Data Protection & Privacy Policy

Introduction

At CPW Computing, we are committed to protecting the privacy of our clients. Please read this policy which, together with our terms and conditions, explains how we collect, manage, use and protect your personal data.

Our details
CPW Computing is a limited company
Company number: 4360368
Company Address: Suite 14 Norfolk House, Williamsport Way, Lion Barn Industrial Estate, Needham Market, Suffolk, IP6 8RW

Contacting us
If you would like to make an enquiry about data protection, update the data we hold about you, request or opt out of receiving marketing communications from us or change the way we process your data, you can let us know in the following ways:

Email: dpo@cpwc.co.uk
Post: Data Protection, CPW Computing Limited, Suite 14 Norfolk House, Williamsport Way, Needham Market, Suffolk, IP6 8RW
Phone: 01449 723650

If you would like to make a request to access the data we hold about you (see ‘Your rights’ section at the end of this document).

To raise a concern about how your personal data has been used; please write to us at:
Post: Data Protection, CPW Computing Limited, Suite 14 Norfolk House, Williamsport Way, Needham Market, Suffolk, IP6 8RW
Email: dpo@cpwc.co.uk

Definitions

Data -  The Data Protection Act 2018 regulates the use of “personal data”.  Data is defined under the act as information which –

(a) is being processed by means of equipment operating automatically in response to instructions given for that purpose,
(b) is recorded with the intention that it should be processed by means of such equipment,
(c) is recorded as part of a relevant filing system or with the intention that it should form part of a relevant filing system,
(d) does not fall within paragraph (a), (b) or (c) but forms part of an accessible record as defined by section 68, or
(e) is recorded information held by a public authority and does not fall within any of paragraphs (a) to (d).

Personal data -  Personal data means data which relate to a living individual who can be identified –

(a) from those data, or
(b) from those data and other information which is in the possession of, or is likely to come into the possession of, the data controller,

and includes any expression of opinion about the individual and any indication of the intentions of the data controller or any other person in respect of the individual.

It does not include anonymised data.

What data we collect about you

Personal data is collected directly from you when you interact with CPW Computing, for example making a request of quotation, purchasing goods or service, sending or receiving an email, making a support request, visiting our websites, applying for a role with us, participating in an event or when signing up to a newsletter. Data may be collected in person, over the phone, via email, through our websites, social media or from something you’ve posted to us.

The data we hold will typically include some, or all of, your name, postal and email addresses, your phone number and may include data like your bank details if you are purchasing from us. We may also receive data about you from other sources (including public sources). This is explained in the ‘How we might use your data’ section below.

How we might use your data if you contact us

For administration purposes

Processing your purchase of Goods and Services
When you make a payment to CPW Computing, we will use your payment and contact details, payment amount, date and time of payment; to process that payment and take any follow-up administrative action needed (for example, sending an invoice or statement).

Responding to enquiries
If you contact us with a question, comment, compliment or complaint then we will keep a record of this correspondence and any associated documents so that we have the data available in the event of a follow-up, dispute or investigation.

Notifying you of changes to policies
If we make significant changes to our policies which may affect you, we will use your contact details to inform you of the changes.

In performing our contractual obligations
Where it is necessary under legitimate interest to collect and store personal data. This may include all or some of the following:

Technical Data may include your login data, internet protocol addresses, browser type and version, browser plug-in types and versions, time zone setting and location

Profile Data may include your username and password

Usage Data may include data about how you use our website, products and services.

For technical reasons

Analysing how emails are opened and read – we may track emails which we have sent to you to see what environment the email has been opened in (mobile or desktop), which messages have the highest response rates and whether there are messages that resonate with particular customer groups. We do this by logging whether emails we send have been opened, deleted and interacted with (for example, by clicking on links within the emails). Although we only use this data to look at general patterns, it is still personal data because it is linked to your email address.

Segmentation – We analyse data such as postcodes of customer. This helps us to tailor appropriate communications to you, as well as improve your experience as a CPW Computing customer.

To enforce and comply with the law

We are responsible for ensuring that our activities comply with the law. Therefore, we may need to share or use your personal data if we are required to do so by law (for example; in response to a warrant or court order) and we may use data from other sources for the purposes of fraud prevention, for example to comply with money laundering regulations, or to protect people’s rights, property or safety.

How we might use your data if you are applying for a role within CPW Computing


Your CV, covering letter and application form for any position with CPW Computing will be used during the recruitment process to short-list suitable candidates who will be invited to proceed to the interview stage, and to select the final candidate that the role will be offered to.

