CKB Ltd
How we use your information:
GDPR website privacy & cookies policy
JUNE 2018

BACKGROUND:

CKB Ltd ® and its group brands including Bar Amigos ® and Lanyards Tomorrow ® understand that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who visits Our Site and will only collect and use personal data in ways that are described here, and in a manner that is consistent with Our obligations and your rights under the law.

Please read this GDPR Website Privacy and Cookies Policy carefully and ensure that you understand it. If you do not accept and agree with this Policy, you must stop using Our Site immediately.

1. Definitions and Interpretation

In this Policy, the following terms shall have the following meanings:  

“Account”

means an account that may be set up to access and/ or use certain areas and features of Our Site. An Account may be useful for repeat purchasers as personal data including address details are stored, saving time at the checkout;

“Cookie”

means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in Part 13, below;

"Cookie Law"

means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended in 2004, 2011, 2015 and 2016;

"Our Site"

means any and all of the CKB Ltd ® group company brand websites including www.ckbltd.com, www.baramigos.co.uk,and www.lanyardstomorrow.co.uk;

“personal data”

means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site. This definition shall, where applicable, incorporate the definitions provided in the EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”); and

“We/Us/Our”

means CKB Ltd ®, a limited company registered in England under 07123102, whose registered address is St. Christopher's House, Ridge Road, Letchworth Garden City, Hertfordshire, SG6 1PT, England and whose main trading address is Unit 5, Business Centre East, Fifth Avenue, Letchworth Garden City, Hertfordshire, SG6 2TS.  Our other group brands including Bar Amigos ® and Lanyards Tomorrow ® also fall under the references to We, Us and Our used in this policy.

2. Information About Us

2.1 Our Site, www.ckbltd.com, is owned and operated by CKB Ltd ®, a limited company registered in England under 07123102, whose registered address is St. Christopher's House, Ridge Road, Letchworth Garden City, Hertfordshire, SG6 1PT, England and whose main trading address is Unit 5, Business Centre East, Fifth Avenue, Letchworth Garden City, Hertfordshire, SG6 2TS. We also operate under our group company brands of Bar Amigos ® on www.baramigos.co.uk and Lanyards Tomorrow ® on www.lanyardstomorrow.co.uk

2.2 Our VAT number is 991324508.

2.3 Our Data Protection Officer is the position holder of Company Secretary, and can be contacted at Unit 5, Business Centre East, Fifth Avenue, Letchworth Garden City, Hertfordshire, SG6 2TS.

3. What Does This Policy Cover?

This Policy applies only to your use of Our Site. Our Site may contain links to other websites. Please note that We have no control over how your data is collected, stored, or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to them.

4. Your Rights

4.1 As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:

4.1.1 The right to be informed about Our collection and use of personal data;

4.1.2 The right of access to the personal data We hold about you (see Part 12);

4.1.3 The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us using the details in Part 14);

4.1.4 The right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you (We only hold your personal data for a limited time, as explained in Part 6 but if you would like Us to delete it sooner, please contact Us using the details in Part 14);

4.1.5 The right to restrict (i.e. prevent) the processing of your personal data;

4.1.6 The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);

4.1.7 The right to object to Us using your personal data for particular purposes; and

4.1.8 Rights with respect to automated decision making and profiling.

4.2 If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided in Part 14 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.

4.3 For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.

5. What Data Do We Collect?

Depending upon your use of Our Site, We may collect some or all of the following personal and non-personal data (please also see Part 13 on Our use of Cookies and similar technologies):

5.1 Name;

5.2 Business/company name

5.3 Contact information such as email addresses, postal addresses and telephone numbers;

5.4 Demographic information such as post code, gender and age;

5.5 IP address;

5.6 Web browser type and version;

5.7 Operating system; and

5.8 A list of URLs starting with a referring site, your activity on Our Site, and the site you exit to.

6. How Do We Use Your Data?

6.1 All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the GDPRat all times. For more details on security see Part 7, below.

6.2 Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of your personal data (e.g. by holding and account), because it is required for financial accounting purposes or because it is in Our legitimate interests. Specifically, We may use your data for the following purposes:

6.2.1 Providing and managing your Account;

6.2.2 Providing and managing your access to Our Site;

6.2.3 Personalising and tailoring your experience on Our Site;

6.2.4 Supplying Our products to you – i.e. fulfilling an order (please note that We require your personal data in order to enter into a contract with you);

6.2.5 Personalising and tailoring Our products for you;

6.2.6 Replying to emails and communications from you;

6.2.7 Analysing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience (including personalising and tailoring Our product adverts on social media, for example, for you); and

6.2.8 As is required under the law for financial accounting purposes, for example.

6.3 We will not use your data for marketing purposes which includes contacting you by e-mail, telephone, text messageand/ or post with news or information about our company or our products.  

6.4 Third parties utilised by the Company, such as Facebook, may, however, engage in what is known as “behavioural advertising” – advertising which is tailored to your preferences, based on your activity. Your activity is monitored using Cookies, as detailed below in Part 13. You can control and limit your data used in this way by adjusting your web browser’s privacy settings. Please note that We do not control the activities of such advertisers, nor the information they collect and use which is based on the third party’s filters. Limiting the use of your data in this way will not necessarily remove the advertising, but it may make it less relevant to your interests and activities.

