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TRUE TRADERS LTD PRIVACY AND COOKIE POLICY

PRIVACY POLICY


1. INTRODUCTION
True Traders Ltd., The True Centre, 31 Caister Road, Great Yarmouth, NR30 4DA, UK, Company number 6304793, (referred to as “True Traders”, "we", “us” or “our”) is committed to protecting and respecting your privacy as a Data Subject under EU and UK data protection laws.

This Privacy Policy (together with our Terms and Conditions) applies to Data Subjects using our websites under the domain names www.truetraders.co.uk, www.premierbarriers.co.uk, www.premiernetting.co.uk, www.christmastreenetting.co.uk and www.christmaschristmas.co.uk (the “Websites”) and also any telephone, face to face, email orders or orders agreed by other means. It explains how we comply with the European Union data protection requirements and sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read this Privacy Policy carefully to understand our practices regarding your personal data and how we will treat it.

For your protection we are registered under the Data Protection Act 1998 (the “Act”) and have made all appropriate notifications to the Information Commissioner. For the purpose of the Act, the data controller is True Traders Ltd of The True Centre, 31 Caister Road, Great Yarmouth, NR30 4DA.

2. LEGAL BASIS WE REPLY ON
The law on data protection sets out a number of different reasons for which a company may collect and process your personal data, including:

• Consent, eg:
In specific situations, we may collect and process your data with your consent. For example, when you tick a box to receive email newsletters.
When collecting your personal data, we’ll always make clear to you which data is necessary in connection with a particular service.

• Contractual obligations, eg:
In certain circumstances, we may need your personal data to comply with our contractual obligations.
For example, if you order an item from us for home delivery, we’ll collect your address details to deliver your purchase, and pass them to our courier.

• Legal compliance, eg:
If the law requires us to, we may need to collect and process your data.
For example, we may pass on details of people involved in fraud or other criminal activity affecting True Traders to law enforcement.

• Legitimate interest, eg:
In specific situations, we may require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests.
For example, we may combine the shopping history of many customers to identify trends and ensure we can keep up with demand, or develop new products/services.
If you visit our premises we may record you on our CCTV systems.
We may use contact information for non Data Subjects for direct marketing purposes.

3. INFORMATION WE MAY COLLECT FROM YOU
We may collect and process the following data about you:

• Information that you provide when you contact us directly or you choose to register or fill in forms on the Website (including, without limitation, information provided when requesting further information, products or services, completing a survey for our research purposes or when you report a problem with the Website). This information may include personal information (including name and contact details) and information regarding your personal or professional interests, experiences with our products and services and contact preferences;
• If you order products or services, we may keep details of your order and any resultant transactions;
• If you contact us, we may keep a record of that correspondence and any information contained therein; and
• Details of your visits to our Websites (including, without limitation, traffic data, location data, weblogs and other communication data) and the resources that you access.
• Details of your participation in our Social Media pages.
• If you visit our premises we may record you on our CCTV systems.

4. HOW LONG DO WE KEEP YOUR DATA
We will normally keep your data for 6 years. This includes information we are legally required to keep. Customer account information will remain with us until 6 years after the account was last used.

At the end of that period, your data will either be deleted completely or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning.

5. IP ADDRESSES AND COOKIES
We may collect information about your computer, including where available your IP address, operating system and browser type for system administration. This is statistical data about our users' browsing actions and patterns, and does not identify any individual.

For the same reason, we may obtain information about your general internet usage by using a cookie file which is stored on the hard drive of your computer. Cookies contain information that is transferred to your computer's hard drive. They help us to improve the Websites and to deliver a better and more personalised service. They enable us:

• to estimate our audience size and usage pattern;
• to store information about web traffic and your preferences and so allow us to customise the Websites according to your individual interests;
• to speed up your searches;
• to recognise you when you return to our site.

A cookie does not allow us access to your computer or any information about you, other than the data you choose to share with us.

You may refuse to accept cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of the Websites. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you log on to the Websites.

See our Cookie Policy for more information.