We sometimes use third-party job application platforms to publish and receive applications for roles at CPW Computing. When you apply through these portals the organisation’s privacy data will be available to you. We only work alongside other organisations in this way if we are satisfied that they will keep your data safely and use it only in the same legal ways that we would.

During the recruitment process, we will perform some checks on your identity, your right to work in the UK, your eligibility to work with vulnerable people and your past employment references.

If your application is successful, this data will then form part of your personnel file.

We delete the personal data of unsuccessful applications six months after the application process ends in case there are follow-up queries about the process, unless a candidate requests that we keep their details for longer.

How we might use your data If you have visited our websites (Cookies)

Our sites use cookies – small text files that are placed on your machine to help the sites provide a better user experience. Cookies are used, in general, to retain user preferences and provide anonymised tracking data to third party applications like Google Analytics. As a rule, cookies will make your browsing experience better. However, you may prefer to disable cookies on this site and on others. The most effective way to do this is to disable cookies in your browser. We suggest consulting the Help section of your browser.  

How to control cookies

You can control and/or delete cookies as you wish – for details, see aboutcookies.org. You can delete all cookies that are already on your computer and you can set most browsers to prevent them from being placed. If you do this, however, you may have to manually adjust some preferences every time you visit a site and some services and functionalities may not work. which offers guidance for all modern browsers.

How is the information used? With whom do we share the information?

We do not rent, sell or share Users’ information with third parties, except as described in this Privacy Policy.

We may use the information for the following:
  • [add types of detailed uses, such as:]
  • Communicating with you – sending you notices regarding our services, providing you with technical information and responding to any customer service issue you may have;
  • To communicate with you and to keep you informed about our latest updates and services;
  • To serve you advertisements when you use our Site (see more under "Advertisements"); 
  • To market our websites and products (see more under "Marketing"); 
  • For statistical and analytical purposes, intended to improve the Site.

In addition to the different uses listed above, we may transfer or disclose Personal Information to our subsidiaries, affiliated companies and subcontractors.

In addition to the purposes listed in this Privacy Policy, we may share Personal Information with our trusted third-party providers, who may be located in different jurisdictions across the world, for any of the following purposes: 
  • Hosting and operating our Site;
  • [Add and amend relevant types of third parties, such as:]
  • Providing you with our services, including providing a personalised display of our Site;
  • Storing and processing such information on our behalf; 
  • Serving you with advertisements and to assist us in evaluating the success of our advertising campaigns and help us retarget any of our users;
  • Providing you with marketing offers and promotional materials related to our Site and services; 
  • Performing research, technical diagnostics or analytics;
We may also disclose information if we have good reason to believe that disclosure of such information is helpful or reasonably necessary to: (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce our policies (including our Agreement), including investigations of potential violations thereof; (iii) investigate, detect, prevent or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues; (iv) to establish or exercise our rights to defend against legal claims; (v) prevent harm to the rights, property or safety of us, our users, yourself or any third party; or (vi) for the purpose of collaborating with law enforcement agencies and/or in case we find it necessary in order to enforce intellectual property or other legal rights.

Cookies

We and our trusted partners use cookies and other technologies in our related services, including when you visit our Site or access our services. 

A "cookie" is a small piece of information that a website assigns to your device while you are viewing a website. Cookies are very helpful and can be used for various different purposes. These purposes include allowing you to navigate between pages efficiently, enabling automatic activation of certain features, remembering your preferences and making the interaction between you and our Services quicker and easier. Cookies are also used to help make sure that the advertisements you see are relevant to you and your interests and to compile statistical data on your use of our Services. 

The Site uses the following types of cookies:

a. 'session cookies' , which are stored only temporarily during a browsing session in order to allow normal use of the system and are deleted from your device when the browser is closed; 

b. 'persistent cookies', which are read only by the Site, saved on your computer for a fixed period and are not deleted when the browser is closed. Such cookies are used where we need to know who you are for repeat visits, for example to allow us to store your preferences for the next sign-in; 

c. 'third-party cookies' , which are set by other online services who run content on the page you are viewing, for example by third-party analytics companies who monitor and analyse our web access.

Cookies do not contain any information that personally identifies you, but Personal Information that we store about you may be linked, by us, to the information stored in and obtained from cookies. You may remove the cookies by following the instructions of your device preferences; however, if you choose to disable cookies, some features of our Site may not operate properly and your online experience may be limited.

