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Stonesthro

Privacy Policy

1. Introduction

  • 1.1 We are committed to safeguarding the privacy of our website visitors, service users, individual customers and customer personnel
  • 1.2 This policy applies where we act as a data controller with respect to the personal data of such persons; in other words, where we determine the purposes and means of processing that personal data.
  • 1.3 We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website and services, we will ask you to consent to our use of cookies when you first visit our website.
  • 1.4 In this policy, "we", "us" and "our" refer to Stonesthro Ltd. For more information about us, see Section 13.
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2. The personal data that we collect

  • 2.1. In this Section 2 we have set out the general categories of personal data that we process and, in the case of personal data that we did not obtain directly from you, information about the source and specific categories of that data.
  • 2.2 We may process data enabling us to get in touch with you ("contact data"). The contact data may include your name, business name, email address, business website address, telephone number, postal address and/or social media account identifiers. The source of the contact data is our public domain research and third-party data suppliers, you and/or your employer.
  • 2.3 We may process your website user account data ("account data"). The account data may include your account identifier, name, email address, business name, account creation and modification dates, website settings and marketing preferences. The primary source of the account data is you and/or your employer, although some elements of the account data may be generated by our website.
  • 2.4 We may process information relating to our customer relationships ("customer relationship data"). The customer relationship data may include your name, the name of your business or employer, your job title or role, your contact details, your classification / categorisation within our customer relationship management system and information contained in or relating to communications between us and you, or between us and your employer. The source of the customer relationship data is you and/or your employer.
  • 2.5 We may process information contained in or relating to any communication that you send to us or that we send to you ("communication data"). The communication data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms.
  • 2.6 We may process data about your use of our website and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system.
  • 2.7 Please do not supply any other person's personal data to us, unless we prompt you to do so.

Data Sources

When we did not obtain personal data directly from you, we may have processed data from a range of sources to enable us to identify potential customers, suppliers and partners. These sources include:

  • (a) data brokers
  • (b) existing customers
  • (c) partners and suppliers
  • (d) Public domain business sources

Public domain data sources include company websites, Companies House or business networking websites where the information is likely to have been published directly by the individual (or on their behalf by a third party with authority to do so) and where the data is likely to have been published for business purposes or with the expectation that this personal data may be processed by third parties for business purposes, including marketing.

Any personal data not processed directly relates to adult individuals engaged in business, specifically relating to that business activity. No “special category” personal data (for example, data relating to your health, race or religion) is processed.

All the data we process, directly or indirectly, is held in our secure CRM system, which is governed by strict data control and management policies.

3. Purposes of processing and legal bases

  • 3.1 In this Section 3, we have set out the purposes for which we may process personal data and the legal bases of the processing.
  • 3.2 Operations - We may process your personal data for the purposes of operating our website, the processing and fulfilment of orders, providing our services, supplying our goods, generating invoices, bills and other payment-related documentation, and credit control. The legal basis for this processing is our legitimate interests, namely the proper administration of our website, services and business.
  • 3.3 Publications - We may process account data, profile data and/or service data for the purposes of publishing such data on our website and elsewhere through our services in accordance with your express instructions. The legal basis for this processing is our legitimate interests, namely the publication of content in the ordinary course of our operations.
  • 3.4 Relationships and communications - We may process contact data, account data, customer relationship data, transaction data and/or communication data for the purposes of managing our relationships, communicating with you (excluding communicating for the purposes of direct marketing) by email, SMS, post, fax and/or telephone, providing support services and complaint handling. The legal basis for this processing is our legitimate interests, namely communications with our website visitors, service users, individual customers and customer personnel, the maintenance of our relationships, enabling the use of our services, and the proper administration of our website, services and business.
  • 3.6 Direct marketing - We may process contact data, account data, profile data, customer relationship data and/or transaction data for the purposes of creating, targeting and sending direct marketing communications by email, SMS, post and/or fax and making contact by telephone for marketing-related purposes. The legal basis for this processing is our legitimate interests, and, where applicable, the soft opt-in allowed by the Privacy and Electronic Communications Regulations (PECR) to promote our business and communicating marketing messages and offers to relevant prospects, our website visitors and service users.
  • 3.7 Research and analysis - We may process usage data, service data and/or transaction data for the purposes of researching and analysing the use of our website and services, as well as researching and analysing other interactions with our business. The legal basis for this processing is our legitimate interests, namely monitoring, supporting, improving and securing our website, services and business generally.
  • 3.8 Record keeping - We may process your personal data for the purposes of creating and maintaining our databases, back-up copies of our databases and our business records generally. The legal basis for this processing is our legitimate interests, namely ensuring that we have access to all the information we need to properly and efficiently run our business in accordance with this policy.
  • 3.9 Security - We may process your personal data for the purposes of security and the prevention of fraud and other criminal activity. The legal basis of this processing is our legitimate interests, namely the protection of our website, services and business, and the protection of others.
  • 3.10 Insurance and risk management - We may process your personal data where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks and/or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
  • 3.11 Legal claims - We may process your personal data where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
  • 3.12 Legal compliance and vital interests - We may also process your personal data where such processing is necessary for compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person.