6. SECURITY
All information you provide to us is stored on secure servers. The data that we collect from you may be transferred to, stored at or processed in a destination outside the European Economic Area ("EEA") in order to, among other things, fulfil your orders, process your payment details and provide support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

Please be aware that the transmission of information via the internet is not completely secure. We cannot therefore guarantee the security of any data you transmit to the Websites and any transmission is at your own risk. We are committed to ensuring that, once we have received your data, any personal data we hold about you is secure. To prevent unauthorised access or disclosure of your personal data we have ensured that strict security measures and procedures are in place.

Where you have chosen a password which enables you to access certain parts of the Websites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone and to sign off when you finish using a shared computer. We do not have access to your chosen password.

7. PAYMENT SECURITY
We do not record and keep payment card details.

All information you give to make a payment on our Websites are directly entered into the Payment Provider’s website embedded in our Website. Or by clicking a link you will go directly to the payment provider’s website. At no time does your online payment information pass through True Traders.

For face to face payments you enter your card details directly into the card machine connected directly to the payment providers systems via the internet. At no time does this payment information pass through True Traders.

For telephone payments your payment information is taken by our staff and entered directly into the payment provider’s website. It is against our company rules for any member of staff to write down card details given during a telephone card payment transaction. We do not keep any card information.

If you give your bank permission to send us a payment by BACS they will do so but we will not be in possession of your bank account details.

8. USES MADE OF YOUR INFORMATION
We may use information held about you in the following ways:

• to ensure that content from the Websites is presented in the most effective manner for you and for your computer;
• to provide you with information, products or services that you request from us;
• to contact you by post, telephone or e-mail to respond to your queries or requests;
• to understand your needs and provide you with a better service;
• to handle orders, deliver products and services, process payments, communicate with you about orders and generally to maintain your account with us;
• to carry out our obligations arising from any contracts entered into between you and us; and/or
• to allow you to participate in interactive features of our service, when you choose to do so.

If you do not want us to use your data in this way, please follow the opt-out or unsubscribe instructions located on our communications to you or log in to your account online and change the settings or delete your account, or please write to us at the address set out in paragraph 15.

9. DISCLOSURE OF YOUR INFORMATION
We may disclose your personal information to any member of our group of companies or businesses (“Group”)

We may disclose your personal information to third parties if we sell or buy any business or assets or if True Traders or another member of the Group or part of the business is acquired by a third party.

We may disclose your information to third parties to allow us to fulfil our contract with you. This includes contact information to Couriers or Royal Mail or other organisation to enable delivery. Contact information and order requirements to sub-contractors to deliver goods direct to you from their warehouse (drop shipping). Please be aware that very occasionally your order may be delivered to a wrong address and your contact information and order details may be in the possession of a stranger.

We may also disclose your personal information if we are under a duty to disclose or share your personal data in order to comply with any legal obligation or in order to enforce or apply our Terms and Conditions and other agreements or to protect the rights, property or safety of True Traders, its customers or others. This may include exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

Our websites are hosted by UK2 (www.uk2.net) and Siteground (www.siteground.co.uk). If you enter your personal data (except payment details) into any of our online shops you will be passing your personal data to one of these companies as well as to us. You may also send us personal data through Amazon or EBay. All of these companies are GDPR compliant and are required by law to manage and store your data responsibly.

Our payment providers are PayPal and WorldPay. If you order and pay by telephone you will give us personal data relating to your card payment that we will give directly to one of our payment providers. Our staff are not allowed to write down or keep your card details. You must not send us your card details by email or in writing by any means.

Disclosure of your personal information may involve sending it outside of the EEA. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

10. YOUR RIGHTS
As a Data Subject you have the right to request:

• A copy of the personal data we hold about you, free of charge in most cases.
• The correction of your personal data when incorrect, out of date or incomplete. Online account customers can check and update their own information at any time.
• That we stop using your personal data for direct marketing (either through specific channels, or all channels).
• That we stop any consent-based processing of your personal data after you withdraw that consent.

Where we rely on our legitimate interest
In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.

Checking your identity
To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Notice. If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.

