1.Purpose of this Privacy Policy

This Privacy Policy aims to give you information on how Cabilla Cornwall collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter, purchase a product or service or take part in a competition.
It is important that you read this Privacy Policy together with any other Privacy Policy or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements the other notices and is not intended to override them.

2. The data we collect about you

• Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
  We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
  Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
• 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.
  Technical Data includes internet protocol (IP) address, 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 this website.
• Usage Data includes information about how you use our website, products and services via our third party Google Analytics https://policies.google.com/privacy?gl=GB&hl=en.
  Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties, your communications with us (for example chat/message room or via social media) or your communication preferences.

If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

3. How is your personal data collected?
We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
• Apply for our products or services;
  request marketing to be sent to you;
  enter a competition, promotion or survey; or
  give us some feedback
• Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using Cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our Cookies (as defined below).

4.  Cookies
Our website uses Cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our website. By continuing to browse our website, you are agreeing to our use of Cookies. A “Cookie” is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.We use traffic log Cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.Overall, Cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.
You can choose to accept or decline Cookies. Most web browsers automatically accept Cookies, but you can modify your browser setting to decline Cookies if you prefer. This may prevent you from taking full advantage of the website however.
We use the following Cookies:

• Essential Cookies – These are Cookies that are required for the operation of our website. They include, for example, Cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
  Analytical/Performance Cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
• Functionality Cookies – These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Targeting Cookies – These Cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it, more relevant to your interests. We may also share this information with third parties for this purpose.

5. How we use your personal data

•  Present our website and provide you with the information, services and support that you request from us.
• Meet our obligations and enforce our rights arising from any contracts with you, including for billing or collections, or comply with legal requirements.
• Fulfil the purposes for which you provided the data or that were described when it was collected.
• Notify you about changes to our website or services.
• Ensure that we present our website content in the most effective manner for you and for your computer.
• Administer our website and conduct internal operations, including for troubleshooting, data analysis, testing, research, statistical and survey purposes.
• Improve our website or services, marketing, or customer relationships and experiences.
• Protect our website, employees or operations.
• Make suggestions and recommendations to you and other users of our website about events and services that may interest you or them.

Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
Third-party marketing
We will get your express opt-in consent before we share your personal data with any company outside of Cabilla Cornwall for marketing purposes.
Opting Out
You can ask us or third parties to stop sending you marketing messages at any time by clicking the unsubscribe link that is contained within all marketing emails or alternatively request removal by email on hello@cabilla.co.uk and we can manually remove from all lists.
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, product/service experience or other transactions.

6. Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out above.

• Internal Third Parties. Other companies in our group acting as joint controllers or processors and that provide IT and system administration services and undertake reporting.
• External Third Parties. Including service providers acting as processors or hosts who provide IT and system administration services and service agents for support and delivery companies for the transportation of products.
• Professional advisers acting as processors or joint controllers including solicitors, barristers, bankers, auditors and insurers based in the United Kingdom or EEA who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
• Government Agencies for example for fraud or illegal activities.
• Third parties to whom we may choose to sell, transfer, or merge parts or all of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy.
• We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

7. International transfers
Some of our external third parties such as PayPal and Google are based outside the European Economic Area (EEA) and so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
  Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

8. Data Security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

9. Data retention
How long will you keep my personal data for?
The period for which we will keep your personal data will depend on the nature of our relationship with you. We will keep your personal data for as long necessary to perform the relevant services that you have requested from us. We will also keep data for as long as we are required to do so for legal or regulatory purposes.

10. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data as listed below:

• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it.
• Object to processing of your personal data where we are relying on a Legitimate Interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.
  Please email us on hello@cabillacornwall if you wish to exercise any of these rights.

Complaints
If you have any complaints about the way we use your personal data then in the first instance please contact hello@cabilla.co.uk who will endeavour to resolve the issue. If we cannot resolve any issue, you have the right to complain to the Information Commissioner.

Contact details
If you have any questions, comments or requests regarding any aspect of this Privacy Notice, please do not hesitate to contact us by email hello@cabilla.co.uk or post: Cabilla Cornwall, Bodmin Moor, Cornwall, PL30 4DW