4. Providing your personal data to others

  • 4.1 We may disclose information about you to any of our employees, officers, agents, suppliers, subcontractors, and customers insofar as reasonably necessary for the purposes as set out in this privacy policy.
  • 4.2 We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.
  • 4.3 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice.
  • 4.4 Your personal data held in our website database will be stored on the servers of our hosting services providers identified at https://hubspot.com.
  • 4.5 In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

In addition, we may disclose your personal information:

  • (a) to provide information for fraud prevention and reducing credit risk
  • (b) to the purchaser (or prospective purchaser) of any business or asset that we are (or are contemplating) selling
  • (c) The Government
  • (d) Police and law enforcement agencies: to assist with the investigation and prevention of crime
  • (e) to any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information

We will not provide your personal information to any third parties for direct marketing without your express consent.

5. International transfers of your personal data

  • 5.1 In this Section 5, we provide information about the circumstances in which your personal data may be transferred to a third country under UK and/or EU data protection law.
  • 5.2 We may transfer your personal data from the European Economic Area (EEA) to the UK and process that personal data in the UK for the purposes set out in this policy, and may permit our suppliers and subcontractors to do so, during any period with respect to which the UK is not treated as a third country under EU data protection law or benefits from an adequacy decision under EU data protection law; and we may transfer your personal data from the UK to the EEA and process that personal data in the EEA for the purposes set out in this policy, and may permit our suppliers and subcontractors to do so, during any period with respect to which EEA states are not treated as third countries under UK data protection law or benefit from adequacy regulations under UK data protection law.
  • The hosting facilities for our website are located in Germany. Transfers to each of these countries is permitted under both UK and EU data protection law, as each of the UK and the EU have determined that the other provides adequate protection for personal data.
  • 5.4 You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

6. Retaining and deleting personal data

  • 6.1 This Section 6 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
  • 6.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
  • 6.3 We will retain your personal data as follows:
  • (a) contact data will be retained for a minimum period of 10 years following the date of the most recent contact between you and us, and for a maximum period of 20 years following that date;
  • (b) account data will be retained for a minimum period of 10 years following the date of closure of the relevant account, and for a maximum period of 20 years following that date;
  • (c) profile data will be retained for a minimum period of 10 years following the date of deletion of the profile by you, and for a maximum period of 20 years following that date;
  • (d) customer relationship data will be retained for a minimum period of 10 years following the date of termination of the relevant customer relationship and for a maximum period of 20 years following that date;
  • (e) service data will be retained for a minimum period of 10 years following the date of termination of the relevant contract, and for a maximum period of 20 years following that date;
  • (f) transaction data will be retained for a minimum period of 10 years following the date of the transaction, and for a maximum period of 20 years following that date;
  • (g) communication data will be retained for a minimum period of 10 years following the date of the communication in question, and for a maximum period of 20 years following that date;
  • (h) usage data will be retained for 10 years following the date of collection;
  • 6.4 In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will keep your personal information for a reasonable period to maintain our records and satisfy our legal obligations.
  • 6.5 If you grant to us a licence to publish any of your personal data, we may continue to retain and publish that personal data after the end of the relevant retention period specified in this Section 6 in accordance with the applicable licence terms, subject to your data subject rights. If we cease to publish such personal data after the end of the relevant retention period specified in this Section 6, that personal data will be retained for a minimum period of 10 years and a maximum period of 20 years following the date that publication ceases.
  • 6.6 Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

