1.1 This policy sets out, as a business, how we process data both inside the business and on the website. This document is primarily for clients, subscribers, website visitors and people who wish to contact us about our services.

1.2 This document is not for staff or contractors.

1.3 We are committed to protecting your privacy and complying with our data protection obligations under the Data Protection Act 2018 (the DPA 2018), the UK General Data Protection Regulation 2016/679 (the UK GDPR) and any other applicable UK legislation (together, Data Protection Law).

1.4 When you interact with us or use the website, we act as the data controller of your personal data. This means we are responsible for processing your personal data and deciding how to use it. This privacy policy explains the types of personal data we may collect about you when you interact with us, why we collect it, what we use it for and what rights you have over it. Personal data is any information about an identifiable person. Processing is anything we do with your personal data, including using, storing, sharing and deleting it.

2. Contact Information

2.1 If you have any concerns or want further information about our use of data or this policy in general, use the details below to contact us;

Contact Name: Liz Wright

Address: 43 High Street, Cranfield, MK43 0DP

Website: https: www.walterandmay.co.uk/

Email Address: hello@walterandmay.co.uk

Company number: 13982127

3. Who Do We Collect Information From?

3.1 We collect information from;

· Visitors to our website

· Subscribers to our email list

· Clients/customers

· Suppliers and contractors

· Contacts (Network)

4. What Information Do We Collect?

4.1 We collect, store and use the types of personal data set out in the tables at the end of this policy. (For employees, please see Data Protection Policy and Record keeping Policy)

5. How Will We Use Your Personal Data?

5.1 We will use your personal data for the purposes set out in the table at the end of this policy.

6. How Do We Share Your Personal Data?

6.1 When we share personal data, we do so under Data Protection Law. We may share specific personal data, where necessary, with employees, contractors, consultants or advisers to facilitate sales and for general commercial purposes.

6.2 We may also provide third parties with aggregated but anonymised information and analytics about our customers. Before doing so, we will ensure that it does not identify you.

6.3 We also may need to share information externally for legal reasons. These include the HMRC, and the police in connection with a police investigation.

7. Sharing Information

7.1 We endeavour to keep as much data within the UK/EU, and however, there may be times when this is not possible. Where the platforms we use are outside of the UK or not a country where we have adequacy regulations, we will assess if the transfer is necessary to perform our service under the contract and that the data transfer comes under a restricted transfer.

7.2 Where we are legally required to do so, information is shared. On occasion, we may not be allowed to tell you of information being shared.

7.3 A full list of the information we collect can be found here.

8. Where Do We Collect Information

Website

8.1 The website, www.walterandmay.co.uk/ (the Website), is operated by Walter and May Ltd (we, us, our).

8.2 The website may contain links to other websites over which we have no control, usually concerning blogs. We are not responsible for and do not review or endorse the privacy policies or practices of other websites you choose to access from this website. We encourage you to review the privacy policies of those other websites to understand how they collect, use and share your personal information.

Type of plugin

Name and link of Business

Payment - Stripe.com

8.8 The website does have plug-ins that we use for third-party platforms.

8.9 We use a number of platforms to deliver our services. For a full list of these, please email us.

Contacts and clients

8.10 We collect information from contacts and clients (and potential clients) through

· Name

· Contact details

· Contact forms

· Emails

· Contracts

· Invoicing

Suppliers

8.11 We collect information from clients (and potential clients) through

· Emails

· Contracts

· Invoicing

· Notes from telephone calls and meetings

9. Your Rights

9.1 We respect your privacy rights and will respond to requests for access or control over information about you under Data Protection Law. We may require you to verify your identity before we take any action.

9.2 Depending on the reason we have your personal data, you have a right to:

· access the personal information we hold about you (commonly known as subject access);

· request that we correct or complete personal information we hold about you that is inaccurate or incomplete;

· request that we erase your personal information in some circumstances or object to our processing it;

· restrict how we use your personal data in certain circumstances;

· request that we provide you with copies of your personal information in a machine-readable format or transfer it across different services; and

· where we have asked for your consent to process your data to withdraw this consent.

9.3 These rights are limited in some situations under Data Protection Law – for example, where we can demonstrate that we are under a legal obligation to process your data.

9.4 If you wish to exercise any of these rights, please contact us.

Your right to object

9.5 You have a right to object to our processing of your personal data and ask us to stop doing so. If we are processing your personal data for direct marketing purposes (which includes profiling to the extent that it is related to such direct marketing) and you object to this, we will stop processing your personal data immediately.

9.6 If our processing of your personal data is in the public interest or under our legitimate interests and you object to this, we will stop processing your personal data unless we have compelling reasons which override your interests or our use of your personal data is for the establishment, exercise or defence of legal claims.

