Copper Horse takes your privacy very seriously and we care about how your personal data is used. We respect and value the privacy of our customers and partners and we will only collect and use data in ways we have outlined in this policy and in a way that’s inline with your rights and our obligations under law. Our policy complies with UK law accordingly implemented, including that required by the EU General Data Protection Regulation (GDPR).
Information About Us:
Copper Horse Ltd is registered in England & Wales under company number 7504334.
We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.
Full name of Legal Entity: Copper Horse Limited.
Registered address: 59-60 Thames Street, Windsor, Berkshire, UK, SL4 1TX
Data Protection Officer: David Rogers
Email address: firstname.lastname@example.org
Telephone number: 0208 1337733
You have the right to make a complaint at any time to your respective supervisory authority. The Information Commissioner’s Office (ICO) is the UK supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Information we may collect and hold about you
We may collect and process the following personal data about you:
- Information you’ve provided to us, such as your name, email address, postal address and contact details. You may give us information about you by filling in forms on the Website or by corresponding with us by phone, email or otherwise. This includes information you provide when you:
- ask us to contact you in relation to services we provide;
- subscribe to our mailing lists;
- book training, a seminar or event run by us;
- order products or services from us;
- interact with us on social media platforms (such as LinkedIn or Twitter); or
- report a problem with our Website.
We may also collect information when you visit the Website, including but not limited to your IP address, location, time of access, the browser you use, your operating system and the pages you visit.
We only obtain information from third parties if this is permitted by law. We may also use legal public sources to obtain information about you.
How long do we retain your information
If we are providing services to you, we will retain your personal information for the duration of the services and for six years thereafter, unless otherwise agreed.
We will review and delete or destroy personal data on a regular basis. If we are unable, using reasonable endeavours, to delete or destroy personal data we will ensure that the personal data is encrypted or protected by security measures so that it is not readily available or accessible by us.
How we may use your information
In addition to using your information to fulfil our contract to provide you with requested products or services, we may also use your information in the following ways (provided that, where we are required to obtain your consent to use your information, you have provided such consent):
- to monitor and improve our products, services and the Website;
- to provide you with information about other goods and services we offer;
- to notify you about changes to our services;
- to administer the Website and for internal operations, including troubleshooting, data analysis, testing, research and statistical;
- to enable us to comply with any legal or regulatory requirements.
The basis on which we collect your information
We collect much of your information on the grounds of: (i) legitimate interests (for example, to send you direct marketing about products and services similar to those you have purchased from us or negotiated or enquired about, or to help us administer the Website); and (ii) fulfilment of a contract with you (for example, to provide you with products or services you have purchased from us).
If we require your personal data for fulfilment of a contract with you (for example, to provide services or products to you or to receive payment from you), we may be unable to fulfil the contract without your personal data.
Where we rely on legitimate interests, our legitimate interests are the promotion of the products and services offered by Copper Horse Ltd and the provision of information in respect of products and services you have already purchased from us or in which you have expressed an interest in purchasing.
If we are unable to rely on legitimate interests, fulfilment of a contract or any other ground set out in the General Data Protection Regulation 2016/679 (“GDPR”) to process your personal data, we will obtain consent from you to the processing. This will be the case if, for example, you download documentation from us and we would like to send you marketing communications about our products and services. If you give us your consent, you can withdraw it at any time by, by emailing email@example.com. Withdrawal of your consent won’t affect any processing we have carried out in respect of your personal data prior to you withdrawing consent.
How we protect your data and keep it secure
We are committed to doing all that we can to keep your data secure. We have set up systems and processes to prevent unauthorised access or disclosure of your data – for example, we protect your data using encryption.
There are a number of rights available to you under GDPR:
Access to your data
You have the right to ask us to confirm that we process your personal data, as well as to have access to and receive copies of your personal data. You can also ask us to provide a range of information, although most of that information corresponds to the information set out in this fair processing notice.
We will provide the information free of charge unless your request is manifestly unfounded or excessive or repetitive, in which case we are entitled to charge a reasonable fee. We may also charge you if you request more than one copy of the same information.
