1.     Introduction

1.1    Triangle Nursery Ltd is committed to safeguarding the privacy of our website visitors and customers; in this policy we explain how we will handle your personal data.

1.2    By using our website and agreeing to this policy, you consent to our use of cookies in accordance with the terms of this policy.

1.3    Our website incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can specify whether you would like to receive direct marketing communications from Triangle Nursery Ltd. You can unsubscribe from our email marketing at any time – the unsubscribe facility is clearly published at the bottom of all marketing emails.

2.     How we use your personal data

2.1    In this Section 2 we have set out:

(a)    the general categories of personal data that we may process;

(b)    the purposes for which we may process personal data; and

(c)    the legal bases of the processing.

2.2    We may process data about your use of our website and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system ‘Google Analytics’. This usage data may be processed for the purposes of analysing the use of our website and services. The legal basis for this processing is for our legitimate interests, namely monitoring and improving our website and services.

2.3    We may process your account data ("account data"). The account data may include your name and email address. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is for our legitimate interests, namely the proper administration of our website and business.

2.4    We may process information that you post for publication on our website, social media platforms or through our services ("publication data"). The publication data may be processed for the purposes of enabling such publication, administering and promoting our website and services. The legal basis for this processing is for our legitimate interests, namely the proper administration of our website and business.

2.5    We may process information contained in any enquiry you submit to us regarding products and/or services ("enquiry data"). The enquiry data may be processed for the purposes of offering, marketing and selling relevant products and/or services to you. The legal basis for this processing is by your request. Enquiry Data is often logged in our CRM system (Customer Relationship Management) for the purposes of contacting customers at a future date.

2.6    We may process information relating to transactions, including purchases of goods and services that you enter into with us and/or through our website ("transaction data"). The transaction data may include your contact details, your card payment details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and Triangle Nursery Ltd and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely our interest in the proper administration of our website and business.

2.7    We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters ("notification data"). The notification data may be processed for the purposes of sending you promotional relevant notifications and/or newsletters. The legal basis for this processing is by your consent by means of the new double opt in laws.

2.8    We may process information contained in or relating to any communication that you send to us ("correspondence data"). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.

2.9    In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

3.     Providing your personal data to others

3.1    We do not exchange or sell your data to any third party web sites or external data suppliers. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.

3.2    We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining and maintaining insurance coverage, managing risks, obtaining professional advice and managing legal disputes.

3.3    We may disclose your data to our web site suppliers or IT subcontractors insofar as reasonably necessary for accurate digital back-ups, web site maintenance and internal IT systems efficiency.

3.4    Financial transactions relating to our website are handled by our payment services providers, Stripe. We will share transaction data with our payment gateway and payment services provider only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about our payment gateway and payment services provider’s privacy policies and practices at https://stripe.com/en-gb/privacy

3.5    We will not disclose your enquiry data to one or more of those selected third party suppliers of goods and services identified on our website for the purpose of enabling them to contact you so that they can offer, market and sell to you relevant goods and/or services.

3.6    In addition to the specific disclosures of personal data set out in this Section 3, we may also disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

4.     International transfers of your personal data

4.1    In this Section 4, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).

4.2    Triangle Nursery Ltd. do not transfer any personal data to countries outside of the European Economic Area (EEA).

4.3    The hosting facilities for our website are situated in UK with Rackspace and then go through Cloudflare proxy for extra security. The European Commission has made an "adequacy decision" with respect to the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission. You can see Rackspace’s Privacy Policy here https://www.rackspace.com/en-gb/information/legal/privacystatement and Cloudflare’s here https://www.cloudflare.com/security-policy/

4.4    You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

5.     Retaining and deleting personal data

5.1    This Section 5 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

5.2    Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

5.3    We will retain and delete your personal data as follows:

(a)    All personal data will be retained for 5 years following the date you register an online account, at the end of which period it will be deleted from our systems if there has been no order placed with Triangle Nursery within this 5 year period. All data will be deleted 5 years from your last order with Triangle Nursery Ltd in most cases.

5.4    In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:

(a)    the period of retention of your personal data will be determined based on any ongoing legal or insurance issues.

5.5    Notwithstanding the other provisions of this Section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

6.     Amendments

6.1    We may update this policy from time to time by publishing a new version on our website.

6.2    You should check this page occasionally to ensure you are happy with any changes to this policy.

6.3    We may or may not notify you of changes to this policy by email or through the private messaging system on our website.

7.     Your rights

7.1    You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to:

(a)    the payment of a £10 fee

(b)    the supply of appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address)].