11. LINKS TO AND FROM OTHER WEBSITES
Links to third party websites on the Websites are provided solely for your convenience. If you use these links, you leave the Websites. We have not reviewed all of these third party websites and do not control and are not responsible for these websites or the protection and privacy of any information you may provide when visiting such websites. If you decide to access any of the third party websites linked to the Websites, you do so entirely at your own risk. Please note that these third party websites have their own privacy policies and you should check these privacy policies before you submit any personal data to these third party websites.

12. ACCESS TO INFORMATION
You have the right to access information held about you free of charge (in most cases). You may request details of personal information we hold about you by writing to the address set out in paragraph 15. If we deem your request to be excessive and unreasonable, or you make multiple requests which we believe to be unreasonable a fee may be charged to cover our costs in providing you with these details.

13. INCORRECT INFORMATION
If you believe that any information we are holding about you is incorrect or incomplete, please write to us to the address set out in paragraph 15. We will promptly correct any information found to be incorrect.

14. CHANGES TO OUR PRIVACY POLICY
Any changes we may make to this Privacy Policy will be posted on the Websites.

15. CONTACT
Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to Company Secretary, True Traders Ltd., The True Centre, 31 Caister Road, Great Yarmouth, NR30 4DA, UK.

For more information on your rights under the GDPR please contact the Information Commissioners Office at www.ico.org.uk



COOKIE POLICY


These websites: (www.truetraders.co.uk, www.premierbarriers.co.uk, www.premiernetting.co.uk, www.christmastreenetting.co.uk and www.christmaschristmas.co.uk ) (the “Websites”)are operated by True Traders Ltd (“True Traders”, “we”, “us”, “our”).

Like many other websites, these Websites uses cookies. This policy explains the way in which cookies are used on our Websites. Please ensure you have read and understood this policy before continuing to use our Websites. If you have any questions about our use of cookies, you can contact us at sales@truetraders.co.uk


1. WHAT ARE COOKIES?
1.1 Cookies are text files containing small amounts of information which are downloaded to your device when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognises that cookie. Cookies are useful because they allow a website to recognise a user’s device. You can find more information about cookies at: www.allaboutcookies.org and www.youronlinechoices.eu for a video about cookies visit policies.google.com/technologies/cookies

1.2 Cookies do lots of different jobs, like letting you navigate between pages efficiently, remembering your preferences, and generally improve the user experience. They can also help to ensure that adverts you see online are more relevant to you and your interests.

2. WHICH COOKIES ARE USED ON THESE WEBSITES?
2.1 The cookies used on these Websites have been categorised based on the categories found in the ICC UK Cookie guide.

2.2 A list of all the cookie types used on the Websites by category is set out below.

2.2.1 Targeting or advertising cookies

These cookies are used to deliver adverts more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. They are usually placed by advertising networks with the website operator’s permission. They remember that you have visited a website and this information is shared with other organisations such as advertisers. Quite often targeting or advertising cookies will be linked to site functionality provided by the other organisation.

2.2.2 Strictly necessary cookies
These cookies are essential in order to enable you to move around the website and use its features, such as accessing secure areas of the website. Without these cookies, services you have asked for cannot be provided.

2.2.3 Performance cookies
These cookies collect information about how visitors use a website, for instance which pages visitors go to most often, and if they get error messages from web pages. These cookies don’t collect information that identifies a particular visitor. All information these cookies collect is aggregated and therefore anonymous. It is only used to improve how a website works.

2.2.4 Functional cookies
These cookies allow the Websites to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customise. They may also be used to provide services you have asked for such as watching a video or commenting on a blog. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites.

2.2.5 Google Analytics
These cookies are used to collect information about how visitors use our Websites. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the Websites, where visitors have come to the Websites from and the pages they visited. For further details visit: www.google.com/analytics/learn/privacy.html

3. HOW CAN THE COOKIES BE REMOVED?
3.1 You may refuse to accept cookies by activating the setting on your internet browser which allows you to refuse the setting of cookies. For more information about cookies including how to set your internet browser to reject cookies please go to www.allaboutcookies.org

3.2 To opt out of Google Analytics visit https://tools.google.com/dlpage/gaoptout