6.5 Third parties (including customer review sites such as eKomi and Google Trusted Store and payment service providers including Amazon Pay, PayPal, and Braintree) whose content appears on Our Site may use third party Cookies, as detailed below in Part 13. Please refer to Part 13 for more information on controlling Cookies. Please note that We do not control the activities of such third parties, nor the data they collect and use and advise you to check the privacy policies of any such third parties.

6.6 You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it.

6.7 We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Data will therefore be retained for the following periods (or its retention will be determined on the following bases):

6.7.1 For the time period required for legal and financial accounting purposes; and/ or

6.7.2 Because you have consented to Our use of your personal data (e.g. by setting up an account).  We will retain your data until you unsubscribe from having an account. Should you decide you no longer wish to have an account, please e-mail support@ckbltd.com confirming whether you wish to cancel your account with CKB Ltd ®, Bar Amigos ® or Lanyards Tomorrow ®.  Should you wish to cancel accounts on all of Our Sites, an e-mail should be sent to support@ckbltd.com confirming this and arrangements will be made for the removal.  

7. How and Where Do We Store Your Data?

7.1 We only keep your personal data for as long as We need to and/ or are required to and/ or have your permission to in order to use it as described above in Part 6.

7.2 Some or all of your data may be stored outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). You are deemed to accept and agree to this by using Our Site and submitting information to Us. If We do store data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the GDPRincluding:

7.2.1 Approaching any relevant partner/ supplier organisations for confirmation that their data storage processes are acceptable (see Part 8); and

7.2.2 putting in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through Our Site

7.3 Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure data collected through Our Site.

7.4 Steps We take to secure and protect your data include: Our Site is PCI DSS compliant and uses a Globalsign SLL (Secure Sockets Layer Software) Certificate to protect your personal information.

7.5 Notwithstanding the security measures that We take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to Us data via the internet.

8. Do We Share Your Data?

8.1 We may share your data within our Company group of brands which includes CKB Ltd ®, Bar Amigos ®, and Lanyards Tomorrow ®.

8.2 We may contract with third parties to supply services to you on Our behalf. These include payment processing, product and service feedback reviews and delivery of goods. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law.

8.3 We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.

8.4 We may sometimes use third party data processors that are located outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). Where We transfer any personal data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the GDPRincluding:

8.4.1 Approaching any relevant partner/ supplier organisations for confirmation that their data storage and processing activities are acceptable.

8.4.2 In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal requirements, a court order, or a governmental authority. We do not require any further consent from you in order to share your data in such circumstances and will comply as required with any legally binding request that is made of Us.

9. What Happens If Our Business Changes Hands?

9.1 We may, from time to time, expand or reduce Our business and this may involve the sale and/or the transfer of control of all or part of Our business. Any personal data that you have provided will, where it is relevant to any part of Our business that is being transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Policy, be permitted to use that data only for the same purposes for which it was originally collected by Us.

9.2 In the event that any of your data is to be transferred in such a manner, you will not be contacted in advance and informed of the changes as we do not issue marketing and information communications. You will, however, continue to have the choice to have your data deleted.

10. How Can You Control Your Data?

10.1 In addition to your rights under the GDPR, set out in Part 4, when you submit personal data via Our Site, you will be given options to restrict Our use of your data (e.g. via accessing the Cookie consent function).

11. Your Right to Withhold Information

11.1 You may access certain areas of Our Site without providing any data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.

11.2 You may restrict Our use of Cookies. For more information, see Part 13.

12. How Can You Access Your Data?

12.1 You have the right to ask for a copy of any of your personal data held by Us (where such data is held). Under the GDPR, no fee is payable and We will provide any and all information in response to your request free of charge. Please contact Us for more details using the contact details below in Part 14.

13. Our Use of Cookies

13.1 A cookie is a small file, typically of letters and numbers, downloaded on to a device when the user accesses certain websites.  Cookies allow a website to recognise a user’s device and provide enhanced website functionality for the user as a result. Cookies are generated when you first visit Our Site as they tell us useful analytical information including which site you have visited from.  You can decline consent for such cookies once on our Site. However, prior to this, acceptance of such cookies is deemed to occur via implied consent as you visited Our Site and the consent option is presented to you once on Our Site (for those landing cookies). We also consider We have a legitimate interest to gather this landing data to inform the success of our investment in online advertising, for example, as a small family run business.

13.2 Cookies can be session cookies or persistent cookies.  Session cookies only last for the duration of your online session and disappear from your device when you close your browser.  Persistent cookies, however, stay on your device after the browser has been closed and last for the period of time specified in the cookie.  Furthermore, persistent cookies are activated each time you visit the site that the cookie was generated by and include analytics tools.

13.3 Our Site may place and access certain first party Cookies on your computer or device. First party Cookies are those placed directly by Us and are used only by Us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve Our products. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.