We will provide the information you request as soon as possible and in any event within one month of receiving your request. If we need more information to comply with your request, we’ll let you know.
Rectification of your data
If you believe personal data we hold about you is inaccurate or incomplete, you can ask us to rectify that information. We will comply with your request within one month of receiving it, unless we don’t feel it’s appropriate for us to do so in which case we’ll let you know why. We’ll also let you know if we need more time to comply with your request.
Right to be forgotten
In some circumstances, you have the right to ask us to delete personal data we hold about you. This right is available to you:
- where we no longer need your personal data for the purpose for which we collected it;
- where we have collected your personal data on the grounds of consent and you withdraw that consent;
- where you object to the processing and we don’t have any overriding legitimate interests to continue processing the data;
- where we have unlawfully processed your personal data (i.e. we have failed to comply with GDPR); and
- where the personal data has to be deleted to comply with a legal obligation.
There are certain scenarios in which we are entitled to refuse to comply with a request. If any of those apply, we’ll let you know.
Right to restrict processing
In some circumstances, you are entitled to ask us to suppress processing of your personal data. This means we will stop actively processing your personal data but we don’t have to delete it. This right is available to you:
- if you believe the personal data we hold isn’t accurate – we’ll cease processing it until we can verify its accuracy;
- if you have objected to us processing the data (see below) – we’ll cease processing it until we have determined whether our legitimate interests override your objection;
- if the processing is unlawful; or
- if we no longer need the data but you would like us to keep it because you need it to establish, exercise or defend a legal claim.
Where Copper Horse Ltd acts as a Data Controller, you have the right to ask us to provide your personal data in a structured, commonly used and machine-readable format so that you are able to transmit the personal data to another data controller. This right only applies:
- to personal data you provide to us;
- where processing is based on your consent or for performance of a contract (i.e. the right does not apply if we process your personal data on the grounds of legitimate interests); and
- where we carry out the processing by automated means.
We’ll respond to your request as soon as possible and in any event within one month from the date we receive it. If we need more time, we’ll let you know.
Right to object
You are entitled to object to us processing your personal data:
- if the processing is based on legitimate interests or performance of a task in the public interest or exercise of official authority;
- for direct marketing purposes (including profiling); and/or
- for the purposes of scientific or historical research and statistics.
In order to object, you must have grounds for doing so based on your particular situation. We will stop processing your data unless we can demonstrate that there are compelling legitimate grounds which override your interests, rights and freedoms or the processing is for the establishment, exercise or defence of legal claims.
If you would like to exercise any of your rights in respect of your personal data, please contact us at firstname.lastname@example.org or write to us at Copper Horse Limited, 59-60 Thames Street, Windsor, Berkshire, UK, SL4 1TX
Job application and employment
If you send us information in connection with a job application, we may keep it for up to three years in case we decide to contact you at a later date.
If we employ you, we collect information about you and your work from time to time throughout the period of your employment. This information will be used only for purposes directly relevant to your employment. After your employment has ended, we will keep your file for six years before destroying or deleting it.
Cookies are small text files that are placed on your computer’s hard drive by your web browser when you visit any website. They allow information gathered on one web page to be stored until it is needed for use on another, allowing a website to provide you with a personalised experience and the website owner with statistics about how you use the website so that it can be improved.
Some cookies may last for a defined period of time, such as one day or until you close your browser. Others last indefinitely.
Your web browser should allow you to delete any you choose. It also should allow you to prevent or limit their use.
Personal identifiers from your browsing activity
Requests by your web browser to our servers for web pages and other content on our website are recorded.
We record information such as your geographical location, your Internet service provider and your IP address. We also record information about the software you are using to browse our website, such as the type of computer or device and the screen resolution.
We use this information in aggregate to assess the popularity of the webpages on our website and how we perform in providing content to you.
If combined with other information we know about you from previous visits, the data possibly could be used to identify you personally, even if you are not signed in to our website.
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
Compliance with the law
However, ultimately it is your choice as to whether you wish to use our website.
We may update this privacy notice from time to time as necessary. The terms that apply to you are those posted here on our website on the day you use our website. We advise you to print a copy for your records.