CEF Privacy Notice
Introduction
The Website www.cef.co.uk is operated by City Electrical Factors (we", "us" or "our") and we are a "data controller" for the purposes of the Data Protection Act 2018 and the EU General Data Protection Regulation 2016/679. This means that we are responsible for, and control the processing of, your personal information.
We take your privacy very seriously and we ask that you read this Policy carefully as it contains important information on:
- the personal information we collect about you;
- what we do with your information; and
- who your information might be shared with
What type of personal information we collect
Personal information means any information about an individual from which the person can be identified. It does not include data where the identity has been removed (anonymous data).
We collect personal information about you when you register with us online, contact us or when you submit a response to an online questionnaire on our website.
- Identity Data includes first name, last name, username or similar identifier, title, data of birth.
- Contact Data includes billing address, delivery address, email address and telephone numbers
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
- Usage Data includes information about how use our website, product and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us.
- Technical Data includes internet protocol (IP) address, your login data, 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 the website.
- Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
We may collect personal information about you from other sources (such as credit reference agencies), which we will add to the information we already hold about you in order to help us improve our products and services and help us access the initial credit limit to be applied to your account and as part of our annual review of your credit status.
Please note that we do not collect or hold any personal information in relation to your payment information, such as credit/debit card details or any ‘Special Categories’ of personal information 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.
How we collect your personal information and why we have it
Most of the personal information we process is provided to us directly by you and we will use it for one or more of the following reasons:
- to identify you and manage any accounts you hold with us;
- to process your order and obtain payment;
- to detect and prevent fraud;
- to carry out security vetting;
- to conduct research, statistical analysis and behavioural analysis;
- to customise our website and its content to your particular preferences; - see 'Cookies and Tracking' section below;
- to notify you of any changes to our website or to our products services that may affect you;
- to improve our product and services; and
- to give to companies and organisations whose products you purchase through the website.
- to let you know about other products or services that may be of interest to you; see 'Marketing' section below;
Generally, we do not rely on consent as a legal basis for processing your personal information although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal information
Under the General Data Protection Regulation (GDPR), the legal bases we rely on for processing your personal information are:
| Purpose of processing | Our legal basis |
|---|---|
|
Performance of a contract with you - we use your personal information in order to meet our obligations under our contract with you, keep you up to date with information about our services, and to respond to your queries. |
| Send you information about products and services, including promotions, exclusive offers, discounts, vouchers, free gifts, information about products and events; | Legitimate interest - we use your personal information to send you this information. You have the right to object to processing of this nature and will always be given the opportunity to do so. |
| Review your past purchases and viewing history on our website to provide you with special offers or to tailor your experience online; | Legitimate interest - we use your personal information to provide you with other and to tailor your experience when using our online services. |
|
Legitimate interest - we use your personal information to help us deliver the best quality of service to you and all of our customers. |
|
Legitimate interest - we use your personal information to deliver you a tailored experience when using such digital services, to help us understand the effectiveness of our advertising, and to make sure you see adverts that are most relevant to you. |
| Provide, enhance and personalise your experience on our digital services provided from our web and mobile portals. | Legitimate interest - we use your personal information to deliver you a tailored experience when using our digital services. |
| Carry out security checks and identity checks to protect against fraudulent transactions and to prevent and detect criminal activity, such as money laundering; | Legitimate interest - we use your personal information to protect against unlawful activities and comply with laws applicable to us. In some cases, we may also be under a legal obligation to disclose your personal information (for example, to law enforcement agencies). Furthermore, if you are from a public authority, we use your personal information on the basis that it is necessary in the public interest or in exercising official authority for is to prevent fraud and money laundering. |
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Marketing
We may periodically send promotional emails about new products, special offers or other information which we think you may find interesting using the email address which you have provided.
From time to time, we may also use your information to contact you for market research purposes. We may contact you by email, SMS or other electronic messaging services, phone, fax or mail. We may use the information to customise the website according to your interests.
We use third parties to carry out certain activities on our behalf that involve the processing of personal information, particularly a third-party service provider to send promotional material via postal mail. We will get your express opt-in consent before we share personal data with any third party for marketing purposes.
