| Privacy PolicyIntroduction to this Website Privacy Policy This website is owned and operated by Coffeeing The World UK Ltd At CTW, we recognize the importance of privacy to you and are firmly committed to protecting your privacy when you visit the Site and provide information to us. As a result, we have instituted this website privacy policy ("Privacy Policy"). CTW is providing this Privacy Policy to explain how we collect, use, disclose and protect the Personal Data you submit to us when accessing and using the Site. CTW is the controller within the meaning of applicable data protection laws. In general, you may visit the Site and view its content while remaining anonymous by not providing any Personal Data. If you do not agree with this Privacy Policy, please do not provide us any information and do not use the Site. As used in this Privacy Policy, "we," "our" and "us" means CTW and its affiliates. The meaning of Personal Data “Personal Data” is defined in data protection laws applicable in your country. It includes any information relating to an identified or identifiable natural person. This means any individual who can be identified directly or indirectly by reference to an identifier such as name, identification number, location data, online identifiers (for example, IP addresses – if they can be used to identify you) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. Put simply, this includes data which either by itself or with other data held by us or available to us, can be used to identify you. Important notice about international transfers Due to the global nature of our business, your Personal Data will be stored and transferred to parties located in other countries, including outside the European Economic Area. These other countries will either have different data protection laws than your country of residence or they will not have data protection laws. They may not be deemed by the European Commission as providing adequate protection for Personal Data. In particular, we store your Personal Data on servers in the United States of America. The US are not deemed by the European Commission to have adequate protections for Personal Data. Steps will be taken to put in place safeguards (including around security) to protect your Personal Data when it is in these other countries. This may include the use of European Model Clause contracts, where required under applicable law. You can find out what these are online at the following address: http://ec.europa.eu/justice/data-protection/international-transfers/transfer/index_en.htm. If you have any questions or wish to be provided with a copy please contact us (details below). Please note commercially sensitive information may be removed/blanked out from copies supplied to you. The categories of Personal Data we may collect, the purpose and the lawful basis Personal Data collected from you include the following:
In summary, we need certain categories of Personal Data because that is necessary in order to administer any contract with you (where relevant). Certain other Personal Data is processed for our legitimate interests in cases where this does not result in prejudice to you. Keeping you informed and direct marketing With your consent, where relevant we will keep your name, address and contact details (including telephone numbers and email addresses) in our databases and may from time to time use that information to make you aware of our own related products and services as well as updates on developments in our industry sector generally which may be of interest to you. We may contact you in writing, by telephone, fax or email for this. If at any time you decide that you do not want your contact details used for these purposes, please tell us (see “Contact us” below). Data anonymization and use of aggregated information We may convert your Personal Data into statistical or aggregated data in such a way as to ensure that you are not identified or identifiable from that data. We may use this aggregated data to conduct market research and analysis, including producing statistical research and reports. For example, we may produce reports on which of our product offerings attract the fewest or the highest number of enquiries from brokers and intermediaries and other persons visiting our Site. In particular, we use technology to collect anonymous information about the use of this Site. For example:
We use this anonymous data to improve the content and functionality of this Site and consider areas and subjects which are attracting interest so that we can focus our e-mail updates (for those that wish to receive such communications). This allows us to better understand our Site visitors’ interest areas generally and therefore to improve our Site and products and services we offer. Cookies and analytic tools We may from time to time use cookies on our Site. Cookies are small text files that your web browser leaves on your hard drive to recognize you as a repeat user of our Site, track your use of our Site and target advertising. This allows for personalization of certain aspects of your visit to our Site. Information gathered from cookies in this way is only used on an aggregate basis. Unless a visitor specifically provides their identity to us, e.g., by registering at our Site, providing information through an online form or sending us correspondence from the Site, we will not know the identification of individual visitors. We may use cookies to store preferences; record session information; develop information about Site visitors' preferences and interests; record past activity at a website in order to provide better service when you return to our Site; or customize web page content based on information you voluntarily provide. You can disable cookies using your Internet browser settings. Please consult your browser's help function for information on how to disable cookies. Note that if you disable cookies, certain features of our Site may not function properly. CTW uses social plug-ins (also known as “buttons”) of social networks such as Facebook, Google+, and Twitter. When you visit CTW's websites the buttons are not activated, and they will remain inactive unless you click on one of the buttons. After you click on a button, it will remain active until you deactivate them or you delete your cookies. If you are logged on to a social network, the network can assign your visit to the website to your user account. If you are a member of a social network, you must log out from the social network before activating the buttons on our website, if you do not want the social network to assign data obtained during your visit to our website with your social membership data. CTW uses Google Analytics