Our Privacy Policy

Identity
Cloth Court Communications Limited (‘the Company’, 'we', 'us' or 'our') is a private company limited by shares, registered in England and Wales with company number 3007359 and registered office address at 20 Britton Street, London EC1M 5UA, United Kingdom.

This Privacy Notice (‘Notice’) aims to inform you about how we collect and process your personal details, whether provided by you directly or otherwise obtained by us.

Scope
This Notice applies to anybody who we do business with, whether a client or a supplier.

Acknowledgement
By submitting personal data to us, you acknowledge and accept the practices described in this Notice. We will endeavour to bring this Notice to your attention every time we ask for your personal information. We will seek your specific consent whenever this is required.

Processing Activities
The following table summarises the types of data processing activities we undertake in order to conduct our business:

Information we Process Purposes for Processing Legal Basis for Processing
Publicly available contact information, either obtained by or provided to us. To contact businesses to enquire whether they are interested in using our services or whether they are interested in acting as suppliers to us. Our legitimate interests, namely the pursuit of our own marketing and business development efforts.
Any information you provide to us, such as names, contact details, position. (1) To help deliver our services by:
  • corresponding with your business representative(s);
  • taking orders and payments;
  • addressing any requests you may have as a client or supplier representative.
(1) The performance or negotiation of the contractual relationship between us and our clients and/or suppliers.
Information you generate when you visit our website. To (1) deliver functionality on our website, to (2) analyse its performance, to (3) make sure it is safe and to (4) deliver relevant marketing from time to time from us and our partners. For further information, please see the cookies section below. (1) Our legitimate interests, namely monitoring and improving our website and services, and (2) your consent whenever required.

Data Sharing
The following table summarises the types of data sharing we undertake in order to conduct our business:

Third Party Purposes for Processing Legal Basis for Processing
Suppliers. If you are a client, we may disclose some of your personal details to our suppliers in order to provide our services. The performance or negotiation of the contractual relationship between us.
Clients. If you are a supplier, we may disclose some of your personal details to our existing and potential clients in order to provide our services. The performance or negotiation of the contractual relationship between us.
Professional advisors, such as accountants, solicitors, etc.
It may become necessary to obtain professional advice and disclose your details. This would be done only when necessary limited to what is necessary. Our legitimate interests, namely the proper administration of our business, or fulfilling our legal obligations or in relation to enforcing or defending legal claims.
Regulatory and law enforcement authorities. We may be required or compelled to disclose your personal details when under an obligation to do so. Compliance with legal obligations.

International Transfers
All data that we process is physically stored in the United Kingdom. Any transfers of your personal data outside the European Economic Area (‘EEA’) will take place only subject to appropriate safeguards as provided in data protection law (unless a valid and appropriate exemption applies). These safeguards are intended to secure your rights as a data subject with respect to any relevant non-EEA domiciled entities. Where a safeguard is unavailable, we may transfer your personal data on the basis of your explicit consent.

Your Rights
We are committed to guaranteeing the statutory rights of private individuals. If you send us a request regarding your rights under data protection law we will respond within 30 calendar days of receipt and, where possible, address your request within such time. Where necessary, this period may be extended by up to a further 60 days.

The persons to whom this Notice applies to are under no statutory or contractual obligation to provide personal data to us. However, should you decide to submit personal data to us, you will have the following rights, as a data subject, under data protection law:

the right to be informed the right to access the right to rectification
the right to erasure the right to restrict processing the right to object to profiling
the right to data portability
the right to complain to the Information Commissioner's Office the right to withdraw consent.

The summary above provides an overview of data subject rights under data protection law and shall not create any rights or obligations additional to those contained in the Data Protection Act 2018.

We do not engage in profiling which is capable of producing legal or other significant effects for individuals.

Detailed information on the content and the means to exercise your rights is provided by the United Kingdom's Information Commissioner's Office, available here.

Retention Policy
We generally retain personal data for a period of seven years. We may retain personal data until you advise us to securely dispose of it, or until it becomes outdated, or it is no longer necessary for us to retain such data in view of the provision of our services. It is your duty to inform us of any material changes to your personal details in order to ensure it is accurate.

Security Measures
We have taken technical and organisational measures to ensure our information security standards are appropriate to the risks associated with the personal data processing we undertake. Our security objectives include guaranteeing the confidentiality, integrity and availability of personal data and the resilience of the systems that process it.

Our systems are protected by a business class Internet firewall device (DrayTek Vigor 2860ac) which runs the latest firmware (v3.8.9.1). We endeavour to keep our software and hardware updated with the latest security patches and upgrades

Changes
We reserve the right to amend this Notice from time to time. You will be informed of any material changes without delay.

We reserve the right, in the event that we buy or sell all or part of our business or assets, to disclose personal information held by us to the prospective seller or buyer of such business or assets.

Contact
In relation to any requests to exercise your rights, any queries about this Notice or any other data protection matters, please contact: Cathy Walker via cathy@clothcourt.com

Cookies
Like most modern websites, www.clothcourt.com is using ‘cookies’. This is a technology which stores and accesses information on the device that you use to access our website. This information generation and collection predominantly relates to technical specifications. However, in certain circumstances it is considered that information generated by cookies may be capable of identifying you. We use cookies to enhance the online experience of our website visitors and to better understand how the website is used. We use first party cookies served directly by us and we also use ‘Google Analytics’ served by Google Inc.

For details regarding Google Analytics’ privacy notice, which applies to their use of your information they obtain via the cookies on our website, please visit: https://support.google.com/analytics/answer/6004245?hl=en.

For blocking Google Analytics, please use the pop-up on the home page or adjust your browser settings.

For blocking any and all cookies, via, among others, browser settings, please visit: https://www.wikihow.com/Disable-Cookies.

For more information on cookie controls, please visit: http://www.aboutads.info/choices/ or http://www.youronlinechoices.com.

For more information on ‘Do Not Track’, please visit: https://allaboutdnt.com.

For more information on cookies, please visit: http://www.allaboutcookies.org.

Last updated: August 2018