Privacy Policy

1. GENERAL
1.1. Curtis Wool Direct Ltd is a company incorporated in England with a registered office at Lawrence House, Dowley Gap Business Park, Bingley, West Yorkshire, BD16 1WA. For the purpose of the General Data Protection Regulation (“GDPR”), the data controller is Curtis Wool Direct Ltd. The terms “we”, “us”, “our” and “ours” when used in this policy means Curtis Wool Direct Ltd. The terms “you”, “your” or “yours” when used in this policy means any person who interacts with and/or does business with us.
1.2. We are committed to taking all reasonable steps to ensure all personal data held by us in relation to our employees, customers, suppliers and all other individuals is kept secure, processed in a fair and lawful manner and managed in accordance with all applicable data privacy laws. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

2. OUR WEBSITE
2.1. We may collect and process personal data about you in the following circumstances:
2.1.1. When you complete forms on our website (“Site”). This includes where you complete and submit a form asking us to contact you about our products or services;
2.1.2. Whenever you provide information to us when reporting a problem with our Site, making a complaint, making an enquiry or contacting us for any other reason. If you contact us, we may keep a record of that correspondence;
2.1.3. Details of your visits to our Site including, but not limited to, traffic data, location data, other communication data, and the resources that you access (see section 2.2.2. on Cookies below);
2.1.4. Whenever you disclose your information to us, or we collect information from you in any other way, through our Site.
2.2. We may also collect data in the following ways:
2.2.1. IP Address
2.2.1.1. We may collect information about your device, including where available your Internet Protocol address, for reasons of fraud protection. We may also collect information about your device’s operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual.
2.2.2. Cookies
2.2.2.1. Our Site does not currently use cookies to.
2.3. We may use your personal data for our legitimate interests in order to:
2.3.1. Provide you with information or services you requested from us;
2.3.2. Ensure that content from our Site is presented in the most effective manner for you and for your device;
2.3.3. Improve our Site and services;
2.3.4. Process and deal with any complaints or enquiries made by you.

3. CUSTOMERS
3.1. We will collect details such as your name, postal address and company details when you register as a customer with us. We use this information to provide you with our services, administer your account, comply with our statutory obligations, and notify you of any changes to our services.
3.2. In order to provide you with our services, we may also need to share personal data with third parties such as hauliers to transport the wool.
3.3. We will retain your information as long as you remain registered with us and for a period of 7 years afterwards.

4. SUPPLIERS (INCL FREIGHT FORWARDERS)
4.1. We will collect details such as contact details and bank details in order to contact you about goods or services ordered with you, to place further orders and to pay you for the goods and/or services supplied. We will keep the personal data for 7 years further to being provided with the goods/services.

5. FAILURE TO PROVIDE PERSONAL DATA
5.1. 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 the data when requested, we may not be able to provide you with the goods or services you require. 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.

6. MONITORING AND RECORDING
6.1. We do not monitor or record telephone or email communications with you.

7. AUTOMATED PROCESSING
7.1. We do not undertake automated decision making with your personal data.

8. LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA
8.1. We will only use your personal data where the law allows us to. Most commonly, we will use your personal data in the following circumstances:
8.1.1. For performance of a contract we enter into with you;
8.1.2. Where necessary for compliance with a legal or regulatory obligation we are subject to;
8.1.3. Where we have obtained your consent;
8.1.4. For our legitimate interests (as described within this policy) and your interests and fundamental rights do not override these interests.

9. DISCLOSURE OF PERSONAL DATA TO THIRD PARTIES
9.1. We may disclose your information to third parties for our following legitimate interests as follows:
9.1.1. To staff members in order to facilitate the provision of products or services to you;
9.1.2. To our affiliated entities to support internal administration;
9.1.3. To external companies, such as freight forwarders, in order to deliver goods or services;
9.1.4. IT Software providers that host our website and store data on our behalf;
9.1.5. Professional advisers including consultants, lawyers, bankers and insurers who provide us with consultancy, banking, legal, insurance and accounting services;
9.1.6. HM Revenue and Customs, regulators and other authorities who require reporting of processing activities in certain circumstances;
9.1.7. Third parties who we may choose to sell, transfer or merge parts of our business or assets. Alternatively, we may seek to acquire other business or merge with them. If a change happens to our businesses then the new owners may use your personal data in the same way as set out in this privacy policy.
9.2. We may disclose personal data to the police, regulatory bodies, legal advisors or similar third parties where we are under a legal duty to disclose or share personal data in order to comply with any legal obligation, or in order to enforce or apply our website terms and conditions and other agreements, or to protect our rights, property or safety of our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protections and credit risk reduction.
9.3. We will not sell or distribute personal data to other organisations without your approval.