7. Security of personal data

  • 7.1 We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.
  • 7.2 We will store your personal data on secure servers, personal computers and mobile devices, and in secure manual record-keeping systems.
  • 7.3 Data relating to your enquiries that is sent from your web browser to our web server, or from our web server to your web browser, will be protected using encryption technology.
  • 7.4 You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.

8. Your rights

  • 8.1 In this Section 8, we have listed the rights that you have under data protection law.
  • 8.2 Your principal rights under data protection law are:
  • (a) the right to access - you can ask for copies of your personal data;
  • (b) the right to rectification - you can ask us to rectify inaccurate personal data and to complete incomplete personal data;
  • (c) the right to erasure - you can ask us to erase your personal data;
  • (d) the right to restrict processing - you can ask us to restrict the processing of your personal data;
  • (e) the right to object to processing - you can object to the processing of your personal data;
  • (f) the right to data portability - you can ask that we transfer your personal data to another organisation or to you;
  • (g) the right to complain to a supervisory authority - you can complain about our processing of your personal data; and
  • (h) the right to withdraw consent - to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.

You may exercise any of your rights in relation to your personal data by written notice to us, using the contact details set out in the Our Details section.

Supply of such personal information will be subject to the submission of appropriate evidence of your identity. For the purpose of identification, we will usually accept a photocopy of your passport certified by a solicitor or bank, plus an original copy of a utility bill showing your current address.

We may withhold such personal information to the extent permitted by law.

You may instruct us not to process your personal information for marketing purposes by sending an email to us (see Our Details section). Our marketing communications will always provide a mechanism to opt out of the use of your personal information for marketing purposes.

Whilst we have summarised your legal rights under data protection law, some of these rights are complex. More information about your legal rights can be found on the Information Commissioner’s website at https://ico.org.uk/for-the-public/.

9. Third party websites

  • 9.1 Our website includes hyperlinks to, and details of, third party websites.
  • 9.2 In general we have no control over, and are not responsible for, the privacy policies and practices of third parties.

10. Updating information

  • 10.1 Please let us know if the personal information that we hold about you needs to be corrected or updated.

11. Acting as a data processor

  • 11.1 Insofar as we act as a data processor rather than a data controller, this policy shall not apply. Our legal obligations as a data processor are instead set out in the contract between us and the relevant data controller.

12. Amendments

  • 12.1 We may update this policy from time to time by publishing a new version on our website.
  • 12.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
  • 12.3 We may notify you of significant changes to this policy by email.

13. Our details

  • 13.1 This website is owned and operated by Stonesthro Ltd.
  • 13.2 We are registered in England and Wales under registration number 15738727, and our registered office is at Unit 4, City Limits, Danehill, Earley, Reading, England, RG6 4UP.
  • 13.3 Our principal place of business is at 11 Roman Way, Warfield, Bracknell, England, RG42 7UT.
  • 13.4 You can contact us:
  • (a) by post, to the postal address given above;
  • (b) using our website contact form;
  • (c) by telephone, on the contact number published on our website; or
  • (d) by email, using the email address published on our website.

14. Data protection contact

  • 14.1 Stonesthro Ltd is committed to following the General Data Protection Regulation (GDPR). If you have queries about our approach to the legislation or you would like to request a copy of the data we hold about you, then please contact us at info@stonesthro.co.uk.

If you are unhappy with how we are using your personal information, you can contact the UK Information Commissioner’s Office (ICO) or your local data protection regulator. However, we would encourage you to contact us to resolve your complaint in the first instance.