You can opt out of us or any third parties sending you marketing messages at any time by sending an email to [email protected] or via the unsubscribe link at the bottom of emails we send to you. Please see 'The right to ask us to stop contacting you with direct marketing' below for further information.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase or other transactions.
Cookies and Tracking
Use of cookies
A cookie is a small text file which is placed onto your computer (or other electronic devices) when you access our website. We use cookies on this website to:
- a) recognise you whenever you visit this website (this speeds up your access to the website as you do not have to log in each time);
- b) obtain information about your preferences, online movements and use of the internet;
- c) carry out research and statistical analysis to help improve our content, products and services and to help us better understand our customer requirements and interests;
- d) target our marketing and advertising campaigns more effectively by providing interest-based advertisements that are personalised to your interests; and
- e) make your online experience more efficient and enjoyable.
In most cases we will need your consent in order to use cookies on this website. The exception is where the cookie is essential in order for us to provide you with a product or service you have requested.
Consent
When you visit the site for the first time you will see a banner where you have the option to accept, reject or manage your cookie preferences. Whether you accept or reject cookies on this visit there is always a cookie symbol at the bottom right side of the screen you can click which allows you to update your preferences or withdraw your consent at anytime.
Description of cookies
The table below provides some information on the cookies which we use on our website
How to turn off cookies
If you do not want to accept cookies, you can change your browser settings so that cookies are not accepted. If you do this, please be aware that you may lose some of the functionality of this website. For further information about cookies and how to disable them please go to the Information Commissioner’s webpage on cookies: https://ico.org.uk/for-the-public/online/cookies/.
CEF Mobile Device APP
Although no cookies are used to operate the CEF Mobile Device App, users should be aware that an element of their device storage or memory will be used in order to store:
- The app itself
- An authorisation token - This is not identifiable to individuals
- The current basket and it's preferences
- Account number so you are not required to sign in each time
By downloading and using the app you consent to the use of your storage in this way. If you do not agree with the conditions detailed, then the app will not be usable.
How long we will use your personal information
We shall retain your information whilst you remain a customer, should you not trade and there is no good business reason to retain your information we will delete your information one year after the month of the final sale or on receipt of your request to be deleted whichever is the sooner, unless we are required by law to retain your personal information for a longer period.
Disclosures of your personal information
Where necessary to fulfil our obligations to you, we may pass your personal information to third parties where this is necessary for the functioning of our business and the purposes set out in the table 'Purposes for which we will use your personal information'. We may share your personal information with:
a) Google
We work with third party company Google to automatically collect information including: IP address; MAC (Media Access Control) address; unique identifier or other persistent or non-persistent device identifier; device software platform and firmware, mobile phone carrier and geo location data to help us understand your use of our app such as how often you return, what parts of the app you visit, how you use the app and how long you spend on the app. This third party provider is prohibited from using our data for any other purposes. Go to http://www.google.com/analytics/terms/us.html to read Google Analytics Privacy Policy. We use the data we collect about your use of our website to analyse trends across the data set of all customers worldwide, and to enable us to offer a better service to you.
b) New Relic
We work with third party company New Relic Cookie. They are used to store a session identifier so they can monitor session counts for an application. The Cookie value is generated by Jetty. This third party provider is prohibited from using our data for any other purpose. Go to https://newrelic.com/termsandconditions/privacy to read New Relic Privacy Policy. This was accurate on 25th May 2018. Parties may have since been added. An up to date list can be obtained at [email protected]
c) Click4Assistance
We use live chat software on our website, this is provided by Click4Assistance, a third party UK based Software Company. Information regarding how the data is processed and stored can be viewed here
d) Microsoft
We work with third party company Microsoft to automatically collect data which is used to compile statistical reports and heatmaps. Go to https://clarity.microsoft.com/terms to read the Microsoft Clarity Privacy Policy. We use the data collected to enable us to offer a better service to you.
e) ITS
ITS is a merchant services and payment processing provider offering a payment gateway for online transactions, CEF share personal transaction data with ITS in order to process these transactions. For further information on how ITS process personal transaction data please see ITS Data Privacy Policy.
f) Equifax
In order to process your application and during our relationship with you, we will perform credit and identity checks on you with our chosen credit reference agency ('CRA'), Equifax. Before we provide services, goods or financing to you, we undertake checks for the purposes of preventing fraud and money laundering, and to verify your identity. These checks require us to process personal data about you.