9.7 Your personal data will only be kept for as long as necessary for our purposes. Specific retention periods are set out in the table at the end of this policy.

9.8 At the end of the specified retention periods, your personal data will either be securely destroyed or anonymised unless we must keep it to comply with our legal obligations.

10. Data Protection Principles

10.1 We process your personal data under the following principles:

· We process your personal data lawfully, fairly and in a transparent way;

· we collect your personal data for specified, explicit and legitimate purposes; any further processing we do is compatible with the original purposes for which we collected it;

· we only process personal data that is adequate, relevant and limited to what is necessary to achieve the goal for which it is processed;

· we take reasonable steps to ensure that all personal data is accurate and kept up to date where necessary;

· we do not store personal data in a form that identifies you for any longer than is required for the purposes of our processing; and

· we process personal data securely and in a way that protects against unauthorised or unlawful processing, accidental loss, destruction or damage.

10.2 When we ask for your personal data, we will tell you whether you are required by law or contract to provide it and what will happen if you do not provide it.

10.3 Any request for consent to processing your personal data will be made directly to you and will include information about why we require the personal data and what will be done with it.

11. What Is Our Lawful Basis For Processing?

11.1 We will only process personal data when we have a lawful basis for processing. The table at the end of this policy sets out the legal basis we rely on for each data type we process.

11.2 We will choose one of the lawful bases in the UK GDPR to justify how we use your personal data. These are:

· Consent: You have given consent to the processing of your personal data for one or more specific purposes. As detailed above, you have the right to withdraw your consent at any time.

· Contract: The processing is necessary to perform a contract with you or to take steps at your request before entering into a contract.

· Legal obligation: We must process your personal data to comply with a legal obligation.

· Vital interests: The processing is necessary to protect the vital interests of you or another person.

· Public interest: Processing is necessary for performing a task in the public interest or the exercise of some official authority.

· Legitimate interests: Processing is necessary for legitimate interests pursued by us or someone else, except where such interests are overridden by your interests or fundamental rights and freedoms requiring the protection of your personal data.

12. How to complain

12.1 If you have any concerns about our use of your personal information, you can make a complaint to us at using the contact details above.

12.2 We hope to satisfy any queries you may have about how we process your data. However, if you have unresolved concerns, you also have the right to complain to data protection authorities (in the UK, the Information Commissioner’s Office)

The ICO’s address:

Information Commissioner’s Office

Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk

13. Policy review

13.1 We update and review this policy at least annually or when required due to changes in practice and legal updates. An updated version on the website and will make reasonable efforts to bring any material changes to your attention.

Date reviewed - 10.01.23

Policy changes - New draft of policy

Version - 2

When collected / stored - Website visit
Category of personal data - Cookies
Purpose of processing - Essential
Lawful basis for processing - Required – legitimate Consent
Retention period -

When collected / stored - Contract/Website Email marketing platform
Category of personal data - Name and contact details
Purpose of processing - To deliver your purchases to you/To send you order updates/For fraud prevention and detection/To contact you with information, newsletters and marketing materials about our products and services
Lawful basis for processing - Performance of sale/Compliance with legal obligation/Consent
Retention period - For three years since you gave consent, or until you withdraw consent if earlier

When collected / stored - Online payment platform/Bank transfer/Cheque
Category of personal data - Payment information
Purpose of processing - To take payment and give refunds/For fraud prevention and detection
Lawful basis for processing - Performance of contract/Compliance with legal obligation
Retention period - For six years after purchase on to the website

When collected / stored - Emails
Category of personal data - Contact history
Purpose of processing - To provide customer service and support/To train our staff
Lawful basis for processing - Performance of contract/Legitimate interests in dealing with complaints or claims
Retention period - For six years since you last logged on to the website

When collected / stored - Platform analytics
Category of personal data - Browser, device and Site usage information
Purpose of processing - To improve the website /To protect the website against fraud/To set default options for you, such as language and currency
Lawful basis for processing - Performance of contract/Legitimate interest in maintaining our website
Retention period - For three years since you last logged on to the website

When collected / stored - Website/Testimonial/capture form/Emails
Category of personal data - Customer comments and product reviews
Purpose of processing - To improve our products and services/Where relevant, to establish, exercise or defend legal claims
Lawful basis for processing - Performance of contract/Legitimate interest in dealing with complaints or claims and improving our products and/or services generally
Retention period - For six years

When collected / stored - Website/Social media platform analytics/Google Analytics
Category of personal data - Information collected through cookies and similar technologies
Purpose of processing - To conduct and store website usage analytics, statistical and trend analysis and market research/To generate customer profiles to facilitate marketing initiatives
Lawful basis for processing - Consent
Retention period - For two years since you gave consent, or until you withdraw consent if earlier