CORNISH MILK MINERAL PAINTS 
PRIVACY POLICY

WHO ARE CORNISH MILK MINERAL PAINT? 
References in this Privacy Policy to “Cornish Milk Mineral Paint”, “Cornish Milk”, “we”, “us” or “our” mean Cornish Milk Mineral Paint.Our company is registered in England and Wales and we control the ways your personal data is collected by us and the purposes for which your personal data is used by Cornish Milk Mineral Paint and are the “data controller” for the purposes of the UK Data Protection Act 1998, EU General Data Protection Regulation (GDPR), PCI-DSS, and European data protection legislation.You may enquire on the data we hold on you at any time by contacting hello@cornishmilkmineralpaint.co.uk and request that such data be removed. 

 WHO IS THIS POLICY FOR? 
We may keep personal data in order to provide you with the best level of service you require from Cornish Milk Mineral Paint.This includes but is not limited to our official stockists, newsletter subscribers, our suppliers and our social media accounts. 

WHEN DO WE COLLECT YOUR PERSONAL DATA? 
We may collect personal data from you in the following ways:When you make an online purchase using our Cornish Milk Mineral Paint website.When you order our exclusive marketing materials and colour charts from us. When you sign up for our email newsletter.When you engage with us on our social media accounts.When you enter competitions or giveaways, either on social media or on our website.When you contact us by any means with queries, complaints, etc.When you email any email with an @cornishmilkmineralpaint domain name (e.g. hello@cornishmilkmineralpaint). When you complete any surveys we send you.When you comment on or review our products and services.When you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions, patterns and the website that referred you to www.cornishmilkmineralpaint.co.uk. 

We collect this personal data by using cookies, server logs and other similar technologies supplied by Shopify protect. Technical Data can also be collected from the following parties: analytics and search information providers (such as Google) and advertising networks. 

THE DATA WE COLLECT? 
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, outlined in the following ways:Identity Data including first name, last name, title. Your image and car number plate may be recorded on CCTV at Cornish Milk's Cornwall HQ location. 

Contact Data including billing address, delivery address, email address, telephone numbers. We will also collect your social media username, if you interact with us through those channels. 

Financial Data including bank account and payment card details.Transaction Data including details about payments to and from you and other details of products you have purchased from us.Technical Data including internet protocol (IP) address, 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 our website.Profile Data including purchases or orders made by you, your interests, preferences, feedback and survey responses.Usage Data including information about how you use our website. This includes information gathered by the use of cookies in your web browser. 

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.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. 

 WHY MAY WE USE YOUR PERSONAL DATA? 
We will only ever use your personal data when the law allows us to. 
Most commonly, we will use your personal data in the following ways: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.Where we need to comply with a legal or regulatory obligation.Legitimate Interest 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.Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.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. 

Examples of how we use information held about you include:To process any orders that you make on our website shop “Cornish Milk Mineral Paint”. If we don’t collect your personal data during checkout, we won’t be able to process and deliver your order and comply with legal obligations. For example, your details may need to be passed to a third party to supply or deliver the product or service that you ordered, and we may keep your details for a reasonable period afterwards in order to fulfil any contractual obligations such as refunds, guarantees and so on. To respond to your queries, refund requests and complaints. Handling the information you send enables us to respond. We may also keep a record of these to inform any future communication with us and to demonstrate how we communicated with you throughout. We do this on the basis of our contractual obligations to you, our legal obligations and our legitimate interests in providing you with the best service and understanding how we can improve our service based on your experience. 

To protect our customers, premises, assets and staff from crime, we operate CCTV systems in our Cornish Milk HQ location which record images for security. We do this on the basis of our legitimate business interests.To process payments and to prevent fraudulent transactions. We do this on the basis of our legitimate business interests. This also helps to protect our customers from fraud.If we discover any criminal activity or alleged criminal activity through our use of CCTV, fraud monitoring and suspicious transaction monitoring, we will process this data for the purposes of preventing or detecting unlawful acts. We aim to protect the individuals we interact with from criminal activities.

WHO DO WE SHARE YOUR PERSONAL DATA WITH? 
We may have to share your personal data with the parties set out below for the purposes outlined in ‘How and why we use your personal data’.Examples of the kind of third parties we work with are:IT companies who support our website and other business systems.Operational companies such as delivery couriers and third party delivery programs that assist with courier delivery. One of these programs is called DPD Local and you can read their Privacy Policy on the DPD Local website.

INTERNATIONAL TRANSFERS 
We will only ever transfer your data outside of the EEA in compliance with data protection laws and provided appropriate or suitable safeguards are in place to protect your data, these being either standard contractual clauses, binding corporate rules or in the case of transfers to the USA, a Privacy Shield Certification. Please contact us if you would like details of the appropriate safeguards used if we transfer your data in such circumstances. 

HOW DO WE PROTECT YOUR DATA? 
The security of your personal data is very important to us and we are committed to treating it with the utmost care, taking all appropriate steps to protect it.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. Access to your personal data is password-protected, and sensitive data (such as payment card information) is secured to ensure it is protected.We secure access to all transactional areas of our websites and apps using ‘https’ technology via Shopify.We regularly monitor our system for possible vulnerabilities and attacks, and we carry out penetration testing to identify ways to further strengthen security.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. 

HOW LONG DO WE KEEP YOUR DATA? 
We will not retain your personal data for longer then necessary for the purposes set out in this Policy. Different retention periods apply for different types of data, however the longest we will normally hold any personal data is 12 months. 

 WHY DO WE REMEMBER YOUR LOCATION? 
We detect your region when you first visit cornishmilkmineralpaint.co.uk to provide a localised version of our Online shop. You can change this location at any time by using the region dropdown in the site’s header. This is to help find your nearest official Cornish Milk Stockist. You may refuse to give this information and we do not use this data for any other purposes.We do not store the location you type into the search field on our website or its pages.

HOW DO WE USE ADVERTISING? 
We use Google AdWords, Facebook, Instagram and Shopify softwares for re-marketing purposes. This helps us reach people who previously visited our website and match the right people with the right message.We use Google AdWords to advertise based on past visits to cornishmilkmineralpaint.co.uk.Third-party vendors, including Google, use cookies to serve ads based on past visits to cornishmilkmineralpaint.co.uk. 

We don’t collect or store your personal information (e.g. your name or address) so this information can’t be used to identify who you are. 

WHAT ARE YOUR RIGHTS OVER YOUR PERSONAL DATA? 
Under certain circumstances, you have rights under data protection laws in relation to your personal data.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.In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We must always comply with your request.If you wish to exercise any of the rights set out above, please contact us at hello@cornishmilkmineralpaint. 

 As an active existing subscriber we will continue to send you email marketing (our newsletters). To opt out from email marketing please click on the unsubscribe link featured at the bottom of each marketing email we send.If we choose not to action your request we will explain to you the reasons for our refusal.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. 

 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.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.
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