7.2    We may withhold personal information that you request to the extent permitted by law.

7.3    You may instruct us at any time not to process your personal information for marketing purposes. This includes unsubscribing from emails and deleting you from some/or all social media marketing projects.

7.4    In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.

OR

7.     Your rights

7.1    In this Section 7, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

7.2    Your principal rights under data protection law are:

(a)    the right to access;

(b)    the right to rectification;

(c)    the right to erasure;

(d)    the right to restrict processing;

(e)    the right to object to processing;

(f)     the right to data portability;

(g)    the right to complain to a supervisory authority; and

(h)    the right to withdraw consent.

7.3    You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee of £10. You can access your personal data by visiting www.trianglenursery.co.uk/login when logged into the website. (Please remember, we never hold your payment card details).

7.4    You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

7.5    In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are certain general exclusions of the right to erasure. Those general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.

7.6    In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, Triangle Nursery Ltd may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

7.7    You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, Triangle Nursery Ltd will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

7.8    You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, Triangle Nursery Ltd will cease to process your personal data for this purpose.

7.9    You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

7.10  To the extent that the legal basis for our processing of your personal data is consent, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

7.11  If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.

7.12  To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

7.13  You may exercise any of your rights in relation to your personal data by written notice to us in addition to the other methods specified in this Section 7.

8.     Third party websites

8.1    Our website may include hyperlinks to, and details of, third party websites.

8.2    We have no control over, and are not responsible for, the privacy policies and practices of third parties.

9.     Personal data of children

9.1    Our website and services are targeted at persons over the age of 16.

9.2    If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.

10.   Updating information

10.1  Please let us know if the personal information that we hold about you needs to be corrected or updated.

11.   About cookies

11.1  A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

11.2  Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

11.3  Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

12.   Cookies that we use

12.1  We use cookies for the following purposes:

(a)    authentication - we use cookies to identify you when you visit our website and as you navigate our website (cookies used for this purpose are: Triangle.Authentication  - Used to determine user information and logged in status).

(b)    status - we use cookies to help us to determine if you are logged into our website (cookies used for this purpose are: Triangle.Authentication  - Used to determine user information and logged in status).

(c)    shopping cart - we use cookies to maintain the state of your shopping cart as you navigate our website (cookies used for this purpose are: ASP.NET_SessionId – Used for storing objects in session i.e. basket state).

 (d)   security - we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally : _cfduid – A Cloudflare cookie used to identify individual clients behind a shared IP address and Triangle.Authentication  - Used to determine user information and logged in status).

(e)    analysis – we use cookies to help us to analyse the use and performance of our web site and services (cookies used for this purpose are: _utma, _utmb, _utmc, _utmz, _ga – Google Analytics cookies, _hjIncludedInSample – A Hotjar cookie used to determine whether to log information on visitor behavior patterns, and fr – A Facebook social plugin cookie).

 (f)    cookie consent - we use cookies to store your preferences in relation to the use of cookies more generally (cookies used for this purpose are: CONSENT – A cookie consent for Wordpress blog).

13.   Cookies used by our service providers

13.1  Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

13.2  We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google's privacy policy is available at: https://www.google.com/policies/privacy/

13.3  We do not publish Google AdSense interest-based advertisements on our website.

14.   Managing cookies

14.1  Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

(a)    https://support.google.com/chrome/answer/95647?hl=en (Chrome);

(b)    https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);

(c)    http://www.opera.com/help/tutorials/security/cookies/ (Opera);

(d)    https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);

(e)    https://support.apple.com/kb/PH21411 (Safari); and

(f)     https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).

14.2  Blocking all cookies will have a negative impact upon the usability of many websites.

14.3  If you block cookies, you will not be able to use all the features on our website.

16.   Our details

16.1  This website is owned and operated by Triangle Nursery Ltd

16.2  We are registered in England and Wales under registration number 03481837, and our registered office is at Unit 50 Martlesham Creek Industrial Estate, Sandy Lane, Woodbridge, Suffolk IP12 4SD.

16.3  Our principal place of business is at the same address.

16.4  You can contact us:

(a)    by post, using the postal address given above;

(b)    using our website contact form;

(c)    by telephone, on 01394 385832

(d)    by email, using the email address published on our website.

17.   Representative within the European Union

17.1  Our representative within the European Union with respect to our obligations under data protection law is Mark Kenny and you can contact our representative by email [email protected]

18.   Data protection officer

18.1  Our data protection officer's contact details are: [email protected]

18.2 Triangle Nursery Ltd’s ICO Registration Reference Number is: ZA316927