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Consumer Privacy Policy

Who we are and why we care about our customers data
Edwards of Conwy Ltd is a private company registered in England and Wales, company number 06302163. Our registered office is; Edwards of Conwy Ltd, 18 High St, Conwy, LL32 8DE.

Here at Edwards of Conwy Ltd we are committed to maintaining the trust and confidence of our customers, we take your privacy very seriously. This document explains how we collect, store and handle your personal data.
For the purpose of this document the data controller is Edwards of Conwy Ltd (referred to in this policy as “we” or “us”). We are committed to ensuring that your privacy is protected.

The purpose of this policy is to:
• set out the types of personal data that we collect
• explain how and why we collect and use your personal data
• explain when and why we will share personal data and with other organisations
• explain the rights and choices you have when it comes to your personal data

This Policy applies to you if you use our services (referred to in this Policy as “our Services”). Using our Services means:
• shopping with us online, in-store, over the phone or where this Policy is posted
• being a member of our loyalty scheme
• being a member of our Christmas savings club
• Contacting us with a query or feedback about any of our services.

Personal Data we collect and who we share this with (by service).
When you use our services, you may provide us with your personal details, including your full name, billing and shipping addresses, email addresses, phone numbers and date of birth and title. In addition to this you may provide the specific information for the services listed below. This information may be shared with the respective third parties (also listed below).

When you use our website, we may collect:
• Information about your online purchases (for example, what you have bought, when and where you bought it and how you paid for it)
• Information about your online browsing behaviour on our Website
• Information about any devices you have used to access our Services (including the make, model and operating system, IP address, browser type and mobile device identifiers)
This information may be shared with: Our website developers, Google Analytics, our chosen payment service provider (such as “Sage Pay” or similar) & our chosen courier company. *

When you use our Loyalty Scheme, we may collect:
•Transaction information, including the in-store purchases you earn loyalty points for and how you use your Loyalty card redemptions.
• Information relating to your hobbies and interests.
•Details of your activity following emails and other digital communications we send to you, including which emails you open, how long you spend reading them, which links (if any) that you may click on
This information may be shared with: Our chosen Loyalty Card Scheme provider *

When you shop with us in-store or over the phone we may collect:
• Transaction information, including the purchases you pre-order.
• Method of payment
• Dietary information.
CCTV images
This information may be shared with: Our chosen courier company. *

When you take part in promotions & competitions we may collect:
• Circumstantial personal data specific to the promotions / competition format, for example you may be asked to share an image, make a comment or give feedback.
This information may be shared with: Our chosen courier company. *

When you contact us with a query (or if we contact you) or when you take part surveys or questionnaires about our services, we may collect:
• Circumstantial personal data you provide about yourself in relation to the query
• Your feedback and contributions to customer surveys and questionnaires

How and why we use your personal data
• To enable you to order/purchase our products and access our services.
• To enable us to fulfil those orders and provide you with progress updates throughout.
• To enable us to provide you with the products and services you have purchased with the highest possible level of customer service.
• To manage any account, you have registered with us including your preferences for marketing communications.
• To carry out market research to better understand your views on our products and services.
• To Manage and improve our day to day operations.
• To carry out internal research to improve the range of products offered and associated products and services we can offer you and to help identify new products and services we may wish to offer in the future.
• To enable us to present you with personalised communications.
• To manage promotions, competitions and any other marketing activity you may take part in.
• To verify your identity
• To detect and prevent fraud and other illegal activities (and to assist regulators, trade bodies and law enforcement agencies in relation to the same)
• To comply with the law

When we share your personal data with 3rd party organisations: *. We may share your personal data with other organisations (which are specific to the product/service you are receiving as listed above), as well as some general core service providers such as IT/Security companies or similar. We will only send our service providers the personal data that they need to fulfil their service to us, this includes the transfer of information between ourselves and our sister company “The Traditional Welsh Sausage Company Ltd.”.
External service providers will each have their own privacy policy however, we will always set out our expectations in relation to keeping your personal data secure and hold them fully responsible for meeting those expectations.
In addition to this we may also share your personal data in the following circumstances:
• if the law or a public authority says we must share the personal data
• if we need to share personal data in order to establish, exercise or defend our legal rights and property.
• As part of the purchase, merger or reorganisation of the business. The organisation receiving your personal data can use your personal data in the same way as us; or to any other successors in title to our business.

Protection of your personal data:
We know how important it is to securely store, protect and manage your personal data
We enforce physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of personal data.
We use computer safeguards such as firewalls and data encryption, and we enforce physical access controls to our buildings and files to keep this data safe.
To ensure internal confidentiality we only authorise access to employees who need it to carry out their job responsibilities, we use full login and password controls on our computer systems.
The personal data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by companies operating outside the EEA who work for us or for one of our service providers. We will put in place appropriate protection to make sure your personal data remains adequately protected and is treated in line with this Policy.

Further Information:
Our Legal basis for collecting data
we only ever collect and process data under one of the following lawful bases:
(a) Consent: you the individual have given clear consent for us to process your personal data for a specific purpose.
(b) Contract: the processing is necessary for a contract we have with you the individual, or because you have asked us to take specific steps before entering into a contract.
( c) Legal obligation: the processing is necessary for us to comply with the law (not including contractual obligations).
(d) Vital interests: the processing is necessary to protect someone’s life.
(e) Public task: the processing is necessary for us to perform a task in the public interest or for our official functions, and the task or function has a clear basis in law.
(f) Legitimate interests: the processing is necessary for our legitimate interests or the legitimate interests of a third party unless there is a good reason to protect you the individual’s personal data which overrides those legitimate interests.

External links
Our Website and Email communications via our loyalty card system may contain links to other websites operated by other organisations that have their own privacy policies. Please make sure you read the terms and conditions and privacy policy carefully before providing any personal data on a website as we do not accept any responsibility or liability for websites of other organisations.

Google analytics
Edwards of Conwy use non-unique cookies on this website for the purpose of website performance. These cookies collect anonymous information on how people use our Site. For example, we may use cookies to help us understand how you arrive at our Site, browse or use our Site and highlight areas where we can improve. The data stored by these cookies never shows personal details from which your individual identity can be established. We use Google Analytics, for example, to anonymously track website usage and activity.

Account based Cookies
The only additional cookies that are used are for allowing users to login to their accounts to ensure that a logged in users are able to access their account information. These cookies expire after 24 hours.
Your rights:
As an individual you have the following rights in relation to your personal information, as outlined by the ICO (information Commissioner’s Office):
1. Your right to be informed
2. Your right of access
3. Your right to rectification
4. Your right to erasure – (also known as your right ‘to be forgotten’)
5. Your right to restrict processing
6. Your right to transfer your personal data (known as data portability)
7. Your right to object
8. Your right to object and your rights related to automated decision making and profiling

For more information on your rights as an individual please visit the ICO’s website: www.ico.org.uk .

You can exercise these rights by contacting us at any time using the details below:
Email: sales@edwardsofconwy.co.uk
Write to us at: Edwards of Conwy Ltd, 18 High St, Conwy, LL32 8DE

Changes and updates to our privacy policy:
We regularly review our privacy policy.
Any changes we make to our privacy policy in the future will distributed through the appropriate communication channels.

This policy was last reviewed and approved on 25/05/2018