We use a tool which is based on the Snowplow Analytics technology to collect information about your use of the Site. The tool collects information such as how often users access the Site, which pages they visit when they do so, etc. The tool does not collect any Personal Information and is only used by our Site hosting and operating service provider to improve the Site and services.

Use of script libraries (Google Web Fonts)

In order to present our contents correctly and make them graphically appealing across all browsers, we use script libraries and font libraries such as Google Web Fonts (https://www.google.com/webfonts) on this website. Google Web Fonts are transferred to your browser's cache to avoid multiple loading. If your browser does not support Google Web Fonts or does not allow access, content will be displayed in a default font. 
  • Calling script libraries or font libraries automatically triggers a connection to the library operator. In theory, it is possible – but currently also unclear whether and, if so, for what purposes – that operators of corresponding libraries collect data.

  • The privacy policy of the library operator Google can be found here: https://www.google.com/policies/privacy.

Third-party collection of information

Our policy only addresses the use and disclosure of information we collect from you. To the extent you disclose your information to other parties or sites throughout the internet, different rules may apply to their use or disclosure of the information you disclose to them. Accordingly, we encourage you to read the terms and conditions and privacy policy of each third party that you choose to disclose information to. 

This Privacy Policy does not apply to the practices of companies that we do not own or control, nor to individuals whom we do not employ or manage, including any of the third parties which we may disclose information to as set out in this Privacy Policy. 

How do we safeguard your information?

We take great care in implementing and maintaining the security of the Site and your information. [explain about your security practices, such as: we employ industry standard procedures and policies to ensure the safety of the information we collect and retain, and prevent unauthorised use of any such information, and we require any third party to comply with similar security requirements, in accordance with this Privacy Policy]. Although we take reasonable steps to safeguard information, we cannot be responsible for the acts of those who gain unauthorised access or abuse our Site, and we make no warranty, express, implied or otherwise, that we will prevent such access.

Transfer of data outside the EEA 

Please note that some data recipients may be located outside the EEA. In such cases we will transfer your data only to such countries as approved by the European Commission as providing adequate level of data protection, or enter into legal agreements ensuring an adequate level of data protection.

Advertisements

 We may use a third-party advertising technology to serve advertisements when you access the Site. This technology uses your information with regards to your use of the Services to serve advertisements to you (e.g., by placing third-party cookies on your web browser). 

[Add information regarding opt-out options from personalised advertisements, such as:] You may opt out of many third-party ad networks, including those operated by members of the Network Advertising Initiative ("NAI") and the Digital Advertising Alliance ("DAA"). For more information about this practice by NAI and DAA members, and your choices regarding having this information used by these companies, including how to opt-out of third-party ad networks operated by NAI and DAA members, please visit their respective websites: http://optout.networkadvertising.org/#!/ and http://optout.aboutads.info/#!/.

Marketing

We may use your Personal Information such as your name, email address, telephone number, etc., ourselves or by using our third-party subcontractors, for the purpose of providing you with promotional materials concerning our services which we believe may interest you.  

To respect your right to privacy, within such marketing materials we provide you with the means to opt out of receiving further marketing offers from us. If you unsubscribe, we will remove your email address or telephone number from our marketing distribution lists. 

Please note that even if you have unsubscribed from receiving marketing emails from us, we may send you other types of important email communications without offering you the opportunity to opt out of receiving them. These may include customer service announcements or administrative notices.

Corporate transaction

We may share information in the event of a corporate transaction (e.g. sale of a substantial part of our business, merger, consolidation or asset sale). In the event of the above, the transferee or acquiring company will assume the rights and obligations as described in this Privacy Policy.

Minors

We understand the importance of protecting children’s privacy, especially in an online environment. The Site is not designed for or directed at children. Under no circumstances shall we allow the use of our services by minors without prior consent or authorisation by a parent or legal guardian. We do not knowingly collect Personal Information from minors. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, he or she should contact us at [add applicable email address].

Updates or amendments to this Privacy Policy

We reserve the right to periodically amend or revise the Privacy Policy; material changes will be effective immediately upon the display of the revised Privacy policy. The last revision will be reflected in the "Last modified" section. Your continued use of the Platform, following the notification of such amendments on our website, constitutes your acknowledgment and consent of such amendments to the Privacy Policy and your agreement to be bound by the terms of such amendments.

How to contact us

If you have any general questions about the Site or the information we collect about you and how we use it, you can contact us at [add applicable email address].

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