on basis of Art. 6 (1) (f) DSGVO, which a web analysis service of Google Inc. (Google) on our Site. Google Analytics uses cookies, i.e. text files stored on your computer to enable analysis of website usage by you. Information generated by the cookie about your use of this website is usually transmitted to a Google server in the United States and stored there. In case of activated IP anonymization on this website, however, your IP address is previously truncated by Google within member states of the European Union or in other states which are party to the agreement on the European Economic Area. Only in exceptional cases is a full IP address transmitted to a Google server in the United States and truncated there. On behalf this website's owner, Google will use this information to evaluate your use of the website, compile reports about website activities, and provide the website's operator with further services related to website and Internet usage. The IP address sent from your browser as part of Google Analytics is not merged with other data by Google. You can prevent storage of cookies by appropriately setting your browser software; in this case, however, please note that you might not be able to fully use all functions offered by this website. In addition, you can prevent data generated by the cookie and relating to your use of the website (including your IP address) from being collected and processed by Google, by downloading and installing a browser plug-in from the following link: http://tools.google.com/dlpage/gaoptout?hl=en CTW uses Google Analytics on the Websites with the extension "anonymizeIP()", IP addresses being truncated before further processing in order to rule out direct associations to persons. Disclosure of your Personal Data to third parties We may disclose your Personal Data to third parties, including but not limited to as follows:
to regulatory authorities, courts and governmental agencies to comply with legal orders, legal or regulatory requirements and government requests; and Security of Personal Data We endeavour to use appropriate technical and physical security measures to protect Personal Data which is transmitted, stored or otherwise processed by us, from an unlawful destruction, loss, alteration, unauthorised disclosure of, or access, in connection with our Site. These measures include computer safeguards and secured files and facilities. Our service providers are also selected carefully and required to use appropriate protective measures. In certain areas, CTW uses industry-standard SSL-encryption to protect data transmissions. Most current browsers support the level of security needed to use these areas. In particular, we endeavour to implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk, including as appropriate: (a) pseudonymisation (such as where data is separated from direct identifiers so that linkage to an identity is not possible without additional information that is held separately) and encryption, (b) ensuring the ongoing confidentiality, integrity, availability and resilience of systems and services used to process your Personal Data, (c) ensuring the ability to restore the availability and access to Personal Data in a timely manner in the event of a physical or technical incident; and (d) ensuring a process for regularly testing, assessing and evaluating the effectiveness of technical and organisational security measures. Retention period or criteria used to determine the retention period We keep your Personal Data for as long as it is necessary to do so to fulfil the purposes for which it was collected as described above. and to the extent we have entered into any contract with you; (iii) Retention in accordance with legal and regulatory requirements. We will consider whether we need to retain it after the period described in (ii) because of a legal or regulatory requirement. If your application for employment is successful and you commence employment with CTW, your Personal Data will be transferred to your personnel file and will be processed for employment purposes. If your application for employment is not successful, we will keep your Personal Data for a period of 6 months upon notification that your application was not successful. If you would like further information about our data retention practices, please contact us (see “Contact Us” below). Your rights under data privacy laws You have various rights under data privacy laws in your country. These may include (as relevant): the right to request access to the Personal Data we hold about you; the right to rectification including to require us to correct inaccurate Personal Data; the right to request restriction of processing concerning you or to object to processing of your Personal Data, the right to request the erasure of your Personal Data where it is no longer necessary for us to retain it; the right to data portability including to obtain Personal Data in a commonly used machine readable format in certain circumstances such as where our processing of it is based on a consent; the right object to automated decision making including profiling (if any) that has a legal or significant effect on you as an individual; and the right to withdraw your consent to any processing for which you have previously given that consent. You can also lodge a complaint with a supervisory authority. Please see “Contact Us” if you wish to exercise any of these rights (as relevant). Links to Other Websites This Site may contain hyperlinks to websites that are not operated by us. These hyperlinks are provided for your reference and convenience only and do not imply any endorsement of the activities of these third-party websites or any association with their operators. We do not control these websites and are not responsible for their data or privacy practices. We urge you to review any privacy policy posted on any site you visit before using the site or providing any Personal Data. Updated and changes to this Privacy Policy We may decide to change this Privacy Policy. If the change is fundamental or may significantly affect you, we will provide you with the updated Privacy Policy in advance of the change actually taking effect. We encourage you to review the content of this Privacy Policy regularly. Contact Details If you wish to exercise your data protection rights against us please e-mail: salesuki@ctwgroup.com Be sure to include your email address and telephone number with your correspondence. Alternatively, write to: Attn: Darren Hutchinson Coffeeing The World UK Ltd 1 Iceni Court, Ickneild Way Letchworth Garden City, Hertfordshire SG6 1TN
Phone: +44 1462 412 353 Last updated: 22/05/2018 |
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