To do this, we will supply your personal information to Equifax and they will give us information about you. This will include information from your credit application and about your financial situation and financial history. Equifax will supply to us both public (including the electoral register) and shared credit, financial situation and financial history information and fraud prevention information.
We will use this information to:
- Assess your creditworthiness and whether you can afford to take the product
- Verify the accuracy of the data you have provided to us
- Prevent criminal activity, fraud and money laundering
- Manage your account(s)
- Trace and recover debts, and
- Ensure any offers provided to you are appropriate to your circumstances.
When the CRA receives a search from us they will place a search footprint on your credit file that may be seen by other lenders. A soft search quotation will not place a search footprint on your credit file.
Equifax’s role as CRA, a fraud prevention agency, the data they hold, the ways in which they use and share personal information, data retention periods and your data protection rights with the CRA is explained in more detail at http://www.equifax.co.uk/crain
Data Security
To protect your personal information, we have policies and procedures in place to make sure that only authorized personnel can access the personal information, that personal information is handled and stored in a secure and sensible manner and all systems that can access the personal information have the necessary security measures in place. To accomplish this, all employees, contractors and sub-contractors have roles and responsibilities defined in those policies and procedures.
To make sure all employees, contractors and sub¬contractors understand these responsibilities they are provided with the necessary training and resources they need.
In addition to these operational measures, we also use a range of technologies and security systems to reinforce the policies.
To make sure that these measures are suitable, vulnerability tests are run regularly. Audits to identify areas of weakness and non-compliance are routinely scheduled. Additionally, all areas of the organisation are constantly monitored and measured to identify problems and issues before they arise.
Your data protection rights
Under data protection law, you have rights in relation to your personal information including:
- The right to be informed You have the right to be informed about the collection and use of your personal data.
- The right to correct and update the personal information we hold about you If the personal information we hold about you is out of date, incomplete or incorrect, you can inform us and we will ensure that it is updated.
- The right to have your personal information erased If you feel that we should no longer be using your personal information or that we are illegally using your personal information, you can request that we erase the personal information we hold. When we receive your request, we will confirm whether the personal information has been deleted or tell you the reason why it cannot be deleted.
- Your right to restriction of processing You have the right to ask us to restrict the processing of your personal information in certain circumstances.
- The right to ask us to stop contacting you with direct marketing You have the right to request that we stop contacting you with direct marketing. You can click the unsubscribe button at the bottom of any of our marketing emails or you can email us at [email protected]
- The right to access information we hold about you At any point you can contact us to request the personal information we hold about you as well as why we have that personal information, who has access to the personal information and where we got the personal information. Once we have received your request, we will respond within 30 days.
- The right to object to processing of your data You have the right to request that we stop processing your personal information. Upon receiving the request, we will contact you to tell you if we are able to comply or if we have legitimate grounds to continue. If personal information is no longer processed, we may continue to hold your personal information to comply with your other rights.
- The right to data portability You have the right to request that we transfer your personal information to another controller. Once we have received your request we will comply where it is feasible to do so. Our security procedures mean that we may request proof of identity before we are able to disclose your personal information to you or comply with other requests, this is to maintain the security of your information. in such cases your response will be necessary to exercise this right.
No fee usually required
You are not required to pay any charge for exercising your rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
Time limit to respond
If you make a request, we have one month to respond to you.
If you wish to make a request, please contact us at:
City Electrical Factors Limited
Janet Nash House
Meadowfield
Industrial Estate
Durham
DH7 8RJ
How to complain
If you have any queries about this privacy notice, need further information or wish to lodge a complaint about the use of your personal information you can use the details below to contact CEF.
City Electrical Factors Limited
Janet Nash House
Meadowfield
Industrial Estate
Durham
DH7 8RJ
You can also complain to the ICO if you are unhappy with how we have used your personal data. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance. The ICO's address:
Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number:
0303 123 1113
www.ico.org.uk
Changes to this Privacy Policy
We may change this Policy from time to time. You should check this policy notice occasionally to ensure that you are aware of the most recent version that will apply each time you access the website.