13.4 By using Our Site you may also receive certain third party Cookies on your computer or device. Third party Cookies are those placed by websites, services, and/or parties other than Us. Third party Cookies are used on Our Site for analysing website usage and trends, for example. For more details, please refer to Part 6, above, and to Part 13.6 below. These Cookies are not integral to the functioning of Our Site and your use and experience of Our Site will not be impaired by refusing consent to them.

13.5 All Cookies used by and on Our Site are used in accordance with current Cookie Law.

13.6 Before Cookies are placed on your computer or device, you will be shown a message requesting your consent to set those Cookies (apart from the landing cookies as outlined in 13.1). By giving your consent to the placing of Cookies (‘functional’ and ‘performance’ Cookies) you are enabling Us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended. You may also later go back into the Cookie consent options after initially consenting and change your consent preferences.

13.7 Certain features of Our Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown below in Part 13.6. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below in Part 13.12, but please be aware that Our Site may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.

13.8 The following first party Cookies may be placed on your computer or device:

Name of Cookie

Purpose

Strictly Necessary

Checkout

To facilitate checking out your stored online basket items

Yes

Account/ user log on

To enable you to set up or access an account to shop, and view purchase history, etc., if functionality allows

Yes

and the following third party Cookies may be placed on your computer or device:

Name of Cookie

Provider

Purpose

Social media links

Facebook, Instagram, Linked In, Pinterest and Twitter

User can share updates or like/ pin items by hitting buttons to alert their own followers to items purchased, etc

Social media advertising

Facebook, Twitter and Pinterest

Behavioural advertising tailored to a user’s preference and based on their activity

Search Engine advertising

Google AdWords, Bing Ads

Online advertising

Analytics

Google

To track user behaviour on Our Site (see table below for more detail)

Tag manager

Google

To allow site traffic to be measured as well as the impact of online advertising including social media channels

Cookie consent function

Civic

To provide cookie consent options post landing on Our Site for cookies other than strictly necessary cookies

Search bar tool

Searchanise

To provide insight into search history on Our Site

Payment

Amazon Pay, PayPal and Braintree

To collect payment data to facilitate payment to Us

Postcode prediction

See Part 13.14

To pre-fill address field based on a postcode

Currency prediction

See Part 13.14

To update the currency to a local currency based on the initial part of an IP address

13.9 Our Site uses analytics services provided by Google. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling Us to better understand how Our Site is used. This, in turn, enables Us to improve Our Site and the products offered through it. You do not have to allow Us to use these Cookies, however whilst Our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable Us to continually improve Our Site, making it a better and more useful experience for you.

13.10 The analytics service(s) used by Our Site use(s) Cookies to gather the required information.  Information pertaining to Location information is also gained from an IP address for consumer behaviour analysis.

13.11 The analytics service(s) used by Our Site use(s) the following Cookies:

Name of Cookie

First / Third Party

Provider

Purpose

Visitor count

Third

Google Analytics

To measure visitors to Our Site

Visitor time on site pages

Third

Google Analytics

To review and inform the impact and appeal of Our Site pages

URL visitor came from

Third

Google Analytics

Online market intelligence

URL visitor exited to

Third

Google Analytics

Online market intelligence

Visitor behaviour on site

Third

Google Analytics

To review and inform the impact and appeal of Our Site pages

Web browser type and version

Third

Google Analytics

To enable cookies to function as best they can for your software needs

Operating system

Third

Google Analytics

To enable cookies to function as best they can for your software needs

Site traffic analysis

Third

Google Tag Manager

To review and inform the impact and appeal of Our Site pages

Impact of online advertising including social media channels

Third

Google Tag Manager

To review and inform the impact of Our online marketing

13.12 In addition to the controls that We provide which are accessed via the Cookie consent function, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party Cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.

13.13 You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.

13.14 We also use software to enhance Our Site’s functionality.  We use postcode prediction software to pre-fill address field based on a postcode as well as using currency prediction software to update Our Site’s currency to a local currency based on the initial part of an IP address.  Details of the software providers have not been included in the table under Part 13.8 for reasons of Our requirement to protect our business knowledge and security. Should a data subject wish to enquire further about this please contact our Data Protection Officer at Unit 5, Business Centre East, Fifth Avenue, Letchworth Garden City, Herts, SG6 2TS.

13.15 It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.

14. Contacting Us

14.1 If you have any questions about Our Site or this Policy, please contact Us by email at support@ckbltd.com, by telephone on +44 (0)1462 682020, or by post at Unit 5, Business Centre East, Fifth Avenue, Letchworth Garden City, Hertfordshire, SG6 2TS. Please ensure that your query is clear, particularly if it is a request for information about the data We hold about you (as under Part 12, above).

15. Changes to Our Website Privacy and Cookies Policy

15.1 We may change this Policy from time to time (for example, if the law changes). Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date.

16. Implementation of Policy

16.1 This Policy shall be deemed effective as of 1st June 2018. No part of this policy shall have retroactive effect and shall thus apply only to matters occurring on or after this date.


V3 Website Privacy & Cookies Policy - effective date 1st June 2018