent use of logincredentials, and to protect our website and services generally.
(f) advertising- we use cookies to help us to display advertisements that will berelevant to you.
(g) analysis- we use cookies to help us to analyse the use and performance of ourwebsite and services.
(h) cookieconsent - we use cookies to store your preferences in relation to theuse of cookies more generally.
13. Cookies used by our service providers
13.1 Ourservice providers use cookies and those cookies may be stored on yourcomputer when you visit our website.
13.2 Weuse Google Analytics to analyse the use of our website. GoogleAnalytics gathers information about website use by means of cookies.The information gathered relating to our website is used to createreports about the use of our website. Google's privacy policy isavailable at: https://www.google.com/policies/privacy/.
13.3 Wemay publish Google AdSense interest-based advertisements on ourwebsite. These are tailored by Google to reflect your interests. Todetermine your interests, Google will track your behaviour on ourwebsite and on other websites across the web using cookies. Wepublish Google AdSense advertisements on our website. To determineyour interests, Google will track your behaviour on our website andon other websites across the web using cookies. This behaviourtracking allows Google to tailor the advertisements that you see onother websites to reflect your interests. You can view, delete or addinterest categories associated with your browser by visiting:https://adssettings.google.com. You can also opt out of the AdSensepartner network cookie using those settings or using the NetworkAdvertising Initiative's multi-cookie opt-out mechanism at:http://optout.networkadvertising.org. However, these opt-outmechanisms themselves use cookies, and if you clear the cookies fromyour browser your opt-out will not be maintained. To ensure that anopt-out is maintained in respect of a particular browser, you maywish to consider using the Google browser plug-ins available at:https://support.google.com/ads/answer/7395996.
14. Managing cookies
14.1 Mostbrowsers allow you to refuse to accept cookies and to delete cookies.The methods for doing so vary from browser to browser, and fromversion to version. You can however obtain up-to-date informationabout blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647?hl=en(Chrome);
(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences(Firefox);
(c) http://www.opera.com/help/tutorials/security/cookies/(Opera);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies(Internet Explorer);
(e) https://support.apple.com/kb/PH21411(Safari); and
(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy(Edge).
14.2 Blockingall cookies will have a negative impact upon the usability of manywebsites.
14.3 Ifyou block cookies, you will not be able to use all the features onour website.
15. Cookie preferences
15.1 Youcan manage your preferences relating to the use of cookies on ourwebsite by following the steps insection 14 most relevant to your web browser software.
15.2 Pleasenote that if you block cookies, you may not be able to use all of thefeatures on our website. This may also “break” certain elementsof our website and prevent them from functioning correctly for youonly.
16. Our details
16.1 Thiswebsite is owned and operated by COTSWOLD RAW LIMITED.
16.2 Our principal place of business is at 28a Weston Industrial Estate, Weston Subedge, WR11 7QB, United Kingdom.
16.3 Youcan contact us:
(a) bypost, to the postal address given above;
(b) usingour website contact form;
(c) bytelephone, on the contact number published on our website from timeto time; or
(d) byemail, using the email address published on our website from time totime.
17. Representative within the European Union
17.1 Youcan contact our Representative within the European Union with respectto our obligations under data protection law using any of the contactmethods listed in section 16.3.
18. Data protection officer
18.1 You can contact our Data Protection Officer with respect to ourobligations under data protection law using any of the contactmethods listed in section 16.3.