10. EXTERNAL DATA TRANSFERS
10.1. The data we collect maybe accessed, transferred to and stored by companies and external service providers established outside the European Economic Area (“EEA”). Transfer of such data is aimed at the following purposes:
10.1.1. In order to provide you with the information, products or services which you have requested;
10.1.2. To comply with legal requirements, for the administration of justice, to respond to valid legal processes from the government or public authorities in any country in which we operate.

11. DATA SECURITY
11.1. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your information transmitted to our Site; any transmission is at your own risk.
11.2. Information you provide to us is shared on our secure servers. We have implemented appropriate physical, technical and organisational measures designed to secure your information against accidental loss and unauthorised access, use, alteration or disclosure. In addition, we limit access to personal data to those employees, agents, contractors and other third parties that have a legitimate business need for such access.

12. ACCESS, AMENDMENT, REMOVAL AND RESTRICTING USE OF PERSONAL DATA
12.1. It is important that the personal data we hold about you is accurate and current. Please let us know if the personal data we hold about you changes.
12.2. Data protection legislation gives you the right to object to the processing of your personal data in certain circumstances or withdraw your consent to the processing of your personal data where this has been provided. You also have the right to access information held about you and for this to be provided in an intelligible form. If you would like a copy of some or all of your personal data, please send an email to gdprdata@curtiswool.co.uk . In certain circumstances we reserve the right to charge a reasonable fee to comply with your request.
12.3. You can also ask us to undertake the following:
12.3.1. Update or amend your personal data if you feel this is inaccurate;
12.3.2. Remove your personal data from our database entirely;
12.3.3. Send you copies of your personal data in a commonly used format and transfer your information to another entity where you have supplied this to us, and we process this electronically with your consent or where necessary for the performance of a contract;
12.3.4. Restrict the use of your personal data.
12.4. We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the personal data that we hold about you or make your requested changes. Data protection legislation may allow or require us to refuse to provide you with access to some or all the personal data that we hold about you or to comply with any requests made in accordance with your rights referred to above. If we cannot provide you with access to your personal data, or process any other request we receive, we will inform you of the reasons why, subject to any legal or regulatory restrictions.
12.5. Please send any requests relating to the above to our Data Protection Officer at Curtis Wool Direct Ltd, Lawrence House, Dowley Gap Business Park, Bingley, West Yorkshire, BD16 1WA or by emailing us at gdprdata@curtiswool.co.uk specifying your name and the action you would like us to undertake.

13. RIGHT TO WITHDRAW CONSENT
13.1. Where you have provided your consent to the collection, processing and transfer of your personal data, you have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, please contact us at Curtis Wool Direct Ltd, Lawrence House, Dowley Gap Business Park, Bingley, West Yorkshire, BD16 1WA or by emailing us at gdprdata@curtiswool.co.uk .

14. CHANGES TO OUR PRIVACY POLICY
14.1. We reserve the right to update this privacy policy at any time, and any changes we make to our privacy policy will be posted on this page. Please check periodically for any updates. If we would like to use your previously collected personal data for different purposes than those we notified you about at the time of collection, we will provide you with notice and, where required by law, seek your consent, before using your personal data for a new or unrelated purpose. We may process your personal data without your knowledge or consent where required by applicable law or regulation.

15. CONTACT US
15.1. We have appointed a Data Protection Officer to oversee compliance with this privacy policy. If you have any questions, comments or requests regarding this policy or how we use your personal data please contact our Data Protection Officer at gdprdata@curtiswool.co.uk or 01274 563444.